United States s Office of Air Quality EPA-450/3-85-003a
Environmental Protection Planning and Standards May 1985
Agency Research Triangle Park NC 27711
Air
&ERA Portland Cement
Plants-
Background
Information for
Proposed Revisions
To Standards
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EPA-450/3-85-003a
Portland Cement-
Background Information for Proposed
Revisions to Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
May 1985 ^ $ Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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This report has been reviewed by the Strategies and Air Standards Division of the Office of Air Quality
Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use. Copies of this report are
available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, or from National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.
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TABLE OF CONTENTS
Page
LIST OF FIGURES iv
LIST OF TABLES v
CHAPTER 1. EXECUTIVE SUMMARY 1-1
1.1 Regulatory History of Current Standards 1-1
1.2 Industry Trends 1-2
1.3 Control Technology 1-2
1.4 Compliance Test Data 1-3
1.5 Cost Considerations Affecting the NSPS 1-4
1.6 Enforcement Aspects 1-4
CHAPTER 2. INDUSTRY DESCRIPTION 2-1
2.1 Introduction 2-1
2.2 Process Description 2-1
2.2.1 Raw Material Handling 2-1
2.2.2 Clinker Production 2-2
2.2.3 Cement Manufacture and Shipment 2-5
2.3 Industry Characterization 2-6
2.3.1 Geographic Distribution 2-6
2.3.2 Production 2-6
2.3.3 Growth Trends 2-7
2.3.4 Process Developments 2-7
2.4 Emissions From Portland Cement Plants 2-9
2.4.1 Particulate Emissions 2-9
2.4.2 Sulfur Oxide Emissions 2-9
2.4.3 Nitrogen Oxide Emissions 2-10
2.5 References for Chapter 2 2-31
CHAPTER 3. CURRENT STANDARDS FOR PORTLAND CEMENT PLANTS 3-1
3.1 New Source Performance Standards 3-1
3.1.1 Summary of New Source Performance Standards ... 3-1
3.1.2 Testing and Monitoring Requirements 3-2
3.1.3 Recordkeeping and Reporting Requirements .... 3-2
3.2 State Regulations 3-3
3.3 References for Chapter 3 3-4
CHAPTER 4. CONTROL TECHNOLOGY AND COMPLIANCE TEST RESULTS .... 4-1
4.1 Available Particulate Control Technology 4-1
4.1.1 Kiln 4-1
4.1.2 Clinker Cooler 4-8
4.1.3 Other Facilities 4-9
4.2 Summary of Particulate Compliance Test Results 4-9
4.2.1 Kiln 4-9
4.2.2 Clinker Cooler 4-11
4.2.3 Other Facilities 4-13
m
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TABLE OF CONTENTS (continued)
4.3 Available Gaseous Pollutant Technology 4-13
4.3.1 Sulfur Dioxide 4-13
4.3.2 Nitrogen Oxides 4-22
4.4 References for Chapter 4 4-23
CHAPTER 5. COST ANALYSIS 5-1
5.1 Approach 5-1
5.2 Estimated Capital and Annualized Costs of
Emission Control 5-1
5.2.1 Kiln 5-2
5.2.2 Clinker Cooler 5-2
5.2.3 Other Facilities 5-2
5.3 Comparison of Estimated and Reported Capital Cost
Data 5-3
5.4 Cost Effectiveness 5-3
5.5 References for Chapter 5 5-12
CHAPTER 6. ENFORCEMENT ASPECTS 6-1
6.1 Varied Exhaust Gas Ducting Configurations 6-1
6.2 Bypass of Electrostatic Precipitators 6-2
6.2.1 CO Trips 6-2
6.2.2 Kiln Startup and Shutdown 6-5
6.3 Continuous Opacity Monitors 6-6
6.4 -Recordkeeping and Reporting Requirements 6-6
6.5 References for Chapter 6 6-7
APPENDIX A. SUMMARY OF PORTLAND CEMENT FACILITIES SUBJECT
TO NSPS A-l
APPENDIX B. SUMMARY OF STATE REGULATIONS FOR PORTLAND CEMENT
PLANT FACILITIES B-l
APPENDIX C. PARTICULATE EMISSIONS AND OPACITY DATA FOR
FACILITIES SUBJECT TO THE NSPS SINCE THE 1979 REVIEW .... C-l
IV
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LIST OF FIGURES
Page
Figure 2-1 Typical Wet Process Material Handling 2-11
Figure 2-2 Typical Dry Process Material Handling 2-12
Figure 2-3 Typical Clinker Production Process 2-13
Figure 2-4 Four-Stage Suspension Preheater With a Precalciner . 2-14
Figure 2-5 Traveling Grate Preheater System 2-15
Figure 2-6 Finish Mill Grinding and Shipping 2-16
Figure 2-7a Portland Cement Plant Locations—Western U. S. ... 2-17
Figure 2-7b Portland Cement Plant Locations—Eastern U. S. ... 2-18
Figure 2-8 Fuel Consumption Per Ton of Clinker Produced by Fuel
Type and Clinker Production Process 2-19
Figure 2-9 Number of Plants Using Wet or Dry Clinker
Production Process 2-20
Figure 2-10 Kiln Construction by Year • 2-21
Figure 2-11 Detail of Roller Mill That Combines Crushing,
Grinding, Drying, and Classifying in One Vertical
Unit 2-22
Figure 2-12 Particle Size Distribution of Cement Dust 2-23
Figure 4-1 Particulate Mass Emissions From Kilns That Have
Become Subject to the NSPS Since 1979 4-10
Figure 4-2 Particulate Mass Emissions From Clinker Coolers That
Have Become Subject to the NSPS Since 1979 4-12
Figure 4-3 S02 Emissions Versus Sulfur in the Coal 4-20
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LIST OF TABLES
Table 2-1 U.S. Clinker Production, Kiln Capacity, and Capacity
Utilization—1972-1982 2-24
Table 2-2 Facilities Subject to the NSPS Since 1979 Review . . . 2-25
Table 2-3 S02 Emission Test Results for Portland Cement
Facilities That Have Become Subject to the NSPS
Since 1979 2-28
Table 2-4 NO Emission Test Results for Portland Cement
Facilities That Have Become Subject to the NSPS
Since 1979 2-29
Table 4-1 Potential Sources of Particulate Emissions and
Typical Control Practices 4-2
Table 4-2 Particulate Control Technology Practices at Plants
With Facilities That Have Become Subject to the NSPS
Since the 1979 Review 4-3 ~
Table 4-3 Summary of Carbon Monoxide Trip Data for Electrostatic
Precipitators on Kilns That Have Become Subject to the
NSPS Since 1979 4-7
Table 4-4 S02 Emissions From Lone Star Industries, Incorporated . 4-16
Table 5-1 Summary of Model Kiln Facility Parameters 5-4
Table 5-2 Estimated Capital and Annualized Costs of
Particulate Emission Control Equipment for Model Kiln
Facilities 5-5
Table 5-3 Summary of Model Clinker Cooler Facility Parameters . . 5-6
Table 5-4 Estimated Capital and Annualized Costs of Particulate
Emission Control Equipment for Model Clinker Cooler
Facilities 5-7
Table 5-5 Summary of Parameters for Model Other Facilities .... 5-8
Table 5-6 Estimated Capital and Annualized Costs of
Particulate Emission Control Equipment for Model Other
Facilities 5-9
Table 5-7 Comparison of Estimated Capital Costs of Emission
Control with Reported Capital Data Costs (From
Industry) 5-10
VI
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LIST OF TABLES (continued)
Table 5-8 Cost Effectiveness of Participate Emission Reduction by
Model Facilities 5-11
Table A-l Summary of Portland Cement Facilities Subject
to NSPS A-l
Table B-l Summary of State Regulations for Portland Cement Plant
Facilities B-l
Table C-l Particulate Emissions and Opacity Data for Facilities
Subject to the NSPS Since the 1979 Review C-l
vn
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1. EXECUTIVE SUMMARY
The Clean Air Act Amendments of 1977 require that the U. S.
Environmental Protection Agency (EPA) review and, if appropriate, revise
new source performance standards (NSPS) every 4 years. This report
presents information on developments that have occurred in the port!and
cement industry since the last review of the standards in 1979.
1.1 REGULATORY HISTORY OF CURRENT STANDARDS
The NSPS for the portland cement industry were proposed on August 17,
1971, promulgated by EPA on December 23, 1971, and revised in response
to a court remand on November 12, 1974 (40 CFR 60, Chapter I, Subpart F).
The standards apply to kilns, clinker coolers, raw mill systems, finish
mill systems, raw mill dryers, raw material storage areas, clinker
storage areas, finished product storage areas, conveyor transfer points,
bagging, and bulk loading and unloading systems that had begun
construction or modification on or after August 17, 1971.
The standards prohibit the discharge into the atmosphere from any
kiln, exhaust gases which:
1. Contain particulate matter in excess of 0.15 kilograms (kg) per
megagram (Mg) of feed (dry basis) to the kiln or 0.30 pounds (lb) per
ton of feed to the kiln, or
2. Exhibit greater than 20 percent opacity.
The standards prohibit the discharge into the atmosphere from any clinker
cooler, exhaust gases which:
1. Contain particulate matter in excess of 0.05 kg/Mg of feed (dry
basis) to the kiln (0.10 lb/ton), or
2. Exhibit 10 percent opacity or greater.
Finally, the standards prohibit the discharge into the atmosphere from
any affected facility other than the kiln or clinker cooler, exhaust
gases which exhibit 10 percent opacity or greater.
The first review of the standard, published in 1979, recommended
that no changes be made to the particulate mass or the visible emission
limits. A recommendation to require opacity monitoring was made. In
addition, it was recommended that a monitoring program be initiated to
determine nitrogen oxide (NO ) and sulfur dioxide (S02) emission rates
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for kilns that have become subject to the NSPS and that research and
development be funded to determine means of reducing NO emissions from
kilns. x
The following sections summarize the results and conclusions of the
second review of the NSPS for portland cement plants.
1.2 INDUSTRY TRENDS
Since the 1979 review, 37 cement plants have added, reconstructed,
or modified facilities so as to bring them under the NSPS for portland
cement plants. Fourteen plants have installed all new facilities (i.e.,
kilns, clinker coolers, and other associated equipment such as mills and
storage and transfer facilities), and the remainder have added new kiln
capacity and/or other equipment.
Ninety-two percent of the kilns built since the 1979 review use the
dry process of cement production instead of the wet process because the
dry process is more fuel efficient. The fuel efficiency of the dry
production process can be increased further by adding a preheater, which
uses the kiln exhaust gases to preheat the raw feed, or by combining a
preheater with a precalciner to preheat and partially precalcine the raw
feed prior to the kiln. Of dry process kilns built since 1979, 17 percent
use a preheater system, and 79 percent use a preheater/precalciner
system.
Fuel efficiency can be improved also by directing all or a portion
of the exhaust gases from the kiln, the preheater (if one exists), or
the clinker cooler through the raw mill prior to a control device for
further heat exchange between the gases and the raw feed material.
Twenty percent less energy was needed to produce I Mg (1.1 ton) of clinker
in 1982 than was needed in 1972.
1.3 CONTROL TECHNOLOGY
Fabric filters or electrostatic precipitators are used to control
emissions from portland cement kilns. Compliance with the particulate
mass and visible emission standards has been demonstrated using either
control device.
At 28 plants with one or more kilns that have become subject to the
NSPS since the 1979 review, 17 kilns are controlled by fabric filters,
and 13 kilns are controlled by electrostatic precipitators (3 kilns at
one plant are controlled by one electrostatic precipitator).
Fabric filters most commonly control emissions from clinker coolers.
Of 23 clinker coolers subject to the NSPS since the 1979 review, 17 are
controlled by fabric filters, 2 are controlled by electrostatic
precipitators, and 4 are controlled by gravel bed filters.
Other affected facilities at cement plants are typically controlled
by fabric filters; however, two finish mills are controlled by
electrostatic precipitators.
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Air pollution control agency personnel expressed concern that
excess particulate emissions from kilns controlled by electrostatic
precipitators were occurring during periods of carbon monoxide (CO)
trips. Because a spark source is present, electrostatic precipitators
used to control kiln particulate mass emissions are equipped with
combustibles or CO monitors that de-energize the electrostatic
precipitator if preset levels are reached that may present an explosion
hazard. Carbon monoxide trips last from less than a minute to more than
20 minutes and may occur from a few times per year to more than 600 times
per year. Annually, particulate emissions resulting from such trips can
be significant.
Emission test data from 19 cement kilns show that kilns can be
major sources of S02 emissions. These emissions result from both sulfur
in the fuel (coal) and sulfur in the raw feed material. Both components
can vary significantly from plant to plant. Data and mass balance
calculations indicate that S02 emissions are reduced by 35 to 75 percent
in the production process; the sulfur can be absorbed into the clinker,
the raw feed, or the control device dust or can be emitted as a gas.
The EPA and the portland cement industry have examined the use of fabric
filters in controlling S02 emissions as well as the use of flue gas
desulfurization systems as potential add-on control. Data on the-amount
of S02 emission reduction achieved by control devices on cement kilns
are inconclusive because many unpredictable factors affect emissions,
such as the sulfur content of the feed, the point in the process at
which S02 removal occurs, and the relative importance of process variables,
Since the 1979 review of the NSPS, research has been conducted on
the emission reduction of NO . Although there are several process
modifications that appear to affect NO emissions, additional research
/\
is required to demonstrate control technology for NO emissions.
/\
1.4 COMPLIANCE TEST DATA
Thirty kilns have become subject to the NSPS since the 1979 review;
however, three of these are under construction, and compliance test data
are not available. All of the 27 operational kilns that have become
subject to the NSPS since the 1979 review are in compliance with the
NSPS particulate mass and visible emission limits. Twenty-three clinker
coolers have become subject to the NSPS since 1979; two are completing
construction, and compliance test data are not available. Nineteen of
the twenty-one operational clinker coolers that have become subject to
the NSPS since the 1979 review are in compliance with the particulate
mass limit; two of the clinker coolers, which were tested under conditions
not representative of those during normal operation, were found to
exceed the particulate mass limit and will be retested during normal
operation. One clinker cooler that is in compliance with the particulate
mass limit exceeds the visible emission limit; plant modifications are
underway to bring the visible emissions below 10 percent opacity. All
of the other affected facilities (mills and storage and transfer
facilities) have been reported to be in compliance with the 10 percent
visible emission limit.
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1.5 COST CONSIDERATIONS AFFECTING THE NSPS
To estimate the cost effects of the NSPS, model facility descriptions
were developed based on information from the industry. The capital and
annualized costs for the control system for each model plant were estimated
using guidelines in the CARD Manual and information supplied by industry.
Costs were updated to July 1983 dollars using the Chemical Engineering
Journal plant cost index.
The cost effectiveness of controlling particulate emissions from
kilns was estimated to range from $34 to $49 per Mg ($31 to $45 per
ton). The cost effectiveness of controlling particulate emissions from
clinker coolers was estimated to range from $27 to $44 per Mg ($25 to
$40 per ton). The cost effectiveness of controlling particulate emissions
from other affected facilities was estimated to range from $30 to $167 per
Mg ($27 to $151 per ton).
1.6 ENFORCEMENT ASPECTS
Chapter 6 discusses Federal, State, and local air pollution control
agency personnel concerns about (1) interpretation of the mass emission
limits for various duct configurations of affected facilities, (2) the
need to bypass an electrostatic precipitator during periods of CO trips,
startups, and shutdowns, (3) monitoring requirements, and (4) recordkeeping
and reporting requirements.
1-4
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2. INDUSTRY DESCRIPTION
2.1 INTRODUCTION
Manufacturing of hydraulic cement is covered by the Standard
Industrial Classification (SIC) code 3241, which includes plants that
manufacture portland, natural, masonry, and pozzolan cements. Over
95 percent of the hydraulic cement manufactured in the United States is
Portland cement, which consists mainly of tricalcium silicate and dicalcium
silicate.1,2 The portland cement production process involves three
basic steps. First, raw materials are crushed and mixed. Second, the
mixture is heated to high temperatures in a kiln where chemical reactions
take place and a rock-like substance called clinker is formed. The
clinker is then cooled in a clinker cooler. Third, the cooled clinker
is crushed, and ground gypsum or other materials are added to'obtain the
properties desired in the finished cement. In the following sections of
this chapter, the portland cement production process is described, the
industry is characterized, and uncontrolled emissions are discussed.
2.2 PROCESS DESCRIPTION
2.2.1 Raw Material Handling
Portland cement is composed of combinations of calcium, silica,
alumina, iron, and gypsum. Limestone is the most common source of
calcium, although oyster shells, chalk, coral rock, or aragonite are
used in some parts of the country.3 Limestone can also have naturally
high amounts of clay or shale, which contain aluminum silicates or free
silica. For example, the mineral components of "cement rock" limestone
from the Lehigh Valley of Pennsylvania are so correctly proportioned
that no additional raw materials are required to make clinker.3 More
commonly, raw materials such as clay, shale, or iron ore must be added
to adjust the chemical composition of the clinker. Processing of these
raw materials into kiln feed involves a quarrying and crushing phase and
a mixing and grinding phase.
Limestone is usually obtained from an open quarry located on or
near the plant site. An explosive such as ammonium nitrate and fuel oil
(ANFO) is often used to quarry the limestone, although, in some instances,
the materials may be quarried mechanically. Raw materials not quarried
at the site are typically brought to the plant by truck or rail and
stored in stockpiles near the crushing machinery.
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The raw materials are crushed in a primary crusher to a maximum
size of approximately 15.2 centimeters (cm) (6 inches [in.]) in diameter.4
Primary crushers may be of the gyratory, jaw, roll, or hammer type.
Secondary crushers, often hammermills, crush the rock to smaller than
2.5 cm (1 in.) in diameter.5 Crushed raw materials are stored in silos
or stockpiles.
During the mixing and grinding phase of raw material handling, the
crushed materials are proportioned, ground so that 70 to 90 percent will
pass through a 200 mesh sieve, and then blended prior to being fed into
the kiln.3,6 Sometimes both proportioning and blending occur after the
grinding phase. Mixing and grinding of raw materials can be done using
either a wet or a dry process.
In the wet grinding process, ball mills or compartment mills (a
ball mill combined with a tube mill) are used, and water is added to the
mill with the crushed raw materials (see Figure 2-1).7,8 The propor-
tioned and ground raw feed is discharged from the mill as a slurry
containing from 30 to 40 percent water.9 Slurry composition is adjusted
in correcting tanks if necessary, and the slurry is then stored in a
slurry basin. This slurry may be fed directly to the kiln or may
first be dewatered to form a cake containing about 20 percent moisture
or dried in a dryer heated by exhaust gases from the kiln or the clinker
cooler.9,10
In the dry grinding process, ball mills, roller mills, or compart-
ment mills are also used, but the materials are ground without water
(see Figure 2-2). Crushed raw materials are dried in the mill itself or
in a direct-contact rotary dryer until the free moisture content is less
than 1 percent.5 Heat for the mill or dryer can be supplied by direct
firing, although it is usually supplied by recirculation of hot exhaust
gases from the kiln or clinker cooler. If a roller mill is used, all
kiln exhaust gases can be directed through the mill for drying and
preheating; if a ball mill is used, only a portion of the exhaust gases
can be directed to the mill.11 The feedstock is typically blended using
compressed air in homogenizing silos and then stored until the material
is fed into the kiln.9
2.2.2 Clinker Production
Figure 2-3 presents a schematic of the basic process of clinker
production. Raw feed (wet slurry or dry feed) is fed into the upper end
of an inclined rotary kiln and conveyed slowly toward the lower end of
the kiln by gravity and rotation of the kiln cylinder. Kilns are fired
from the lower end so that the hot gases pass countercurrent to the
descending raw feed material. The temperature of the feed material
increases to a maximum of about 1500°C (2700°F) during passage through
the kiln.12 The temperature increase is accompanied by a series of
physical and chemical changes: (1) evaporation of the free water,
(2) evaporation of the combined water in the clay, (3) calcination of
the magnesium carbonate (MgC03 •* MgO + C02), (4) calcination of the
calcium carbonate (CaC03 -> CaO + C02), and (5) combination of the lime
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and clay oxides at the firing end of the kiln to form the rock-like
substance called clinker.13,14 Clinker is comprised of four major
compounds: tricalcium silicate [(CaO)3 • Si02], dicalcium silicate
[(CaO)2 • Si02], tricalcium aluminate [(CaO)3 • A1203], and tetracalcium
alumino-ferrite [(CaO)4-Al203-Fe203].14
2.2.2.1 Wet process of clinker production. In the wet process of
clinker production, feed material enters the kiln in a wet slurry form.
For a slurry containing 40 percent moisture, 2.6 megagrams (Mg) (2.8 tons)
of slurry feedstock will yield 0.9 Mg (1 ton) of clinker.15,lg The
balance of. the feedstock, about 1.7 Mg (1.8 tons), is lost during clinker
production a-s water vapor, carbon dioxide, and other volatile compounds.3
Wet process kilns average 160 meters (m) (525 feet) in length, and
evaporation of moisture from tbe feed occurs in the first 20 to 25 percent
of the kiln's length.15 Metal-chains are often hung inside the kiln to
aid in heat transfer to the wet slurry and to help break up clumps of
raw materials.1-7
2.2.2.2 Dry process of clinker production. The only difference in
the calcination process between a wet process and a dry process kiln is
that less moisture needs to be evaporated from dry process feed material.
Because dry kiln feed typically contains less than 1 percent moisture,
approximately 1.6 Mg (1.8 tons) of raw feed are needed to produce 0.9 Mg
(1 ton) of clinker.5,15,16 Again, the remainder of the kiln feed,
0.7 Mg (0.8 ton), is lost during clinker production as water vapor,
carbon dioxide, and other volatile compounds.3 Dry process kilns can be
20 to 25 percent shorter than wet process kilns because little or no
kiln residence time is needed to evaporate water from dry feed.15 The
water vapor produced in a wet kiln increases the heat loss from the
kiln. Therefore, dry process kilns require less fuel per kilogram of
clinker produced than wet process kilns.18 In 1982, average consumption
of kiln fossil fuel per kilogram of clinker produced by the wet process
was 6.5 megajoules (MJ) (5.6 million British thermal units [Btu's] per
ton) compared to 4.6 MJ (4.0 million Btu's per ton) per kilogram of
clinker produced by the dry process.19
Dry process kilns that have become subject to the new source
performance standards (NSPS) since 1979 commonly employ a preheater or
preheater/precalciner system.13 Both the preheater and the preheater/
precalciner systems allow the sensible heat in kiln exhaust gases to
preheat and partially calcine the raw feed before the feed enters the
kiln.
Addition of a preheater to a dry process kiln permits use of a kiln
one-half to two-thirds shorter than a dry kiln without a preheater
because heat transfer to the dry feed (whether ground or pelletized) is
more efficient in a preheater than in the preheating zone of the kiln.14
Also, because of the increased heat transfer efficiency, a preheater
kiln system requires less energy than a wet kiln or a dry kiln without a
preheater to achieve the same amount of calcination. Wet raw feed
(containing 20 to 40 percent moisture) requires a longer residence time
for preheating, which is best provided in the kiln itself. Therefore,
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wet process plants do not use preheater systems.20 Compared to a wet
process kiln, a dry process kiln with a preheater system can use 50 percent
less fuel.21 There are two kinds of preheater systems: the suspension
system and the traveling-grate system.
The suspension preheater is the most commonly used preheater system
and usually consists of a vertical tower containing a multistage cyclone-
suspension process interconnected with pipes (see Figure 2-4). Dry
ground feed typically containing less than 1 percent moisture enters at
the top of the tower and exits at the bottom into the feed end of the
kiln.5 Hot kiln exhaust gases exit at the feed end of the kiln and
travel upward through the preheater system countercurrent to the flow of
the descending feed. The dry feed particles can be entrained by and
uniformly dispersed within the ascending hot gas stream.13 Thus, the
feed is separated and preheated in each stage, and, in the lower stages
of the preheater where the off-gases are the hottest, up to 40 percent
of the calcining may occur.22
In the traveling-grate preheater system, the blended raw feed is
moistened to form small pellets that measure about 2.5 cm (1 in.) in
diameter and that contain 10 to 12 percent water.12 These pellets are
spread upon a grate that travels slowly toward the feed end of the kiln.
Hot exhaust gases leaving the kiln pass through the pellet bed, drying,
heating, and partially calcining the pellets.12 A traveling-grate
preheater is shown in Figure 2-5.
Addition of a precalciner system to a preheater system allows about
95 percent of the calcining of the raw material to be accomplished
before the raw material enters the kiln.17,21 Figure 2-4 depicts a
suspension preheater/precalciner kiln system. In this system, a vessel
called a flash precalciner is located between the preheater and the kiln
and is fueled by a separate burner. The calciner may use air from the
kiln (air-through system) or from the clinker cooler (air-around system)
and, depending on the specific system, will burn 40 to 60 percent of the
total kiln fuel.23 Rapid calcination occurs in the precalcining vessel.
By monitoring the precalciner temperature, adjustments to the calcination
rate can be quickly made. This helps to yield uniform calcination of
the kiln feed material.24 Gases from the precalciner continue up through
the preheater.17
The direct contact that occurs in preheater and preheater/precalciner
systems between hot kiln exhaust gases and the raw feed can allow conden-
sation of sulfur and alkalies on the feed, which can result in a high
concentration of these substances in the clinker. Excessive sulfur in
the cement can delay some of the hydration reactions until after the
final setting of the concrete. The delayed hydration reactions can
cause expansion of the concrete and cracking of the final structure.25
Therefore, the American Society of Testing and Materials (ASTM) limits
the total sulfur trioxide (S03) content of finished cement to 2.3 to
4..5 percent, depending on the type of cement and the content of tri-
calcium aluminate [(CaO)3 • A1203].9 Alkalies in cement can react with
certain aggregates to cause swelling and weakening of the concrete.26
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Also, excessive alkalies can lead to ring formations inside the kiln or
preheater vessels, which can adversely affect clinker formation.
Therefore, ASTM has placed an optional limit on the total alkali content
in portland cement of 0.6 percent.9
Alkali metals (sodium and potassium oxides) and sulfates are
volatilized in the calcining area of the kiln; and, if the kiln exhaust
gases travel through a preheater, raw mill, or dryer, these alkali
metals and sulfates condense on the raw feed that is entering the kiln.27
This condensation can set up a recirculation of volatile compounds that
could increase the alkali metal and sulfur content of the clinker.27 To
avoid excessive buildup of alkali and sulfur on the raw feed, some
preheater kiln systems have an alkali bypass exhaust gas system added
between the kiln and the preheater.28 Some of the kiln exhaust gases
are ducted to the alkali bypass prior to the preheater, thus reducing
the alkali fraction passing through the feed.29 Particulate emissions
from the bypass are controlled by a separate pollution control device.
Dust collected in the alkali bypass control device is usually disposed
of, although it can be recycled to the kiln after leaching to remove the
alkali content.
Dry process kilns with a preheater or preheater/precalciner have
higher production capacities than simple dry process kilns of the same
diameter.22 Preheaters can increase the capacity of a dry process kiln
by 20 to 30 percent, and a flash calciner can add another 25 percent
clinker production capacity.21 Kiln capacity increases because the
preheater and precalcining vessels accomplish some of the feed calcination
much more quickly than can occur in the kiln. Also, because some drying
and calcining of the feed has already been accomplished by the preheater
or preheater/precalciner systems, the kiln itself can be shorter and,
therefore, can be rotated more quickly while maintaining proper feed
residence time and bed depth.21,30
2.2.2.3 Clinker cooling. Clinker is discharged from the kiln to a
clinker cooler. Ambient air is passed through a moving bed of hot
clinker, cooling the clinker from about 1500°C (2700°F) to about 65°C
(150°F).13,31 Clinker coolers can be the planetary, grate, or vibrating
type. Cooled clinker can be stored in silos, storage halls, or outdoor
stockpiles. Clinker cooler exhaust gases can be ducted to emission
control equipment or can be recycled to the kiln, the preheater (or
precalciner), the raw mill, or a raw feed dryer.
