1 What’s Up With Cement Plant Permitting? What’s BACT? Presented by A. A. Linero, P.E. Adminstrator New Source Review Section June 27, 2001

1

What’s Up With Cement Plant Permitting?

What’s BACT?

Presented byA. A. Linero, P.E. AdminstratorNew Source Review Section

June 27, 2001

AWMA Conference, June 2001 2

Overview

Kiln Construction is BackFocus on Preheater/Calciner

ProcessFormation and Control of PollutantsWhat’s Going on in Europe Some BACT and LAER RangesLook at a Current ProjectWhat Next? Questions?


Views are Author’s !

Not Opinions of Florida DEPWe do Case-by-Case ReviewsLiterature Search, Not a Technical

PaperAs Seen by a Permitting EngineerThere are Very Diverse OpinionsGreatly Simplified


Dry Process Preheater Calciner Kilns


Limited to New Dry Process Preheater Calciner Kilns

Rinker Photo By FDEP


From Top of Preheater

Devil’s Slide Photos by FDEP


Leaning Tower of Polysius?

Florida Rock Photo by A. Linero


Lot’s of Projects

Production is up Nationwide. 80 Million TPYFlorida Rock – First New Kiln in a Dozen YearsNew Plants – CO, FL, MS, NY, TXModernizations and ExpansionsAL, AZ, CA, CO, FL, IN, MS, SC, TX, UTMost Require PSD Review and BACT (or LAER)Others “Net Out” – Switch Wet to Dry Process


Pollutant Formation - NOX

Thermal NOX Temp. > 1200 OCKiln Burner ~ 2000 OCOxidizing ConditionsCalciner ~ 1000 OCFuel NOX

Kiln and CalcinerDevils’ Slide Photo by FDEP


Pollutant Control - NOX

Minimize T and Raw Materials Fluctuations

Optimum Process and Raw Mix ControlIntelligent Systems – Linkman, PyroExpertMinimize Primary Air from Coal MillMaximize Hot Air From Clinker CoolerAll New Projects Do These Things


Kiln Burner NOX

Graphic Source: F.L.Smidth/Fuller Multi-channel BurnerPyrojet, Swirlax, Duoflex, GyroTherm, RotoflamFlame Shaping and Localized Reducing

Conditions High Momentum Primary Air EnvelopeCompatible with Low NOX. All New Projects Do.


SC Calciner

Staged Combustion (SC)Lower Stage – Reducing ZoneTires (15%), TDF, DDF, Bottle CapsTertiary Air and FuelUpper Stage – Top AirFlorida Rock InstallingMaybe 30 – 45% ReductionAll New Projects Do This

Graphic Source: Polysius


Diaper Derived Fuel?

Devil’s Slide Filmed by FDEP


Tire Gasification and SC

Whole TiresMaybe 40% TiresJura Cement - WildeggPossible at Suwannee, FL

Graphic Source: Polysius


SNCR

Ammonia or Urea Injection

High T, Near Calciner15+ Kilns in EuropeTaiwanMost Without SCZero in U.S.

Graphic Source: Fueltec


SNCR – Problems?

Much Resistance in U.S.“Slip” and Possibility of Detached

PlumeOften Occurs Even w/o SNCRAmmonia Sulfates and ChloridesCompatibility Question With SC

Graphic Source: EnviroCare


SNCR – Opacity?

No Steam Plume in Dry Preheater Calciner Process Baghouse Will Help Ameliorate Problem Author saw No Plume at Siggenthal Still Getting Plume? Manage and Solve Detached Plume Problem Well Described by EnviroCare and CTL, Inc. Incorporate Into SO2 Control Hydrated Lime MicroMist, Avoid Aluminum Dross

Siggenthal Photo by A. Linero


SNCR – SC Compatibility

For SNCR to Work, Need High T and O2

In SC Calciner, T is High where O2 is “Low”Outside of Calciner, O2 is “High” and T is “Low” Is Lower End of Window 800 or 900 OC Jura Zement Has SC and SNCR and Gasification!“No Effect on (Pre-SNCR) Excellent Plume

Opacity”No Ammonia Slip (Low Removal Objective?)

Graphic Source: Jura Zement


Selective Catalytic Reduction

Catalyst and Low T Ammonia InjectionDemonstration Stage at SolnhofenExtremely Dusty EnvironmentOr Need to Re-heat Stack GasMaybe Exotic Compared to Other OptionsBetter to See What SC, SNCR, Achieve

First


European Emission Limits

Polysius Graphic Modified by A. Linero


SNCR at Leimen Plant - Germany

Graphic Source: Heidelberger

2.3 lb/ton

3.7 lb/ton

~1.3 ?


What is BACT?

2.5 lb/ton at Kiln Built Circa 1980! Slug of 2.3 – 2.9 lb/ton BACTs, e.g. FRI 2.8 in

1996 ~ 1 lb/ton in Slite, Sweden (80% Reduction) ~ 1 lb/ton in Taiwan by SNCR ~ 1 lb/ton in 1994 Ash Grove SNCR Test ~ 1.2 lb/ton Annual Limit at Holnam Midlothian European IPPC BAT (200 – 500 mg/m3) Equals 0.9 to 2.3 lb/ton LAER? Must Be Near 1 lb/ton. Lower if SCR

Photo Source: RMC Lonestar


Pollutant Formation – SO2

Fuel Sulfur – Kiln/CalcinerRoasting of Pyrites in PH

Graphic Source: F.L.Smidth/Fuller


Pollutant Control – SO2

Raw Material Selection (Avoid Pyrites!) Fine CaO in Calciner Scrubs Kiln ~ 100% Move CaO by P to Upper Preheater Can Reduce Pyritic Emissions ~ 20-30% Capitol Cement and Ash Grove Chanute Need More Fuel, Balance Heat Capital Investment Looks Low

