EPA-450/2-77-007a
April 1977
STANDARDS SUPPORT AND
ENVIRONMENTAL IMPACT STATEMENT
VOLUME 1: PROPOSED STANDARDS
OF PERFORMANCE FOR LIME
MANUFACTURING PLANTS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA.450/2-77-00;
STANDARDS SUPPORT AND
ENVIRONMENTAL IMPACT STATEMENT
VOLUME 1: PROPOSED STANDARDS
OF PERFORMANCE FOR LIME
MANUFACTURING PLANTS
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
April 1977
U.S. Environmental Protection Agtnqr
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Flow
Chicago. II 60604-3590
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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air and
Waste Management, Environmental Protection Agency, and approved for publica-
tion. Mention of company or product names does not constitute endorsement
by EPA. Copies are available free of charge to Federal employees, current
contractors and grantees, and non-profit organizationsas supplies permit--
from the Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711; or may be obtained,
for a fee, from the National Technical Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161.
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Draft
Standards Support and
Environmental Impact Statement
Lime Manufacturing Plants
Type of Action: Administrative
Prepared by
/*/
- ? 7
Don R. Goodirin (Date)
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Approved by
(Date)
Assistant Administrator
Office of Air and Waste Management
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Additional copies mav be obtained at:
Public Information Center (PM-215)
Environmental Protection Agency
Washington, D. C. 20460
m
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IV
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TABLE OF CONTENTS
Page
LIST OF FIGURES viii
LIST OF TABLES ix
CHAPTER 1. SUMMARY 1-1
1.1 PROPOSED STANDARDS 1-1
1.2 ENVIRONMENTAL IMPACT 1-3
1.3 INFLATION IMPACT 1-5
1.4 CAPACITY AND COST IMPACT 1-6
CHAPTER 2. INTRODUCTION 2-1
2.1 AUTHORITY FOR THE STANDARDS 2-1
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES 2-4
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE. ... 2-6
2.4 CONSIDERATION OF COSTS 2-8
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS 2-10
2.6 IMPACT ON EXISTING SOURCES 2-11
2.7 REVISION OF STANDARDS OF PERFORMANCE 2-12
REFERENCES FOR CHAPTER 2 2-12
CHAPTER 3. THE LIME INDUSTRY 3-1
3.1 GENERAL 3-1
3.2 PROCESSES AND THEIR EMISSIONS 3-3
REFERENCES FOR CHAPTER 3 3-17
CHAPTER 4. EMISSION CONTROL TECHNOLOGY 4-1
4.1 CALCINATION EMISSION CONTROL TECHNOLOGY 4-1
4.2 HYDRATION EMISSION CONTROL TECHNOLOGY 4-12
4.3 FUGITIVE EMISSION CONTROL TECHNOLOGY 4-14
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TABLE OF CONTENTS (continued)
Page
4.4 STATE REGULATIONS 4-15
REFERENCES FOR CHAPTER 4 4-16
CHAPTER 5. MODIFICATION AND RECONSTRUCTION OF ROTARY LIME KILNS
AND LIME HYDRATORS 5-1
5.1 CONVERSION FROM NATURAL GAS OR FUEL OIL TO COAL FIRING. . . 5-3
