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 DAKOTA
 TABLE 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 Deterioration (PSD) Permit Review 11 

4.1 Best Available Control Technology (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 28 
 TABLE 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 47
 LIST 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 Sources Impacted by Kiln # 6 Upgrade 6 

 3 Particulate Emission Rates 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 Significant 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 Deterioration 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 Emission Limit for Kiln System 42 

 24 Nitrogen Oxide BACT Emission Limit for Kiln System 44 

 25 Carbon Monoxide BACT Emission Limit for Kiln System 45 

 
 LIST 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 Congress 

 
 Page 1 

1.0 BACKGROUND 

On June 14, 1993, Dacotah Cement submitted an application 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, sand, and gypsum in the surrounding area to provide 

raw materials for its portland cement plant. Other 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 and 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 silos before it is transferred to the 

kilns. The dry kiln process is capable of receiving 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 storage 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 alternative operating scenario be placed in its permit that would 

allow Dacotah Cement to upgrade kiln #6 by increasing 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 installation of an indirect coal firing system. 

On May 13, 1994, the Department of Environment and Natural Resources (department) issued an 

air quality permit to Dacotah Cement. The permit required Dacotah Cement to submit general 

specifications and application forms for the kiln #6 upgrade and indirect coal firing system. On 

June 23, 1994, Dacotah Cement submitted the general specifications and application forms for 

the kiln #6 upgrade as required by the existing air quality permit. The application included the 

modification to kiln #6, kiln feed system, dry process clinker cooler, the pre-heater tower, and 

the installation of a precalcinator. The application identified expected air emission increases, 

dispersion modeling results, and proposed particulate 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 department that kiln #6 would be shutdown on 

January 14, 1995, to initiate the upgrade. Dacotah Cement experienced operational problems 

after the upgrade was completed and the department 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 should have been considered a major modification 

under the PSD program based on the results of the stack tests in November 1996. On December 

27, 2000, the department issued a notice of violation 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 limestone quarry and portland cement plant and 

took over responsibility for fulfilling the settlement agreement and compliance plan. GCC 

Dacotah submitted a PSD permit application for particulate on November 16, 2001. On January 
 Page 2 

17, 2002, GCC Dacotah submitted a PSD permit application for nitrogen oxide and carbon 

monoxide. The applications were considered incomplete because the applications did not 

contain all of the maximum process rates, process descriptions did not agree with the existing 

permit and stack tests, the application 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, the department concluded the kiln #6 upgrade was also 

applicable to a PSD review for sulfur dioxide. At a June 18, 2002, meeting, the department 

requested GCC Dacotah reexamine the sulfur dioxide 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 dioxide was required. On September 5, 2002, GCC 

Dacotah submitted the sulfur dioxide PSD permit application. The department considered the 

proposed sulfur dioxide emission limits too 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 precalcinator. 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 referred to as fuel input. The existing operations have 

approximately 90 percent of the coal 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 additional material handling points to control particulate emissions; 

2. Proposed to upgrade the precalcinator so it produces 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 that were impacted by the kiln #6 upgrade and 

will be consider under this PSD review. In addition, Table #1 notes if the control device is 

existing, proposed, and/or previously permitted. 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 3 

Table #1 

Description of Units, Operations, and Processes Impacted by Kiln #6 Upgrade 

Maximum Control D

Unit Description of Process Operating Rate Description S

1 EDC101 Primary and secondary crushers 1,000 tons per hour Baghouse E2 EDC102 Screen 1,000 tons per hour Baghouse E9 EDC619 Loesche mill and rotary kiln #6 2,250 tons clinker per day 

Preheater, Precalcinator, and Baghouse 

E

6 EDC652 Raw material storage building to two kiln feed storage silos 180 tons per hour Baghouse E

6a EDC501 Rock silo to Loesche mill 180 tons per hour Baghouse E

6b EDC602 Kiln feed storage silo to kiln #6 160 tons per hour Baghouse E7b EDC710 Clinker shed to finish mills 500 tons per hour Baghouse E

7c EDC706 Raw shed to Loesche mill 40 tons per hour 2001 Fuller baghouse Pr

7d EDC701 Raw material transferred from belt conveyor 107 to belt conveyor 108 800 tons per hour 2001 Fuller baghouse Pr

10 EDC615 Dry process clinker cooler 2,250 tons clinker per day Baghouse E

7e EDC705 Gypsum raw shed to old clinker building 350 tons per hour 2001 Fuller baghouse Pr

7f EDC703 Raw shed to Loesche mill 40 tons per hour 2001 Fuller baghouse Pr

7g EDC704 Gypsum raw shed to old clinker building 350 tons per hour 2001 Fuller baghouse Pr