2.2.3 Cement Manufacture and Shipment
Figure 2-6 presents a schematic of finished cement grinding and
shipping. Cooled clinker is mixed with about 5 percent gypsum and
ground to a size such that 90 to 100 percent of it passes a minus-325 mesh
sieve.16,32 Gypsum is added to regulate the setting time of the finished
cement.33 Depending on the type of cement being made, other additives
may be mixed in at this time. These other additives could include
dispersal, water proofing, or air-entraining agents.8 The finish mill
can be an open circuit, where the material passes through the mill
2-5
-------
regardless of particle size, or a closed circuit, where air classifiers
send over-sized clinker back through the mill for further grinding.34
The finished cement is packaged in bags or bulk loaded and delivered by
rail, truck, or ship.
2.3 INDUSTRY CHARACTERIZATION
As of December 1983, there were 143 portland cement manufacturing
plants in 40 States and Puerto Rico. Eight of these plants do not
produce clinker but grind purchased clinker into finished cement.20 The
143 plants are operated by 45 different companies.20 By comparison, in
1979, 53 companies operated 166 cement plants, and, in 1974, 51 companies
operated 179 cement plants.35,36 As of December 1983, 56 percent of the
industry clinker capacity was owned by 10 companies. The five companies
that owned about 36 percent of industry clinker capacity at that time
were: Lone Star Industries, Inc. (11.9 percent), General Portland, Inc.
(7.0 percent), Ideal Basic Industries, Inc. (6.2 percent), Gifford-Hill
& Company, Inc. (5.3 percent), and Lehigh Portland Cement Company
(5.1 percent).37
2.3.1 Geographic Distribution
Geographic distribution of domestic portland cement plants as of
December 1983 is shown in Figures 2-7a and 2-7b. Portland cement plants
tend to be located near adequate supplies of suitable raw materials,
sufficient fuel of a consistent quality, electrical power, and a source
of labor.38 Because portland cement is expensive to transport, proximity
and economical transportation to regional markets is also necessary.
About 95 percent of portland cement is shipped less than 483 kilometers
(300 miles).39
Regional concentration of cement plants has shifted in recent
years. Previously, clinker capacity was concentrated in the Eastern and
the Great Lakes-Midwestern regions of the U.S. where construction activity
was high. Clinker capacity has increased in the West and the South
Central regions of the country because of the changing construction
market, the availability of limestone, and, in the case of the South
Central region, the availability of inexpensive fuel.36
California plants have the capacity to produce the largest quantity
of domestic cement, followed by plants in Texas and Pennsylvania.39
Texas, however, accounts for the largest consumption of portland cement,
followed by California and Florida.39
2.3.2 Production
Growth of the portland cement industry is closely tied with growth
of the construction industry. As shown in Table 2-1, clinker production
reached a peak of 70.9 xlO6 Mg (78.2 xlO6 tons) of clinker in 1973.40
Clinker production reached a 10-year low of 54.7 xlO6 Mg (60.2 xlO6 tons)
in 1982.39 Cement consumption was 57.2 xlO6 Mg (63.1 xlO6 tons) in 1982
and increased to 63.0 xlO6 Mg (69.4 xlO6 tons) in 1983.41,42 The Portland
2-6
-------
Cement Association predicts 68.9 xlO6 Mg (76 xlO6 tons) of cement
consumption in 1984, 74.8 x 106 Mg (82.5 xlO6 tons) in 1985, and
77.8 xlO6 Mg (85.8 xlO6 tons) in 1986, yielding an estimated average
annual increase in cement consumption of 7 percent.42
2.3.3 Growth Trends
As of December 1983, 64 of the 143 port]and cement plants are
subject to the NSPS for the portland cement industry. One plant is a
grinding-only facility. Of the 63 conventional plants, 24 plants have
all-new facilities such that the entire plant is subject to the NSPS;
31 plants have at least one kiln subject to the NSPS; and 8 plants have
nonkiln facilities only, such as a finish mill or transfer facilities,
subject to the NSPS. Appendix A lists information for plants with
facilities subject to the NSPS.
Table 2-2 lists 37 cement plants that have facilities that have
become subject to the standards since the 1979 review and identifies the
affected facilities and the control equipment used at these facilities.
Fourteen of the plants have installed all new facilities (i.e., kilns,
clinker coolers, and other associated equipment such as mills, transfer
facilities, and storage facilities) since 1979, and 23 plants have added
new kiln capacity and/or other equipment.
Growth of the portland cement industry after 1971 was projected to
be about six kilns and six clinker coolers per year.43 As shown in
Appendix A, 63 kilns and 54 clinker coolers have become subject to the
NSPS in the 12 years since 1971. This growth rate is equivalent to
about five kilns and more than four clinker coolers per year.
Construction of several entirely new cement plants is planned in
the U.S. Four new cement production plants have received permits for
construction, and two more plants have submitted permit applications.
Four additional plants have in the past had active, approved construction
permits, but the permits have expired and would have to be reapproved
before construction could commence.44 In addition, several expansions
or modifications of existing facilities have been planned. Three plants
not currently subject to the NSPS have modification/reconstruction plans
that would bring them under the standards.44 These plans include adding
new kilns and converting from the wet process to the dry process. Four
existing plants with facilities already subject to NSPS each plan to add
an additional kiln. One of these will be a wet process kiln, and the
other three will be dry process preheater/precalciner systems. Another
plant plans to add a preheater/precalciner system to an existing dry-
process kiln currently subject to the NSPS.44
2.3.4 Process Developments
Three developments have occurred in the manufacture of portland
cement in the last decade.
2-7
-------
First, many plants have converted their kilns to coal firing because
of the high cost of oil and gas fuels. In 1983, 98 percent of all
cement kilns were fired by coal; in 1973, 31 percent of the kilns were
coal fired.45 Many plants continue to have the capability to use oil or
gas as a backup fuel.22 Figure 2-8 illustrates consumption of coal,
oil, and natural gas by the cement industry from 1970 to 1980.
Waste fuels are sometimes used as alternative kiln fuels because
they are less expensive than oil and gas. Waste fuels used in some
Portland cement plants include solvents (eight plants), waste oil (three
plants), and wood chips (one plant).46 No waste fuel was burned in
cement kilns in 1972; in 1982, 525 xlO6 MJ (498 xlO9 Btu's) of energy
were generated in cement kilns from waste fuels.19
The second development in the port!and cement industry has been a
trend from the wet process of clinker production to the dry process,
usually including a preheater/precalciner system. Figure 2-9 illustrates
the change over time in the number of plants using the wet or dry produc-
tion process, and Figure 2-10 shows the construction of wet and dry
clinker production capacity in the U.S. between 1930 and 1982. Until
recently, the wet process was more common than the dry process because
wet raw materials blend more easily and more consistently, producing a
higher quality clinker.47 Dry raw materials are, however, easier to
handle, and dry blending and material handling techniques have improved
significantly.47
Overall, about 62 percent of cement plants use the dry cement
production process. Eighty percent of the post-1971 kilns use the dry
process compared to 46 percent of the pre-1971 kilns.48 Additionally,
67 percent of the newer kilns have preheater or precalciner systems;
whereas only 6 percent of the pre-1971 kilns have preheater systems, and
none have precalciner systems.48 The trend in the portland cement
industry is toward the construction of dry process kilns as a means of
conserving energy, increasing production capacity, and reducing material
handling problems.
The third development has been a trend toward the use of the roller-
type raw mill systems. These mills combine drying and classifying of
the raw feed with crushing operations. Drying is accomplished by the
use of hot exhaust gases recovered from the kiln, preheater, or clinker
cooler. The use of this type of raw mill system improves productivity
and energy efficiency.49 Figure 2-11 depicts a roller mill.
These three developments have resulted in an increase in energy
efficiency and average kiln capacity. Fuel efficiency in cement produc-
tion has increased because of the increased use of the dry process of
clinker production and associated preheater and preheater/precalciner
systems and because of increased use of kiln or clinker cooler gases to
preheat raw materials in the raw mill. Twenty percent less energy was
needed to produce 1 Mg (1.1 ton) of clinker in 1982 than was needed in
1972.50
2-8
-------
Average plant capacity has increased because production costs per
ton of product are less for the larger dry process plants.51 For this
reason, the recent economic downturn caused the closing of many smaller
wet process facilities, which, while decreasing the total number of
operational cement plants, increased average kiln capacity.52 Twenty-
eight percent of the 274 kilns in operation in the U.S. by the end of
1983 have been built since 1971, and these kilns represent 47 percent of
the domestic clinker capacity.53 Clinker capacity from these kilns
averages 496,000 Megagrams per year (Mg/yr) (547,000 tons/yr) per kiln,
which is more than twice the clinker production potential of their
pre-1971 counterparts.53
2.4 EMISSIONS FROM PORTLAND CEMENT PLANTS
2.4.1 Particulate Emissions
Portland cement plants were selected for NSPS development because
cement clinker production facilities can be significant sources of par-
ticulate matter. The most significant sources of particulate emissions
at a cement plant are the kiln and clinker cooler. Kilns controlled by
a cyclone dust collector for product recovery purposes can emit as much
as 22.5 kilograms of particulate matter per megagram (kg/Mg) of raw
material (45 pounds per ton [lb/ton]), and clinker coolers controlled by
a cyclone dust collector can emit as much as 15 kg/Mg (30 lb/ton) of raw
material.54 Thus, a plant with facilities controlled only by cyclones
and producing 544,000 Mg/yr of clinker (600,000 tons/yr) would emit
about 21,900 Mg/yr (24,200 tons/yr) of particulate matter from the kiln
and about 14,600 Mg/yr (16,100 tons/yr) from the c-1 inker cooler.
Figure 2-12 presents particle size distribution ranges for
uncontrolled particulate emissions from a dry process kiln, a wet process
kiln, and a clinker cooler.55 Approximately 50 percent of the particles
in exhaust gases from a dry process kiln with a preheater are smaller
than 1.5 to 3.5 micrometers (urn) in diameter (i.e., the mass median
diameter [MMD] is 1.5 to 3.5 urn), and 85 to 99 percent of the particles
are smaller than 10 urn. Similarly, for wet process kiln exhaust gases,
the MMD is 7 to 40 urn, and 20 to 60 percent of the entrained particulate
matter is smaller than 10 urn in diameter. However, the clinker cooler
exhaust gas particles are larger; the MMD is 30 to over 100 urn, and less
than 20 percent of clinker cooler dust is smaller than 10 urn in diameter.
2.4.2 Sulfur Oxide Emissions
Emissions of sulfur oxides from portland cement kilns are caused by
fuel combustion and clinker formation. Sulfur oxide emissions are
almost solely in the form of sulfur dioxide (S02), although small
quantities of sulfuric acid (H2S04) and S03 may exist in kiln exhaust
gases.
Actual S02 emission test results for facilities that have become
subject to the NSPS since 1979 range from 0.2 to 265 parts per million
(ppm) by volume and from 0.09 to 277 kg/h (0.2 to 611 Ib/h). Table 2-3
2-9
-------
presents the S02 emission test results by plant. Assuming 7,200 hours
per year (h/yr) of operation, approximately half of the plants would be
considered significant sources of S02 emissions (i.e., greater than
91 Mg/yr [100 tons/yr] of S02 emissions).
The S02 emissions result from both sulfur in the fuel and sulfur in
the raw materials. Direct correlation of these factors with S02 emissions
is difficult because of the complex chemistry of sulfur in the kiln.
Sulfur can be absorbed into the clinker, raw feed, or dust collected in
a control device or emitted as a gas. In addition, the amount of sulfur
found in the fuel and the feed can vary significantly from plant to
plant. The sulfur content of the fuel ranges from 0.5 to 3 percent. As
shown in Table 2-3, wet process kilns tend to emit larger quantities of
S02 than dry process kilns because they burn more coal per Mg of clinker
produced than do dry process plants. The sulfur content of the raw feed
material is known to vary considerably. One source reported an average
sulfur content of 0.05 percent by weight in the feed of nine California
cement plants.56 One of these California plants reported 0.2 percent
sulfur in the feed.57 A plant in Oregon reported 0.02 percent sulfur in
the feed.58 A plant in Colorado, which uses shale containing kerogen as
a raw material, reported 0.6 percent sulfur in the feed.59
Emissions of S02 from the kiln are reduced significantly by the
production process because the S02 is absorbed into the clinker. About
75percent of the S02 formed in the kiln reportedly is absorbed into the
clinker.60 One mass balance calculation measured approximately 38 percent
removal of S02 into the clinker.61 Industry personnel state that removal
efficiencies within the production process can exceed 90 percent.62
Data on reduction of S02 emissions in the production process vary widely
because of differences in process parameters and in sulfur content of
raw feed material and fuel.
2.4.3 Nitrogen Oxide Emissions
Parameters that affect emissions of nitrogen oxides (NO ) from
s\
cement kilns include the nitrogen content in the coal and raw materials.
Nitrogen oxides can form in portland cement kilns at temperatures of
1400° to 1650°C (2600° to 3000°F). Because clinkering occurs at about
1500°C (2732°F), temperatures favorable for NO formation are reached in
routine kiln operation.63 x
As shown in Table 2-4, actual kiln NOV emissions range from 116 to
s\
609 ppm by volume and from 14 to 294 kg/h (31 to 649 Ib/h). Assuming
7,200 h/yr of operation, all but one kiln would be considered a major
source of NOX emissions (i.e., greater than 91 Mg/yr [100 tons/yr] of
NO emissions).
2-10
-------
CRUSHED RAW
MATERIALS
FROM STOCKPILE
ro
i
SLURRY
BASIN
RAW MATERIALS —
ARE PROPORTIONED
RAW MATERIALS
MILL
SLURRY
FEEDER
Figure 2-1. Typical wet process material handling.
64 65
-------
CRUSHED RAM
MATERIALS FROM
STOCKPILE
INJ
Ul
t-
Ul
UJ
Z
JLlL
f'gH
o
oc
_-J > —
-.»...
Q
<
IA
"Tl
>i
11
;
«
X¥¥Y i
AW MATERIALS -» \l
RE PROPORTIONED
RAW MATERIALS
MILL
-n ~t
': •- :•
'.-
>
,' .•
h ., ,iu— n-i
TO
PREHEATER
4
DRV MIXING AND
BLENDING SILOS
GROUND RAW
MATERIAL STORAGE
Figure 2-2. Typical dry process material handling.
64
-------
EXHAUST STACK
ro
i
Co
GAS FLOW
MATERIAL FLOW
PRIMARY AIR
AND FUEL
RAW
FEED
MATERIAL
SECONDARY
AIR
COOLER
U
CLINKER
OUTLET
Figure 2-3. Typical clinker production process.28
-------
CXHRUST -«-EEEE
ro
i
FEED (FROM 3RD STflCEJ
FUEL (COflL. CflS. OIL. ETC. J
OXYGEN CCOOLER. KILN, flTMOSPHERE)
PRODUCT CTO 4TH STflGEl
FLASH PRECALCINER
KILN
BURNER
COOLER
»- VENT
CLINKER
Figure 2-4. Four-stage suspension preheater with a precalciner.28
-------
I
t—•
(Jl
PELLETIZER
PAN
TO COLLECTION
DEVICE
Figure 2-5. Traveling grate preheater system.66
-------
ro
i
5«/. GYPSUM |
ADDED
BULK STORAGE
BULK BULK BOX PACKAGING TRUCK
TRUCK CAR CAR MACHINE
Figure 2-6. Finish mill grinding and shipping.
65
-------
ro
i
ANNUAL GRAY CEMENT GRINDING CAPACITY
• Under SOO.OOO Shorl Tons
454.000 Metric Tons
• SOO.OOO lo 900.000 Shod Tons
454.000 lo 816.000 MeUlc Tons
• O«e(800.000 Shorl Tons
816.000 Metric Tons
• Grinding Only
Figure 2-7a. Portland cement plant locations—Western U.S.67
-------
r\j
i
oo
ANNUAL GRAV CEMENT GRINDING CAPACITY
• Under 500,000 Short Tons
4S4.000 Metric Tons
• 500.000 to 900.000 Short Tons
454.000 to 816.000 Metric Tons
• Over 900.000 Short Tons
816.000 Metric Tons
• Grinding Only
Puerto Rico (1 plant)
Figure 2-7b. Portland cement plant locations—Eastern U.S.67
-------
Mq (tons)
0.2 (0.2) -
0.1 (0.1)
cubic meters
(barrels)
0.03
(0.2) "
0.03
(0.1)
I I I I I I I i I T
70 72 74 76 78 80
year
(a) Coal
000 (000
liters cubic feet)
93 (3.0)
62 (2.0) -
31 (1.0)
70 72 74 76
(b) 011
Wet process
Dry process
1 I l
78 80
year
70 72 74 76 78 80
(c) Natural Gas
year
Figure 2-8. Fuel
uel consumption per megagram (ton) of clinker produced by
fuel type and clinker production process.68
2-19
-------
= WET PROCESS
= DRY PROCESS
= WET AND DRY PROCESS
200
oo
2%
4%
20
1966 1973 1980 1982
YEAR
Figure 2-9. Number of plants using wet or dry
clinker production process.53,68,69
2-20
-------
TOTAL WET AND
DRY PROCESS
1 1 1 1 1 f !
1930 1935 1940 1945 1950 1955 1960 1965 1970 1975 1980 1985
YEAR OF CONSTRUCTION
Figure 2-10. Kiln construction by year.
53
2-21
-------
RAW MATERIAL
FEED SPOUT
GRINDING ROLLER
PRODUCT DISCHARGE PORT
CLASSIFIER BLADE
GAS INTAKE PORT
HOT GAS FROM KILN,
PREHEATER OR COOLER
Figure 2-11. Detail of roller mill that combines crushing,
grinding, drying, and classifying in one vertical unit.70
2-22
-------
Leas Than Indicated Particle Diameter, %
ro
i
rv>
to
c.
rt>
Oi
r+
n
(D
in
tM
ID
Q.
en
CT
c
n-
O
-t>
O
(V
fD
ri-
Q.
01
tn
-------
TABLE 2-1. U.S. CLINKER PRODUCTION, KILN CAPACITY,
AND CAPACITY UTILIZATION—1972-198239
Year
Clinker production,
106 Mg (106 ton)
Kiln capacity,
106 Mg (106 ton)
Utilization
rate,
percent
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
70.2 (77.4)
70.9 (78.2)
70.8 (78.1)
58.5 (64.5)
62.2 (68.6)
65.3 (72.0)
68.5 (75.5)
69.0 (76.1)
63.2 (69.7)
61.4 (67.7)
54.7 (60.3)
77.5 (85.4)
78.8 (86.9)
82.5 (90.9)
83.7 (92.3)
77.5 (85.4)
80.0 (88.2)
80.8 (89.1)
81.4 (89.7)
83.5 (92.1)
82.8 (91.3)
80.6 (88.9)
90.6
90.0
85.8
70.0
80.2
81.6
84.7
84.9
75.8
74.1
67.9
2-24
-------
TABLE 2-2. FACILITIES SUBJECT TO THE NSPS SINCE 1979 REVIEW
1
fXJ
en
Company/
plant location
Alamo Cement Co.
San Antonio, Tex.
Alaska Basic Ind.c
Anchorage, Alaska
Ash Grove Cement Co.d
Louisville, Nebr.
California Portland
Cement Co.
Mojave, Calif.
Capitol Aggregates,
Inc.T
San Antonio, Tex.
Centex Corp.
Buda, Tex.
Columbia Cement Co.
Zanesville, Ohio
Davenport Ind.
Buffalo, Iowa
Dixie Cement Co.
Knoxville, Tenn.
Genera) Portland, Inc.
New Braunfels, Tex.
Genstar, Ltd.
Redding, Calif.
San Andreas, Calif.9
Gulf Coast Portland
Cement Co.
Houston, Tex.
Ideal Basic Ind. , Inc.
Theodore, Ala.
La Porte, Colo.9
Tijeras, N. Hex.
Date- type
1981-D.PC
--
1982-0, PC
1
1981-D, PC
1983-D, PC
1983-D, PC
--
1981-D, PC
1979-D.PC
1980-D.PC
1981-D, PC
1945-W
1952-W
1956-W
--
1981-D, PC
1981-D.PH
Clinker
capacity,
105 Mg/yr
(103 tons/yr)
474
(523)
.-
506
(558)
907
(1,000)
453
(500)
425
(468)
--
734
(809)
464
(512)
794
(875)
518
(571)
174 (192)
174 (192)
174 (192)
—
1,284
(1,415)
399
(440)
Kiln
Fuel,
sulfur
content, %
Coal, 1.5/
Coke, 3.9
„
Coal, 0.9
Coal, 0.53
Coal/coke,
3.35
Coal
__
Coal
Coal, 1.5
Coal
Coal /wood,
2.0
Coal,
0.6
--
Coal, 1.5
Coal, <1.0
AFFECTED FACILITIES
Clinker cooler
Emission
control
ESP (w/cooler
and raw mi 11)
__
ESP
FF(-) (w/raw
mill)
FF
FF (w/raw mill)
__
FF (w/raw mill)
FF(-)
2 ESP's (w/raw
mill)
FF(-) (w/cooler
and raw mill)
ESP
--
FF(-) (w/cooler
and raw mill
dryers)
FF(+)
"
Trans-
mi sso-
meter
Yes
—
Yes
NA (e)
Pro-
posed
No
—
NA
Yes
Yes
Yes
Yes
--
Yes
Yes
"
Date
1981
__
1982
1981
1983
__
—
1981
1979
1980
1981
--
--
1981
1981
Emission
control
(w/kiln and raw
mill)
__
FF( + )
FF(-)
FF
—
—
FF
FF(-)
GB
FF(-) (w/raw mill
and kiln)
..-
--
FF(-) (w/kiln and
raw mill dryers)
FF(-) (w/raw mill)
"
Date
1981
1982
-.
1981
1983
1983
1978
1981
--
1980
1981
--
1973
& 1978
1978
1981
1981
>1979
Other
Facil ity-control
Entire plant except
finish mill-FF
Finish mill , stor-
age, transfer FF(-)
--
Raw mill FF(-)
(w/kiln)
Entire plant-FF
Raw mill (w/kiln)
Finish mill-FF
Entire plant-FF
--
Entire plant-FF
Raw mill-FF(-) (w/
kiln and cooler)
--
Finish mill
Storage-FF
Entire plant-FF(-)
Entire plant, except
finish mill-FF
F inish mi 1 1-fF
(continued}
-------
TABLE 2-2. (continued)
AFFECTED FACILITIES
Company/
plant location
Kaiser Cement Corp.
lucerne Valley, Calif
Permanente, Calif.
San Antonio, Tex.
Lehigh Portland
Cement Co.
Mason City, Iowa
Lone Star Ind. , Inc.
Davenport, Calif.
Ewa Beach, Hawai i
Cape Girardeau, Mo.
ro
I Pryor, Okla.
ro
Maryneal , Tex.
Salt Lake City, Utahd
Martin Marietta Corp.
Lyons, Colo.
Leamington, Utah
Monolith Portland
Cement Co.
Laramie, Wyo.
Moore McCormack
Cement, Inc.
Brooksville, Fla.
Oregon Portland Cement
Durkee, Oregon
River Cement Co.
Festus, Mo.
Date-type3
1982-D, PC
1981-D.PC
1975-D.2PC
(second PC
in 1979)
1979-D.PC
1981-D.PC
-
1981-D.PC
1979-0
--
1979-W
1979-0, PC
1982-D, PC
1981 -W
1982-0, PH
1979-D.PH
--
Clinker
capacity,
105 Mg/yr
(103 tons/yr)
1,379
(1,520)
1.J79
(1,520)
703
(775)
493
(543)
675
(744)
-
900
(992)
242
(267)
--
136
(150)
367
(405)
547
(603)
272
(300)
508
(560)
454
(500)
--
Kiln
Fuel,
sulfur
content, %
Coal
Coal, <0.5
Coal, 1.0
Coal
Coal
--
Coal, 3
Coal, 3-4
--
Coal, oil
gas, 0.4-0.6
Coal, 0.52
Coal,
0.4-0.6
Coal,
0.5-0.9
Coal, 1.5
Coal, <1.0
--
Clinker cooler
Emission
control
FF (w/raw mill )
FF(-)
3 ESP's
FF (on
alkali bypass)
ESP (w/raw mill)
ESP (w/raw mill)
--
ESP
FF
--
FF(-)
FF(-)
FF (w/raw mill)
ESP
FF(-)
ESP (w/cooler)
--
Trans-
misso-
meter
NA
No
No
No
Yes
—
Yes
No
--
NA
Yes
NA
No
NA
Yes
--
Date
1982
1981
1975
--
1981
-
1981
1979
—
1979
--
1982
1981
1982
1979
—
Emission
control
FF (with alkali
bypass)
FF(-)
FF
--
G8
--
2 FF's (w/raw mill)
mill
GB
--
FF(-)
--
FF
FF(-)
FF(-)
ESP (w/kiln)
--
Date
1982
1981
1977
1980
1981
>1979
1981
--
1979
--
1979
1982
1981
--
1979
>1979
Other
Faci lity-control
Entire plant-FF
Entire plant except
finish mill-FF(-)
Finish mill-FF
Mil 1 , separators-FF
Entire plant-FF
Mill, storage-FF
Entire plant-FF
—
Coal transfer-FF
--
Limestone dryer-
-FF(-)
Entire plant-FF
finish mill,
Cement cooler-Fr(-)
--
Entire plant-FF(-)
Finish mill-ESP
Raw mill-FF
-------
TABLE 2-2. (continued)
ro
t
ro
Company/
plant location
Southwestern Portland
Cement Co.
Victorville, Calif.
Bush land, Tex.
Odessa, Tex.
Texas Industries, Inc.
Hunter, Tex.
Midlothian, Tex.
Clinker
capacity,
, 105 Mg/yr
Date-type (103 tons/yr)
1984-D
--
1978-D
1980- D
--
?Kiln types: W = wet process; D
Emission control types: ESP =
cfabric filter; and GB = gravel
,PC 726
(800)
—
,PH 253
(279)
,PC 602
(664)
--
= dry process; D,PH = dry
electrostatic precipitator
bed filter.
Kiln
Fuel,
sulfur
content, %
Coal
--
Coal, 0.5
Coal, 1.2
--
process with
; FF = fabric
AFFECTED
Emission
control
FF
--
FF
ESP
--
preheater; and D, PC
filter (baghouse); F
FACILITIES
Clinker cooler
Trans-
misso- Emission
meter Date control Date
NA 1984 GB 1984
1981
No — -- 1982
Yes 1980 FF 1980
1979
= dry process with preheater/precalciner
F( + ) = positive-pressure fabric filter; FF(-)
Other
Facility-control
Entire plant-FF
Coal storage,
Coal transfer-FF
Coal transfer,
Coal storage-FF
Entire plant-FF
Finish mill-ESP
= negative-pressure
grinding only is performed.
mPlant has more than one kiln; other kilns subject to NSPS installed prior to 1979.
,NA = not available.
facilities under construction.
uPlant is closed.
-------
ro
rv>
oo
TABLE 2-3. S03 EMISSION TEST RESULTS FOR PORTLAND CEMENT FACILITIES THAT
HAVE BECOME SUBJECT TO THE NSPS SINCE 1979
Process type
Wet
Dry
No PH, PC
Preheater
Preheater/
precalciner
Facility
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
Kiln
Kiln,
Kiln1
Kiln
Kiln
Kiln
Kiln
Kiln (with cooler)
Kiln
Bypass
Kiln + raw mill
Bypass
Kiln.