Graphic Source: F.L.Smidth/Fuller


Pollutant Control – SO2

CaCO3 and Moisture on Raw Mill Surface Some of the CaO from D-SOX

Maybe Together 70+ Percent of Residual SO2

When Raw Mill Out – Control Gas Temperature Spray Fine Ca(OH)2 Mist into Conditioning Tower Not Enough - More Conventional Scrubbers Achieve as much as 90 Percent Removal

Pfeiffer Raw Mill


Effect of Raw Materials & Process on SO2

PH/Calciner Kilns in TX – 1000’s of TPY of SO2

High Pyrites in Raw Materials Wet Kilns in Florida – 1000’s of TPY of SO2

Fuel Sulfur, No Calciner - less Self Scrubbing PH/Calciner Kilns in Florida – << 100 TPY No Pyrites in Raw Materials Florida Rock Kiln, Rinker Modernization From 1000+ TPY to ~ 20 TPY

Florida Rock Photo By FDEP


What is BACT?

< 0.23 (or Better) in Florida With No Controls ~ 0.05 at Siggenthal by (Incidental) Coke

Filter ~ 1.3 lb/ton at TXI Midlothian to Avoid PSD < 1 lb/ton at Slite, Sweden (90% Reduction) European IPPC BAT (200 – 400 mg/m3) Equals 0.9 to 1.8 lb/ton D-SOx & Lime Mist With Moderate Pyrites 90 % Scrubber Control With Very High Pyrites


Pollutant Formation - CO & VOC

CO From Incomplete CombustionVery Little VOC From Kiln and

CalcinerEvolution in PreheaterOrganic Carbon from Raw MaterialsCarbon from Coal AshVOC from Mill Scale, etc.


Pollutant Control - CO & VOC

Hot Excess Air, Mixing Tertiary Air After Calcining E.G. Pyrotop after SC Raw Material Selection – e.g. Millscale ~ 70% VOC Reduction at Florida Rock Must Install Continuous Monitor Grind and Introduce Directly into Kiln

Graphic Source: KHD


Regenerative Thermal Oxidation

Texas Cement MidlothianAbout 10 ModulesArea of a Football FieldEnter Market at Earliest DateAvoid PSD Delays “up to 3

Years”$17,500,000 for RTO$13,000,000 for SO2 Scrubber

Graphic Sources: Durr/Reeco


Active Coke Filter

Siggenthal Switzerland In Conjunction with Dried Sludge Burning$15,000,000 Partly Funded by Zurich“Environmentally Friendly Dried Sludge

Burning”Concern Was Thallium and Mercury (on Cows?)Also Cleans up, SO2, dioxin/furan, and AmmoniaWith SNCR Constitutes POLVITEC by Polysius


What is BACT?

VOC = ~ 0.1 lb/ton in Florida (Hard to Meet!)VOC = ~ 0.026 lb/ton at TXI (By RTO - LAER?)CO = ~ 2 – 3.6 lb/ton in Florida CO = ~ 6 – 8 lb/ton in SC CO = ~ 0.37 lb/ton at TXI (By RTO - LAER?)


European Rule 2000/76/EG

Pollutant Concentration Process LimitDust 30 mg/m3 ~ 0.14 lb/ton

NOX 500 mg/m3 * ~ 2.3 lb/ton *800 mg/m3 ** ~ 3.7 lb/ton **

SO2 50 mg/m3 *** ~ 0.23 lb/ton ***Mercury 0,05 mg/m3 ~ 0.00023 lb/tonFluorides 1 mg/m3 ~ 0.0046 TOC 10 mg/m3 *** ~ 0.046 lb/ton ***CO _

* New Sources ** Existing Sources (Swedish non-EU standard is 200 mg/m3 ~ 0.9 lb/ton)*** Non Raw Material-Specific Emission


Pollutant Concentration Process Limit

Chlorides 10 mg/m3 ~ 0.046 lb/ton

Cd and Thallium 0.05 mg/m3 ~ 0.00023 lb/ton

Sb+As+Pb+Cr+

Co+Cu+Mn+Ni+V 0.5 mg/m3 ~ 0.0023 lb/ton

Dioxin and Furan 0.1 ng ITEQ/m3

European Rule 2000/76/EG


Ozone Non-Attainment Area

Pollutant

Requirement

Top Limit

Technology

Draft Limit

Proposed Control

NOX (4121 tpy)

LAER ~ 1 SNCR 3.61 2.82,3

SC SC &

SNCR(?)

VOC (129 tpy)

LAER 0.026 RTO ~0.11

Materials?

SO2 (850 tpy)

BACT 0.23 Varies ~0.74

Scrubbers

CO (3983 tpy)

BACT 0.37 RTO ~3.5 Materials?1. Initial Limit is 3.6 lb/ton during first two years by Staged Combustion 12-Month Average2. Limit is stepped down from 3.6 to 2.8 lb/ton between years 2 and 3 3. Company proposes LAER after 38 months of operation. Department sets LAER (2007 ??)


Final Thoughts

4000 TPY of NOX equates to 50 Gas-fired Combined Cycle Plants = to 12,500

MW At 3 million Btu/ton of Clinker 3.6 lb NOX /ton limit equates to

1.2 lb NOX/million Btu heat input Order of magnitude > than new coal power plant Two orders > greater than gas-fired power plant Some low hanging fruit to pick here.


Documents

1 What’s Up With Cement Plant Permitting? What’s BACT? Presented by A. A. Linero, P.E. Adminstrator New Source Review Section June 27, 2001