8 EDC614 Penthouse storage #2 (north) 2,250 tons clinker per day Baghouse E

8a EDC627 Penthouse storage #2 (north) 2,250 tons clinker per day Baghouse E

8b EDC613 Penthouse storage #2 (north) 2,250 tons clinker per day Baghouse E

8c EDC707 Rock silo discharge 1,000 tons per hour 2001 Fuller baghouse Pr

11 EDC623 Alkali bypass and alkali waste to waste bin transfer system 2,250 tons clinker per day Baghouse E12 EDC731 Finish mill #3 35 tons per hour Baghouse E
 Page 4 

Maximum Control D

Unit Description of Process Operating Rate Description S

13 EDC741 Finish mill #4 40 tons per hour Baghouse E14 EDC751 Finish mill #5 45 tons per hour Baghouse E15 EDC761 Finish mill #6 45 tons per hour Baghouse E16 EDC771 Finish mill #7 (mill sweep) 85 tons per hour Baghouse E

16a EDC772 Finish mill #7 (mill separator) 85 tons per hour Baghouse E

16b EDC708 Finish mill #7 (transfer) 500 tons per hour Baghouse E

16c EDC709 Finish mill #7 (transfer) 500 tons per hour Baghouse E

16d EDC713 Clinker transfer system 500 tons per hour 2001 BHA baghouse Pr

17 EDC804 Bulk storage silos 125 tons per hour Baghouse E18 EDC821 Bulk storage silos 125 tons per hour Baghouse E19 EDC805 Bulk storage silos 125 tons per hour Baghouse E20 EDC832 Bulk storage silos 125 tons per hour Baghouse E21 EDC824 Bulk storage silos 200 tons per hour Baghouse E24 EDC827 Rail storage silos 125 tons per hour Baghouse E25 EDC828 Rail storage silos 125 tons per hour Baghouse E26 EDC834 Rail storage silos 125 tons per hour Baghouse E27 EDC853 Bulk rail loadouts 500 tons per hour Baghouse E28 EDC854 Bulk rail loadouts 500 tons per hour Baghouse E35 EDC825 East bulk truck loadout 500 tons per hour Baghouse E36 EDC826 West bulk truck loadout 500 tons per hour Baghouse E37 EDC801 Cement bagging 114 tons per hour Baghouse E38 EDC802 Cement bagging 114 tons per hour Baghouse E39 EDC803 Cement bagging 114 tons per hour Baghouse E41 

ECD628 EDC629 1995 ABB Raymond coal mill 20 tons coal per hour 5.3 MMBtus per hour Single stage cyclone followed by two E
 Page 5 

Maximum Control D

Unit Description of Process Operating Rate Description S

heat input baghouses operated in 

parallel 

41b EDC274 Coal stacker top 400 tons per hour Baghouse E

41c EDC275 Coal surge bin top 400 tons per hour Baghouse E

41d EDC702 Coal tunnel to coal stacker 400 tons per hour New baghouse Pr

41e EDC276 Coal surge bin top 400 tons per hour Baghouse E

41f EDC277 Coal transfer 400 tons per hour Baghouse E

41i EDC278 Coal bin #6 400 tons per hour Baghouse E

41j EDC630 Coal dryer – FK pump 20 tons per hour Baghouse E

62b 

EDC272 EDC273 Coal – hopper to conveyor 400 tons per hour Two baghouses operated in parallel E
 Page 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 shed (90% from offsite delivery 

and 10% from storage pile) Partially enclosed 

54a Sand: truck to pile (10% from 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 back-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 None 
 Page 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 permit application. The emission 

rates and proposed limits listed in this section were derived from the application, FL Smidth 

performance data, the state’s air emission inventory data, and 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 and 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 between some of the emission rates 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 rates prior to the upgrade. The department 

reviewed the data and believes emission rates based on calendar years 1993 and 1994, are more 
 Page 8 

representative of the prior operations. Therefore, the annual emission rates prior to the upgrade 

in Tables #3 through #7 are based on calendar years 1993 and 1994 data. 

Trinity originally determined particulate emissions from the material handling equipment for 

particulate based on annual emission inventories provided by the 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 attributed 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 material processed to determine the emission 

increases attributed to the kiln #6 upgrade. Trinity reviewed the department’s information and 

submitted an addendum to the PSD permit application in September 2002. The revised 

particulate calculations may be observed in Appendix B. The revised particulate emission rates 

are reflected in the “Summary of Annual Particulate Emission Rates” section of Table #3. 

Table #3 

Particulate Emission Rates and Proposed Limits

Unit Emission Rates Unit Emission Rates 

Prior to Upgrade1 Proposed Limit 3 Prior to and After Upgrade2

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/ton 
 Page 9 

Unit Emission Rates Unit Emission Rates 

Prior to Upgrade1 Proposed Limit 3 Prior to and After Upgrade2

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 year 
 Page 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 upgrade from historical data. The developed 

emissions are higher than those noted in the application. 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 year 
 Page 11 

Table #7 

Volatile Organic Compound Emission Rates 

Annual Emission Rates 

Unit Prior to Upgrade After Upgrade 

9, 11, and 411 38 tons/year 74 tons/year 

1

 - The emission factor is from AP-42 for a kiln as a whole process, which would include the emissions from the 

main stack, alkali bypass, and coal dryer stack. 