KilnK
Kiln + raw mill
Kiln
Kiln
Kiln + raw mill
Bypass
Kiln + raw mill
Bypass
Kiln
Kiln
Kiln
Kiln,+ raw mill
Kiln*
Kiln
Control
type
ESP
ESP
ESP
FF
FF(-)fl
FF
FF(+)9
ESP
FF(-)
FF
FF
FF
FF(-)
FF(-)
FF
FF(-)
FF
ESP
ESP
ESP
ESP
ESP
ESP
ESP
ESP
ESP
ESP
Date
tested
5/82
10/79
11/79
3/80
9/82
2/83
4/82
5/80
10/80
10/80
11/83
11/83
5/83
5/81
5/83
5/82
9/82
1/83
1/83
10/83
4/84
5/82
7/81
3/82
12/83
12/83
4/81
SO, emissions3
Fuel,
Coal,
Coal,
Coal,
Coal,
Coal,
Coal,
Coal,
Coal,
Coal,
Coal,
Coal
Coal,
Coal,
Coal
Coal,
Coal
Coal,
Coal,
Coal,
Coal,
Coal
Coal,
Coal,
Coal
Coal
Coal
% S
coke, 0.76b
°'6d
0.6d
A
3.5d
1.0db
0.5d.
<1.0d
0.55b
0.52b
H
0.5d
ft
0.53d
2.0fl
A
<0.50d
coke
coke
coke
coke
ft
l'2d
3.0d
ppm, vol.
--
240e
237e
17.8
—
0.2
71
6.5
-------
TABLE 2-4. NO EMISSION TEST RESULTS FOR PORTLAND CEMENT FACILITIES THAT HAVE BECOME
SUBJECT TO THE NSPS SINCE 1979
ro
<£>
NO., emissions
Process type
Wet
Dry
No PH, PC
Preheater
Preheater/
precalciner
Facility
1.
2.
--
3.
4.
5.
6.
7.
8.
9.
10.
11.
Kiln
K11nd
Kilna
Kiln
Kiln
Kiln
Alkali
Kiln +
Alkali
Kiln
Kiln
Kiln +
Kiln
Kiln +
bypass
raw mill
bypass
raw mi 1 1
raw mill
Control
type
ESP
ESP
ESP
FF
FF
FF(-)e
FF
FF
FF
FF(-)
FF(-)
FF
FF(-)
ESP
Date
tested
6/81
10/79
11/79
2/83
9/82
10/80
10/80
11/83
11/83
5/83
5/81
5/83
5/82
1/83
ppm,
vol.
— _
258C
332C
384
—
259f
116?
320T
809
--
--
279, 462C
55
103, 219C
145
631
y\
kg/h (Ib/h)
46.
54.
102
108
98.
--
—
—
—
112
7.0
181
14.
93.
108
227
9 (103)
4 (120)
(225)
(238)
4 (217)
(248)
(15.4)
(399)
1 (31.0)
9 (207)
(237)
(502)
kg/Mg (Ib/ton)
__
0.
0.
1.
--
—
--
--
1.
0.
0.
0.
0.
0.
I.
39
73
64
03
06
9
16
38
43
63
+ cooler
12.
Alkali
Kiln +
+
Kiln +
bypass
raw mi 1 1
cooler
cooler
ESP
ESP
ESP
1/83
10/83
5/82
76
--
609
3.8
141
294
(8.3)
(311)
(649)
0.
--
1.
025
64
(0.78)
(1.47)
(3.28)
(2.06)
(0.13)
(1.8)
(0.31)
(0.76)
(0.86)
(3.26)
(0.05)
(3.28)
(continued)
-------
TABLE 2-4. (continued)
ro
i
CO
o
NO,, emissions
Process
Precalci
(cont1
type
ner
d)
Facil
13.
14.
Ki
Ki
Ki
ity
ln,+ raw mill
lnh
In
Control
type
ESP
ESP
ESP
Date
tested
12/83
12/83
4/81
ppm,
vol .
220
184g
kg/h
112
78.0
205.
(Ib/h)
(247)
(172)n
9 (454)
kg/Mg
0.72
0.50
1.44
(Ib/ton)
(1.45).
(1.01)n
(2.87)
Emission test results received from State and local air pollution control agencies, EPA regional
.offices, and industry contacts.
Average of 1.8 kilns in operation.
. ppm normalized to 3 percent 02
Average of 3 kilns in operation.
,(-) = negative-pressure fabric filter.
Type I clinker production
uType II clinker production.
Kiln in raw mill bypass mode; i.e., raw mill is off.
-------
2.5 REFERENCES FOR CHAPTER 2
1. U. S. Environmental Protection Agency. Multimedia Assessment and
Environmental Research Needs of the Cement Industry. Publication
No. EPA-600/2-79-111. May 1979. p. 2.
2. Kirk, R. and D. Qthmer. Cement. In: Encyclopedia of Chemical
Technology, 3rd Edition, Vol. 5. New York. John Wiley and Sons,
Inc. 1979. p. 163.
3. U. S. Environmental Protection Agency. Environmental Considerations
of Selected Energy Conserving Manufacturing Process Options:
Vol. X—Cement Industry Report. Publication No. EPA-600/7-76-034J.
December 1976. p. 84.
4. Portland Cement Association. Cement and Concrete Reference Book.
Chicago, Illinois. 1964. p. 17.
5. Kreichelt, T., D. Kemnitz, and S. Cuffe. Atmospheric Emissions
From the Manufacture of Portland Cement. U. S. Department of
Health, Education, and Welfare. Cincinnati, Ohio. Publication
No. AP-17. 1967. p. 10.
6. Letter from Greer, W., Lone Star Industries, Inc., to Cuffe, S. ,
EPA/ISB. August 28, 1984. Response to request for comments on the
draft review document, p. 3.
7. U. S. Environmental Protection Agency. Industrial Process Profiles
for Environmental Use: Chapter 21~The Cement Industry. Publication
No. EPA-600/2-77-023u. 1977. p. 17.
8. Reference 1, p. 37.
9. Reference 2, p. 183.
10. Reference 5, p. 11.
11. Telecon. Maxwell, C., MRI, with Kreisberg, A., Fuller Company.
April 12, 1984. Discussion of kiln design parameters.
12. U. S. Environmental Protection Agency. Inspection Manual for
Enforcement of New Source Performance Standards: Portland Cement
Plants. Publication No. EPA-340/1-75-001. September 1975. p. 3-5.
13. Reference 2, p. 165.
14. Reference 3, p. 18, 19.
15. Reference 7, p. 20.
2-31
-------
16. Reference 7, p. 24.
17. Reference 2, p. 184.
18. Energy Conservation in the Cement Industry. Pit and Quarry. July
1982. p. 61.
19. Portland Cement Association. Energy Report: U. S. Portland Cement
Industry. Skokie, Illinois. October, 1983.
20. Portland Cement Association. U. S. and Canadian Portland Cement
Industry: Plant Information Summary. Skokie, Illinois. December 31,
1983. pp. 55-80.
21. Reference 3, p. 24.
22. Reference 1, p. 38.
23. Letter from Gebhardt, R., Lehigh Portland Cement Company, to Cuffe, S.,
EPA/ISB. June 6, 1984. Response to request for comments on draft
review document, p. 2.
24. Reference 3, p. 37.
25. Reference 3, p. 63.
26. Letter and attachments from Venturini, P., California Air Resources
Board, to Cuffe, S., EPA/ISB. January 17, 1984. Data for California
plants, p. 27.
27. Reference 3, p. 25.
28. KVB, Inc. Emissions Reductions by Advanced Combustion Modification
Techniques for Industrial Combustion Equipment. Prepared for U. S.
Environmental Protection Agency. Industrial Advisory Panel Meeting.
June 8, 1983.
29. Reference 3, p. 22.
30. Reference 23, p. 3.
31. Friedman, D. Coal-Fired Preheater/Flash Furnace Boosts Production
and Fuel Efficiency. Pit and Quarry. July 1981. p. 109.
32. Reference 5, p. 13.
33. Reference 3, p. 62.
34. Reference 2, p. 185.
35. Barrett, K. A Review of Standards of Performance for New Stationary
Sources—Portland Cement Industry. U. S. Environmental Protection
Agency. Publication No. EPA-450/3-79-012. March 1979. p. 4-1.
2-32
-------
36. Reference 20, p. 1.
37. Reference 20, p. 13.
38. Reference 5, p. 3.
39. Portland Cement Association. United States Cement Industry Fact
Sheet. Second edition. Skokie, Illinois. September 1983.
40. Portland Cement Association. The U. S. Cement Industry—An Economic
Report. Third edition. PCA Market and Economic Research. Skokie,
Illinois. January 1984. p. 17.
41. Portland Cement Association. Portland Cement Consumption. Vol. 5,
No. 12. PCA Market and Economic Research. Skokie, Illinois.
February 22, 1984. p. 3.
42. Portland Cement Association. U. S. Cement Consumption Forecast.
PCA Market and Economic Research. Skokie, Illinois. October,
1983.
43. U. S. Environmental Protection Agency. Background Information for
Proposed New Source Performance Standards: Steam Generators,
Incinerators, Portland Cement Plants, Nitric Acid Plants, and
Sulfuric Acid Plants. Publication No. APTD-0711. August 1971
p. 32.
44. Memorandum from Clark, C., MRI, to Project File. January 20, 1984.
Compilation of data from telephone contacts with State and local
air pollution control agencies regarding construction and modifica-
tions of cement plants.
45. Reference 20, p. I.
46. Portland Cement Association. U.S. and Canadian Portland Cement
Industry: Plant Information Summary. Skokie, Illinois. December 31
1982. p. 37.
47. Reference 1, p. 33.
48. Reference 20, p. 9.
49. Reference 40, p. 6.
50. Reference 40, p. 10.
51. Reference 1, p. 21.
52. Reference 20, p. 31-34.
53. Portland Cement Association. Design and Control of Concrete Mixtures.
Skokie, Illinois. 1979. pp. 32-40.
2-33
-------
54. Reference 43, pp. 28-29.
55. Reference 35, p. 4-16.
56. Reference 26, pp. 112-121.
57. Reference 26, p. 117.
58. Information from Bosserman, P., Oregon Department of Environmental
Quality, to Clark, C., MRI. January 9, 1984. Summary of source
test results for Oregon Portland Cement Company, Lake Oswego,
Oregon, p. 15.
59. Information from Clouse, J., Colorado Air Pollution Control Division,
to Clark, C., MRI. November 10, 1983. Notice of intent to construct
and operate Martin Marietta Cement, Lyons, Colorado, p. 15.
60. Ketels, P., J. Nesbitt, and R. Oberle (Institute for Gas Technology)
Survey of Emissions Control and Combustion Equipment Data in Industrial
Process Heating. Prepared for U. S. Environmental Protection
Agency. Publication No. EPA-600/7-76-022. October 1976. p. 72.
61. Reference 26, p. 238.
62. Reference 23, p. 4.
63. Reference 3, p. 102.
64. Reference 53. pp. 18-19.
65. Reference 1, p. 35.
66. Reference 12, p. 3-8.
67. Reference 20, p. 53-54.
68. Reference 18, p. 62.
69. Reference 5, pp. 33-47.
70. Reference 40, p. 8.
2-34
-------
3. CURRENT STANDARDS FOR PORTLAND CEMENT PLANTS
3.1 NEW SOURCE PERFORMANCE STANDARDS
On August 17, 1971, the Environmental Protection Agency proposed
standards for port!and cement facilities under Section 111 of the Clean
Air Act to control particulate matter and visible emissions. The standards
were promulgated on December 23, 1971, and revised in response to a
court remand on November 12, 1974.x-3
3.1.1 Summary of New Source Performance Standards
The affected facilities under the new source performance standards
(NSPS) for Portland cement plants are the: kiln, clinker cooler, raw
mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, and
bagging and bulk loading and unloading systems.4
The standards prohibit the discharge into the atmosphere from any
kiln, exhaust gases which:
1. Contain particulate matter in excess of 0.15 kilograms per
megagram (kg/Mg) (0.30 pounds per ton [lb/ton]) of feed (dry basis) to
the kiln, or
2. Exhibit greater than 20 percent opacity.
The standards prohibit the discharge into the atmosphere from any
clinker cooler, exhaust gases which:
1. Contain particulate matter in excess of 0.05 kg/Mg (0.10 Ib/ton)
of feed (dry basis) to the kiln, or
2. Exhibit 10 percent opacity or greater.
Finally, the standards prohibit the discharge into the atmosphere
from any affected facility other than the kiln or clinker cooler, exhaust
gases which exhibit 10 percent opacity or greater.1
The standards apply to any facilities that have been built, modified,
or reconstructed after August 17, 1971. The term "modified facility"
applies to facilities to which physical or operational changes have been
made that caused an increase in the emission rate of particulate matter
or visible emissions (i.e., the pollutants to which this standard
applies).5 The term "reconstructed facility" applies when the
3-1
-------
replacement cost of components exceeds 50 percent of the cost of building
a comparable new facility.6
3.1.2 Testing and Monitoring Requirements
3.1.2.1 Particulate Matter. Test methods used to determine
compliance with the standards covering particulate matter emissions are:
1. Method 5 for the concentration of particulate matter and the
associated moisture content of the exhaust gases,
2. Method 1 for sample and velocity traverses,
3. Method 2 for stack gas velocity and volumetric flow rate deter-
minations, and
4. Method 3 for analysis of exhaust gases for carbon dioxide
(C02), excess air, and dry molecular weight.
The sampling time for Method 5 must be at least 60 minutes for
emission testing of the kiln or the clinker cooler. The sample volume
collected using Method 5 must be at least 0.85 dry standard cubic meters
(dscm) (30 dry standard cubic feet [dscf]) for testing of the exhaust
gases from the kiln and 1.15 dscm (40.6 dscf) for testing of the clinker
cooler.4 Particulate mass emission rate in grams per hour (g/h) can be
calculated by multiplying the volumetric flow rate of the gases (in
dscm/h) as determined by Method 2 times the particulate concentration
(in g/dscm) as determined by Method 5.
Total kiln feed rate (excluding fuel) must be determined during
each testing period by suitable methods in order to calculate particulate
mass emissions per unit of kiln feed. Total kiln feed rate is expressed
in units of Mg (or tons) per hour of dry feed to the kiln and is to be
confirmed by a material balance over the production system.
At all times, the air pollution control equipment associated with
the affected facility (or facilities) should be maintained and operated
to minimize particulate emissions. Monitoring of operation or maintenance
procedures may include opacity observations, review of procedures, and
facility inspections. The owner or operator of a portland cement plant
with one or more facilities subject to the NSPS is required to monitor
and record daily production rates and kiln feed rates.4
3.1.2.2 Opacity. Methods for determining compliance with opacity
standards are defined in Section 60.11 of the Code of Federal Regula-
tions.7 Method 9 is used for measuring visible emissions from stationary
sources. Continuous monitoring of opacity is not required.
3.1.3 Recordkeeping and Reporting Requirements
Notification of construction, reconstruction, or modification as
well as initial startup is to be provided to the Administrator of the
EPA.8
3-2
-------
Within 60 days after achieving the maximum production (or throughput)
rate of an affected facility but no later than 180 days after initial
startup of the facility, the owner or operator of the plant is required
to conduct a performance test and furnish to the Administrator a report
of the test results. Emissions measured during periods of startup,
shutdown, and malfunction are not considered representative for the
purpose of demonstrating compliance. Under Section 114 of the Clean Air
Act, performance tests may be required by the Administrator at other
times.9
Records are to be maintained by the plant owner or operator of the
occurrence and duration of startup, shutdown, and malfunctions in the
process and of malfunctions of air pollution control equipment.8
A file of all performance tests and other reports and records
required is to be kept for a period of at least 2 years.8
3.2 STATE REGULATIONS
Portland cement manufacturing plants are currently operating in
40 States and Puerto Rico. Appendix B presents a summary of particulate
and visible emissions regulations for these States as well as regulations
for S02 and NOX that are applicable to Portland cement production processes
in the absence of NSPS.10 Enforcement authority for the NSPS for the
Portland cement industry has been delegated to most States.
•Of the 40 States, 24 States have particulate matter regulations for
all or part of the State that are defined by one of two sets of process
weight rate equations. For a kiln feed rate of 136 Mg/h (150 tons/h),
the allowable (State) emissions are 17.5 and 25.1 kg/h (38.6 and 55.4 Ib/h),
for the two sets of process weight rate equations. These emissions
convert to 0.128 and 0.185 kg/Mg (0.257 and 0.369 Ib/ton) of kiln feed
(units of the NSPS for particulate mass emissions).
Limitations on particulate matter emissions for existing sources in
the 16 other States range from 0.15 to 0.75 kg/Mg (0.30 to 1.5 Ib/ton)
of kiln feed. However, variations in exhaust gas flow rates from particular
facilities or variations in emission testing methods could result in
some States requiring more stringent emission control levels than the
NSPS.
Most of the States limit visible emissions to 20 percent opacity or
less for new facilities and to 40 percent opacity or less for existing
facilities. Some State regulations are more stringent than the NSPS
(i.e., requiring visible emissions of 10 percent opacity or less).
Sulfur dioxide regulations are specified in one of five categories:
1. Parts per million (ppm), by volume,
2. Kilograms per megajoule (kg/MJ) (pounds per million British
thermal units [Btu's]) of heat input,
3-3
-------
3. Ambient air quality levels similar to or the same as the national
ambient air quality standard (NAAQS) for S02)
4. Kilograms per megagram (kg/Mg) (pounds per ton [lb/ton]) of
material processed, or
5. Requirements on the sulfur content of the fuel.
Sulfur dioxide regulations for 34 of the 40 States fall into
categories (1), (2), and (3) above. The most stringent regulations in
each of the first two categories stipulate (a) less than 500 ppm of S02,
by volume, and (b) less than 0.003 kilograms of S02 per megajoule
(0.7 pounds of S02 per million Btu's) of heat input.
Only 6 of the 40 States have regulations specific to NO that may
X
be applicable to portland cement plants. California requires the lowest
achievable emission rate (LAER), and some districts within California
have specific NO regulations. The remaining five States have regulations
/\
specific to fuel-burning equipment (expressed in units of pounds per
million Btu's). According to telephone contacts with the State air
pollution control agencies, only two of the five States (Indiana and
Oklahoma) enforce the fuel-burning standards at portland cement
facilities.
In addition to State regulations or NSPS, some portland cement
plants may be required to achieve more stringent emission levels under
regulations for the Prevention of Significant Deterioration (PSD).11
Also, if a new plant is located in a nonattainment area for National
Ambient Air Quality Standards (NAAQS), the LAER would be required for
the nonattaining pollutant.12 Facilities that are subject to PSD as
well as NSPS (since the 1979 review) are listed in Table 2-2.
3.3 REFERENCES FOR CHAPTER 3
1. Federal Register. Standards of Performance for New Stationary
Sources.Proposed Standards for Five Categories. Washington, D.C.
Office of the Federal Register. August 17, 1971. 36 FR 15704-15722.
2. Federal Register. [Promulgation of Standards for Five Categories
Proposed August 17, 1971.] Washington, D.C. Office of the Federal
Register. December 23, 1971. 36 FR 24876-24899.
3. Federal Register. [Revision to opacity standard for portland
cement plants.] Washington, D.C. Office of the Federal Register.
November 12, 1974. 36 FR 39872-39877.
4. U. S. Environmental Protection Agency. Code of Federal Regulations.
Title 40, Chapter I, Part 60. Sections 60.60 through 60.64.
Washington, D. C. Office of the Federal Register. July 1, 1982.
5. Reference 4, Section 60.14.
3-4
-------
4. CONTROL TECHNOLOGY AND COMPLIANCE TEST RESULTS
This chapter presents participate and gaseous emission control
technology used on portland cement facilities that have become subject
to the NSPS since 1979. Emission test results for those facilities are
also presented. Appendix C presents compliance test results by plant.
This information was obtained from State and local air pollution control
agencies, EPA regional offices, and individual portland cement plants.
4.1 AVAILABLE PARTICIPATE CONTROL TECHNOLOGY
Fabric filter control of wet and dry process kilns, clinker coolers,
and other facilities as well as electrostatic precipitator control of
kilns provide the basis for the particulate matter and visible emissions
standards that were proposed and promulgated in 1971 and revised (visible
emissions only) in 1974.1
Typical methods used for control of particulate emissions from
potential sources at portland cement manufacturing facilities are listed
in Table 4-1. The kiln and clinker cooler are the first and second
largest sources, respectively, of particulate emissions at a cement
plant. Particulate emissions also occur during material handling,
transfer, and storage.
Table 4-2 summarizes the particulate control technology currently
in use at facilities that have become subject to the NSPS since the 1979
review. Particulate emissions from kilns are controlled by either
fabric filters or electrostatic precipitators. Particulate emissions
from clinker coolers and other facilities (mills, storage facilities,
and transfer facilities) are typically controlled by fabric filters.
Two plants have finish mills controlled by electrostatic precipitators.
4.1.1 Kiln
At the 28 plants with one or more kilns that have become subject to
the NSPS since the 1979 review, 17 kilns are controlled by fabric filters
and 13 kilns are controlled by electrostatic precipitators (3 kilns at
one plant are controlled by one electrostatic precipitator).
4.1.1.1 Fabric Filters. Most of the fabric filters used for
control of kiln emissions are the negative-pressure (suction) type.
Only one positive-pressure fabric filter system is used for control of
emissions from a kiln that has become subject to the NSPS since 1979.
4-1
-------
TABLE 4-1. POTENTIAL SOURCES OF PARTICULATE EMISSIONS AND
TYPICAL CONTROL TECHNOLOGIES
Source
Particulate control technology
Raw material system (including
crushing and grinding)
Raw material dryer
Raw material storage (except
coal piles)
Kiln (including preheater/
precalciner systems and
alkali bypass systems)
Clinker cooler
Clinker storage
Finish mill system (excluding
fugitive emissions)
Finished product storage
Conveyor transfer points (e.g.,
to primary crusher, secondary
crusher, elevators, material
storage, grinding mill)
Packaging (i.e. , bagging)
Low flow fabric filter systems
Fabric filters
Low flow fabric filter systems
Fabric filters, electrostatic
precipitators
Fabric filters, gravel bed filters
Low flow fabric filter systems
Fabric filters, electrostatic pre-
cipitators (on large mills)
Low flow fabric filter systems
Low flow fabric filter systems
Low flow fabric filter systems
4-2
-------
TABLE 4-2. PARTICULATE CONTROL TECHNOLOGY CURRENTLY IN USE
AT PLANTS WITH FACILITIES THAT HAVE BECOME SUBJECT TO THE
NSPS SINCE THE 1979 REVIEW
Affected
facil ity
Kiln:
Wet
Dry, without
Parti cul ate
FF
1
1
control
ESP
o'
technology3
GB
0
0
Total
3
1
preheater or
precalciner
Dry, with preheater 3 lc
Dry, with preheater/
precalciner
Cl inker cooler
Other facilities
5,§d,
2e
13 2d
2I'
31
' 4,3d,
le
lc,le
2f
0
4
0
20
23
31
ESP = electrostatic precipitator; FF = fabric filter; GB = gravel bed
filter; NA = data not available. Note that some of these facilities
.may have cyclone precollection devices.
Exhaust gases from 3 kilns (at one plant) ducted to one control system.
.Kiln and clinker cooler exhaust gases combined.
Exhaust gases combined with raw mill.
Kiln, clinker cooler, and raw mill or raw mill dryer exhaust gases
..combined.
Finish mill facilities at these two plants are controlled by electro-
static precipitators; the remaining other facilities at these two plants
are controlled by fabric filters.
4-3
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Fabric filter systems (often called baghouses) consist of a structure
containing tubular bags made of woven fabric through which the exhaust
gas stream is passed. Particles are collected on the upstream side of
the fabric. Dust on the bags is periodically removed and collected in a
hopper.
The efficiency of a fabric filter is directly proportional to the
fabric area. Design efficiencies of greater than 99.9 percent are
typical. The air-to-cloth ratio of fabric filters ranges from about
1.3:1 to 2:1 for kilns and alkali bypass systems. The bags are typically
made of fiberglass and cleaned by reverse air.
Kiln exhaust gases must be cooled to about 200° to 315°C (400° to
600°F) before entering the fabric filter to preclude damage to the
filter fabric.2 Cooling of exhaust gases from dry process kilns may be
accomplished by water sprays and/or bleed-in air.s Bleed-in air (i.e.,
colder air), which is the most commonly used coolant, condenses alkali
material onto the particulate. Control of the alkali content of the
clinker is effectively accomplished by cooling a portion of the kiln
exhaust gases (i.e., alkali bypass) and then directing them to a separate
fabric filter. At plants using dry process kilns with preheater or
preheater/precalciner systems, kiln exhaust gases may be ducted to a raw
mill (or raw material dryer) to dry the raw feed material; this procedure
increases the moisture content and reduces the temperature of exhaust
gases entering the fabric filter.4 For wet process kilns, the high
moisture content of exhaust gases requires adequately insulated fabric
filter systems to prevent corrosion of the ducts and blinding of the
filter bags because of a wet filter cake.3
The temperature of gas entering the fabric filter must be maintained
above the dew point of the gas to prevent blinding of the filter bags.5
One plant has experienced blinding of the bags as a result of kerogen (a
bituminous material in the raw feed) in the dust. Process modifications
made to burn off the kerogen prior to feed entering the kiln are expected
to correct the problem.6
Bag life is affected by the abrasiveness of the particulate matter
in the exhaust gases, temperature of the gases, and maintenance
practices.7,8 Abrasion of filter bags (and peripheral equipment) can
also be a problem because of high flow rates.5 Heat recovery techiques
and new bag materials (e.g., Nomex® and Gore-tex®) are expected to
increase bag life.7 Improved methods of detecting leaks in bags and
fastening bags are also available.7
Disadvantages of fabric filters include the need for a high pressure
drop (necessitating high energy consumption), a low resistance to
temperatures above 3158C (60CrF), and the potential for blinding of the
bags at temperatures below the dew point.9
Advantages of fabric filters include high efficiencies, simplicity
in operation, reliability, and compartments that can be isolated for
repairs.9
4-4
-------
4.1.1.2 Electrostatic Precipitators. Cleaning of exhaust gases
using electrostatic precipitators involves three steps: (a) passing the
suspended particles through a direct-current corona to charge them
electrically, (b) collecting the charged particles on a grounded plate,
and (c) removing the collected particulate from the plate by a mechanical
process (i.e., rapping).
At 11 of the 28 plants with kilns subject to the NSPS since the
1979 review, emissions from the cement kiln are controlled by electro-
static precipitators. Design efficiencies of greater than 99.9 percent
are typical. The specific collection area (SCA) is a parameter used to
ensure design efficiency of an electrostatic precipitator. The SCA is
defined as the ratio of the total plate area to the gas flow rate. As
the SCA of an electrostatic precipitator increases, collection efficiency
improves. Information from industry contacts indicates that the SCA's
for electrostatic precipitators controlling kilns that have become
subject to the NSPS since 1979 range from 1.0 to 1.9 square meters per
cubic meter per minute (m2 per 1,000 m3/min) (310 to 570 square feet per
1,000 actual cubic feet per minute [ft2/!,000 acfm]).
The high resistivity of particles in cement kiln exhaust gases
requires that the gases be conditioned prior to entering the electrostatic
precipitator. Resistivity is about a factor of 10 lower for wet process
kilns than for dry process kilns because of the moisture in the gases;
however, the resistivity of exhaust gases from the dry process kiln can
be lowered by spray cooling.10 Exhaust gases from dry process kilns
with preheaters have higher resistivity than those from dry process
kilns without preheaters.11 Electrostatic precipitators can operate at
high temperatures and at temperatures below the dew point.
Startup of the kiln requires a period of several hours (for a
downtime of only a few hours) to more than 24 hours (for a cold start).
During startup, there are more combustible materials in the kiln than
are present during normal operation. Because of this hazard, some kiln
operators reportedly deenergize the electrostatic precipitator during
the startup period because sparks in the electrostatic precipitator
could ignite the combustibles. As a result, particulate emissions could
be uncontrolled for a period of several minutes to more than a day.