5.2 ADDING A STONE PREHEATER TO AN EXISTING KILN 5-3
5.3 ADDING INTERNALS TO AN EXISTING KILN 5-4
5.4 DEBOTTLENECKING 5-4
CHAPTER 6. ENVIRONMENTAL IMPACTS 6-1
6.1 IMPACTS OF CONTROL TECHNOLOGY FOR ROTARY LIME KILNS .... 6-1
6.2 IMPACTS OF CONTROL TECHNOLOGY FOR LIME HYDRATORS 6-24
REFERENCES FOR CHAPTER 6 6-29
CHAPTER 7. COSTS AND ECONOMIC IMPACTS 7-1
7.1 INDUSTRY ECONOMIC PROFILE 7-1
7.2 COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS . . . 7-22
7.3 OTHER COST CONSIDERATIONS 7-37
7.4 ECONOMIC IMPACT OF ALTERNATIVE EMISSION CONTROL SYSTEMS . . 7-38
REFERENCES FOR CHAPTER 7 7-54
CHAPTER 8. RATIONALE FOR THE PROPOSED STANDARDS 8-1
8.1 SELECTION OF THE SOURCE FOR CONTROL 8-1
8.2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES 8-4
8,3 SELECTION OF THE BEST SYSTEM OF EMISSION REDUCTION
CONSIDERING COSTS 8-11
8.4 SELECTION OF THE FORMAT OF THE PROPOSED STANDARDS 8-15
8.5 SELECTION OF THE EMISSION LIMITS 8-16
8.6 VISIBLE EMISSIONS LIMITS 8-19
8.7 MODIFICATION AND RECONSTRUCTION CONSIDERATIONS 8-24
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TABLE OF CONTENTS (continued)
Page
8.8 SELECTION OF MONITORING REQUIREMENTS 8-24
8.9 SELECTION OF PERFORMANCE TEST METHODS 8-27
REFERENCES FOR CHAPTER 8 8-28
APPENDIX A. EVOLUTION OF THE PROPOSED STANDARDS A-l
APPENDIX B. INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS B-l
APPENDIX C. EMISSION SOURCE TEST DATA C-l
APPENDIX D. EMISSION MEASUREMENT D-l
APPENDIX E. IMPACT CALCULATIONS E-l
ABSTRACT AND TECHNICAL REPORT DATA F-l
VII
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LIST OF FIGURES
Page
Figure 3-1 Flowsheet for Modern Lime Calcination and Hydration. . .3-4
Figure 4-1 Particulate Emissions from Rotary Lime Kiln
Facilities 4-4
Figure 4-2 Sulfur Dioxide Emissions from Rotary Lime Kiln
Facilities 4-5
Figure 4-3 Particulate Emissions from Lime Hydration Facilities . .4-13
Figure 7-1 Trends in the Major Uses of Lime 7-10
vm
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LIST OF TABLES
Table 1-1
Table 1-2
Table 3-1
Table 3-2
Table 3-3
Table 6-1
Table 6-2
Table 6-3
Table 6-4
Table 6-5
Table 6-6
Table 6-7
Table 6-8
Table 6-9
Table 6-10
Table 6-11
Table 6-12
Table 6-13
SUMMARY OF PROPOSED STANDARDS AND MONITORING
REQUIREMENTS
Page
1-2
MATRIX OF THE ENVIRONMENTAL AND ECONOMIC IMPACTS OF
ALTERNATIVE STANDARDS FOR THE LIME KILN AND THE
HYDRATOR 1-4
EMPLOYMENT IN THE LIME INDUSTRY IN RECENT YEARS .... 3-2
UNCONTROLLED MODEL LIME PLANT 3-10
TYPICAL LIME HYDRATE PLANT 3-15
ALTERNATIVE EMISSION CONTROL SYSTEMS FOR ROTARY LIME
KILNS
6-2
CONVERSION FACTORS FOR MODEL KILN AND MODEL HYDRATOR. . 6-3
ROTARY KILN FACTORS 6-7
REDUCTION OF PARTICULATE AND SO? EMISSIONS OF FOUR
CONTROL SYSTEMS COMPARED TO STATE REGULATIONS FOR
ROTARY LIME KILNS IN THE UNITED STATES, 1987 6-8
EMISSIONS FROM MODEL KILN BURNING 3 PERCENT SULFUR
COAL 6-12
AIR QUALITY IMPACT - MODEL 500 TPD ROTARY LIME
KILN 6-13
SOLID WASTE IMPACT ON MODEL ROTARY KILN 6-15