4.0 PREVENTION OF SIGNIFICANT 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 (BACT) to minimize air pollutants emitted by the 

proposed project; 

2. Ensure compliance with the NAAQS; 

3. Ensure the applicable PSD air quality 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 sources and major modifications to existing major 

stationary sources in areas designated as attainment or unclassifiable under Section 107 of the 

Clean Air Act for any criteria pollutant. If the source is considered one of the 28 named PSD 

source categories listed in Section 169 of the federal Clean Air Act, the major source threshold is 

100 tons per year of any regulated pollutant. The 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 than or equal to 10 microns (PM10); 

• Sulfur dioxide (SO2); 

• Nitrogen oxides (NOx); 

• Carbon monoxide (CO); 

• Ozone – measured as volatile 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 dioxide, nitrogen oxides, and carbon monoxide greater than 100 tons 

per year. Therefore, GCC Dacotah is considered an existing major source under the PSD 

program for those pollutants. Once a source is considered major any new construction, 

reconstruction or modification that increases potential air emissions 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 emission 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 for lead, fluorides, sulfuric acid mist, hydrogen 

sulfide, reduced sulfur compounds and total reduced 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 sulfuric acid mist and hydrogen sulfide. 

Therefore, sulfuric acid mist and hydrogen sulfide 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 

Pollutant Rate 

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 No 
 Page 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, sulfur 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 pollutant subject to regulation under the federal 

Clean Air Act for which it would result in significant net emissions at the source. Based on 

Table #8, GCC Dacotah’s kiln #6 upgrade had the potential to emit the following air pollutants at 

or equal to the federal significant emission rates: 

1. Total suspended particulate (PM) 

2. Particulate equal to or less than 10 microns in diameter (PM10); 

3. Sulfur dioxide (SO2); 

4. Nitrogen oxide (NOx); and 

5. Carbon monoxide (CO). 

BACT is based on the maximum reduction achievable for each pollutant subject to a regulation 

under the federal Clean Air Act. The department determines BACT on a case-by-case basis 

taking into account energy, environmental, and economic impacts, and other costs. BACT is 

achievable through application of production processes 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 greater than the emission limit allowed by any applicable standard 

under 40 CFR Parts 60 and 61. 

The BACT analysis is based on four steps. The first step consists of the applicant identifying all 

available control options for the pollutant under consideration (Identifying Options). The 

department reviews these options to ensure all available control options are considered. 

In the second step the applicant evaluates the technical feasibility of the various control options 

in relationship to the specific unit under consideration (Technical Feasibility). The department 

reviews the technical feasibility provided by the applicant to determine 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 control measures will be evaluated first and if 

they are not feasible, the next best control measure will be evaluated. In this step the applicant 

lists the control efficiency, the expected emission 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 applicant 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 under review (BACT Determination). 
 Page 14 

4.1.1 PM and PM10

4.1.1-1 – Identifying Options 

GCC Dacotah considered the following options to control PM and PM10 emissions frompoint 

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 1
 Page 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 2
 Page 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 silt content of four percent or greater, 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 considers 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 storage piles that meet the definition 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 precipitator are technically feasible. 

The particulate control device serving kiln #6’s main stack receives the product 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 scrubber would defeat the purpose of collecting a dry 

product. Therefore, GCC Dacotah believes a wet scrubber is not technically feasible for kiln 

#6’s main stack. 

The particulate control device serving the kiln #6’s alkali bypass and clinker cooler receives dust 

from the rotary kiln and clinker cooler, respectively. The dust collected contains particles of 

portland cement clinker, which is used to produce portland cement. Collection of this material 

by a wet scrubber would set up in the wet scrubber and render the wet scrubber inoperable. GCC 

Dacotah believes a wet scrubber is not technically feasible in controlling particulate emissions 

from the alkali bypass and clinker cooler. 

The particulate control device serving the coal mill/dryer receives and collects 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 using a wet scrubber defeats the purpose of drying the coal. GCC 

Dacotah believes a wet scrubber is not technically 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 precipitator are technically feasible for 

the point sources operated by GCC Dacotah. The department 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 technically feasible to install or implement for the kiln 

#6 upgrade. The two approaches are the installation of a fabric filter or an electrostatic 

precipitator. Both technologies have comparable particulate control efficiencies. 

The control technologies that are technically feasible for fugitive dust sources are based on GCC 

Dacotah’s application and the Natural Events Action Plan for Rapid City. Both approaches will 

be compared to each other and the control technique that has the best control will be required. 
 Page 18 

4.1.1-4 – BACT Determination for Particulate 

The department concurs with GCC Dacotah that BACT for point sources is a fabric filter or 

electrostatic precipitator. The department will let 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 requirements 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 and will also evaluate low sulfur coal and raw 

materials. 