Similarly, the electrostatic precipitator could be deenergized during
gradual cool down of the kiln because of the potential for ignition of
combustibles. However, electrostatic precipitator vendors and plant
operators state that, because of improved process control, it is now
normal practice for new electrostatic precipitators to start up and shut
down concurrent with the kiln induced draft fan.12-14
Due to the presence of a spark source, shut-offs of the electrostatic
precipitator can also occur if carbon monoxide (CO) or excess air concen-
trations reach a preset critical level at which an explosion could occur
in the electrostatic precipitator. This automatic shut-off is called a
CO trip. The fundamental cause of potential explosive conditions is
incomplete combustion of the fuel in the presence of a spark source.15
These conditions result if there are irregularities in the feed,
4-5
-------
disturbances in the coal conveying and feeding, insufficient fuel
preparation (i.e., drying, grinding), insufficient combustion chamber
temperature, or disturbances in the air and gas flow system (i.e mill
bypass, preheater draft).16
Table 4-3 summarizes CO trip data from electrostatic precipitators
on kilns subject to the NSPS since 1979. The composition of the kiln
exhaust gases may be monitored at a given plant by CO, 02, or
combustibles monitors. A trip level and, in some cases, an alarm level
are set by each plant. Table 4-3 lists the gases that are monitored to
set off the alarm or the CO trip at each plant and the location of the
monitor. The annual frequency of CO trips and the duration of each trip
are also presented. Levels set for shut-offs (CO trips) range from 0 2
to 6 percent CO for kilns subject to the NSPS since 1979, and duration
of CO trips per occurrence ranges from less than 1 minute to about
20 minutes.17 Two types of trips are common: a spike CO event of short
duration (i.e., a few seconds to 5 minutes) and long term instability
(10 minutes to 4 hours). The frequency of trips ranges from a few trips
per year to over 600 trips per year.17 State air pollution control
agency enforcement personnel indicated that CO trips of electrostatic
precipitators are typically treated as malfunctions of the control
device; emissions during malfunctions are not considered representative
for the purpose of demonstrating compliance (see Chapter 3).
Electrostatic precipitator vendors and plant personnel state that
if a kiln is properly designed and operated, CO trips of the precipitator
should be infrequent.18-22 Several equipment vendors noted that one or
two CO trips per month is an average frequency for a properly operated
kiln.21,22 Each trip would average about 3 minutes.22 Chapter 6 dis-
cusses some design and operation parameters that can be used to minimize
the occurrence of CO trips.
Cleaning of the electrostatic precipitator plates is sometimes
hampered by the fineness of the dust. In addition, air leaks, high
moisture content, low gas temperature, and the alkali, sulfur and chloride
content of the exhaust gases may produce conditions that promote corrosion
within the precipitator that may cause reduced efficiency, short circuits,
and downtime. Good operation and maintenance practices should prevent
these problems.
Advances in the design of electrostatic precipitators such as the
use of wide duct spacing, prechargers, or pulse energization are available
and could improve dust collection and reduce costs.25 Electrostatic
precipitation is used almost exclusively for control of kiln emissions
in Europe and Japan where such design advances have been applied.24
4.1.1.3 Cyclones. Cyclone collection systems consist of one or
more conically shaped vessels in which the gas stream follows a circular
motion prior to outlet (typically at the bottom of the cone).25 Collec-
tion efficiency is a function of (a) size of particles in the gas stream,
(b) particle density, (c) inlet gas velocity, (d) dimensions of the
cyclone, and (e) smoothness of the cyclone wall.26
4-6
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-p»
I
TABLE 4-3. SUMMARY OF CARBON MONOXIDE TRIP DATA FOR ELECTROSTATIC PRECIPITATORS ON
KILNS THAT HAVE BECOME SUBJECT TO THE NSPS SINCE 1979.17
Process typea
1980- D, PH/PC
(K)
1975-D, PH/PC
(K)
1980-D, PH/PC
(K)
1975-D, PH (K);
1982-0, PH/PC (K)
1979-D, PH/PC
(K)
\n /
1981-D PH/PC
(K + RM)
1979-D, PH
(K + CC)
1983-D, PH/PC
(K + CC)
1981-W
(K)
\nJ
1981-0, PH/PC
(K)
processdasC-PF -'
KE = kiln exit; P
ESPO = outlet to
Coal
firing method Location
Direct (K); ESPI
Indirect (PC)
Pneumatic blowers FSO, ESPI
to riser duct
Direct (K); KE, PE, ESPI
Indirect (PC)
tec
I\C
Injected KE, ISO, FSO
SC-PF KE, TSO, FSO
Fluidizing KE, PE
pump
OC, PE,
KE, ESPI
--
--
Ic^Sllfw-VJssufi'fan^ = ^ ""^
E = precalciner exit- TSO = third-sta
electrostatic Drecinitstnr ^
Monitor
Measured gas
Combustible
gas
Combustible
gas, 02
CO, 02
Combustible
gas, 02, C03
Combustible
CO, 02
Combustible
gas
CO, 02
CC = clinker cooler; 1
tl t- FSO - f '
i e , bu - Tirst-sta(
Alarm level Trip level
>0.6%
2% 5%
0.7% 1.5%
None 0.8%-TSO
0. 6%-FSO
1% CO 1% CO
0.4% 0.6%
0.2%/ 2.0% NGC
0.8% 4.0% coal
>2%-CO
<1.5%-02
) = dry process; PH = preheater;
_
je outlet; ESPI = inlet to electi
CO trip
Frequency Duration per
per year event, minutes
15 12.8
7.7 4
690.7 11.3
177 19.7
177 4.4
3.0 4
15 <1
122.2 3.3
Seldom <3
PC = precalciner; W = wet
rostatic precipitator;
NG = natural gas.
-------
In the cement industry, cyclone-type collection systems are used
for product recovery. Cyclones are typically used as precollection
systems in combination with fabric filters or electrostatic
precipitators.27
4.1.2 Clinker Cooler
Of 23 clinker coolers subject to the NSPS since the 1979 review, 17
are controlled by fabric filters, 2 are controlled by electrostatic
precipitators, and 4 are controlled by gravel bed filters.
4.1.2.1 Fabric Filters. Most of the fabric filters used for
control of clinker cooler emissions are the negative-pressure type.
Only one positive-pressure fabric filter system is used for control of
emissions from a clinker cooler that has become subject to the NSPS
since 1979.
The bags in fabric filters controlling clinker coolers are typically
cleaned by a pulse jet cleaning mechanism and have air-to-cloth ratios
ranging from about 4:1 to 9:1. One fabric filter controlling clinker
cooler exhaust gases is cleaned by reverse air flow and has an air-to-cloth
ratio of 2:1. The bags may be made of fiberglass, Nomex®, or Gore-Tex®.
Clinker cooler exhaust gas temperatures range from about 93° to 230°C
(200° to 450°F).
4.1.2.2 Electrostatic Precipitators. No plants that have become
subject to the standard since 1979 use electrostatic precipitators for
control of exhaust gases from the clinker cooler. In two cases where
the kilns are controlled by an electrostatic precipitator and where
planetary type clinker coolers are used, the gases from the cooler are
ducted to the kiln as preheated combustion air.28,29 One precipitator
vendor states that in other countries electrostatic precipitators are
successfully used for control of grate-type clinker coolers in the
cement industry.29
4.1.2.3 Gravel Bed Filters. Gravel bed filters consist of a bed
of granules for particle collection. Particles are collected by inertial
impaction, flow interception, diffusional collection, and gravity
settling.30 The first such system was installed in 1973, and three are
currently in use on clinker coolers that have become subject to the
standard since 1979. One clinker cooler under construction will be
controlled by a gravel bed filter. Gravel bed filters generally have
reverse air cleaning, separate compartments, and no electric field
augmentation.30,31
Gravel bed filters have been applied to control emissions from
five clinker coolers subject to the NSPS (four clinker coolers since
1979). The principal advantages of gravel bed filters for control of
clinker cooler exhaust gases are the ability to withstand temperatures
exceeding about 480°C (900°F) and to provide continuous control of
emissions at wide temperature fluctuations.31
4-8
-------
4.1.3 Other Facilities
Affected facilities other than the kiln and clinker cooler are:
raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points,
bagging, and bulk loading and unloading systems.
Raw materials, clinker, and cement handling are typically controlled
by enclosures (total or partial) and/or hooding of transfer points with
exhaust gases directed to fabric filters. Thirty-one plants have
facilities other than the kiln and clinker cooler that have become
subject to the NSPS since the 1979 review. All of these other affected
facilities are controlled by fabric filters except for two finish mills
that are controlled by electrostatic precipitators.
The air-to-cloth ratios of fabric filters controlling other
facilities range from 4:1 to 8:1. The bags are less heat resistant than
those used to control kilns or clinker coolers (i.e., used at temperatures
from ambient to 107°C [225°F]) and may be made of polyester felt, Dacron®
felt, or polypropylene. The fabric filter bags are cleaned by pulse jet
cleaning mechanisms at most facilities subject to the standard since
1979.
4.2 SUMMARY OF PARTICIPATE COMPLIANCE TEST RESULTS
4.2.1 Kiln
Since the 1979 review, 30 kilns (at 28 plants) have become subject
to the NSPS. Of the 30 kilns, emission test data are available for
27 kilns. Three of the 30 kilns are completing construction. The
27 kilns produce from 136,000 to 1,380,000 megagrams of clinker per year
(Mg/yr) (150,000 to 1,520,000 tons per year) with an average production
of 570,000 Mg/yr (630,000 tons/yr).
Figure 4-1 shows particulate mass emission data for kilns subject
to the NSPS since the 1979 review. In some cases, exhaust gases from
the kiln are ducted individually; in other cases the exhaust gases from
the kiln and one or more additional affected facilities (e.g., clinker
cooler and/or raw mill) are vented together. These varied ducting
configurations are discussed in Section 4.2.4. Exhaust gases from kilns
are controlled by fabric filters or electrostatic precipitators. All of
the 27 operational kilns comply with the NSPS of 0.15 kilograms per
megagram (kg/Mg) (0.30 pounds per ton [lb/ton]) of feed (dry basis) to
the kiln.
Visible emissions from the kiln are limited by the NSPS to less
than or equal to 20 percent opacity. Opacity data for 11 of the 30 kilns
are presented in Appendix C; these data represent observations (by plant
or State/local personnel) of visible emissions using EPA Reference
Method 9. All 11 of these kilns are in compliance with the visible
emission regulation. The visible emissions range from 0 percent opacity
to 10 to 15 percent opacity. State and local agency personnel have
4-9
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PARTICULATE
MASS EMISSIONS,
KG/HG (LB/TON)
0.15 (0.30)"
KILN NSPS LIMIT
0.1 (0.20) - -
-pi
I
0.05 (0.10)
(3 KILNS)
O
D
D
O
D •
a o
D
D
P
O
_.
U 0
a
a D
a
KILN +
RAW KILL
O
KILN +
CLINKER
COOLER
O
a
D
KILN +
CLINKER COOLtR
+ RAW MILL
LEGEND
WET
PROCESS
ELECTROSTATIC
PRECIPITATOR
FABRIC FILTER
DRY
PROCESS
O
D
FACILITY
Figure 4-1. Participate mass emissions from kilns that have become subject to the NSPS since 1979.
-------
indicated that none of the 30 operational kilns had problems complying
with the visible emission limit. However, some plants have had detached
plumes. At least 13 of the 28 plants have transmissometers for monitoring
opacity of kiln exhaust gases.
One kiln that has become subject to the NSPS since 1979 has a
detached plume.32 The dry process coal-fired kiln controlled by an
electrostatic precipitator is in compliance with the mass standard, and
opacity is monitored by a transmissometer. The cause of the detached
plume is unknown.32
Two plants have corrected detached plume problems caused by kerogen
(a bituminous material) in the limestone feed material. Both plants use
fabric filters for control. One plant added a precalciner and shortened
the kiln. The precalciner is operated at a temperature high enough to
combust kerogens from the kiln feed.33 The other plant uses a uniquely
designed preheater system.6
Another plant had a detached plume on wet process kilns controlled
by electrostatic precipitators and on wet process kilns controlled by
fabric filters when the kilns were oil-fired. The plant now operates
one dry process kiln that is coal-fired and controlled by a fabric
filter, and the plant has had no further problems.34
Although detached plumes have been studied extensively at several
facilities, no one cause appears to be responsible for their occurrence.
The raw materials, the fuel, the blasting explosive used in mining, and
the ambient temperature are potential contributing causes.35-37
4.2.2 Clinker Cooler
Since 1979, 23 clinker coolers have become subject to the NSPS.
Emission test data are available for 21 of the 23 facilities. Two
plants are completing construction of their clinker coolers.
Figure 4-2 presents the particulate mass emission data for 21 clinker
coolers. In some cases, exhaust gases from the clinker cooler are
ducted to individual control devices and stacks, and, in other cases,
exhaust gases from the clinker cooler are vented to one or more additional
affected facilities prior to the control device (see Section 4.2.4).
Two of the 21 facilities exceed the NSPS mass emission limit of
0.05 kg/Mg (0.10 lb/ ton) for the clinker cooler. At one facility, a
portion of the exhaust gases from the clinker cooler is recycled to the
kiln and a portion is exhausted through the roller mill. The clinker
cooler and roller mill combined emissions are 0.095 kg/Mg (0.19 Ib/ton),
which exceeds the particulate mass emission limit for the clinker cooler.38
This plant is uniquely designed and, at the time of testing, process
conditions were not representative of normal operating conditions.6 The
clinker cooler will be retested. One other facility with a similar
configuration (combined clinker cooler and raw mill emissions ducted to
a fabric filter) is able to meet the 0.05 kg/Mg (0.10 Ib/ton) standard.
4-11
-------
PARTICULATE
MASS EMISSIONS,
KG/MG (LB/TON)
0.15 (0.30H-
KILN NSPS LIMIT
0.1 (0.20)
0.05 (0.1)
D
nn A
~~| i J ^~^ ^~^
n
D
i — i n n n
— U U— -LJ-LJ-
CLINKER COOLER
FACIL
q
CLINKER COO
D '
CLINKER COOLER
+ RAM MHL
TY
•
_ER NSPS
O
CLINKER
COOLER +
KILN
O
D
LIMIT
D
CLINKER COOLER
+ KILN
+ RAW HILL
LEGEND
ELECTROSTATIC PRECIPITATOR Q
FABRIC FILTER
GRAVEL BED FILTER
D
A
Figure 4-2. Particulate mass emissions from clinker coolers
that have become subject to the NSPS since 1979.
-------
A second facility controlled by a fabric filter was recently tested and
found to exceed the participate mass emission limit. Data from these
tests were not representative of normal operating conditions because the
clinker cooler was tested during startup. During the test, the air flow
was 125 percent of design, and the production rate was only 68 percent
of design.39 The clinker cooler will be retested.
The NSPS limits visible emissions from the clinker cooler to less
than 10 percent opacity. State and local air pollution control agency
contacts indicated that 22 of the 23 clinker coolers are in compliance
with the visible emissions limit.
Opacity data for five clinker coolers that have become subject to
the NSPS since 1979 are presented in Appendix C. Data show that visible
emissons are 0 percent at four plants and 5 to 10 percent at one plant.
The one clinker cooler that exceeds the visible emission limit is
controlled by a gravel bed filter and is in compliance with the mass
emission standard. The plant expects to correct the visible emission
problem by venting the exhaust gases from the clinker cooler to a closed
loop heat exchanger system and returning the exhaust gases to the
cooler.40
4.2.3 Other Facilities
Fourteen plants have installed all new facilities (i.e., kilns,
clinker coolers, and other associated equipment such as mills, transfer
facilities, and storage facilities) since 1979. Seventeen additional
plants have added equipment other than kilns or clinker coolers since
1979. State agency personnel indicated that none of these facilities
had problems meeting the visible emission limit of less than 10 percent
opacity. (There is no mass emission limit for these facilities).
4.3 AVAILABLE GASEOUS POLLUTANT TECHNOLOGY
4.3.1 Sulfur Dioxide
Sulfur dioxide (S02) emissions from kilns can be controlled in the
process itself by (a) reduction of the sulfur content of the fuel and
the raw feed material, (b) absorption of S02 by calcium carbonate (CaC03)
in the raw feed material (in the preheater and in the raw mill),
(c) maintenance of excess oxygen in the kiln at an optimal level (about
1 to 2 percent), and (d) combination of the sulfur with alkali oxides
(in the firing end of the kiln) to form alkali sulfates within the
clinker.41,42 The degree to which each of these methods affect S02
reduction can vary considerably depending on process parameters.
Data were obtained to determine those control devices and process
modifications that might reduce S02 emissions from portland cement
plants. Total potential S02 emissions from a kiln are equal to sulfur
from the coal combustion plus sulfur from the raw feed calcination.
4-13
-------
Both components can vary significantly from region to region and, within
a region, from plant to plant.
Between 4.6 and 6.5 xlO9 Joules (4 and 5.6 xlO6 Btu's) are needed
to produce 1 Mg (1 ton) of clinker.43 Assuming an average of 26.7 xlO6
Joules per kilogram (11.5 xlO3 Btu's per pound) of coal, 158 to 221 kg
(348 to 487 Ib) of coal are needed to produce 1 Mg (1 ton) of clinker.
A typical plant produces approximately 544,000 Mg (600,000 tons) of
clinker in a year. With the use of coal that is 1 percent sulfur by
weight, potential S02 emissions from fuel combustion would range between
1,894 and 2,650 Mg (2,088 and 2,922 tons) per year. The potential for
S02 emissions is much higher when the sulfur content of the raw materials
used to produce Portland cement is considered. As an example, sulfur
content in the raw feed was reported to be 0.02 percent by weight at one
plant and 0.6 percent at another plant.44,45 At a typical plant
(544,000 Mg [600,000 tons] of clinker a year), use of raw feeds containing
these percentages of sulfur would add between 388 and 11,657 Mg (428 and
12,852 tons) per year to the potential S02 emissions mentioned above
that are attributable to the coal. Thus, the potential S02 emissions
from both the coal and raw feed would range between 2,282 and 14,307 Mg
(2,516 and 15,774 tons) per year.
The actual S02 emissions from portland cement plants (although, in
some cases, greater than 91 Mg/yr [100 ton/yr]) are significantly less
than potential S02 emissions because sulfur is retained in the product
during production. It was reported in the 1979 portland cement NSPS
review that 75 percent of the S02 emission -potential is absorbed in the
clinker as potassium or sodium sulfates.46 Assuming this 75 percent
reduction does occur, S02 emission potential from coal combustion in the
kilns would decrease to between 473 and 663 Mg (522 and 731 tons) per
year. For raw feed calcination, potential S02 emissions would decrease
to between 97 and 2,914 Mg (107 and 3,213 tons) a year. The total
potential S02 emissions would decrease to between 570 and 3,577 Mg (629
and 3,944 tons) per year.
Sulfur dioxide emission data were obtained from source test reports.
Potential S02 emissions based on the sulfur in the coal burned by the
kiln were calculated. Actual S02 emissions were subtracted from this
amount. The result was divided by the calculated potential S02 emissions
from the coal to determine potential S02 reduction efficiency from the
production process. The reduction efficiency does not include potential
S02 emissions from the raw feed. Based on potential S02 emissions from
fuel alone, reduction efficiencies higher than 75 percent can be achieved.
These percent reduction levels would be higher if sulfur in raw feed was
accounted for. (Only three plants reported the sulfur content in the
raw feed.)
4.3.1.1 Flue Gas Desulfurization Systems. Three types of flue-gas
desulfurization (FGD) systems exist that could provide control of S02
emissions from portland cement kilns: the lime spray-drying system, the
wet limestone desulfurization system, and the dry lime injection system.
4-14
-------
Lime spray drying is being successfully introduced into utility and
industrial boiler systems to reduce S02 emissions. Sulfur dioxide
reduction efficiencies of 60 to 87 percent are guaranteed by equipment
vendors for those plants that will be using this control process.47 In
lime spray drying, atomized lime slurry reacts with S02-laden flue gas
in a spray dryer. Either an electrostatic precipitator or a fabric
filter then collects the dried particulate matter exiting the spray
dryer.48 The byproduct from the scrubbing of the spray dryer could be
used for fertilizer, boiler S02 control, soil stabilization, aggregate
road bases, or as an acid neutralizing agent.49,50
There is no known application of a full-scale lime spray-drying S02
control system in the portland cement industry. However, to meet
California regulations, one portland cement plant, Lone Star Industries,
Inc., is experimenting with a pilot-scale lime spray-drying system to
reduce S02 emission levels.51 Lone Star has had mixed results with this
system; nevertheless, the company is planning to install a full-scale
system.
To install the pilot-scale system, the main conditioning tower,
which is upstream of the electrostatic precipitator, was retrofitted to
be used as a type of lime spray-dryer ("dry scrubber"). In this spray-
dryer tower, slurry containing 90 percent available lime is atomized and
mixed with the kiln exhaust gases. Slurry droplets react with the S02
and are then dried by the hot exhaust gases as shown by the following
simplified reaction:
Ca(OH)2 + S02 -»• CaS03 + H20.
There is a gas retention time of 4 seconds in the tower. The resulting
dry particulate matter is usually exhausted from the tower to the raw
mill. When the raw mill is not operating, particulate matter passes
directly to the main electrostatic precipitator.
Lone Star Industries has found that the efficiency of the spray-dryer
system in reducing S02 emissions is affected primarily by two factors:
the temperature of the exhaust gases and the use of the raw mill. Lower
gas temperatures in the tower allow better sulfur absorption by the
lime. However, when the raw mill is operating, the temperature of gases
leaving the tower must remain high so that materials can be dried in the
mill; When the raw mill is not operating, lower gas temperatures are
possible, and gases are ducted directly from the tower to the electrostatic
precipitator. Therefore, when the mill is on, the spray dryer achieves
a significantly lower percent S02 reduction than when the mill is off.
However, when the raw mill is on, a significant amount of reduction in
S02 occurs in the mill itself by reactions of S02 with the CaC03 in the
raw materials. Thus, temperature of exhaust gases and use of a raw mill
counterbalance each other to bring about S02 reductions presented in
Table 4-4.
The operating permit for the plant allows emissions of no more than
37 kg (82 Ib) of S02 per hour (about 54 ppm). The lime spray-dryer has
4-15
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TABLE 4-4. S02 EMISSIONS FROM LONE STAR INDUSTRIES, INCORPORATED
kg/h
Raw mill off (gas temperature
177°C [350°F])
Raw mill on (gas temperature
260° to 288SC [500° to 550°F])
Lime spray-
dryer off
193 (4-2ST
102 (-2250"
Lime spray-
dryer on
81 ei?9")
78 (iH)
Based on S02 emission tests of a pilot-scale lime spray-dryer system.
4-16
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not enabled the plant to meet this limit. Lone Star believes that this
is because the calculations on which the permit was based assumed that
all the S02 was generated from fuel combustion. Lone Star Industries
has found, however, that sulfur from the fuel tends to be absorbed into
the clinker and that only sulfur from the raw materials tends to be
emitted. The company has calculated a 95 percent correlation between
S02 emissions and sulfur in the raw feed material. Generation of S02 in
the preheater from pyrites in the raw feed was not forecast by the
company or the FGD vendor.
Although lime spray drying is demonstrated in other industries,
there are differences in exhaust characteristics that lessen the perfor-
mance of this technology in the portland cement industry as demonstrated
in this pilot study.
The wet limestone desulfurization system involves mixing the kiln
exhaust gas stream with an alkali slurry in a wet scrubber located down-
stream of the particulate matter control device. The S02 in the gas
stream is reacted with the alkali slurry. This technology has been
demonstrated on sources such as utility and industrial boilers. Sulfur
dioxide removal efficiencies of greater than 90 percent are possible
with this control device.52
The Lone Star Industries portland cement plant in California that
installed the pilot-scale lime spray-drying system considered an alkali
slurry scrubbing control system but decided against use of such a system
for several reasons. First, a wet scrubber would require 380 to 473 liters
(100 to 125 gallons) of water per minute, and the plant might not always
have that much water available. Second, the steam plume that occurs as
a result of the use of a wet scrubber might not be acceptable to neighbors
or the local air pollution control agency. Third, the kiln electrostatic
precipitator is a component of the production process. All process
materials from the raw mill (about 180 Mg [200 tons] per hour) go into
the electrostatic precipitator, and raw feed that is collected in the
electrostatic precipitator is conveyed to the preheater tower. Gases
are exhausted to the atmosphere. Therefore, if the electrostatic
precipitator were to be shut down for any reason, the wet scrubber,
which would be downstream of the electrostatic precipitator, would also
need to be shut down. Fourth, the sludge from the wet scrubber would
require disposal. The sludge could be recycled, or it could be converted
to gypsum and, if the quality of gypsum were satisfactory, combined with
the ground clinker. However, there would be costs associated with
drying and converting the sludge. Because a dry lime spray-dryer would
not require such a large water supply, would produce no steam plume,
could be placed upstream of the electrostatic precipitator, and disposal
of the dust would be relatively simple, Lone Star Industries decided
that the lime spray-dryer was the better S02 control system for its
Portland cement plant.M (No wet limestone desulfurization systems have
been installed at portland cement plants, however.)
In the dry lime injection system, lime or limestone is injected
into the exhaust gas where the S02 is absorbed into the lime. The
4-17
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resulting dry powder is collected in the particulate control device.
One kiln that has become subject to the NSPS since 1979 has a modified
precalciner with a limestone dust injection system to remove sulfur.53
The raw feed material at this plant includes kerogen-bearing shale,
which has a high sulfur content.
4.3.1.2 Fabric Filters^and Electrostatic Precipitators. EPA and
industry personnel have examined the possibility that fabric filters
used for particulate control can provide some control of S02 in industries
such as portland cement manufacturing where the particulate fabric
filter cake is alkaline in nature. Studies of the industrial boiler
industry have shown that fabric filters located downstream of lime
spray-dryers effect from 5 to 30 percent of the overall S02 removal,
depending on the ratio of lime to S02, the approach temperature, and the
fabric filter pressure drop.54 These same studies report that, in
contrast, electrostatic precipitators located downstream of a lime
spray-dryer remove as much as 6 percent of the overal1 S02 removal.54
Typical raw kiln feed contains about 75 percent calcium carbonate.
Typical kiln dust contains from 40 to 65 percent free and combined
calcium oxide depending on the process, degree of calcination, and
degree of reaction.55 Studies indicate that a fabric filter that controls
a kiln, or kiln and raw mill, and that collects the compounds mentioned
above may have some potential for S02 reduction through reaction of S02
to calcium sulfate.
Industry personnel state, however, that, depending on the chemistry
of the filter cake, no significant S02 reduction may occur in the fabric
filter. A fabric filter may have insufficient moisture present to allow
formation of calcium sulfate on the filter cake.56 If kiln exhaust
gases do not pass through a raw material mill prior to the fabric filter,
the filter would probably contain substantial amounts of calcium oxide,
which might absorb significant quantities of S02.57 If, however, kiln
exhaust gases do pass through a raw material mill prior to the fabric
filter, the filter cake may be primarily calcium carbonate, which may
not react appreciably with S02 at the high temperature and low humidity
found in a fabric filter.57
In the raw mill itself, however, for raw feed with a high surface
area that is exposed to both the S02-laden gas stream and to 15 to 20
percent moisture levels up to 50 percent of the S02 is reported to be
absorbed into the raw materials as calcium sulfate.57,58
Industry personnel also note that dry process plants have long gas
paths between the point of formation of S02 and the control device,
which allow potential absorption of S02 prior to the control device.18
Recent studies are inconclusive regarding significant reduction in
S02 emissions through a fabric filter.5^,60 One study states that,
although S02 molecules would have substantially more contact with the
dust surface in a fabric filter than in an electrostatic precipitator,
particle reactivity seems to have a greater influence on S02 reduction
4-18
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than does particle/gas contact.61 Particle reactivity would not be
significantly affected by the control device used. The study concluded
that a fabric filter probably would not absorb significant amounts of
S02 because the system studied currently provides poor S02 emissions
absorption.62 However, another study, performed by Price Waterhouse for
the Portland Cement Association (PCA), used sulfur material balance data
to show an average reduction in potential S02 emissions of 66 percent
from plants using electrostatic precipitators and 70 percent from plants
using fabric filters.63 These reductions include sulfur absorbed by the
product and sulfur retained in the dust collected by the control device.