1987 ELECTRICAL ENERGY IMPACT 6-19
ELECTRICAL AND TOTAL ENERGY USE FOR MODEL ROTARY
KILN
6-20
ENVIRONMENTAL IMPACT OF DELAYED OR NO STANDARDS FOR
ROTARY LIME KILNS 6-23
1987 REDUCTION OF PARTICULATE EMISSIONS FOR LIME
HYDRATORS IN THE UNITED STATES 6-25
PARTICULATE EMISSIONS FROM A MODEL LIME HYDRATOR. . . 6-26
AIR QUALITY IMPACT - MODEL 17 TPH LIME HYDRATOR . . . 6-27
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LIST OF TABLES (CONTINUED)
Page
Table 6-14 ENVIRONMENTAL IMPACT OF DELAYED OR NO STANDARDS FOR
LIME HYDRATORS 6-28
Table 7-1 NUMBER AND CHARACTERISTICS OF LIME PLANTS, BY REGION
(1974) 7-3
Table 7-2 HISTORICAL CONCENTRATION RATIOS IN THE LIME INDUSTRY. . 7-6
Table 7-3 LIME PRODUCTION COSTS AS A PERCENT OF VALUE OF
SHIPMENTS FOR S1C3274 ESTABLISHMENTS 7-8
Table 7-4 PLANT AND EQUIPMENT EXPENDITURES IN THE LIME INDUSTRY . 7-9
Table 7-5 HISTORICAL LIME PRODUCTION, CONSUMPTION, AND
REPRESENTATIVE PRICES 7-12
Table 7-6 PROJECTED NEW KILN AND HYDRATOR CONSTRUCTION 7-21
Table 7-7 MODEL PLANT CHARACTERISTICS 7-24
Table 7-8 SUMMARY OF COSTS FOR VARIOUS CONTROL DEVICES ON
ROTARY KILNS 7-27
Table 7-9 ENGINEERING PARAMETERS FOR ESTIMATING OPERATING
COSTS 7-29
Table 7-10 SUMMARY OF ALTERNATIVE EMISSION CONTROL SYSTEMS .... 7-30
Table 7-11 INCREMENTAL CONTROL COSTS FOR ALTERNATIVE EMISSION
CONTROL SYSTEMS - NEW SOURCES 7-32
Table 7-12 INCREMENTAL CONTROL COSTS FOR ALTERNATIVE EMISSION
CONTROL SYSTEMS - MODIFIED SOURCES 7-34
Table 7-13 PROFITABILITY IMPACT ANALYSIS FOR ALTERNATIVE
CONTROL SYSTEMS ON 500 TPD PLANT - NEW SOURCES .... 7-41
Table 7-14 INCREASE IN CAPITAL REQUIREMENTS FOR EACH
ALTERNATIVE EMISSION CONTROL SYSTEM - NEW SOURCES. . . 7-44
Table 7-15 PROFITABILITY IMPACT ANALYSIS FOR ALTERNATIVE
CONTROL SYSTEMS ON 500 TPD PLANT - MODIFIED SOURCES. . 7-46
Table 7-16 INCREASE IN CAPITAL REQUIREMENTS FOR EACH ALTERNATIVE
EMISSION CONTROL SYSTEM - MODIFIED SOURCES 7-49
Table 7-17 SUMMARY OF 1974 FUEL USE ANALYSIS FOR S1C3274 7-51
Table 8-1 SUMMARY OF VISIBLE EMISSIONS DATA 8-21
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1. SUMMARY
U PROPOSED STANDARDS
Standards of performance for new and modified rotary lime kilns and
hydrators at lime manufacturing plants are being proposed under the authority
of section 111 of the Clean Air Act. The standards require the control of
particulate emissions from the specified affected facilities. These
facilities account for virtually all of the particulate emissions at lime
plants. A summary of the proposed standards and monitoring requirements is
presented in Table 1-1. Preceding the act of proposal has been the
Administrator's determination that emissions from lime plants contribute
to the endangerment of public health or welfare. In accordance with section
117 of the Act, proposal of the standards was preceded by consultation with
appropriate advisory committees, independent experts, industry representatives,
and Federal departments and agencies.