4.1.2-2 – Technical Feasibility 

A wet scrubber reduces the sulfur dioxide emissions 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 slurry that contains calcium sulfite or calcium 

sulfate. A review of cement plants in the United States showed that one cement plant (Dragon 

Cement Plant in Thomaston, Maine) tried to operate 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 feasible option. 

Sulfur dioxide emissions are effectively reduced when the flue gas is in contact with limestone. 

Cement kilns have large quantities of crushed limestone and fresh highly reactive lime present to 

reduce the sulfur dioxide emissions. Therefore, GCC Dacotah believes that inherent sulfur 

dioxide removal is technically feasible. 

Dry reagent injection reduces the sulfur dioxide emissions by injecting a dry absorbent into the 

exhaust gas stream. Common absorbents are calcium hydroxide or hydrated lime. The 

absorbent reacts with the sulfur dioxide to form calcium sulfite or calcium sulfate. Hot meal 
 Page 19 

injection and spray dryer absorbers operate in similar manner as a dry reagent 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 inherent sulfur dioxide removal, 

dry reagent injection, hot meal injection and spray dryer absorbers are technically feasible. 

In addition, the amount of sulfur dioxide emissions that may be produced is dependent on the 

sulfur content in the material processed through kiln #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 technically feasible to use raw materials 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 approaches 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 injection, and spray dryer absorber all commonly use 

hydrated lime (limestone) as its absorption 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 installing the dry reagent injection, 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. Therefore, shipping costs would 

make it economically infeasible to lower sulfur dioxide emission by lowering the sulfur content 

of the raw materials because of shipping costs. The coal used to feed 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 Determination for Sulfur Dioxide 

GCC Dacotah proposes using the inherent 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 considered BACT. Based on the RBLC, BACT for 

“new” cement plants and modifications to existing plants has been inherent sulfur dioxide 

removal and/or limits on the sulfur content of the coal and raw material in a 

preheater/precalcinator type kiln. Therefore, the department agrees with GCC Dacotah’s BACT 

determination on using the inherent sulfur dioxide removal process for cement kilns. 
 Page 20 

4.1.3 Nitrogen Oxide

4.1.3-1 – Identifying Options 

GCC Dacotah considered the following options to control nitrogen 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-catalytic 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 combustion products contained 

in the recycled flue gas. FGR relies on cooling the flame and generating an oxygen deficient 

atmosphere for combustion to reduce nitrogen oxide 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 technology 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 conventional wet and long-dry kilns by injecting solid 

fuel into the calcining zone. GCC Dacotah’s kiln #6 is a preheater/precalcinator 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 provides 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 nitrogen 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 technically 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 turbulence, delay fuel/air mixing, and establish 

fuel-rich zones for initial combustion. The fuel-rich/oxygen poor zone provides the high 

temperature for completion of the clinker process and the nitrogen oxide emissions are 

minimized by the oxygen deprived zone. Therefore, 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 the 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 population of 90,000. If each person in Pennington County owns 

a vehicle and changes their tires 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 three to five years. In either case, the Pennington County area does 

not generate enough used tires to support a TDF 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 higher 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 may not be burned alone because it does not provide 

enough volatile matter. Therefore, the use of petroleum coke as an independent fuel source is 
 Page 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 dependent. 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 lower 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 presence 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 desired 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 reactions 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 need 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 not 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 reduction process. Instead of using ammonia or urea for reduction 

of nitrogen oxide emissions, the naturally occurring ammonia in the biosolids (sludge from the 

treatment of municipal wastewater) is used. The above information was obtained from pages 72 

through 73 of NOx Control Technologies for the Cement Industry (September 19, 2000) 

GCC Dacotah believes BSI is technically feasible for kiln #6, but is not considered a practical 

method of control for nitrogen oxide based on the following reasons: 

1. A constant and adequate supply of biosolids is required for this process to be effective. BSI 

is being used at Mitsubishi Cement Corporation’s Cushenbury plant in Lucerne Valley, 
 Page 23 

California. Lucerne Valley is located in San Bernadino County and is about two hours from 

Orange County and Los Angeles. San Bernadino County has a population of about 1.7 

million. GCC Dacotah is located in Rapid City, 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 biosolids may not be available in Rapid City. 

2. The biosolids have a high water content. The #6 kiln is a dry process. Therefore, the 

addition of wet material to a dry process causes 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 increase 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 producing the steel slag in a steel furnace. This requires less fuel to 

complete the final chemical reactions to convert the steel slag to clinker than it would for the raw 

material to clinker. The above 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 kiln #6. However, the CemStar process is not 

considered a practical method of control for nitrogen 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 Superfund Amendments and Reauthorization Act 

(SARA). Accidental release of the ammonia can occur during the handling and storage of 

ammonia. Another environmental concern is the ammonia slip. The portion of unreacted 
 Page 24 

ammonia passing through the catalyst and emitted form the stack is called ammonia slip. The 

ammonia emitted into the ambient air may cause secondary 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. Therefore, SNCR is not considered an appropriate 

control device for nitrogen oxide in Rapid City. 