No continuous monitoring or Method 6 inlet and outlet data are
available for facilities subject to the NSPS, however, to assess S02 ^
removal through a fabric filter or an electrostatic precipitator on a
cement kiln. Figure 4-3 presents S02 outlet emission data for 19 of the
30 cement kilns that have become subject to the NSPS since the 1979
review. The S02 emissions in Ib (kg) of S02 per ton (Mg) of raw feed
are plotted versus the percent sulfur in the fuel for both fabric filter
and electrostatic precipitator control. These data do not show
significantly lower S02 emissions from kilns controlled by fabric filters
than from kilns controlled by electrostatic precipitators.
Information on the amount by which particulate control devices
reduce S02 emissions from cement kilns is inconclusive. This is because
many unpredictable factors affect emissions such as the sulfur content
of the feed, the point in the process at which S02 removal occurs (e.g.,
clinker, control device, exhaust gases), and the relative importance of
process variables (e.g., temperature, moisture, feed chemical composi-
tion).
4.3.1.3 Process Modifications. Process modifications that can
affect S02 emission levels include using the dry rather than the wet
process, increasing the oxygen level in the kiln, reducing the percent
sulfur in the coal, switching to raw feed materials that are low in
sulfur, and use of coal slurry.
Approximately 6.5 xlO9 Joules (5.6 xlO6 Btu's) are required to
manufacture 1 Mg (1 ton) of clinker in a wet process portland cement
plant. In a dry process plant, only 4.6 xlO9 Joules (4 xlO6 Btu's) are
needed. The added coal required in wet process kilns increases the S02
emission potential. A nationwide 50-plant survey sponsored by the PCA
reported that dry process kilns emitted half as much S02 as wet process
kilns.64 The typical S02 emission level from the dry process electro-
static precipitator-controlled plants is 23 kg/h (50 Ib/h) less than
that from the wet process electrostatic precipitator-controlled plants.
The increased energy efficiency of the dry process results in substan-
tially decreased production costs. Because of this energy cost savings,
the dry production process has become the predominant process in the
Portland cement industry for new plants. Of the 30 kilns subject to the
NSPS since 1979, only 5 have used the wet production process, and 3 of
the 5 are older kilns that were converted to coal-firing.
4-19
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Ib/ton
(kg Mg)
6.0
(3.or-
4.0
(2.0!
2.0.
(1.0)
a
a
a
a
B
a
1 2-3
PERCENT SULFUR
FABRIC FILTER
1b/ton
(kg/Mg)
6.0
(3.0TT
4.0
(2.0;
2.04.
(1.0)
a
LEGEND
D DRY PROCESS
• WET PROCESS
a
1 2 3
PERCENT SULFUR
Figure 4-3. S02 emissions versus sulfur in coal
4-20
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Unfortunately, the PCA survey did not take into account the control
device the plant used or the level of sulfur in the fuel or raw materials.
Further study is needed to determine exact relationship between S02
emissions and the type of production process.
Several California studies have shown that increased oxygen levels
in the kiln will reduce S02 emissions.65,66 It is theorized that the
S02 reacts with the oxygen to form S03, which reacts better with the
alkali dust from the raw materials and is absorbed by the clinker or the
dust cake on a fabric filter.65
The oxygen level in the kiln is easily controlled and would not
involve any changes or additions in equipment. However, operators might
strongly resist a requirement to maintain a specific oxygen level. The
oxygen level presently used is based on the individual operator's
experience with the level that results in a consistent product. Varia-
tion of oxygen level at one plant and among plants is unknown. Also,
increasing oxygen levels may increase nitrogen oxide emissions.
Because coal is usually the main source of sulfur in the portland
cement process, burning coal with a low sulfur content is a simple way
to reduce potential S02 emissions. Most plants in this industry use
coal with less than 2 percent sulfur by weight. Much of the growth in
the portland cement industry occurs at sites in close proximity to
sources of low sulfur coal.67 One disadvantage to this method is that
lower sulfur coal is more expensive on the average than high sulfur
coal:
Switching from raw feed materials with a high sulfur content to
those with a low sulfur contents can also reduce potential S02 emissions.
For instance, oil shale that is occasionally used as part of the raw
feed materials can contain high levels of organic materials rich in
sulfur. Oil shale has been identified as a major source of S02 emissions
at two Colorado cement plants.6 Oil shale can be replaced by shale with
lower sulfur content or replaced by other silicon-rich materials such as
clay, sand, or sandstone.
Limestone can contain sulfur-rich pyrite (FeS2). Pyrite has been
identified as the cause of high S02 emissions at one California plant.17
Limestone with pyrite could be replaced either by pyrite-free limestone
or other calcium-rich products, or the pyrite could be "washed" from the
limestone by allowing it to settle out when the limestone is pulverized
and mixed with water. The amount of pyrite in limestones around the
country varies depending on mining techniques and the purity of the
limestone formation.
An estimated 50 percent of all industrial waste products could be
used in the production of portland cement, and these products are lower
in sulfur than most natural fuels. Because most portland cement plants
are near population and industrial centers, industrial waste products as
raw feed could be readily available and reduce the reliance of the plant
on natural materials.
4-21
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Although many natural and man-made substitutes are available for
limestone and shale, the costs of replacement materials or "cleaning" of
the raw materials could be higher than costs for raw materials presently
being used. Because of the high cost of transporting cement, port!and
cement plants must be located near areas of product demand and must make
do with the raw materials locally available in order to keep costs
reasonable. Also, some raw materials that increase potential S02
emissions are attractive to plant operators for other reasons. For
example, the use of oil shale reduces energy costs because oil shale
adds combustible products that help fire the kiln. Also, the iron in
pyrite-rich limestone is a necessary ingredient for portland cement
production. Although the relationship between the chemical composition
of different raw materials and the amount of S02 emissions has been
shown in some parts of the country, further study is needed to determine
if this relationship exists nationwide.
Use of coal slurry has been estimated by one vendor to reduce S02
emissions up to 90 percent compared to emissions from other fuel
sources.68 Pulverized coal is mixed with water to allow any pyrite in
the coal to settle out. A commercial coal slurry process has been
demonstrated on asphalt concrete plants in Illinois and is being promoted
for portland cement plants. The vendor of the commercial process stated
that coal slurry produced in this process is two to three times less
expensive than fuel oil.68 If low sulfur coal is unavailable or
prohibitively expensive, this process may be a cost-effective way of
reducing the sulfur content of other coals.
The cost of a new portland cement plant would increase by the
amount required to build the coal slurry process plant unless a local
commercial coal slurry process were available. Costs would be incurred
for replacing or modifying the burners in plants to burn coal slurry.
Exact costs for the use of a coal slurry in a portland cement plant are
unknown because no coal slurry process plant large enough to supply fuel
for a portland cement plant has been built. However, the costs would be
higher for processing and firing coal slurry than for firing coal dry.
Disposal costs might increase because of the increased solid waste from
the coal slurry production process.
Because excessive sulfur in the clinker can cause cracking of the
final cement product, ASTM has set recommended standards for the amount
of sulfur allowed in the clinker. Plant operators meet clinker specifica-
tions (and, as a side benefit, reduce potential S02 air emissions) by
limiting the sulfur content of raw materials and fuels.
4.3.2 Nitrogen Oxides
At least six kilns that have become subject to the NSPS since 1979
have nitrogen oxides (NO ) monitors.
Since the 1979 review of the NSPS, research has been conducted on
N0x emission reduction by combustion modification techniques on a pilot-
scale system, a small scale kiln, and a full scale kiln. This study has
4-22
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shown that N0x emissions may be reduced through recirculation of flue
gases into the primary combustion air of the kiln.69 Recirculation of
flue gases reduces the local oxygen content in the kiln flame, which, in
turn, lowers the flame temperature. The lower flame temperature reduces
N0x emissions that are caused by coal burning.
Although the process modifications tested did reduce NO emissions,
the effects of flue-gas recirculation could not be separatedxfrom
variations in process parameters. Therefore, additional research is
needed to demonstrate the effectiveness of flue gas recirculation or
other NO emission reduction methods.
/\
4.4 REFERENCES FOR CHAPTER 4
1. U. S. Environmental Protection Agency. Response to Remand Ordered
by U. S. Court of Appeals for the District of Columbia in Portland
Cement Association v. Ruckelshaus. Publication EPA-450/2-74r023
November 1974. p. 7-14.
2. U. S. Environmental Protection Agency. Control Techniques for
Particulate Emissions from Stationary Sources. Volume II. Publi-
cation No. EPA-450/3-81-005b. September 1982. p. 9.7-78.
3. Phillips, N. and W. Brumagin. Fabric Filters in the Cement Industry.
Pit and Quarry. Volume 73. Number 1. July 1980. p. 96.
4. U. S. Environmental Protection Agency. Inspection Manual for
Enforcement of New Source Performance Standards. Portland Cement
Plants. Publication No. EPA-340/1-75-001. September 1975. p. 3-13.
5. Reynolds, J. and L Theodore. Analysis of an APCA Baghouse Operation
and Maintenance Survey. Journal of the Air Pollution Control
Association. November 1980. pp. 1255-1257.
6. Telecon. Clark, C., MRI, to Clouse, J. , Colorado Air Pollution
Control Division. October 13, 1983. Discussion of cement plants
in Colorado.
7. Murray, J. and C. Rayner. The State-of-the-Art of Dust Collectors
on Preheater Kilns. (Presented at the 22nd IEEE Cement Industry
Technical Conference. Toronto, Ontario, Canada. May 19-22, 1980 )
pp. 15-16.
8. Bundy, R. Operation and Maintenance of Fabric Filters. Journal of
the Air Pollution Control Association. July 1980. p. 757.
9. Barrett, K. A Review of Standards of Performance for New Stationary
Sources—Portland Cement Industry. U. S. Environmental Protection
Agency. Publication No. EPA-450/3-79-012. March 1979. pp 4-21
4-22.
4-23
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10. Reference 7, p. 5.
11. Reference 9, p. 4-20.
12. Comments and attachments presented by Brown, R., Environmental
Elements Corp., to the National Air Pollution Control Techniques
Advisory Committee. August 30, 1984. Response to the NSPS for
Portland cement plants, p. 5, 7-9.
13. Letter from Lotz, W., Lehigh Portland Cement Company, to Farmer, J.,
EPA/OAQPS. September 6, 1984. Transmitting summary of comments
presented to the National Air Pollution Control Techniques Advisory
Committee on August 30, 1984. p. 2, 3.
14. Letter from Greer, W., Lone Star Industries, Inc., to Cuffe, S. ,
EPA/ISB. June 22, 1984. Response to request for comments on the
draft review document, p. 5.
15. PEDCo Environmental, Inc. Technical Assistance to the State of
Iowa--Excess Emissions at Lehigh Cement, Mason City, Iowa. EPA
Contract No. 68-01-6310. February 1984. p. 59.
16. Reference 15, p. 61.
17. Reference 15, pp. 93-94.
18. Comments presented by Orem, S., Industrial Gas Cleaning Institute,
to the National Air Pollution Control Techniques Advisory Committee.
August 30, 1984. Response to the NSPS for portland cement plants.
p. 1.
19. Reference 12, pp. 4, 5.
20. Comments presented by von Seebach, M. , Polysius Corp., to the
National Air Pollution Control Techniques Advisory Committee.
August 30, 1984. Response to the NSPS for portland cement plants.
p. 3.
21. Reference 13, p. 3.
22. Letter from Riley, J., Lurgi Corp., to Farmer, J., EPA/OAQPS.
August 31, 1984. Transmitting summary of comments to have been
presented to the National Air Pollution Control Techniques Advisory
Committee on August 30, 1984. p. 1.
23. Petersen, H. New Trends in Electrostatic Precipitation: Wide Duct
Spacing, Precharging, Pulse Energization. (Presented at the 22nd
IEEE Cement Industry Technical Conference. Toronto, Ontario,
Canada. May 19-22, 1980.) pp. 4-14.
24. Reference 23, p. 14.
4-24
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25. U. S. Environmental Protection Agency. Control Techniques for
Participate Emissions from Stationary Sources. Volume I.
Publication No. EPA-450/3-81-005a. September 1982. p. 4.2-6.
26. Reference 16, pp. 4.2-19 - 4.2-30.
27. Reference 9, pp. 4-17 - 4-19.
s 28. U. S. Environmental Protection Agency. Portland Cement Plant
A Inspection Guide. Publication No. EPA-340/1-82-007. June 1982.
p. 27.
29. Comments presented by Prior, 0., F. L., Smidth and Company, to the
National Air Pollution Control Techniques Advisory Committee.
August 30, 1984. Response to the review of NSPS for portland
cement plants, p. 3.
30. Reference 25, p. 8-32.
31. Reference 9, pp. 4-22 - 4-25.
32. Telecon. Clark, C.-, MRI, with Frances, J. , Nebraska Department of
Environmental Control. November 4, 1983. Discussion about Ash
Grove Cement Company, Louisville, Nebraska.
33. Herod, S. Martin Marietta Clears the Air Over Colorado Plant. Pit
and Quarry. July 1981. p. 85.
34. Telecon. Clark, C., MRI, with Johnson, H., Bay Area Air Quality
Management District. October 27, 1983. Discussion about Kaiser
Cement Corp., Permanente, California.
35. Armstrong, J., P. Russell, and M. Plooster. Balloon-Borne Particulate
Sampling of the Glens Falls Portland Cement Plant Plume. EPA Grant
No. R805926-01. July 16, 1979.
36. Information from Fulton, R., Jefferson County Bureau of Environmental
Health, to Clark, C., MRI. January 16, 1984. Formation of a
Detached Plume in the Exhaust Gas of a Portland Cement Kiln. EPA
Contract No. 68-01-4146. September 1981.
37. Winberry, W., Jr., Engineering-Science, Inc. Survey of Detached
Plumes With Potential Formation of Inhalable Particulates. Durham,
North Carolina. June 1983.
38. Information from Clouse, J., Colorado Air Pollution Control Division,
to Clark, C., MRI. November 10, 1983. Results for February 25 and
26, 1982, roller mill/clinker cooler tests at Ideal Basic Industries,
Inc., Fort Collins, Colorado.
4-25
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39. Information from Phelps, D., Iowa Department of Water, Air, and
Waste Management, to Clark, C., MRI. November 4, 1983. Emission
test summary for Davenport Cement.
40. Telecon. Eddinger, J., EPA/ISB, with Thoits, F., Monterey Bay
Unified Air Pollution Control District. August 27, 1984. Discussion
about visible emissions.
41. Letter and attachment from Miller, E. , Oregon Portland Cement
Company, to Farmer, J., EPA/OAQPS. November 22, 1983. Response to
Section 114 information request, p. 21.
42. Telecon. Clark, C., MRI, with Lewis M., and J. Macias, Texas Air
Control Board, Region 8. December 7, 1983. Discussion about
cement plants in the Region.
43. Portland Cement Association. Energy Report: U.S. Portland Cement
Industry. Skokie, Illinois. October 1983.
44. Information from J. Clouse, Colorado Air Pollution Control Division,
to C. Clark, MRI. November 10, 1983. Notice of intent to construct
and operate Martin Marietta Cement, Lyons, Colorado, p. 15.
45. Information from P. Bosserman, Department of Environmental Quality,
Oregon, to C. Clark, MRI. January 9, 1984. Summary of source test
results for an Oregon portland cement plant.
46. Ketels, P., 0. Nesbitt, and R. Oberle, (Institute-for Gas Technology.)
Survey of Emissions Control and Combustion Equipment Data in Industrial
Process Heating. Preapred for U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. Publication
No. EPA-600/7-76-022. October 1976. p. 72.
47. Kelly, M. and S. Shareef (Radian Corporation). Third Survey of Dry
S02 Control Systems. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. Publication
No. EPA-600/S7-81-097. August 1981. p. 4.
48. Apple, C. and M. Kelly. Mechanisms of Dry S02 Control Processes.
U. S. Environmental Protection Agency. Publication
No. EPA-600/S7-82-026. June 1982. p. 2.
49. Reference 9, p. 4-12.
50. U. S. Environmental Protection Agency. Multimedia Assessment and
Environmental Research Needs of the Cement Industry. Publication
No. EPA-600/2-79-111. Cincinnati, Ohio. May 1979. p. 53.
51. Memorandum from Clark, C., MRI, to Tabler, S., EPA/SDB. January 30,
1985. Minutes of October 2, 1984, discussion about the Lone Star
flue-gas desulfurization system.
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52. Telecon. M. Maul, MRI, to D. Seaward, Wheelabrator-Frye, Inc.
March 30, 1984. Alkaline slurry injection system costs for portland
cement plants.
53. Memorandum from Maxwell, C., MRI, to Glowers, M., EPA/ISB. November 18,
1983. Trip report: Ideal Basic Industries, Inc., Fort Collins,
Colorado, on November 8, 1983.
54. Sedman, C. Performance of Spray Drying FGD Systems. Draft. U. S.
Environmental Protection Agency. Research Triangle Park, North
Carolina. August 8, 1984. p. 13.
55. Letter from Gebhardt, R., Lehigh Portland Cement Company, to Cuffe, S.,
EPA/ISB. June 6, 1984. Response to request for comments on draft
review document, p. 4.
56. Reference 12, p. 4.
57. Reference 14, p. 6.
58. Reference 20, p. 2.
59. Reference 12, pp. 2-4.
60. Energy and Resource Consultants, Inc. Background Document on SO
and NO Emissions From Five Industrial Process Categories. x
September 20, 1982. Prepared for the Office of Technology Assess-
ment. Washington, D.C. p. 2-12.
61. KVB, Inc. An Evaluation of S02 Removal Across a Fabric Filter.
July 1983. Prepared for Lone Star Industries, Inc. p. 21, 30.
62. Reference 61, p. 23.
63. Comments presented by Gebhardt, R., Lehigh Portland Cement Company,
to the National Air Pollution Control Techniques Advisory Committee.
August 30, 1984. Response to the review of NSPS for portland
cement plants, p. 4.
64. Letter from Schneeberger, C., Portland Cement Association (PCA), to
Maxwell, C., MRI. November 17, 1983. Transmittal of PCA report:
Kiln Gaseous Emissions Survey. August 18, 1983. p. 2 of 6.
65. Reference 47, pp. 20, 24, 25.
66. KVB, Inc. Emissions Reduction by Advanced Combustion Modification
Techniques for Industrial Combustion Equipment. Prepared for U. S.
Environmental Protection Agency Industrial Advisory Panel Meeting.
June 8, 1983. p. 58.
67. Wark, K. and C. Warner. Air Pollution: Its Origin and Control.
2nd Edition. New York, Harper and Row. 1981. p. 351.
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68. Duncan, C. and V. Swanson. Organic-Rich Shale of the U.S. and
World Land Areas. U.S. Geological Survey. Circular 523.119.4/2:53.
U.S. Department of Interior. Washington, D.C. 1965. pp. 1-27.
69. KVB, Inc. Application of Combustion Modification Technology for
NO Control to Cement Kilns. Prepared for U. S. Environmental
Protection Agency.
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5. COST ANALYSIS
This chapter presents the costs of complying with the new source
performance standards (NSPS) for affected portland cement facilities.
5.1 APPROACH
Model facility parameters were established to represent the range
of facilities that have become subject to the NSPS since the 1979 review.1
Capital and annualized costs of emission control equipment for the model
facilities were estimated using the CARD manual (in December 1977
dollars).2 These costs were updated to July 1983 dollars using the
Chemical Engineering fabricated equipment cost index and statistics from
the Bureau of Labor and the Bureau of Industrial Economics.3-5
The capital cost of a control system includes the cost of design
and installation of the major control device and of auxiliaries such as
fans and instrumentation; the cost of foundations, piping, electrical
wiring, and erection; and the cost of engineering construction overhead
and contingencies.6,7
The annualized cost of a control system represents the yearly cost
to the company of owning and operating the system. This cost includes
direct operating costs such as labor, utilities, and maintenance and
capital related charges such as depreciation, interest, administrative
overhead, property taxes, and insurance. Annualized costs presented in
this chapter do not include credits for product recovery.6/
The estimated capital and annualized costs of emission control
equipment are presented in Section 5.2. A comparison of estimated and
reported capital costs is presented in Section 5.3. Cost effectiveness
of emission control is presented in Section 5.4.
5.2 ESTIMATED CAPITAL AND ANNUALIZED COSTS OF EMISSION CONTROL
Estimated capital and annualized costs for each of 17 model facilities
(7 kilns, 3 clinker coolers, and 7 other facilities, [i.e., raw mill,
blending silos, clinker storage, 2 finish mills, cement storage and
transfer facilities]) are presented in the following subsections.
5-1
-------
5.2.1 Kiln
Model kiln facilities were developed to represent emission control
by fabric filters and by electrostatic precipitators on kilns installed
since 1979. Parameters describing the facilities and emission control
equipment are presented in Table 5-1. The exhaust gas flow rate is the
critical parameter for costing both types of emission control equipment.
Exhaust gas flow rates for each model kiln were developed using reported
air flow data from industry and State and local agencies in combination
with design flow data from a control equipment manufacturer.8
Table 5-2 presents the estimated capital and annualized costs in
July 1983 dollars of control equipment for each of the seven model kiln
facilities. Kilns A, B, and C represent small, medium, and large kilns,
respectively, with exhaust gases controlled by fabric filters. Kiln D
represents a medium kiln with a main fabric filter emission control
system and an alkali-bypass fabric filter control system (which handles
about 25 percent of the exhaust gases). Kilns E, F, and G represent
small, medium, and large kilns, respectively, with exhaust gases
controlled by electrostatic precipitators.
5.2.2 Clinker Cooler
Most of the 23 clinker cooler facilities subject to the NSPS since
the 1979 review are controlled by fabric filters.
Fabric filter control of a clinker cooler was evaluated for three
sizes of model facilities: small, medium, and large. Parameters that
describe the fabric filters used to control clinker cooler exhaust gases
are shown in Table 5-3. The data for exhaust gas flow rates and for
other parameters were derived from data for similar facilities that have
become subject to the NSPS since 1979.
Table 5-4 presents the estimated capital and annualized costs in
July 1983 dollars of control equipment for each of the model clinker
cooler facilities.
5.2.3 Other Facilities
Other affected facilities (mills, storage, and transfer facilities)
at portland cement plants are subject only to a visible emissions limit
under the NSPS of less than 10 percent opacity. Fabric filters are used
to control emissions from most of these facilities that are subject to
NSPS since the 1979 review. Two plants have finish mills controlled by
electrostatic precipitators.
Capital and annualized costs were estimated for six model facilities
(raw mill, blending silo, clinker storage, finish mill, cement storage,
and transfer) controlled by fabric filters and for one model facility
(finish mill) controlled by an electrostatic precipitator. Parameters
describing the emission control equipment for each model facility are
presented in Table 5-5. These parameters were based on reported data
5-2
-------
from medium-size facilities that have become subject to the NSPS since
1979 and are representative of facilities at a medium size plant
(544,000 Mg/yr [600,000 tons/year] per kiln).
Table 5-6 presents the capital and annualized costs of particulate
emission control equipment for these model facilities. Because a portland
cement plant will have more than one of several of the facilities shown
in Table 5-6, total plant capital costs for control of other facilities
can be substantially more than the sum of the individual costs in the
table. Two plants with facilities that have become subject to the NSPS
since 1979 reported more than 50 fabric filter control devices (at each
plant) controlling exhaust gases from these other facilities. Based on
the capital costs for fabric filter control of the individual facilities
shown on Table 5-6, the total plant capital cost of such fabric filter
systems is estimated to be $5,000,000 per plant.
5.3 COMPARISON OF ESTIMATED AND REPORTED CAPITAL COST DATA
Reported capital cost data were obtained from individual plants.
These data were converted to 1983 dollars for comparison with the
estimated capital cost data presented in Section 5.2.9-12 Table 5-7
presents the estimated and reported capital costs by facility size and
type of control equipment.
5.4 COST EFFECTIVENESS
Table 5-8.presents the cost effectiveness of the 17 model facilities.
Cost effectiveness is the annualized cost of emission control divided by
the annual emission reduction. Uncontrolled and NSPS (allowable)
particulate emissions are calculated for each model facility by
multiplying the raw material feed rate by an emission factor.1^,14
Uncontrolled emissions are assumed to be those exiting a product
recovery cyclone. The annual emission reduction is calculated as
uncontrolled emissions minus NSPS (allowable) emissions.
The cost effectiveness of controlling emissions from kilns ranges
from $34 to $50 per Mg of emissions ($31 to $45 per ton). The cost
effectiveness of controlling emissions from clinker coolers ranges from
$27 to $44 per Mg ($25 to $40 per ton). The cost effectiveness of
controlling emissions from other facilities was estimated to range from
$30 to $167 per Mg ($27 to $151 per ton).
5-3
-------
TABLE 5-1. SUMMARY OF MODEL KILN FACILITY PARAMETERS
en
i
Model
Size
facility
Produc- Exhaust gas
tion rate. rate, mVmin
Mg (tons) (acfm)
Temp, inlet/ Pressure
outlet, drop, .
°C (°F) in. WG Other parameters
I. Fabric filter control
A Small:
B Medium:
C Large:
D Medium
alkali
272,000
(300,000)
544,000
(600,000)
1,089,000
(1,200,000)
with
bypass:
544,000
(600,000)
4,250
(150,000)
8,500
(300,000)
17,000
(600,000)
Main:
7,650
(270,000)
Bypass:
2,270
(80,000)
246 (475)7
149 (300)
246 (475)7
149 (300)
246 (475)7
149 (300)
232 (450)7
149 (300)
260 (500)7
149 (300)
6 For all fabric filter con-
trolled facilities:
6 Air-to-cloth ratio: 1.3:1 to
1.5:1; 7,200 h/yr operation;
6 fiberglass bags; reverse air
cleaning.
5
5
II. Electrostatic precipitator control
E Small:
F Medium:
G Large:
272,000
(300,000)
544,000
(600,000)
1,089,000
(1,200,000)
3,540
(125,000)
7,080
(250,000)
14,160
(500,000)
177 (350)7
177 (350)
177 (350)7
177 (350)
177 (350)7
177 (350)
5 For all electrostatic precipi
tator controlled facilities:
5 precipitator efficiency =
99.95%; precipitation rate
parameter =5.5 m/min
5 (18 fpm); SCA = 1.4 m2 per
mVmin (420 ft2 per
1,000 acfm); 7,200 h/yr
operation.
.Megagrams (tons) of clinker produced per year per kiln.
m3/min = Actual cubic meters per minute; acfm = actual cubic feet per minute.
Temperature estimated at inlet to and outlet of control device.
-------
TABLE 5-2. ESTIMATED CAPITAL AND ANNUALIZED COSTS OF PARTICULATE EMISSION
CONTROL EQUIPMENT FOR MODEL KILN FACILITIES
Model kiln
I. Fabric filter
A
B
C
D
II. Electrostatic
E
F
G
Model
facility type
control
Small
Medium
Large
Medium, with
alkali bypass
precipitator control
Small
Medium
Large
Capital
cost, $a
1,925,000
3,572,000
10,344,000
3,904,000
2,212,000
3,542,000
8,748,000
Annual ized
cost, $
548,000
924,000
2,030,000
1,099,000
480,000
765,000
1,615,000
aJuly 1983 dollars.