GCC Dacotah proposed to use 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 

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 effectiveness 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 GCC 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 for 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 system would have to have a new separate structure 

built and some of the existing equipment would need 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 feasible at this time. 

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

The department reviewed the RACT/BACT’/LAER Clearinghouse (RBLC) to determine if GCC 

Dacotah’s proposal was representative of previous BACT determinations. Based on the RBLC, 

BACT for “new” cement plants has been staged combustion in a preheater/precalcinator type 

kiln. The department agrees with GCC Dacotah’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 nitrogen oxide emission controls. 

4.1.4 Carbon Monoxide 

4.1.4-1 – Identifying Options 

GCC Dacotah considered the following options 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, LAER Clearinghouse (RBLC) database and 

technical literature for carbon monoxide control technology. The RBLC listed only good 
 Page 25 

combustion practices as a carbon monoxide control method for cement kilns. The other three 

methods were reviewed based on technical literature. 

The department reviewed the control options provided by GCC Dacotah and agrees with the four 

options. 

4.1.4-2 – Technical Feasibility 

The process of oxidizing carbon monoxide and other hydrocarbons to carbon dioxide is similar 

for regenerative thermal oxidation (RTO), thermal oxidation (TO), and regenerative catalytic 

oxidation (RCO) units. Temperature, residence time, and turbulence are the three key factors for 

the destruction of carbon monoxide to carbon dioxide for all three control devices. The 

temperature required to reduce the carbon monoxide 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, Anthony; 1892 by Prentice Hall Inc., 

Englewood Cliffs, NJ. 

The exhaust gases from the main kiln stack, coal mill/dryer stack, and alkali bypass would have 

to be reheated from 250 to 550 degrees Fahrenheit to 1,300 to 1,500 degrees Fahrenheit by the 

RTO and TO. The exhaust gas temperatures would 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 and 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, and 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 increase of air emissions. 

 

Carbon monoxide emissions are generally generated from the incomplete combustion of the fuel 

material in the kiln system. By using 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 practices 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 oxidation, and regenerative catalytic oxidation 

control devices are considered feasible technologies but not practical technologies due to the 

increase of air emissions. Therefore, 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 found that good combustion practices has been 

approved for numerous new and modified cement plants. The department agrees with the GCC 

Dacotah’s BACT determination on using good combustion 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 limit for each point source with a fabric filter 

to be 0.01 grains per dry standard cubic foot. The department agrees with an emission limit of 

0.01 grains per dry standard cubic foot. This type of emission limit varies depending on the size 

of the fan pulling air into or through 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 inherent 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 consumed a majority of the PSD increments for 

sulfur dioxide, would prohibit economic growth in the quarry area and 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 Standards, 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 emission point. The emissions limits of 885 tons per 

year is approximately 2.2 pounds of sulfur dioxide 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 limits stated in the RBLC. The BACT sulfur 

dioxide emission limits displayed in RBLC for the new and retrofitted preheater/precalcinator 

type kilns range from 0.3 to 7.6 pounds per ton clinker produced for the entire 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 the 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 for 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 the preheater tower going to the coal mill/dryer. 

Discussions with the manufacturer noted that the 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/dryer. Based on this information GCC Dacotah 

submitted a letter stating the BACT limit is 2,267 tons 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 nitrogen oxide per ton of clinker produced. The 

emission limit was compared to the 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 kilns 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 emission 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 Dacotah’s permit application. The department 

reviewed the operations to determine 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 precalcinator system at Ash Grove in Seattle that used 20 percent of 

the heat input and had an emission limit of 4.5 pounds 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 satellite cooler make it possible to obtain 

lower nitrogen oxide emissions. GCC Dacotah’s existing 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 determined to be good combustion practices. GCC 

Dacotah proposed a BACT limit of 2,079 tons per year 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-term emission limit to maintain the short-term National Ambient 

Air Quality Standards. 

GCC Dacotah’s proposed limits for 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 the preheater tower going to the coal mill/dryer. 

Discussions with the manufacturer noted that the 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/dryer. 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 tons per). In addition, GCC Dacotah accepted a 

short-term emission limit of 3,250 pounds per hour. 

Because the emissions are 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 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 satisfy 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 preconstruction ambient air quality monitoring; 

2. The air quality analysis must demonstrate that the BACT emission limits from the proposed 

modification added with the background concentrations 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 approved models. GCC Dacotah used terrain data for 

the area, five years of meteorology data from the 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 during the kiln #6 upgrade and were modeled for 

sulfur dioxide, nitrogen oxide, and carbon monoxide. Stack locations and parameters are 
 Page 29 

provided for the units described in Table #10. Due 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 correspond to the emission limits used for sulfur 

dioxide, nitrogen oxide, and carbon 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 long-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/year 
 Page 30 

The highest modeled ambient air 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 

Pollutant Easting Northing Proposed Project 

(meters) (meters) (ug/m3

) 

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 8.98 
 Page 31 

UTM Location Ambient Air Impacts 

Pollutant Easting Northing Proposed Project 

(meters) (meters) (ug/m3

) 

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 particulate emission increases were negated by particulate 

emission decreases in the same area, modeling would 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 may be conducted to determine if the proposed 

BACT emission limits would exceed the de minimis monitoring levels. If the de minimis 

monitoring levels are not exceeded, preconstruction ambient monitoring is not required. 

Preconstruction ambient monitoring is used to determine the background concentration prior to a 

new source or new modification is constructed. 

GCC Dacotah’s kiln #6 upgrade occurred in 1996. Therefore, in the pre-application meeting, the 

department agreed that GCC Dacotah did not need to conduct preconstruction ambient 

monitoring and could use existing 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 project does not exceed the Class II significant 

impact levels then EPA does not require any further NAAQS or PSD Class II increment analyses 
 Page 32 

for that pollutant. Table #13 shows a comparison of the maximum modeled concentrations as 

noted Table #12 and the significant impact levels. 

Table #13 

PSD Class II Significant Impact Levels 

Significant Project Impact Pollutant Impact Level 

(ug/m3) (ug/m3) 

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 particulate matter, sulfur 

dioxide, nitrogen oxide and carbon monoxide (1-hour) concentration levels for PSD Class II 

significant impact levels. The modeled project 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 was conducted to determine if the project would 

exceed the NAAQS. Based on the Class II significant impact level 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 background 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 Dakota 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 nitrogen 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 concentration to compare to the National Ambient Air 

Quality Standards. Table #14 shows the comparison of the modeled impacts to the National 

Ambient Air Quality Standards. 

Table #14 

National Ambient Air Quality Standards (NAAQS) 

Existing Sources 

and 

Proposed Project 

Monitor 

Background 

Total 

Impact NAAQS NAAQS Pollutant 

(ug/m3) (ug/m3) (ug/m3) (ug/m3) 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 existing sources. Therefore, the total concentration is conservatively 

high because it includes the emissions from existing 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 dioxide, nitrogen oxide, and carbon monoxide. 

4.3.3 Increment Consumption 

Black Hills Power and Light Company’s Lange Combustion 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 sulfur dioxide. There is no increment for carbon 

monoxide at this time. Any future PSD applications within the 50 kilometer radius of the Black 

Hills Power and Light Company’s Lange Combustion Turbine Facility and GCC Dacotah have 

to take into account major and minor source changes for PM10, 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 occurred 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 CFR § 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 after 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 noted in Table #12 that was used to demonstrate 

compliance with the increments. Please note due 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 manufacturer’s mass balance. The 

mass balance was calculated on a dry basis. The department reviewed historical data and 

developed a baseline sulfur dioxide emission of 551 tons per year. The department’s calculation 

was based on a wet basis because the historical data is on a wet basis. If Trinity’s mass balance 

is converted from a dry basis to a wet basis, the mass balances 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 sulfur 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 the 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) 7.871

 302 22.13 No 

PM 10 (annual) 2.28 17 14.72 No 

SO2 (3-hour) 3391

 5122 173 No 

SO2 (24-hour) 72.41

 912 18.6 No 

(SO2 annual) 8 20 12 No 

NOx (Annual) 10.73 25 14.27 No 

 1 – Represents the highest 2nd 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 determine 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 results of the analysis for the emission increases 

noted in Table #15 and #16 are found in Table #18. The Class I significant impact levels are 

calculated as four percent of the 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 analysis is required for Class I area increment analysis. However, 

the department did review how the Class I sulfur dioxide increments would be impacted by this 
 Page 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 review 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 absorption of light due to particles and gases emitted from this 

project. Regional haze impairs visibility by obscuring the clarity, color, texture and form of what 

is seen at these Class I areas. This 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 projects 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 meteorological data for five years. However, GCC 

Dacotah only conducted the modeling for the calendar year 1990. The 1990 calendar year is the 

only year that all of the meteorological data has been compiled and is readily available for air 

modeling. Therefore, additional air modeling years were not 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 visual 
 Page 38 

impacts (Bexts) should attain less than five percent change in the background extinction 

coefficient (Bextb) for each Class I area. 

The background extinction coefficient is derived from the following equation: 

 Bextb = 3.912/vr where Bextb = 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: 

 Bexts = (3)(RHf)[(NH4)2SO4 + NH4NO3)] + (1)(PMfine) 

Where RHf = Relative humidity correction factor to adjust for the 

effects of the ambient humidity on light extinction 

calculations 

 (NH4)2SO4 = Concentration of ammonium sulfate in units of ug/m3 - 

(note because SO2 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) 

 NH4NO3 = Concentration of ammonium nitrate calculated as NO3 24 

hour concentration ug/m3 times 1.29, the ratio of molecular 

weights of NH4NO3 and NO3, assuming all NO3 converts 

to NH4NO3

 PMfine = 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 (Bexts) is divided 

by the Class I areas background extinction coefficient (Bextb) and multiplied by 100 percent. 