5-5
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TABLE 5-3. SUMMARY OF MODEL CLINKER COOLER FACILITY PARAMETERS
cr>
cl
A
B
C
Model
inker cooler
Small:
Medium:
Large:
Model
facility size,
Mg (tons)3
272,000
(300,000)
544,000
(600,000)
1,089,000
(1,200,000)
Exhaust
gas flow
rate, mVmin
(acfm)D
2,830
(100,000)
5,660
(200,000)
9,910
(350,000)
Temp.
inlet/
outlet,
°C (°F)
177 (350)/
121 (250)
204 (400)/
121 (250)
204 (400)/
121 (250)
Pressure
drop,
in. W.G.
4
6
6
Air-to-
cloth
ratio
5:1
5:1
5:1
Other
parameters
For all model
clinker cooler
facilities:
7,200 h/yr of
operation;
Nomex bags;
pulse jet
cleaning.
.Megagrams (tons) of clinker produced per year per kiln.
mVmin = actual cubic meters per minute; acfm = actual cubic feet per minute.
Temperature estimated at inlet to and outlet of control device.
-------
TABLE 5-4. ESTIMATED CAPITAL AND ANNUALIZED COSTS OF PARTICULATE EMISSION
CONTROL EQUIPMENT FOR MODEL CLINKER COOLER FACILITIES
Model Capital, Annualized
Model clinker cooler facility size cost, $ cost, $
A Small 931,000 321,000
B Medium 1,731,000 523,000
C Large 2,959,000 800,000
.Exhaust gases controlled by fabric filter.
DJuly 1983 dollars.
5-7
-------
TABLE 5-5. SUMMARY OF PARAMETERS FOR MODEL OTHER FACILITIES
en
i
oo
Exhaust
gas flow rate,
Model other facility mVmin (acfm)
I. Fabric filter control
Raw mill 1,130
(40,000)
Blending silo 280
(10,000)
Clinker storage 170
(6,000)
Finish mill 710
(25,000)
Cement storage 420
(15,000)
Transfer facility 70
(2,500)
II. Electrostatic precipitator control
Finish mill 710
(25,000)
Temp.
inlet/outlet
°C (°F)C
88 (190)/
38 (100)
38 (100)/
38 (100)
38 (100)/
38 (100)
121 (250)/
52 (125)
38 (100)/
38 (100)
38 (100)/
38 (100)
121 (250)/
93 (200)
Pressure Air-to-
drop, cloth .
in. W.G. ratio Other parameters
4 7:1 For fabric filter-controlled
facilities:
4 • 5:1 5,000 h/yr operation (except
7,200 h/yr for finish mill);
4 8:1 polyester or Dacron bags;
pulse jet cleaning.
4 6:1
4 7:1
4 6:1
5 -- For electrostatic precipi-
tator controlled facilities:
precipitator efficiency
= 99.95%; precipitation rate
parameter =5.5 m/min
(18 fpm); SCA = 1.4 m2 per
mVmin (420 ft2 per
1,000 acfm); 7,200 h/yr
operation.
All facilities are representative of facilities at a medium-size plant (i.e., 544,000 Mg of clinker
.produced per year per kiln [600,000 tons/yr]).
rnVmin = actual cubic meters per minute; acfm = actual cubic feet per minute.
Temperature estimated at inlet to and outlet of control device.
-------
TABLE 5-6. ESTIMATED CAPITAL AND ANNUALIZED COSTS OF PARTICULATE EMISSION
CONTROL EQUIPMENT FOR MODEL OTHER FACILITIES
Model
I.
II.
other facility3
Fabric filter control
Raw mill
Blending silo
Clinker storage
Finish mill
Cement storage
Transfer facility
Electrostatic precipitator control
Finish mill
Capital.
cost, $
344,000
154,000
84,000
254,000
146,000
68,000
914,000
Annual i zed
cost, $
102,000
54,000
38,000
81,000
54,000
34,000
189,000
a.,, , •-[•+• 4. 4. • *• -i-4.-
All facilities are representative of facilities at a medium-size plant
(i.e., 544,000 megagrams of clinker produced per year per kiln
,[600,000 tons/yr]).
July 1983 dollars.
5-9
-------
TABLE 5-7. COMPARISON OF ESTIMATED CAPITAL COSTS OF EMISSION
CONTROL WITH REPORTED CAPITAL DATA COSTS (FROM INDUSTRY)
Capital cost, 1983 $
Estimated Reported
Model facility
Kiln .
A. Small (FF)D 1,925,000 1,500,000
B. Medium (FF) 3,572,000
C. Large (FF) 10,344,000 14,000,000^
D. Medium, with 3,904,000 l,000,000a
alkali bypass (FF)
E. Small (ESP)D 2,212,000
F. Medium (ESP) 3,542,000 3,200,000,
3,500,000
G. Large (ESP) 8,748,000 4,700,000
Clinker cooler
A. Small (FF) 931,000
B. Medium (FF) 1,731,000 1,000,000
C. Large (FF) 2,959,000
Other facilities
(FF) 68,000 42,000
to 344,000 to 73,000
28,000,
and 73,000
(ESP, finish mill) 914,000 850,000
Reported capital costs from industry (References 9-12). Reported costs
are installed costs of control systems (assumed to include the cost of
.the control device and all auxiliaries).
FF = Fabric filter; ESP = electrostatic precipitator.
.Control system for large kiln and clinker cooler.
Cost of alkali bypass system only.
/Two-year-old electrostatic precipitator purchased from another company.
The $28,000 capital cost is the average for 14 dust collectors.
5-10
-------
TABLE 5-8. COST EFFECTIVENESS OF PARTICIPATE EMISSION
REDUCTION BY MODEL FACILITIES
Model facility3
I. Kiln
A. Small (FF)
B. Medium (FF)
C. Large (FF)
D. Medium, with
alkali bypass (FF)
E. Small (ESP)
F. Medium (ESP)
G. Large (ESP)
II. Clinker cooler
A. Small (FF)
B. Medium (FF)
C. Large (FF)
III. Other facilities1
Raw mill (FF)
Blending silo (FF)
Clinker storage (FF)
Finish mill (FF)
Cement storage (FF)
Transfer facility (FF)
Finish mill (ESP)
Facility
size,
Mg/yr .
(tons/yr)D
272,000
(300,000)
544,000
(600,000)
1,089,000
(1,200,000)
544,000
(600,000)
272,000
(300,000)
544,000
(600,000)
1,089,000
(1,200,000)
272,000
(300,000)
544,000
(600,000)
1,089,000
(1,200,000)
Annual-
ized
cost,
$/yrc
548,000
924,000
2,030,000
1,099,000
480,000
765,000
1,615,000
321,000
523,000
800,000
102,000
54,000
38,000
81,000
54,000
34,000
189,000
Particulate d
emissions, Mq/yr (tons/yr)
Un-
controlled
11,200
(12,300)e
22,300
(24,600)e
44,600
(I9,200)e
22,300 .
(24,600)
11,200 .
(12,300)e
22,300
(24,600)e
44,600 a
(49,200)
7,300
(8.040)9
14,600
(16.100)9
29,200
(32.200)3
1,420 .
(1,570)J
1,420 .
(1,570)J
1,420 .
(1,570)J
1,420 .
(1,570)J
1,420 .
(1.570)3
1,420 .
(1,570)J
1,420 .
(1,570)J
NSPS
73 f
(80)r
146 f
(161)
292 f
(322)T
146 f
(161)
73 f
(SO/
146 f
(161)
292 f
(322)r
24 h
(27)h
49 h
(53)n
97
(107)"
286 .
(315)k
286
(315)*
286 ..
(315)K
286 .,
(315)K
286
(315r
286 .,
(315)"
286
(315)K
Emission
reduction
11,100
(12,200)
22,100
(24,400)
44,300
(48,900)
22,100
(24,400)
11,100
(12,200)
22,100
(24,400)
44,300
(48,900)
7,250
(8,000)
14,500
(16,000)
29 , 100
(32,100)
1,130
(1,250)
1,130
(1,250)
1,130
(1,250)
1,130
(1,250)
1,130
(1,250)
1,130
(1,250)
1,130
(1,250)
Cost
effectiveness
STRg ($/ton)
49
42
46
50
43
34
36
44
36
27
90
48
34
72
48
30
167
(45)
(38)
(42)
(45)
(39)
(31)
(33)
(40)
(33)
(25)
(82)
(43)
(30)
(65)
(43)
(27)
(151)
&FF = Fabric filter; ESP = electrostatic precipitator.
Megagrams (tons) of clinker produced per year per kiln.
iJuly 1983 dollars.
1.7 Mg kiln feed per Mg cement; 1.05 Mg cement per Mg clinker; Reference 14.
fKiln: 23 kg of particulate emissions per Mg of kiln feed (45 lb/ton); Reference 13
'Kiln: NSPS limit of 0.15 kg/Mg kiln feed (0.30 lb/ton).
^Clinker cooler: 15 kg of particulate emissions per Mg of kiln feed (30 lb/ton); Reference
10.
•Clinker cooler: NSPS limit of 0.05 Kg/Mg kiln feed (0.10 lb/ton).
All other facilities are representative of facilities at medium-size plants that have become subject to the
.NSPS since 1979.
J0ther facilities: estimated 10 kg of particulate emissions per Mg of cement (20 lb/ton) (Reference 14). Assumed
k?5 percent control efficiency if controlled by cyclone dust collector.
Other facilities: estimated 10 kg/Mg of cement or 20 lb/ton (Reference 14), and assumed 95 percent control
efficiency (minimum) if controlled by fabric filter, i.e. a conservative estimate used to calculate maximum cost
effectiveness.
5-11
-------
5.5 REFERENCES FOR CHAPTER 5
1. Memorandum from Maxwell, C., MRI, to Eddinger, J., EPA/ISB. August 6,
1984. Model facility sizes and exhaust gas characteristics.
2. Neveril, R. (Gard, Inc.) Capital and Operating Costs of Selected
Air Pollution Control Systems. Prepared for the U.S. Environmental
Protection Agency. Publication No. EPA-450/5-80-002. December
1978.
3. Economic Indicators. Chemical Engineering. November 28, 1983.
p. 7.
4. Producer Prices and Price Indexes for Commodity Groupings and
Individual Items. U.S. Department of Commerce. Bureau of Labor
Statistics. November 1983. pp. 90, 112, 114, 115.
5. 1983 U.S. Industrial Outlook for 250 Industries With Projections
for 1987. U.S. Department of Commerce. Bureau of Industrial
Economics. January 1983. p. 2-8.
6. Memorandum from Maxwell, C., MRI, to Eddinger, J. , EPA/ISB. August 6,
1984. Capital and annualized costs of air pollution control equipment.
7. Memorandum from Maxwell, C., MRI, to Eddinger, J. , EPA/ISB. August 6,
1984. Revised cost analysis.
8. Telecon. Maxwell, C., MRI, to Kreisberg, A., Fuller Company.
April 12, 1984. Discussion of design parameters for cement kiln
control equipment.
9. Letter and attachments from Miller, E., Oregon Portland Cement
Company, to Farmer, J., EPA/OAQPS. November 22, 1983. Response to
Section 114 information request, p. 35.
10. Letter and attachments from Powledge, H., Ideal Basic Industries,
Inc., to Farmer, J., EPA/OAQPS. December 30, 1983. Response to
Section 114 information request, p. 97.
11. Letter and attachments from Gebhardt, R., Lehigh Portland Cement
Company, to Farmer, J., EPA/OAQPS. January 6, 1984. Response to
Section 114 information request, pp. 10, 14, and 15.
12. Letter and attachments from Greer, W., Lone Star Industries, Inc.,
to Farmer, J., EPA/OAQPS. March 30, 1984. Response to Section 114
information request, pp. 12, 13 and 51.
13. U. S. Environmental Protection Agency. Background Information for
Proposed New Source Performance Standards; Steam Generators,
Incinerators, Portland Cement Plants, Nitric Acid Plants, Sulfuric
Acid Plants. Publication No. APTD-0711. August 1971. pp. 28-29.
5-12
-------
14. U. S. Environmental Protection Agency. Industrial Process Profiles
for Environmental Use: Chapter 21--The Cement Industry. Publi-
cation No. EPA-600/2-77-023u. February 1977. pp. 18, 20, 22, 24.
5-13
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6. ENFORCEMENT ASPECTS
This chapter presents the concerns of Federal, State, and local air
pollution control agencies based on their experience in enforcing the
Portland cement NSPS. These enforcement concerns may be grouped into
four areas: (1) interpretation of the particulate mass emission limits
for various duct configurations of affected facilities; (b) the emissions
generated during bypass of an electrostatic precipitator during periods
of carbon monoxide (CO) trips, startups, and shutdowns; (c) monitoring
requirements; and (d) recordkeeping and reporting requirements.
6.1 VARIED EXHAUST GAS DUCTING CONFIGURATIONS
At some plants with facilities subject to the NSPS since 1979,
exhaust gas streams are ducted from one facility through another facility
prior to a control device. Exhaust gases can also be split among several
control devices. Enforcement personnel expressed concern that either of
these configurations can result in redistribution of particulate matter
emissions.
In 13 cases, plants are ducting the kiln or clinker cooler exhaust
gases through additional facilities prior to the emission control equip-
ment and stack. Hot exhaust gases from the kiln, the preheater, or the
clinker cooler may be ducted through the raw mill. These gases allow
the raw mill to dry the raw materials in addition to crushing and
classifying them. This preheating is a recent development to improve
productivity and fuel efficiency.1
Seven plants currently duct kiln exhaust gases through the raw
mill, and one of the plants under construction also plans to duct kiln
exhaust gases through the raw mill. In all seven cases, particulate
mass emissions are below the kiln NSPS limit of 0.15 kg/Mg (0.30 Ib/ton).
One plant with combined kiln and clinker cooler emissions is in compliance
with the kiln NSPS and also with the more stringent clinker cooler NSPS
of 0.05 kg/Mg (0.10 Ib/ton). Three plants combine kiln, clinker cooler,
and raw mill or raw mill dryer emissions; all three of these plants are
in compliance with the kiln NSPS. At one of two plants with combined
clinker cooler and raw mill exhaust gases, emissions are below the
clinker cooler NSPS limit. The second plant exceeds the NSPS limit.
This is a uniquely designed plant, and, at the time of testing, process
conditions were not representative of normal operating conditions.2 The
clinker cooler will be retested under normal operating conditions.
6-1
-------
In other cases, plants are splitting exhaust gases from the kiln or
the clinker cooler. For example, exhaust gases from a dry process kiln
are often split to allow part of the gases to travel through a preheater
and/or a raw mill and part to bypass these facilities. Such a bypass
system reduces buildup of alkalies and sulfates from the exhaust gases
onto the raw feed. Emissions from the bypass may be recombined with the
preheater or raw mill gases prior to a control device or may be controlled
by a separate control device. In the latter case, the particulate mass
emissions from the main stack and bypass stack should be added to obtain
total kiln emissions.
6.2 BYPASS OF ELECTROSTATIC PRECIPITATORS
Air pollution control agency personnel from several States expressed
concern that excess particulate emissions from kilns controlled by
electrostatic precipitators were occurring during bypass of the control
device because of a CO trip (see 4.1.1.2). These CO trips of electro-
static precipitators typically are treated as malfunctions of the control
device.
After a kiln system has achieved smooth, normal operation, some CO
trips may still occur, although infrequently. These CO trips may be
caused by one or more of the following reasons: malfunction of equipment
ahead of the ESP, poor maintenance, or operator error. Malfunctioning
equipment could include the kiln, fans, preheater (plugups), coal mill,
and gas analysis equipment. Poor maintenance will cause all system
conditions to deteriorate with time. There may also be improper actions
or reactions by the operator that contribute to CO trips.
Electrostatic precipitators may also be bypassed during startup and
shutdown of the kiln due to increased combustibles in the flue gases.
Emissions during startup, shutdown, and malfunctions are not considered
representative for the purpose of demonstrating compliance with the
NSPS, and emissions in excess of the applicable emission limit during
startup, shutdown, and malfunctions are not considered a violation
unless otherwise specified in the applicable standard. However,
Section 60.11(d) of the General Provisions requires that "[a]t all
times, including periods of startup, shutdown, and malfunction, owners
and operators shall, to the extent practicable, maintain and operate any
affected facility including associated air pollution control equipment
in a manner consistent with good air pollution engineering control
practice for minimizing emissions."
6.2.1 CO Trips
Information gathered during this review from plant personnel and
equipment vendors concerning operation and maintenance of electrostatic
precipitators controlling cement kilns is presented below.
As shown in Table 4-3, the frequency of CO trips of electrostatic
precipitators can range from a few times a year to over 600 times a
year. Assuming 7,200 hours per year of operation and 23 kg/Mg
6-2
-------
(45 Ib/ton) of uncontrolled emissions (i.e., cyclone control only),
annual particulate emissions during CO trips can vary from 0.21 Mg/yr
(0.23 ton/yr) for one CO trip of 4-minutes1 duration to 390 Mg/yr
(430 tons/yr) for 600 trips of average 11-minutes1 duration.
Electrostatic precipitator vendors and plant operators indicate
that, if process, control, and monitoring equipment are properly designed,
operated, and maintained, CO trips of the precipitator should be infre-
quent.3-7 Short CO increases, or CO spikes, can be disregarded or
eliminated, and proper attention to complete fuel combustion can minimize
the number of extended CO increases that necessitate de-energization of
the electrostatic precipitator to ensure safety of the control equipment.
Several equipment vendors noted that one or two CO trips per month is an
average frequency for a properly operated kiln.5,7 Each CO trip would
average about 3 minutes.7 Another source stated that a electrostatic
precipitator could be operated to reduce CO trips to three or four
occurrences per year.8
As described in the following sections, the use of continuous com-
bustibles monitors with time delay trips and careful attention to the
coal metering system and general process operation should minimize
unpreventable CO trips.
6.2.1.1 Continuous Monitor
6.2.1.1.1 Type, number, and location of monitor. Continuous
monitors can be installed to measure oxygen, carbon monoxide, or com-
bustibles in the gas stream entering the electrostatic precipitator.9
Combustibles monitors are especially advantageous because they monitor
CO as well as methane gas.8,10 At new plants in the cement industry,
continuous monitors are typically installed at three locations: one at
the kiln exit, one at the outlet to the third-stage preheater cyclone,
and one at the outlet to the first-stage preheater cyclone. Gases
extracted from these locations are cooled and cleaned prior to analysis.9
This conditioning causes a delay of 30 seconds to 2 minutes from the
time of sample extraction until the data are available to the kiln
operator.11 Because the most common increase in kiln combustibles is a
CO spike, which lasts less than 30 seconds, the monitor delay usually
allows the potentially explosive combustibles to exit the stack before
the recorder registers the event.12 De-energization of the electrostatic
precipitator in these cases is too late to be effective and, thus,
serves no purpose.4
In situ continuous monitors require no time to condition the gases
and, therefore, instantaneously register CO or combustibles levels.8,11
Such monitors cannot be used where high temperatures or dust loadings
are present, and would be most useful, therefore, for monitoring exhaust
gases at the outlet of the electrostatic precipitator.10,13 Monitors
that require conditioning of the gases would probably be used in
conjunction with in situ monitors.
6-3
-------
Monitors located at the first-stage preheater outlet, the electro-
static precipitator inlet, or the precipitator outlet may receive a
lower level of combustibles than those at earlier process locations.
Conditions prior to the ESP are most likely to cause CO trips.13 Monitors
at the earlier locations can reduce the chance that the electrostatic
precipitator will be de-energized because of a CO spike. The monitor at
the kiln exit is most commonly used only for information purposes because
of maintenance problems with the extractive probe.13 One vendor indicated
that, in some cases, plants de-energize the electrostatic precipitator
only when two or three monitors indicate that de-energization is
appropriate.10
6.2.1.1.2 Trip and alarm levels. As reported in Chapter 4
(Table 4-3), the uu trip level for electrostatic precipitators varies
from 0.2 to 5 percent combustibles or CO. Alarms, which warn the kiln
operator that the level of combustibles is approaching the trip level,
are often set at levels that range from 0.2 to 2 percent combustibles or
CO. Three electrostatic precipitator vendors believe that an alarm is
appropriate and should be set to go off from 0.2 to 0.5 percent
combustibles or CO.10,14,15 They state that the CO trip level should be
set from 0.7 to 2 percent combustibles or CO.10,14,15 Further, time
delays can be incorporated into the monitor so that instantaneous CO
spikes are disregarded and only an extended CO increase can de-energize
the electrostatic precipitator.15 For all types of monitors, including
in situ monitors, such time delay trips could be designed. For example,
a monitor that records the combustible level once per minute could be
programmed to de-energize the electrostatic precipitator only after
receiving 2 to 5 consecutive readings above the trip level (thereby
allowing a 1 to 4 minute trip delay). The electrostatic precipitator
would, thus, only be de-energized for these extended increases in com-
bustibles, i.e., those that risk the safe operation of the precipitator.
One electrostatic precipitator vendor stated that even a 4-minute delay
would not endanger the electrostatic precipitator.16
Some plants incorporate time delays of about 2 minutes before
re-energizing the electrostatic precipitator after corrective action has
been taken to ensure that the problem has been solved. Other plants
re-energize the electrostatic precipitator immediately (within about
5 seconds).17
6.2.1.2 Coal Metering System. The method by which coal is fired
both in the kiln and in the precalciner can affect CO trips. Coal can
be fired by the direct or the indirect method. In a direct-fired system,
coal is conveyed directly from the coal mill to the kiln; this is the
system generally used in the cement industry.18 In an indirect-fired
system, coal is stored in bins between the mill and the kiln. Because
the coal is not stored in a direct-fired system, no combustible gases
can accumulate in the system. Coal irregularities (particle size,
moisture) or disturbances in coal feeding and conveying (surges), how-
ever, are translated immediately into the kiln, potentially resulting in
incomplete combustion.18 Although indirect coal firing generally allows
more consistent fuel conveying, precipitator vendors state that proper
6-4
-------
coal metering can be accomplished with both direct and indirect coal-fired
systems.10,15
6.2.1.3 General Process Operation. The ultimate causes of CO
trips are process upsets upstream of the electrostatic precipitator.
For this reason, experienced personnel that are well trained in standard
procedures for operation and maintenance are essential to provide kiln
operation that eliminates unnecessary CO increases and to ensure prudent
use of monitor information in deciding which CO increases necessitate
de-energization. Plant personnel can make process modifications as
necessary to minimize these trips and should maintain the required
equipment (e.g., parts for the combustibles analyzer).10
Increases in combustibles that necessitate de-energization of the
electrostatic precipitator are the result of hours of improper kiln
operation, not of an instantaneous process event. One vendor states
that every electrostatic precipitator fire he has examined has been the
result of 24 to 48 hours of kiln maloperation with no operational
combustibles analyzer present.10 No electrostatic precipitator fires
observed by the vendor have been caused by an instantaneous CO spike.10
Another vendor noted that environmental regulations in Europe
require that the raw feed to the kiln and the raw material drying and
grinding systems be interlocked with the high voltage supply of the
electrostatic precipitator.19 This ensures shutdown of air flow and
feed to the raw mill and kiln during a CO trip.19 Although the kiln may
continue to rotate, emissions would be significantly less than during
full operation. Such an interlock system could provide strong incentive
for plant personnel to minimize the number of CO trips.19
6.2.2 Kiln Startup and Shutdown
Electrostatic precipitator vendors and plant operators state that,
because of improved process control and advancements in microprocessor
control, it is now normal practice for new electrostatic precipitators
to start up and shut down concurrent with the kiln induced draft fan.20-23
Startup of a large "cold" precalciner kiln can take from 20 to 36 hours
depending on the type of refractory brick installed in the kiln.19 In
the first few hours, a low flame is used to cure and dry the refractory,
no induced draft fan is used (natural draft is sufficient), no raw
material is fed to the kiln, and the kiln is occasionally turned for
about one-third of its circumference to ensure consistent warming.21
When the refractory is heated, the temperature can be raised; therefore,
more fuel is added, and the induced draft fan is turned on to provide
more oxygen.21 At this point, the electrostatic precipitator is often
energized because the draft will stir dust in the kiln, causing emissions.
Feed to the kiln is begun at some later point when the necessary
temperature has been reached.21
Most modern kilns start up on oil or gas because a stable flame is
easier to maintain with these fuels and because the coal is often dried
6-5
-------
by kiln or clinker cooler exhaust gases.21 Therefore, the coal mill is
turned on only after the kiln produces sufficient heat to dry the coal.21
Plant personnel also note that if kiln oxygen levels are kept above
4 percent until the kiln is near full production and at normal temperature
levels, complete combustion is better assured.21 High oxygen levels are
not economical for general kiln operation, however.21
6.3 CONTINUOUS OPACITY MONITORS
The current NSPS do not require continuous monitoring of visible
emissions. EPA Reference Method 9 is used to assess compliance with the
visible emissions limit.
Continuous opacity monitors can automatically alert facility personnel
to a control device problem, thereby facilitating prompt repair of the
device. Continuous opacity monitors are effective in all weather condi-
tions and at night. At least 13 of the 28 plants that have become
subject to the NSPS since the 1979 review have installed continuous
opacity monitors because of State requirements.
Continuous opacity monitors work well on all types of control
devices where flue gases are exhausted to the atmosphere through a
single stack. A single continuous opacity monitor may not, however,
measure accurately the opacity of visible emissions from the multiple
stacks or monovents associated with some positive-pressure fabric filters
or the multiple stacks associated with some negative-pressure fabric
filters.24 One kiln and one clinker cooler that have become subject to
the standard since 1979 are controlled by positive-pressure fabric
filters. In both cases, however, the fabric filters are vented to a
single stack. One company in this industry is known to use negative-
pressure fabric filters with multiple stacks at two of its plants that
have become subject to the NSPS since 1979.
6.4 RECORDKEEPING AND REPORTING REQUIREMENTS
Performance test results for affected facilities must be reported
to the EPA within 60 days after achieving maximum production but no
later than 180 days after startup of the facility. The Portland Cement
Association, plant personnel, and personnel at one State pollution
control agency indicated that this time allowance is too short.25-28
Personnel at one plant noted that they could not correct all the
mechanical, electrical, and physical problems involved with startup of
their entire new plant within 180 days.26 Personnel at another plant
stated that optimal operating settings for a fabric filter cannot be
developed until all process systems are stabilized and that testing
before this time gives results that are not indicative of the normal
operation of the control equipment.27
6-6
-------
6.5 REFERENCES FOR CHAPTER 6
' 1. Portland Cement Association. The U. S. Cement Industry: An Economic
Report. Skokie, Illinois. January 1984. pp. 6, 8.
2. Telecon. Clark, C., MRI, to Clouse, J. , Colorado Air Pollution
Control Division. October 13, 1983. Discussion of cement plants
in Colorado.
3. Comments presented by Orem, S., Industrial Gas Cleaning Institute,
to the National Air Pollution Control Techniques Advisory Committee.
August 30, 1984. Response to the review of NSPS for portland
cement plants, p. 1.
4. Comments and attachments presented by Brown, R., Environmental
Elements Corp., to the National Air Pollution Control Techniques
Advisory Committee. August 30, 1984. Response to the NSPS for
Portland cement plants, p. 4, 5.
5. Comments presented by von Seebach, M., Polysius Corp., to the
National Air Pollution Control Techniques Advisory Committee.
August 30, 1984. Response to the NSPS for portland cement plants.
p. 3.
6. Letter from Lotz, W., Lehigh Portland Cement Company, to Farmer, J.,
EPA/OAQPS. September 6, 1984. Transmitting summary of comments
presented to the National Air Pollution Control Techniques Advisory
Committee on August 30, 1984. p. 3.
7. Letter from Riley, J., Lurgi Corp., to Farmer, J., EPA/OAQPS.
August 31, 1984. Transmitting summary of comments to have been
presented to the National Air Pollution Control Techniques Advisory
Committee on August 30, 1984. p. 1.
8. Telecon. Clark, C., MRI, with Hawks, R., PEDCo Environmental, Inc.
August 22, 1984. Discussion of CO trips, startup, and shutdown of
an electrostatic precipitator.