GCC Dacotah conducted the Calpuff model. The analysis resulted in a few background 

extinctions of greater than 5 percent. The modeling analysis resulted in six days and one day 

where the percent changes were greater than five percent at the Badland 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 and Wind Cave National Parks, respectively. 
 Page 39 

Visibility Extinction Discussion:

Significant impairment to visibility as defined 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 visibility impairment, and how these factors 

correlate with (1) times of visitor use of the mandatory Class I Federal Area, and (2) the 

frequency and timing of natural conditions that reduce 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 Impairment Conditions 

Date Class I 

Area 

Percent 

Extinction 

Time 

Period1 Sunrise Sunset

Percent 

Relative 

Humidity2

Weather 

Conditions3

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 28 
 Page 40 

Date Class I 

Area 

Percent 

Extinction 

Time 

Period1 Sunrise Sunset

Percent 

Relative 

Humidity2

Weather 

Conditions3

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 from 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 Oceanic and Atmospheric Administration weather data for 

Rapid City, South Dakota, for the date and time period selected. 

In modeling the visibility impairment, the relative humidity correction factor used in the 

visibility calculation has a significant 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 significantly 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 Humidity1 

Temperature 

Fahrenheit 

Relative Humidity 

Percent 

Relative Humidity 

Correction Factor 

26 100 18.1 

27 95 9.8 

28 90 4.7 
 Page 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, 7th

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 high 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 sundown 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 National 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 department concludes that GCC Dacotah’s kiln 

#6 upgrade does not have a significant 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 increase in the labor force during the construction phase 

to finish this project. There 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 ambient 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, therefore, 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 point sources to be a fabric filter or electrostatic 

precipitator. The BACT PM10 emission limit for the fabric filter and electrostatic precipitator 

will be 0.01 grains per dry standard cubic foot. There are seven units that do not have a fabric 

filter or electrostatic precipitator installed at this time. GCC Dacotah decided to install fabric 

filters on these seven operations. The permit will require the installation of a fabric filter on all 

seven units within 12 months of permit issuance. Compliance with the PSD emission limit for 

particulate matter will be based on stack performance tests. 

Rapid City experienced problems with exceeding the National Ambient Air Quality Standards 

for particulate matter. Therefore, the department requires at least one-to-one offsets for 

particulate matter (PM10) emissions from new facilities and modifications 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 program. For the Title V review, the department 

determined that GCC Dacotah should offset an increase of particulate emissions of 35 tons per 

year. Particulate offsets have been created when the fabric filters that were installed to control 

particulate emissions from material 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 City Natural Events Action Plan. 

4.5.2 Sulfur Dioxide, Nitrogen Oxide, and Carbon Monoxide

The air emissions from the kiln system are created as a whole and routed through three separate 

emission points (Unit #9 - main kiln, Unit #11 - alkali bypass, and Unit #41 - coal mill/dryer). 

The sulfur dioxide, nitrogen oxide, and carbon monoxide 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 dioxide removal of the raw 

material and the use of low sulfur coal. Table #23 displays the BACT emission 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 year 
 Page 43 

Compliance with the short term limit will be based on a 24-hour block average. Compliance 

with the long term limit will be based on a 12-month rolling average. 

GCC Dacotah proposes to demonstrate compliance with the sulfur dioxide emission limits by 

estimating sulfur dioxide emissions from the coal mill/dryer stack and alkali bypass stack. The 

sulfur dioxide emissions would be estimated by calculating monthly emissions for these two 

units based on the main kiln stack’s continuous 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 amount of sulfur dioxide emissions the airflow rates 

and sulfur dioxide concentrations need to be constant. If the airflow rate 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 all three emission points. GCC Dacotah will install, 

operate, and maintain continuous emission monitoring 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 estimated 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 concentrations are significantly 

different between these two emission 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, operate, and maintain a continuous emission monitoring 

system to measure the sulfur dioxide 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 kiln stack. When the raw mill is in operation, it has the inherent property of 

scrubbing out sulfur dioxide emissions. GCC Dacotah’s application states 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 material increases. Therefore, estimating 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 emission 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 emission 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 based on a 12-month rolling average. Nitrogen 

oxide does not have a short-term National Ambient Air Quality Standard or PSD Increment to 

met, therefore, a short term limit is not required. 