9. PEDCo Environmental, Inc. Technical Assistance to the State of
Iowa--Excess Emissions at Lehigh Cement, Mason City, Iowa. Prepared
for U. S. Environmental Protection Agency. February 1984. p. 27.
10. Telecon. Clark, C. , MRI, with Brown, R., Environmental Elements
Corp. September 14, 1984. Discussion of techniques to minimize CO
trips of electrostatic precipitators.
11. Reference 9, p. 31, 61.
12. Reference 9, p. 95.
13. Reference 9, p. 31.
6-7
-------
14. Telecon. Clark, C., MRI, with von Seebach, M., Polysius Corp.
September 14, 1984. Discussion of techniques to minimize CO trips
of electrostatic precipitators.
15. Telecon. Clark, C., MRI, with Prior, 0., F. L Smith and Company.
October 2, 1984. Discussion of CO trip levels.
16. Telecon. Clark, C., MRI, with Brown, R., Environmental Elements
Corp. October 2, 1984. Discussion of time delays for CO trips.
17. Reference 9, p. 63.
18. Reference 9, p. 20-23, 61.
19. Reference 5, p. 3, 4.
20. Reference 4, p. 5, 7-9.
21. Reference 6, p. 2.
22. Letter from Greer, W., Lone Star Industries, Inc., to Cuffe, S. ,
EPA/ISB. June 22, 1984. Response to request for comments on the
draft review document, p. 5.
23. Letter from Schneeberger, C., Portland Cement Association, to
Cuffe, S., EPA/ISB. August 29, 1984. Comments on draft review
document and Advanced Notice of Proposed Rulemaking for the review
of standards for portland cement plants, p. 3.
24. U. S. Environmental Protection Agency. Electric Arc Furnaces and
Argon-Oxygen Decarburization Vessels in Steel Industry—Background
Information for Proposed Revisions to Standards. Draft EIS.
Publication No. EPA-450/3-82-020a. July 1983. pp. D-18 to D-20.
25. Reference 23, p. 10.
26. Letter and attachments from Gebhardt, R., Lehigh Portland Cement
Company, to Farmer, J. , EPA/OAQPS. January 6, 1984. Response to
Section 114 information request, p. 13.
27. Letters and attachments from Powledge, H., Ideal Basic Industries,
Inc., to Farmer, J., EPA/OAQPS. December 30, 1983. Response to
Section 114 information request, p. 5.
28. Telecon. Clark, C., MRI, with Gore, R., Alabama Department of
Environmental Management. September 29, 1983. Discussion of
cement plants in the State of Alabama.
6-8
-------
APPENDIX A
SUMMARY OF PORTLAND CEMENT FACILITIES SUBJECT TO NSPS
A-l
-------
TABLE A-l. SUMMARY OF PORTLAND CEMENT FACILITIES SUBJECT TO NSPS
PLANT DATA
Name/ local ion
tPA Region 11
Moore McCormack
Cement, Inc.
Glens Falls Portland Cement
313 Warren St.
Glens Falls, N.Y. 12801
San Juan Cement
GPO Box 2888
San Juan, Puerlo Rico
LPA Region III
Coplay Cemenl Manufacturing Co.6
Nazareth, Pa. 18064
General Portland, Inc.
Whitehall Cement
Whitehall, Pa. 18052
Lone Star Industries, Inc.6
P.O. Box 27
Cloverddle, Va. 24077
(Roanoke, Va. )
LPA Region IV
General Portland, Inc.6
(formerly Citadel Cement Corp.)
Arcola Rd.
KILN DATA
lota) cement
capacity
Kiln year
fuel/%S wet or dry
450
Coal
Oil (coal by
end of 1983)
1,095
Coal
800
Coal
(No. 1, No. 2 kiln)
Oil
(No. 3 kiln)
1,200
Coal
1.28
750
Coal
1973-D
1967-W
1967-W
1975-W
1978-D
1956-D
1965-0
1975-D ,
1951-D
1951-D
1953-D
1956-D
1976-D
1977-D
Clinker^ Preheater/
capacity precalciner
543
972
174
333
257
140
140
140
140
540
708
ft Neither
M Preheater
u Precalciner
M Neither
o Preheater
n Precalciner
u Neither
M Preheater
n Precalciner
u Neither
M Preheater
n Precalciner
(All kilns)
u Neither
M Preheater
u Precalciner
(1976 kiln only)
n Neither
M Preheater
n Precalciner
DATA ON FACILITIES SUBJECT TO NSPS
Facilities
subject
to NSPS
Kiln
Cooler
Kiln
Cooler
Mills
Storage
Kiln
Cooler
Mills
Storage
Transfer
Kiln
Kiln
Cooler
Kiln
Cooler
Reason-
N, M, RV
date
N-1973
N-1973
N-1975
N-1975
N-1975
M-Conveyors
N-1978
N- 1978
N-1978
N-1978
N-1978
N-1975
N-1976
N-1976
N-1977
N-1977
Control .
equipment
ESP
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF(O
ESP
ESP
FF
(continued)
-------
TABLE A-l. (continued)
PLANT DATA
Name/location
EPA Region IV (continued)
Ideal Basic Industries, Inc.a
Theodore Industrial Park
Theodore, Ala. 36582
Lehigh Portland Cement Co.6'9
(formerly Universal Atlas Cement)
800 Second Ave.
Leeds, Ala. 35094
j. National Cement Co.6
i Highway 144
00 Ragland, Ala. 35131
Moore McCorroack Cement, Inc.e
Florida Mining and Materials
605 W. Broad St.
Brooksville, Fla. 33512
Lone Star Industries, Inc.6
(formerly Maule Industries, Inc )
Hialeah, Fla. 33012
Medusa Cement Company6
Clinchfield, Ga. 31013
Total cement
capacity3
fuel/%S
2,365
Coal
1.5
600
Coal
800
Coal
1,200
Coal
1.04
1,200
Coal , gas
790
Coal
Low sulfur
KILN
Ki In year
wet or dry
1981-D
1976-D
1976-D
1975-0
1982-D ,
1970-W
1970-W
1975-W
1961-W
1974-D
DATA
Clinker-
capacity
1,415
558
804
560
560
231
231
752
193
546
DAIA ON FACII ITIFS SIIR.IFf
Preheater/
precalciner
Q Neither
M Preheater
W Precalciner
n Neither
M Preheater
o Precalciner
u Neither
M Preheater
M Precalciner
n Neither
on Preheater
Q Precalciner
(both kilns)
M Neither
ci Preheater
a Precalciner
Q Neither
os Preheater
n Precalciner
(1974 kiln)
Faci 1 ities
subject
to NSPS
Kiln
Cooler
2 raw mi 1 1
dryers
Raw mill
Finish mill
Storage
Transfer
Kiln
Cooler
Mills
Storage
Transfer
Kiln
Cooler
Storage
Kiln
Kiln
Cooler
Cooler
Mills
Storage
Transfer
Kiln
Cooler
Kiln
Cooler
Reason:
N, M, R /
date
N-1981)
N-1981 >
N-1981)
N-1981
N-1981
N-1981
N-1981
N-1976
N-1976
N-1976
N-1976
N-1976
N-1976
N-1976
N-1975
N-1982
N-1975
N-1982
N-1975
N-1975
N-1975
N-1975
N-1975
N-1974
N-1974
'T TO NSPS
Control
equipment
FF(-)
FF(-)
FF(-)
FF(-)
FF(-)
ESP
Gravel bed
ESP
Gravel bed
FF(-)
FF(-)
FF(-)
FF(-)
FF(-)
FF(-)
FF(-)
ESP
FF
FF(79)
(continued)
-------
TABLE A-l. (continued)
PLANT DATA
Name/location
EPA Region IV (continued)
Moore McCormack Cement, Inc.c
(formerly Flintkote Co.)
Kosmos Cement Co.
Kosmobdale, Ky. 40272
Texas Industries, Inc.6
United Cement
Artesia, Miss 39/36
Giant Portland Cement Co.e
P.O. Box 218
Hdrleyville, S.C. 29448
Giffot'd-Hill & Company, Inc.e
P.O. Box 326
Harleyville, S.C. 29448
Dundee Cement Co.e
Santee Portland Cement
Hwy. 453 South
Holly Hill, S.C. 29059
Moore McCormack Cement, Inc.
Dixie Cement Co. (formerly Ideal
Basic Industries, Inc.)^
Knoxvil le, Tenn. 37914
KILN DATA
Total cement
capacity
fuelTts
660
Coal
0.6-0.8
525
Coal
1.0
855
Coal
650
Coal
1,700
Coal
750
Coal
1.5
Kiln year
wet or dry
19/4-0
1974-W
1952-W
1957-W
1960-W
1974-W
1974-D
1966-W
1972-W
19/9-D
Clinker^ Preheater/
capacity precalciner
651 11 Neither
M Preheater
o Precalciner
456 Hi Neither
o Preheater
o Precalciner
200 M Neither
185 ci Preheater
185 o Precalciner
200
551 a Neither
M Preheater
a Precalciner
363 M Neither
693 n Preheater
o Precalciner
512 u Neither
M Preheater
B Precalciner
DATA ON FACILITIES SlIR.lFrT TO NSPS
Facilities
subject
to NSPS
Kiln
Cooler
Finish mill
Raw blending
silo
Transfer
Kiln
Cooler
Mills
Storage
Transfer
Kiln
Cooler
Kiln
Dryer
Cooler
Mills
Storage
Transfer
Kiln
Cooler
Kiln
Coo lei-
Raw m i 1 1
Finish mi 1 1
Reason-
N, M, RC/
date
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974
N-1974)
N-1974)
N-1974
N-1974
N-1974
N-1974
N-1972
N-1972
N-1979
N-1979
N-1974
N-1975
Control .
equipment
ESP
FF
FF
FF
FF
ESP
Wet scrub-
ber
FF( + )
FF( + )
FF( + )
FF
FF
FF
Ff
ESP
Fl
FF(-)
FF(-)
FF
FF
(continued)
-------
TABLE A-l. (continued)
PLANT DATA
Name/loration
EPA Region V
Centex Corp.
Illinois Cement Co.
P.O. Box 442
LaSalle, 111. 61301
Missouri Portland Cement Co.e
Joppa, 111. 62953
Lehigh Portland Cement Co.e
Mitchell, Ind. 47446
Louisville Cement Co.e
Speed, Ind. 47172
National Gypsum Co.6
Huron Cement
Alpena, Mich. 49707
Columbia Cement Co. (Ashland Oil)
P.O. Box 1531
Zanesville, Ohio 43701
Southwestern Portland Cement Co.e
Fairborn, Ohio 45324
KILN DATA
Total cement
capacity
fuel/%S
380
Coal
2.0
1,314
Coal
2-2.5
725
Coal
1,094
Coal
2,450
Coal
3
700
Coal
730
Coal
Kiln year
wet or dry
1974-D
1963-D
1975-D
1960-D
1960-D
1976-D
1973-D
1977-D
1962-D
1965-D
1965-0
1975-D
1975-D
1955-W
1963-W
1955-W
1974-0
Clinker.
capacity
428
544
672
248
248
264
331
602
318
318
318
508
508
241
360
124
569
Preheater/
precalciner
n Neither
M Preheater
D Precalciner
a Neither
a Preheater
n Precalciner
(1975 kiln)
a Neither
a Preheater
D Precalciner
(1976 kiln)
a Neither
a Preheater
D Precalciner
(1977 kiln)
a Neither
n Preheater
o Precalciner
a Neither
n Preheater
D Precalciner
n Neither
a Preheater
D Precalciner
DATA ON FACILITIES SUBJECT TO NSPS
Facilities
subject
to NSPS
Kiln
Cooler
Mills
Storage
Transfer
Kiln
Cooler
Mills
Storage
Transfer
Kiln
Cooler
Kiln
Cooler
Kiln
Cooler
Mortar kiln
Kiln
Kiln
Cooler
Cooler
Finish mill
Kiln
Cooler
Reason:
N, M, RV
date
N-1974
N-1974
N-1974
N-1974
N-1974
N-1975
N-1975
N-1975
N-1975
N-1975
N-1976
N-1976
N-1973
N-1973
N-1977
N-1977
N->1971
N-1975
N-1975
N
N
N-1978
N-1974
N-1974
Control .
equipment
FF(-).
FF(-)h
FF(-)
FF(-)
FF(-)
ESP .
FF(-)1
FF(-)
FF(-)
FF(-)
ESP
FF(-)
ESP
FF(-)
ESP
FF(-)
ESP
FF
FF
FF
FF
ESP
FF(+)
(continued)
-------
TABLE A-l. (continued)
cr>
PLANT DATA
Name/location
EPA Region VI
Lone Star Industries, Inc.
(formerly OKC Cement)
Louisiana Cement Division
New Orleans, La. 70129
Ideal Basic Industries, Inc.
Tijeras, N.M. 87059
Lone Star Industries, Inc.®
Oklahoma Cement
9250 Amberton Pkwy.
Pryor, Okla. 74361
Alamo Cement Co."
5675 FM 1604 NE
San Antonio, Tex. 78233
Capitol Aggregates, Inc.
Capitol Cement
Nacigdiches at Bulve
San Antonio, Tex. 78233
Centex Corp.e
Texas Cement Co.
Buda, Tex. 78610
KILN DATA
Total cement
capacity
fuel/%S
750
Coal
<0.7
660
Coal
725
Coal
3-4
600
Coal /coke
1.5-coal
3.9-coke
800
Coal /coke
3.35
si ,300
Coal
Kiln year
wet or dry
1964-W
1974-W
1959-D
1960-D
1961-D
1962-D
1979-D
1981-0
1965-W
1983-D
1978-D
1983-D
Clinker.
capacity
347
347
237
237
205
205
267
523
338
500
468
=468
Preheater/
precalciner
a Neither
n Preheater
D Precalciner
a Neither
S> Preheater
D Precalciner
(Both kilns)
a Neither
n Preheater
a Precalciner
a Neither
a Preheater
a Precalciner
B Neither (wet)
a Preheater
a Precalciner
(PH, PC- 1983
kiln)
a Neither
B Preheater
a Precalciner
PH-1978 kiln
PH.PC-1983 kiln
DATA ON FACILITIES SUBJECT TO NSPS
Facilities
subject
to NSPS
Kiln
Cooler
Transfer
Finish mill
Kiln
Cooler
Kiln
Cooler
Raw mi 1 1
Storage
Transfer
Kiln
Cooler
Raw mill
Coal/coke
transfer
Storage
Transfer
Kiln
Raw mill
Cooler
Mill
Storage
Transfer
Kiln
Raw mill
Reasoni
N, M, RV
date
N->1974
N->1974
N->1974
N->1979
N-1979
N-1979
N-1981
N-1981
N-3981
N-1981
N-1981
N-1983
N-1983
N-1983
N-1983
N-1983
N-1983
N-1978
N-1978
N-1978
N-1978
N-1978
N-1978
N-1983
N-1983
Control .
equipment
ESP
FF
FF
Gravel bed
ESP
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF
FF
— _ _,, _-
-------
TABLE A-l. (continued)
PLANT DATA
Name/location
LPA Region VI (continued)
General Portland, Inc.
Wald Rd. & Solms Rd.
New Braunfels, Tex. 78130
(Balcones, Tex. )
Gulf Coast Portland Cement Co.
6203 Industrial Way
Houston, Tex. 77011
e f
Kaiser Cement Corp. '
P. 0. Box 34210
San Antonio, Tex. 78265
lone Star Industries, Inc.
Jet. FM 608 FM 1170
Maryneal, Tex. 79556
Southwestern Portland Cement Co.
Bushland, Tex. (Amarillo, Tex.)
Southwestern Portland Cement Co.
Odessa, Tex. 79760
lexas Industries, Inc.a
8100 Carpenter Frwy
Hunter, Tex. 78130
Texas Industries, Inc.
Midlothian, Tex. 76065
-
KILN DATA
Total cement
capacity
fuel/%S
925
Coal
940
Coal
490
Coal
1.0
545
Coal
242
Coal
550
Coal
0.5
840
Coal
1.2
1,400
Coal
Kiln year
wet or dry
1980-D
1961-W
1975-D
1951-D
1951-D
1953-D
1963-W
1958-D
1978-D
1980-0
1960-W
1963-W
1967-W
1972-W
Clinker.
capacity
875
333
775
151
151
243
230
248
279
664
304
304
304
304
Preheater/
precalciner
u Neither
M Preheater
S) Precalciner
M Neither
n Preheater
o Precalciner
D Neither
M Preheater
M Precalciner
(2nd PC added
LI Neither
M Preheater
Q Precalciner
(All kilns)
M Neither
n Preheater
n Precalciner
H Neither
M Preheater
n Precalciner
(1978 kiln)
n Neither
M Preheater
a Precalciner
W Neither
u Preheater
N Precalciner
DATA ON FACILITIES SUBJEC1
Faci lities
subject
to NSPS
Kiln
Raw mill
Cooler
Finish mil 1
Storage
Transfer
Finish mill
Finish mill
Storage
Kiln
Cooler
1979) Finish mill
Coal transfer
Coal storage
Coal transfer
Kiln
Coal storage
Coal transfer
Kiln
Cooler
Mills
Storage
Transfer
Finish mi 1 1
Transfer
Reason:
N, M, RV
date
N-1980)
N-1980/
N-1980
N-1980
N-1980
N-1980
N-1973
N-1978
N-1978
N-1975
N-1975, 1979
N-1979
N-1979
N-1981
N-1981
N-1978
N-1982
N-1982
N-1980
N-1980
N-1980
N-1980
N-1980
N-1979
N-1979
TO NSPS
Control £|
equipment
2 LSP's
Gravel bed
FF
FF
FF
FF
FF
FF
3 ESP's
FF (AB)
FF
FF
FF
FF
FF
FF
FF
K
ESP
FF
FF
FF
FF
ESP
FF
TcontiiuiedJ
-------
TABLE A-l. (continued)
oo
PLANT DATA
Name/location
EPA Region VII
Davenport Industries
Davenport Cement
Buffalo, Iowa 52808
(Scott City, Iowa)
Lehigh Portland Cement Co.
Mason City, Iowa 50401
Northwestern States Portland Cement Co.e
N. Federal 17th St.
Mason City, Iowa 50401
Monarch Cement Co.
Humboldt, Kans. 66748
Lone Star Industries, Inc.^
Marquette Cement Co.
Box 520
Cape Girardeau, Mo. 63701
River Cement Co.
Festus, Mo. 63028
Ash Grove Cement Co.e
Louisville, Nebr. 68037
KILN DATA
Total cemegt
capacity
fuel/%S
850
Coal
750
Coal
1,150
Coal
600
Gas
1,200
Coal
3.0
1,060
Coal
790
Coal
0.9
Kiln year
wet or dry
1981-D
1958-D
1979-D
1960-D
1966-D
1976-0
1972-D
1974-D
1975-0
1981-D
1965-D
1969-D
1975-D
1982-D
Clinker.
capacity
809
233
543
163
450
252
116
248
248
992
558
558
400
558
Preheater/
precalciner
n Neither
a Preheater
a Precalciner
D Neither
a Preheater
8 Precalciner
(1979 kiln only)
a Neither
a Preheater
D Precalciner
n Neither
N Preheater
n Precalciner
(1974, 1975
kilns)
a Neither
H Preheater
a Precalciner
a Neither
a Preheater
D Precalciner
a Neither
a Preheater
a Precalciner
(PH-1975 kiln)
(PC-1982 kiln)
DATA ON FACILITIES SUBJECT TO NSPS
Facilities
subject
to NSPS
Kiln
Raw mill
Cooler
Finish mill
Storage
Transfer
Kiln
Mill
Separators
Kiln
Cooler
Kiln
Cooler
Kiln
Cooler
Raw mill
Finish mill
Storage
Transfer
Raw mill
Kiln
Cooler
Kiln
Cooler
Reason-
N, M, RV
date
N-1981*
N-1981/
N-1981
N-1981
N-1981
N-1981
N-1979)
N-1980/
N-1980
N-1976
N-1976
N-1975
N-1975
N-1981
N- 19811
N-1981 /
N-1981
N-1981
N-1981
N>1979
N-1975
N-1975
N-1982
N-1982
Control d
equipment
FF
FF
FF
FF
FF
ESP
FF
FF
(1979)
FF
FF
ESP
2 FF's
FF
FF
FF
FF
ESP
FF(+)
ESP
FF(-)
-------
TABLE A-l. (continued)
PLANT DAI A
Name/ local ion
EPA Region VIII
Ideal Basic Industries, Inc.
Boettcher Plant
P.O. Box 2227
Ft. Collins, Colo. 80522
(La Porte, Colo.)
Ideal Basic Industries, Inc.6
Portland, Colo. 81226
Martin Marielta Corp. ^
P.O. Box 529
Lyons, Colo. 80540
South Dakota Cement Plant6
(State of South Dakota)
> P.O. Box 351
ua Rapid City, S.D. 57709
Lone Star Industries, Inc.6
Utah Portland Cement Co.
615 W. 8th South
Salt Lake City, Utah 84110
Martin Marietta Corp.9
P 0 Box 40
. Leamington, Utah 84648
Monolith Portland Cement Co f
P.O. Box 40
Ld ramie, Wyo. 82070
KILN DATA
Total cement
capacity
fuel AS
768
Coal
1,070
Coal
<1.0
405
Coal
0.52
1,100
Coal
Low sulfur
420
Coal , oil ,
gas
0.4-0.6
650
Coal
0.4-0.6
700
Coal
0.5-0.9
Kiln year
wet or dry
1981-D
1948-W
1948-W
1974-W
1979-0
1950-W
1956-W
1958-W
1978-0
1960-W .
1975-W
19/9-W
1982-D
1961-W
1981-W
Clinker.
capacity
440
184
184
480
405
151
151
151
503
120
150
150
603
200
300
Preheater/
precalciner
U Neither
M Preheater
o Precalciner
» Neither
a Preheater
fi Precalciner
Q Neither
8 Preheater
M Precalciner
n Neither
8 Preheater
Q Precalciner
(1978 kiln)
« Neither
o Preheater
a Precalciner
a Neither
M Preheater
M Precalciner
M Neither
n Preheater
n Precalciner
DATA ON FACIIITJF"; UlR.lFfT rn N<;P<;
Facilities
subject
to NSPS
Kiln
Cooler
Raw mill
Storage
Transfer
Kiln
Cooler
Mill
Storage
Kiln
Limestone
dryer
Kiln
Cooler
Kiln
Cooler
Kiln
Raw ra i 1 1
Cooler
Finish mill
Storage
Transfer
Kiln
Cooler
Finish mi) 1
Cement cooler
Reason-
N, M, Rc/
date
N-1981
N- 19811
N-1981/
N-1981
N-1981
N- 1974 1
N-1974/
N-1980
N-1979
N-1978
N-1978
N-1979
N-1979
N- 19821
N-1982/
N-1982
N-1982
N-1982
N-1982
N-1981
N-1981
N-1981
N-1981
Control .
equipment1
FF(0
FF(-)
FF
FF
LSP
FF
FF
FF(-)
FF(-)
FF(-)
FF(-)
FF(-)
FF(-)
FF
H
FF
FF
FF
tSP
FF(-)
FF(-)
FF(-)
(continuelT)
-------
TABLE A-l. (continued)
PLANT DATA
Name/location
EPA Region IX
California Portland Cement Co.a
SOC 24 TUN R1AW
Mojave, Calif. 93501
Genstat', Ltd.
Genstar Cement and Lime Co.
Redding, Calif. 96001
Genstar, Ltd.
Genstar Cement and Lime Co.
San Andreas, Cal if. 95249
Kaiser Cement Corp.9
CuslienLuiry Plant
Star Route Box 400
Lucerne Valley, Calif. 92356
Kaiber Cement Corp.9
Perraanente Plant
Permanente, Calif. 95014
Lone Star Industries, Inc.9
Davenport, Calif. 95017
(Santa Cruz, Calif. )
KILN DATA
lotal cement
capacity11
fuel/%S
1,700
Coal
0.53
600
Coal /wood
chips
2.0
770
Coal
0.6
1,600
Coal
1,600
Coal
<0.5
775
Coal
Ki In year
wet or dry
1955-D
1955-D
1981-D
1981-D
1945-w
1952-W
1956-W
1982-D
,
1981-D
J981-D
Clinker^ Preheater/
capacity precalciner
218 11 Neither
218 W Preheater
1,000 M Precalciner
(1981 kiln only)
571 cj Neither
M Preheater
M Precalciner
192 M Neither
192 a Preheater
192 u Precalciner
1,520 n Neither
M Preheater
a Precalciner
1,520 u Neither
w Preheater
W Precalciner
744 o Neither
M Preheater
M Precalciner
DATA ON FACILITIES SUBJECT TO NSPS
Facilities
subject
to NSPS
Kiln
Raw mill
Cooler
Storage
Transfer-
Kiln
Cooler
Raw mi 1 1
Kiln
Kiln
Kiln
Kiln
Raw mill
Cooler
Alkali bypass
Finish mill
Storage
Transfer
Kiln
Cooler
Mills
Storage
Transfer
Kiln
Raw mi 1 1
Cooler
Finish Mill
Raw feed silo
Transfer
Reason'
N, M, R /
date
N- 19811
N-1981/
N-1981
N-1981
N-1981
N-1981)
N-1981)
N-1981)
M-1975)
M-1975 >
M-1975)
N-1982)
N- 1982 (
N-1982)
N-1982
M-1982
N-1982
N-1981
N-1981
N-1981
N-1981
N-1981
N- 19811
N-1981)
N-1981
N-1981
N-1981
N-1981
Control .
equipment
FF(-)
FF(-)
FK-)
FF(-)
FE(-)
Multi-
cyclone/ESP
IF
FF
FF
FF
FF
FF(-)
FF(-)
FF(-)
FF(-)
FK-)
ESP
Gravel hed
FF(-)
FF(-)
FF(-)
"Tcontinued]
-------
TABLE A-l. (continued)
PLANT DATA
Name/location
EPA Region IX (continued)
Monolith Portland Cement Co.e
Monolith, Calif. 93548
(Kern, Calif. )
Southwestern Portland Cement
Victorville, Calif. 92392
Lone Star Industries, Inc.
Lone Star Hawaii Cement
Ewa Beach, Hi. 96706
EPA Region X
Alaska Basic Ind.
Anchorage, Alaska 99501
Oregon Portland Cement^
Durkee, Oreg. 97905
KILN DATA
Total cemegt
capacity
ftiel/%5
1,000
Coal
2.0
1,400
Coal
270
Coal
<1. 1
260
630
Coal
0.55
Ki In year
wet or dry
1974-w
1949-W
1953-W
1954-W
1955-W
1956-W
1965-0
1984-D
1972-0
GRINDING
1979-D
Clinkerb
capacity
518
• 78
124
124
124
124
574
800
257
ONLY
500
Preheater/
precalciner
a Neither
n Preheater
o Precalciner
D Neither
8 Preheater
M Precalciner
(1984 kiln only)
n Neither
H Preheater
D Precalciner
H Neither
n Preheater
a Precalciner
u Neither
ta Preheater
a Precalciner
DATA ON FACILITIES SUBJECT TO NSPS
Facil ities
subject
to NSPS
Kiln
Cooler
Finish mill
Storage
Loading
Ore conveyor
Kiln
Cooler
Mills
Storage
Transfer
Mill
Storage
Finish mil 1
Storage
Transfer
Kiln
Cooler
Finish mill
Raw mill
Storage
Transfer
Reason:
N, M, RV
date
N-1974
N-1974
N-1972
N-1974
N-1974
N-1974
N-1984
N-1984
N-1984
N-1984
N-1984
N->1979
N->1979
N-1982
N-1982
N-1982
N-1979)
N-1979)
N-1979
N-1979
N-1979
N-1979
Control .
equipment
FF
FF
FF
FF
FF
FF
FF
Gravel bed
FF
FF
FF
FF
FF
FF(-)
FF(-)
FF(-)
ESP
ESP
FF(-)
FF(-)
FF(-)
.1,000 short tons cement per year.