GCC Dacotah proposes to estimate the nitrogen oxide 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 determine 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/dryer stack and alkali bypass stack to the main kiln 

stack, respectively. Based on the previous discussion for sulfur dioxide, a continuous emission 

monitoring system will be installed, operated, and maintained 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 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 nitrogen oxide concentrations are significantly different 

between these two emission points. In addition, GCC Dacotah stated during meetings that the 

concentrations in the alkali bypass and main kiln stack were not the same. Therefore, this 

approach is not valid. The nitrogen oxide emissions need to be measured from the main kiln 

stack and alkali bypass stack. GCC Dacotah will be required to install, operate, 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 information, 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 displays 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 based on an 8 hour block average. There will be 

three 8 hour block averages per day. The three 8 hour blocks shall be from 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 monoxide 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 determine carbon monoxide 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 air flow rates from the coal mill/dryer stack and alkali bypass stack to the 

main kiln stack, respectively. Based on the previous discussion for sulfur dioxide, a continuous 

emission monitoring system will be installed, operated, and maintained to measure the air flow 

rate for all three units. 

GCC Dacotah’s proposal assumes that the carbon monoxide concentrations are the same for the 

main kiln stack and alkali bypass stack and estimates a 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 nitrogen oxide concentrations are significantly different 

between these two emission points. It is assumed that this effect is the same for carbon 

monoxide. In addition, GCC Dacotah stated during meetings that the concentrations in the alkali 

bypass and main kiln stack were not the same. Therefore, 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, operate, 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 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 the 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 information, the carbon monoxide 
 Page 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 and processes at portland 

cement plants that commence construction or modifications after August 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 new source performance standards contained in 40 

CFR Part 60, Subpart F. Therefore, 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 commence construction or modifications after October 24, 1974: thermal 

dryers, pneumatic coal cleaning equipment, coal 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 dry 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 parallel. 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 dryer system (Unit #41) is subject to a total 

suspended particulate emission limit of 0.031 grains per dry standard cubic foot. The BACT 

emission limit for Unit #41 is 0.01 grains per dry standard cubic foot and is measured as PM10. 

Therefore, the BACT emission limit is more 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 to 
 Page 47 

Subpart F that commences construction or modifications 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 crushing and screening operations that occur prior 

to the raw mill system would not be covered by Subpart F. A review of the construction date of 

the crushing and screening operation demonstrates that GCC Dacotah’s crushers were 

constructed prior to August 31, 1983. GCC Dacotah did not upgrade 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 crushing and screening operation. 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 operating at that production rate. GCC Dacotah’s crusher and screening 

operations were capable of handling the increase of “actual” production rate. Therefore GCC 

Dacotah is not subject to this subpart at this time. 

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

The PSD regulations do not require the National Emission Standards for Hazardous Air 

Pollutants also known as Maximum Achievable Control Technology (MACT) standards be 

included or reviewed for PSD permits. Since the following MACT is taking the place of a Part 

60 requirement, this review is briefly discussing it applicability. 

4.7.1 40 CFR, Part 63, Subpart LLL – National Emission Standards for Hazardous Air 

Pollutants from the Portland Cement 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 Title V permit but not the PSD permit. 

4.8 Title V Air Quality Operating Permit 

Any source operating in South Dakota that meets 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 potential criteria air emissions are greater than 

100 tons per year. In accordance with the ARSD 74:36:05:03.01, GCC Dacotah is required to 

submit an application for a Title V air quality operating permit within 12 months after 

commencing operation. The requirements for the kiln #6 upgrade are already in the Title V air 

quality operating permit. However, the permit will 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 required. Modeling results indicate that the increase in air emissions 

will not cause an exceedance of the National Ambient 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 application and this analysis, the department 

recommends issuance of a PSD permit to GCC Dacotah. Any questions pertaining to this permit 

recommendation should be directed to Kyrik Rombough, Natural Resources Engineering 

Specialist. 
 A-1 

Appendix A 

Potential Criteria Air Emissions Factor Determination 
 A-1 

Particulate

The emission factors for particulate are derived 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 Pollutants, 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 and 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 Rates1 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, 6/00
 A-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 10/01
 A-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 Provided 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 Application
A: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 Application
A: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 standard cubic feet. The manufacturer of the baghouses guarantees the 

exit concentration. The exit concentration was back calculated to determine the pound per hour 

emission rate. 

Table #A-5 

Dust Collectors BACT (PM10) Limit 

Unit Description Emission Rates Emission Derivation1

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/dscf
A:4

Unit Description Emission Rates Emission Derivation1

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/dscf
A:5

Unit Description Emission Rates Emission Derivation1

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 manufacturer of the baghouses guarantees 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 GCC 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 S03 (%) 1 S (%) 2 Flowrates Operating Rate3

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 from the US Geological Survey. 3

 – These parameters were determined by the operational reports submitted in 1991 through 1994. 4

 – mtph – metric tons per hour 

Table A-8 

Operational Parameters used to Develop Operating Rates1 

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 54.94 
A:7

1

 The operational parameters were taken from the annual operational 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 Emission 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 Existence 
A: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-Butanone) 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 1/95 
A: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-Butanone) 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