1,000 short tons clinker per year.
C,N = new facility, R = reconstructed facility, M = modified facility.
ESP = electrostatic precipitator; FF = fabric filter; (») = positive pressure; (-) = negative pressure;
gravel bed = gravel bed filter; AB = alkali bypass.
^Listed in the 1979 review of the NSPS for the portland cement industry.
Plants visited in 1983.
?Plants sent Section 114 information reguests in 1983
•Baghouse with heat exchanger.
'Baghouse with gravel bed filter.
-------
APPENDIX B
SUMMARY OF STATE REGULATIONS FOR PORTLAND CEMENT PLANT FACILITIES
B-l
-------
TABLE B-l. SUMMARY OF STATE REGULATIONS FOR PORTLAND CEMENT PLANT FACILITIES
03
I
n'A
Rpgion
1
11
111
State
Conn.
Me
Mass.
N.H.
R.I.
Vt.
N.J
N.Y
P.R.
Dela.
Md.
No. of
plants3
0/0
1/0
0/0
0/0
0/0
0/0
0/0
5/1
2/1
0/0
3/0
State regulation .
Nitrogen oxides Sulfur dioxide Particulate ' '
Regulations based Equation Set 1
on fuel type and
sulfur content of
fuel.
NAAQS' E = 0.024P0-665;
P < 100, 000 Ib/h
E = 0.05 gr/dscf;
P > 100, 000 Ib/h
After 12/31/80; NSPS
41,000 ppm E = 3.59P,0-62;
P = <30 tons/h
E = 4. IP0-67,
P = 30 tons/h
E = 55P°-"-40;
P >30 tons/h
<0 7 lb/106 NAAQS E = linear inter-
Btu polation from table;
Opacity0
4 20% except for 5 min
in any 60-min period;
or NSPS.
Existing plants 420%;
New plants 410% for 3
or more min during 60 min
period.
420% for 3 min or more
during 60 min period.
460% any time.
40% or 420%, depending
on area except for 6 min
Ai r pol 1 ution
regulation reference
Chapters 101; 105, 106;
December 22, 1982.
Part 220; March 16, 1973.
Sections 403, 40/, 412,
June 27, 1980.
litle 10; June 24, 1983.
Penn.
Va.
W. Va.
11/2
1/1
1/0
4500 ppm
42,000 ppm
42000 ppm
SO.05 gr/dscf or
E = 55po.11-40 for
P >30 ton/h.
K:£ = 6.23P0-12;
P = tons/h dry feed
CC:E = 3.93p°-4*;
P = tons/h product.
Equation set 2
0-99 )b/h for wet
cement processes.
0-21.2 Ib/h for dry
cement processes.
period in 60 min 440%;
or NSPS.
for 3 min or more
during 60 min period.
460% any time.
420% except for one
6-min period in any
hour not to exceed
60%; or NSPS.
420% except for one
2-min period in any
60-min period 440%.
0% for storage
structures.
Paragraphs 123 13, 123.21,
123.41, May 13, 1983
Rules EX 2, 4, 5; March 1.
1983
Regulations VII and X;
April 8, 1982.
ecll
-------
TABLE B-l. (continued)
CO
I
CO
EPA No. of
Region State plants3
IV Ala 5/4
Fla. 6/2
Ga 2/1
Ky. 1/1
Miss. 1/1
N.C. 0/0
S.C.f 3/3
Tenn. 2/1
V 111. 4/2
State regulation A
Nitrogen oxides Sulfur dioxide
Class 1 county:
a. 8 lb/106 Btu.
Class 11 county:
S4.0 lb/106 Btu
-
Ib/h limit based
on stack height.
<0.2-0.8 lb/106 Btu
<4.8 lb/106 Btu
or
Existing process:
<2,000 ppm
New process:
<500 ppm
'2.3 lb/106 Btu
NAAQS; cement
processes not
considered fuel
burning sources.
<4 lb/106 Btu;
<2,000 or <500 ppm
depending on
county.
<2,000 ppm.
Participate ' •
Class I county:
Equation Set 1.
Class II county:
Equation Set 2.
Equation Set lh
Equation Set 2
0.8-3.0 lb/106 Btu
Equation Set 2,
except equation 2B
for P = 30 tons/h.
Emissions SO. 437 lb/
barrel cement. 99 7%
efficiency of control
system.
For production rate
(R), in tons/h (each
kiln):
R = 10 E < 14
R = 15 E < 18
R = 20 E < 22
R = 25 E < 25
R = 30 E < 29
R = 50 E < 40
R = 60 E < 42
R - 80 E c 45
R = 100 E < 47
R = 120 E < 48
Equation Set 2
Equation Set 2, except
equation 2B for
P = 30 tons/h
Opacity0
S20% except for one
6-min period in any
60-min period not to
exceed 40%; or NSPS.
S20%, or NSPS.
S40% or NSPS.
Equation Set 1
(exception for plants
with heat exchangers).
S40%; or NSPS.
S40% except for 5 min
period in one hour.
$40% for existing
sources or S20% for
new sources.
NSPS for new
facilities.
Existing plants: S30%;
no period >60% for
8 min period during
1 hour and less than
3 times per day
New plants: S10%
Air pol lution
regulation reference
Chapters 4 and 5; March 23,
1982.
Part VI; July 1, 1983.
Chapter 391-3-1; August 27,
1982.
S20%; or NSPS
APC-S-1: Sections J, 4, 6;
December 8, 1982.
Title 15; Subchapter 20,
March 1, 1983.
Standard I, Standard III, and
Standard IV-Section 111.
June 24, 1983.
Chapter 1200-3-7, 1200-3-14,
March 2, 1983
Rules 203(b), 203(d), 204;
April 8, 1983.
(conlinueTn
-------
TABLE B-l. (continued)
tPA
Region State
Ind.
Mich
No of
plants
State legislation c_,j_e_
Nftrogen oxides Sulfur dToxide Participate ' '
4/2
'0 7 lb/10r'Btu '6 lb/101' Btu.
6/1
NAAQS; cement
processes not
considered fuel-
burning sources.
Prior to 12/6/68:
E - 8.6 P»-fi7
P < 30 tons/h
[ -- 15.0 P°-s"
P > 30 tons/h
After 12/6/83: Plant
specific or NSPS.
K: <0.25 lb/1,000 Ib
gas
CC. <0 30 lb/1,000 Ib
gas. ESP1s must have
automatic controller.
Opacity
Attainment areas:
540% in 6 mill average;
460% in 15 min average
Nonattainment areas:
J30% in 6 min average;
$60% in 15 min average.
$20% except: (a) $40%
for S3 min in 60 min
period no more than
3 times per 24 h,
(b) water vapor, or
(c) technologically and
economically not feasible.
An pel lution
requl.it inn reference
Article b. Rule 3, Section 2,
Article 5, Article /, June 15,
1983
General rules, Parts 3 & 4,
August 21, 1981
Minn
Ohio
00
I
-P"
0/0
6/2
<7 lb/10'1 Btu.
f = 0 !>51,
P ' 0.05 ton/h.
Equation Set 2;
P f 0.05 tons/h
S20% except for one
6-min average in any
60-min period not to
exceed 60% and except
for water vapor and
startup/shutdown/
incidents.
litle J/45-1/-11 Aiiqust 1,
1982
VI
Wis
Ark.
2/0
2/0
Ambient S02
levels: < 0.2 ppm
Specific for K and CC's
at existing plants.
Existing plants: S40%
except for 5 min period
in 60 min.
Sections 4, 7, 8; July 30,
1973
La.
N.M
Okla.
Tex.
1/1
1/1
3/1
<0 7 Ib/Btu.
20/11
52,000 ppm.
NAAQS.
Ambient concentra-
tion outside plant
property <0.52 ppm
for 5 min period,
<0.48 ppm for 1-h
period; <0.05 ppm
for 24 h period.
Ambient concentra-
tion <0.4 ppm for
any 30 min period.
Equation Set 2.
$230% mg/m:s (adopted
January 23, 1970).
Equation- Set 2.
E = 0.048 Qn-b2
Q = stack flow rate,
in acfm.
$20% except for 4 min
period in 60 min.
$20%.
$20% except for 5 mm
period in 60 min.
Existing plants: $30%
over 5 min period. New
plants after 1/31/72:
$20% over 5 min period.
Sections 19, 24; January 27,
1983.
Regulation 401, 'M?,
November 24, 1980
Regulations 3 I, 32, J 4,
3.5; Apiil 9, 1982
Regulation I, February 1, 1982;
Regulation II, March 4, 1981;
-------
TABLE B-l. (continued)
CO
en
tl'A Nn nf
Region jUU plants Nitrogen oxides Sulfur dioxide
VU Iowa 1/3 - <500ppm
Kans 9 5/1 - NAAQS
Mo 5/2 -- Ambient air.
<0 25 ppm for 1 h
except for once
in 4 days; and
<0.07 ppm for 24 h
except for once in
90 days; Existing
sources: ^2,000
ppm New sources:
<500 ppm
Nebr 2/1 - NAAQS
VUI Col°- 3/3 - / )b/lon of
material (in-
cluding fuel)
processed.
Mont- 2/° — Requirements on
sulfur content of
fuel .
N D. 0/0
s D- 1/1 " <3.0 lb/106 Btu.
Utah 3/2 -- NAAQS
Wyo 1/1 <0. 7 lb/106 Btu NAAQS.
... _. . _ . . ..
b
regulation ,
Particulate0'"78"
K. <0.1 gr/dscf and
$0.3 % of inlet mass
loading or NSPS.
Equation Set 2
Equation Set 2
Equation Set 2.
Equation Set 1
Equation Set 2.
Equation Set 2
Existing and new
facil ities same as
NSPS.
Equation Set 2.
— _ — =_:— ^-. — --._-=-_- r _ — __;
Opacityc
$40% or NSPS
$40% or NSPS.
120% for existing
sources or $10% for new
sources except for
6 min period in any
60 min not to exceed
60% or NSPS
$20% or NSPS.
520% or NSPS.
Facilities prior to
12/23/68: $40% for
6-tnin period.
Facilities after
12/23/68: S20% for
6-min period; or NSPS
Existing sources: $20%
except for one 3-min
period in 60-min period
not to exceed 60%;
New sources: 410% from
kiln and all other
affected facilities.
$20% or NSPS.
Existing sources: «40%
New sources: $20% or
NSPS.
_=_ ,_ _ .
Air pol lut ion
regulation leference
Chapter 4 November 17, 1982.
Title 28, Part 3, May 1, 1983
Title 10: 10CSR 10-2 060;
10 CSR 10-2.160, 10 CSR
10-3 050, 10 C',R 10-3.080;
May 12, 1983
Rules 4, 5, 9, and 13;
August 6, 1982.
Part 1, Common Provision
Regulations 11, 111, VI,
July 1, 1983.
Rules 16 8. 1403, 16.8:1404,
16.8.1411, September 30, 1982.
Chapter 74.26:06-
Chapter 74 26-07,
Chapter 74:26:12
March 18, 1982
Parts 111 and IV, July 29,
1982
Sections 4, 10, 14; August 26
1981.
(conTTnuedy
-------
TABLE B-l. (continued)
03
I
Cr>
[PA
Region
IX
State
Ariz
Calif.
(Monterey)
(Mountain)
(San B. )
(Shasta)
(SCAQMD)
(Bay A )
(Kern)
Hawa i i
Nev. f
No of
plants'*
2/0
13/8
(1/1)
(1/1)
(3/2)
(1/1)
(3/0)
(1/1)
(3/2)
2/1
1/0
State r
Ultrogen oxides Sulfur dioxide
For K. 193 tons/h of feed
CC:
E = 0.1 P
P s 733 tons/h of feed
E = 55 P"-"-40
P >733 tons/h of feed.
Installation prior to
11/1/82. NAAQS.
Installation after
11/1/82: NSPS.
E = 0.45(PW)°-BO;
PW < 17,000 Ib/h for
existing sources or
PW <9,250 Ib/h for new
sources. E = 1.12(PW)°-27,
PW S17.000 Ib/h for existing
sources E -- l.O(PW)0-25;
PW i9,250 Ib/h for new
sources.
Other S10%
$20% for 3 min period
in 60 min.
Sections 8 and 13; May 13,
Section ]6 3 1; July 1981
Article 1, 198'i
Sections 1-1201, 1-1329, and
1-1330 September 5, 1980
TcontTnueiTy
-------
TABLE 8-1. (continued)
00
LPA
Region State
X Oreg.
Wash
No of
plants8
2/1
4/0
State
Nitrogen oxides Sulfur dioxide
NAAQS
< 1,000 ppm
(corrected to 7%
02) for 60 min
period
regulation H
Particulatec'a'°
Equation Set 2.
•-0.1 gr/dscf.
Opacity0
Facilities prior to
6/1/70; «40% for 3 min
in 1 h Facilities since
6/1/70; «20% for 3 rain in
1 h or NSPS.
30 tons/h of feed (IB)
Equation Set 2:
E = 4.1 P0-67 for P s 30 tons/h of feed (IB); E - 55P"-"-40 for P > 30 tons/h of feed (2B)
'NSPS not formally adopted in SIP.
jjState has not accepted NSPS delegation.
|Exception for General Portland, Inc., plant in Tampa, Florida.
•NAAQS = National ambient air quality standard.
JNA = not available.
Source. State Air taws. Environment Reporter. Bureau of National Affairs, Inc , Washington, 0 C 1983.
Air pol Iulion
regulation reference
Division 21, January 22, 1982
Title 173, WAC 1/1-400-040,
WAC 173-400-060,
WAC 173-400-115; Apri I 15,
-------
APPENDIX C
PARTICULATE EMISSIONS AND OPACITY DATA FOR FACILITIES
SUBJECT TO THE NSPS SINCE THE 1979 REVIEW
C-l
-------
TABLE C-l. PARTICULATE EMISSIONS AND OPACITY DATA FOR FACILITIES
SUBJECT TO THE NSPS SINCE THE 1979 REVIEW
o
I
ro
EPA
region
IV
V
VI
Company/locat ion
Ideal Basic Ind., Inc.
Theodore, Ala.
Moore McCormack
Cement, Inc.
(Fla. Mining 4 Materials)
Brooksvi 1 le, F la.
Moore-McCormack
(Dixie Cement Co.)
(formerly Ideal Basic)
Knoxvi 1 le, Tenn.
Columbia Cement Co.
Zanesvl 1 le, Ohio
Ideal Basic Ind., Inc.
lijeras, N. Hex. '
lone Star Ind. Inc.
(Oklahoma Cement )
Pryor, Ok la.
Alamo Cement Co.
San Antonio, lex.
Clinker
capa-
city.
Date- tons/
typea yr
1981- 1,415
D,PC
1982- 560
O.Ptl
1979- 512
0,HC
—
--
1979-D 267
1981- 523
D,PC
Emission
control
equipment
(FF (-)
(w/cooler
and raw
mi 1 1
dryers )
FF(-)
FF(-)
-
--
FF
ESP
(w/cooler
and raw
mi 1 1 )
KILN
Participate Opa-
^ emissions city,
" Ib/h
52.18
(9/83)
6.5
(9/82)
4.63
(12/79)
-
—
6.5
(3/80)
22
Main stack
15.8
Bypass stack
Ib/ton J
0.22 12.06
(9/83) (Avg.)
0.058 0
(9/82) (9/82)
0.039
(12/79)
—
~-
0.112
(3/80)
0.19
( 1 /83 )
0.01
(1/83)
CLINKER COOLER
Emission Particulate
control h emissions
Date equipment Ib/h Ib/ton
1981 FF(-) (w/
kiln and
raw mitt
dryers)
1982 FF(-) 4.98 0.044
(9/82) (9/82)
1979 FF(-) 0.82 0.008
(12/79) (12/79)
—
—
1979 GB 13.8 0.10
(3/80) (3/80)
1981 ESP (w/kiln
and raw mi M )
OTHER FACILITIES
Opa- Emission
city, control .
t Date equipment
1981 Entire
plant-FF(-)
0
(9/82)
.. _ _
19/8 Finish
mill-FF
>1979 Finish
mlll-FF,
CYC
—
1981 Entire
plant-FF
(except
finish mill )
Opa-
city,
I
~
1C
1C
—
"
4.0 0.024
Bypass stack (4/84)
1715531
-------
TABLE C-l. (continued)
o
I
OJ
tPA
region Company/local ion
VI Capital Aggregates, Inc.
San Antonio, Tex.
Centex Corp.
(Texas Cement )
Buda, lex.
General Portland, Inc.
New Uraunfefs, Tex.
Gul 1 Coast Portland
Cement Co,
(Uiv. ol McOonough)
Houston, lex.
Kaiser Cement Corp.
(Longhorn plant)
San Antonio, Tex.
Lone Star Ind. Inc.
Maryneal , Tex.
Southwestern Portland
Cement Co.
Bush land (Amarillo), Tex.
Southwestern Portland
Cement
Odessa, Tex.
KILN
(' 1 ! nL*ir- ~ ~~~ — " ~~ ~~ ~— ^— — — — — — .
L 1 1 nker
capa-
city, tmission Particulate Opa-
Date- tons/ control . emissions city.
tyPe yr equipment Ib/h Ib/ton <
1983- 500 FF NAc'd NAC'd NAc>d
O.PC
1983- 468 FF (w/raw NAC NAC NAC
D,PC mill)
1980- 875 2-F.SP's ?5.6 0.129 0-5
".PC (-/raw (5/8?) (5/82)
mi II )
1975- 775 3-ESP's; FF 13.89 0.088 -10
D, 2PC on alkal i
(2nd PC bypass
in 1979)
—
__
1978- 279 FF 10.73 0.148 3.7
°.PH (2/83) (2/83) (2/83)
CLINKER COOLER OTHER FACILITItS
Fmisslon Particulate Opa-
control ^ emissions city.
Date equipment Ib/h Ib/ton t Date
1983 FF NAC'd NAc'd NAC'd 1983
1983
1980 GB 19.3 0.100 5-10 1980
(7/82) (7/82)
1973
and
1978
1978
1975 FF 1.889 <0.05 — 1977
1979
1981
1982
Emission
control
equipment
Mil Is,
storage.
transfer -FF
Raw mi 1 1 -II
(w/ki In)
Entire
plant-FF
Finish
mil Is-FF
storage-f F
Finish
mi II -FF
Coal
transfer -FF
Coal
storage.
coal
transfer-FF
Coal
storage.
coal
transfer, FF
Opa-
city,
%
__
-
1C
..
"
(conf TnuetTT
-------
TABLE C-l. (continued)
EPA
region Company/location
Texas Industries
Hunter, Tex.
Texas Industries
Midlothian, lex.
VII Davenport Industries
BuUalo, lo»a
Lehigh Port land
Cement Co.
Mason City, Iowa
lone Star tnd. Inc.
(Marquette Cement )
Cape Girardeau, Mo.
River Cement Co.
Festus, Mo
<"> Ash Grove Cement Co.
^ Louisvi 1 le, Nebr.
VIII 1 dea 1 Bas i c 1 ad . , 1 nc .
(Boettcher plant)
la Porte (Fort
Col lins), Colo.
Martin Marietta Corp.
Lyons, Colo.
Date-
type3
1980-
D,PC
„
1981-
D.PC
1979-
D,PC
1981-
D,PC
—
1982-
D,PC
1981-
D,PII
1979-
D,PC
KILN
Clinker
capa-
clty, Emission Particulate Opa-
tons/ control K emissions city.
yr equ i pmen t 1 b/h
664 ESP 31.87
(7/81)
809 FF (w/raw 20.37
mill) (8/83)
543 ESP (w/raw 35.4
mill) (6/83)
992 ESP 29.17
(3/82)
„
558 tSP 7.87
(7/83)
440 FF(t) 13.1
(4/82)
405 FF(-) 10.29®
9.98
(10/80)
FF(-) 3.30
(Alkali (10/80)
bypass >
Ib/ton %
0.229
(7/81 )
0.1358
(8/83)
0.266
(6/83)
0.12
(3/82)
—
0.065
(7/83)
0.14
(4/82)
0.095?
0.094
(10/80)
0.03
(10/80)
CLINKER COOLER OTHER FACILITIES
Emission Particulate Opa- Emission Opa-
control h emissions city, control < city,
Date equipment Ib/h Ib/ton ( Date equipment I
1980 FF 3.25 0.0233 — 1980 Entire
(12/81) (12/81) plant-FF
1979 Finish
ml II-ESP,
transfer-FF
1981 FF 20.75 0.138 -- 1981 Entire
(8/83) (8/83) plant-FF
1980 Mill,
separators-
FF
1981 2 FF "s 13.7 0.06 — 1981 Entire
(N/raw mill) plant-FF
>1979 Rawmill-FF
1982 FF(*) 5.83 0.048
(7/83) (7/83)
1981 FF(-)(w/raw 16.4 0.191 — 1981 Entire
(mill) (2/82) (2/82) plant
(exept finish
mill)-FF
1979 Limestone
dryer -FF(-)
-------
TABLE C-l. (continued)
o
I
EPA
region Company/location
VIII lone Star Ind., Inc.
(Utah Portland Cement)
Salt lake City, Utah
Martin Marietta Corp.
Leamington, Utah
Monolith Portland
Cement Co.
Laranne, Wyo.
IX Cal ifornia Portland
Cement Co.
Mojave, Cal i 1.
Genstar, Ltd.
(Div. ol Flintkote)
Read ing, Ca 1 i I .
Genstar, Ltd.
(Div. of Fl intkote)
San Andreas, Cal if.
Kaiser Cement Corp.
Cushenbury Plant
Lucerne Valley, Calif.
Kaiser Cement Corp.
(Cupert ino)
Permanent e, Cal i f .
Date-
type3
1979-W
1982-
D.PC
198 I-W
1981-
D,PC
1981-
D,PC
1945-H
1952-W
1956-W
1982-
D,PC
1981-
D,PC
capa-
clty,
tons/
yr
150
603
300
1,000
571
192
192
192
1,520
1,520
KILN
Emission
control
equipment
FH-)
FF <«/raw
mi II )
FF
(Alkali
bypass )
ESP
FF(-)
(M/raw
mill)
FF(-)
(w/rax
mi 1 1 and
Multi-CYC,
ESP
FF (H/rav
mil 1 )
FF(-)
Part icu late Opa-
emissions city,
Ib/h
8.74
(9/80 )
9.949
(6/83J
5.8?"
(10/82)
5.5
(No. 2
kiln
5/82)
15.34
(5/83)
2.87?
5.061
(5/81)
45J
(11/79)
18
(5/83)
8.0
(9/83,
10/83)
Ib/ton I
0.294 0
(9/80) (9/80)
0.089
(6/83J
0.0411
(10/82)
O.lll 5-15
(No. 2 (No. 2
kiln kiln
5/82) 6/82)
0.07
(5/83)
0.027? 0
0.05)'
(5/81 )
0.29 4
(11/79)
0.066
(5/83)
0.030
(9/83,
10/83)
CLINKER COOLER
Emission
control
Date equipment
1979 FF(-)
1982 FF
1981 FF(-)
1981 FF(-)
1981 FF(-)
(•/raw mi 1 1
and cooler)
1982 FF («/
alkali
bypass)
1981 FF(-)
OFHER FACILITIES
Part icu late Opa-
emissions city.
Ib/h
1.58
(10/80)
3.96
(!2/83>
0.17
(5/82)
4.98
(5/83)
—
1.9"
(5/83)
2.3
(10/83)
1 b/ton I Date
0.049 0
(10/80) (10/80)
0.034 0 1982
(12/83) (12/83)
0.004 0 1981
(5/82) (5/82)
0.04 — 1981
(5/83)
1981
0.006" — 1982
(5/83)
0.0082 — 1981
(10/83)
Emission Opa-
control . cHy,
equipment %
-
Entire 1C
plant-FF
F inish mi 1 1 ,
cement
cooler-FF(-)
Raw mill-
IP!-)
(•/kiln)
Raw mi 1 1-
FF(-) (*/
kiln and
cooler)
Entire
plant-FF
Entire
plant-FF (- )
-------
TABLE C-l. (continued)
o
cr>
KILN
Ci;n|(er —
capa-
fp. city. Emission Particulate Opa-
. Date- tons/ control emissions r.tw
region Company/location Ivoe vr .n,,i™L t° — ll/i -ILJI CI'Y.
IX tone Star Ind., Inc. 1981- 744 ESP (./ran 3.75? 0 0229 3
Davenport (Santa Cruz), D,PC m, ,, ) 6.451 O.OK1 (12/83)
'-<""• (12/83) (12/83)
Southwestern Portland 1984- 800 NAc'd NAc>d u»c'd u»c.d
Cement Co. 0 PC Nfl NA
Viclorvi lie, Cal if .
lone Star Ind., Inc.
Ewa Beach, Hawai >
X Alaska Basic Inc.
Anchorage, Alaska
Oregon Portland Cement 1979- 500 ESP (w/ 6 35 0 055 I
Durkee, Oreg. 0,PH COOier) (10/83) (10/83)
Cl INKER COOLER OTI€R FACILITIES
Emission Particulate Opa- Emission Opa-
control . emissions city rontmi ^i*u
Date equipment" -fb>h Ib/ton /' Date equfpmenl" ' \'
1981 M "-54 0.056 - 1981 Finish mill
(12/83) (12/83) ra« feed
si lo.
transfer-
FF(-)
>1979 Mill,
storage-FF
1982 Finish mill.
storage.
transfer-
FF(-)
1979 ESP - - - )979 Ent|re
plant-FF(-),
finish mlll-
ESP
cfabrlc filter; GB = gravel bed filter.
dNA - Data not available; test data not completed.
fiFacililies under construction.
flype \ clinker production.
Fype 2 clinker production.
^Rao mi I I on-IIne.
Alkali b/pass.
Haw mill bypassed.
Ihree ktlns in opetatioo.
ocess with preheater, D, PC = Dry process «tth precalclner/preheater
preclpltator; fF - fabric filter (baghouse); FF(O = positive-pressure fabr
Ic filter; FF(-) = negative-pressure
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing/
1. REPORT NO.
EPA-450/3-85-003a
4. TITLE AND SUBTITLE
Portland Cement Plants--Bac
Proposed Revisions to Stand
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AIN
Office of Air Quality Planni
U. S. Environmental Protecti
Research Triangle Park, Nort
12. SPONSORING AGENCY NAME AND AOC
Director for Air Quality Pla
Office of Air and Radiation
U. S. Environmental Protecti
Research Triangle Park, Nort
2. 3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
kground Information for May 1985
ar(js 6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
IO ADDRESS 10. PROGRAM ELEMENT NO.
ng and Standards
on Agency 11. CONTRACT/GRANT NO.
h Carolina 27211 68-02-3817
RESS 13. TYPE OF REPORT AND PERIOD COVERED
nning and Standards Final
14. SPONSORING AGENCY CODE
on Agency FPA/200/04
h Carolina 27711 hPA/^uu/U4
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Revisions to the standards
cement plants (40 CFR Part
Section 111 of the Clean Ai
information gathered during
17.
a. DESCRIPTORS
Air pollution
Pollution control
Standards of performance
Portland cement plants
Kilns
Clinker coolers
Particulates
18. DISTRIBUTION STATEMENT
Unlimited
of performance for the control of emissions from port! and
60.60) are being proposed under the authority of
r Act. This document contains a summary of the
the review of this new source performance standard.
KEY WORDS AND DOCUMENT ANALYSIS
b.lDeNTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Pollution Control 13 B
19. SECURITY CLASS (This Report) 21. NO. OF PAGES
Unclassified 123
20. SECURITY CLASS (This page) 22. PRICE
Unclassified
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDI TION IS OBSOLETE
-------
.4
-------
UnHed Statps
Environmental Protection
Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park NC 27711
Official Business
PuM.illy lor Private Use
'..100
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