The proposed standards for the rotary lime kiln limit emissions to
0.15 kilogram of particulate matter per megagram of limestone feed (0.3 l.b/
ton) and 10 percent opacity. These standards are based on the results of
EPA source tests at six lime plants. The data are summarized in Appendix C.
The owner or operator of the affected facility will be required to con-
tinuously monitor the opacity of the emission plume. When a wet scrubber
is used for control, the opacity monitoring requirement is waived, and the
pressure drop and liquid supply pressure of the scrubber must be monitored
instead.
The proposed standards for the lime hydrator limits the emissions to
0.075 kilogram of particulate matter per megagram of lime feed (0.15 Ib/ton).
1-1
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No opacity standard is being proposed for the hydrator. The proposed parti-
cipate standard is based on the results of EPA source tests on two hydrator
facilities. The data are summarized in Appendix C. The proposed standards also
require that the pressure drop and the liquid supply pressure of the scrubber
used to control the emissions must be monitored.
1.2 ENVIRONMENTAL IMPACT
The beneficial and adverse environmental impacts associated with the
proposed standards and with the various emission control alternatives that
were considered in selecting the standards are presented in this section.
The impacts are discussed in detail in Chapter 6, Environmental Impact, and
in Chapter 7, Economic Impact. A cross reference between the EPA guidelines
for the preparation of Environmental Impact Statements and this document
is included in Appendix B.
Table 1-2 is a matrix summarizing the environmental, economic, and
inflationary impacts that have been considered. Although the quantified
values presented are somewhat subjective, the table presents the type and
relative magnitude of the impacts.
For the lime kiln, alternative C is the baseline system upon which
the impacts associated with the other alternatives are measured. Alternatives
A-l, A-2, B-l, and B-2 are combinations of the various control levels
for particulate matter and SOg that have been considered. Alternative A
represents the use of a dry control system, such as a baghouse or an ESP,
to control particulate emissions from the lime kiln. A-l requires high
efficiency control and A-2 requires medium efficiency control. Alternative B
represents the use of a scrubber to control both particulate matter and
S02 from the kiln. Both B-l and B-2 require control of S02 emissions to
a concentration of 100 parts per million. B-l requires high efficiency
particulate control and B-2 requires medium efficiency particulate control.
1-3
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The impacts on air quality are beneficially large for alternatives A-l and
B-l. Significant negative impacts on water, energy demand, and solid waste
occur under alternatives B-l and B-2. There are no known noise or radiation
impacts associated with any of the alternatives considered for the lime kiln.
For the hydrator unit, there were only two alternatives considered:
alternative I, the proposed standard, and alternative II, the baseline system.
Significant reduction in particulate emissions occur under alternative I,
With only negligible impacts on energy demand. No incremental impacts on
water or solid waste are anticipated. There are no known noise or radiation
impacts associated with either the alternatives considered for the hydrator.
1.3 INFLATION IMPACT
The costs associated with the proposed standards for new and modified
facilities at lime plants have been judged not to be of such magnitude to
require an analysis of the inflationary impact. Screening criteria have
been developed by EPA to be used in the impact analysis. These criteria
have been outlined in an Agency publication and include:
(1) National annualized cost of compliance.
(2) Total added production cost in relation to sales price.
(3) Net national energy consumption increase.
(4) Added demands or decreased supplies of selected materials.
Should any of the guideline values listed under these criteria be exceeded,
a full inflationary impact assessment would be required.
1-5
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1.4 CAPACITY AND COST IMPACT
The proposed standards will impact an estimated 6.8 teragrams (7.5 x 10
tons) of lime manufacturing capacity through 1982. It is projected that the
equivalent of 10 new and modified rotary lime kilns and 1 new lime hydrator
will be affected per year through 1982. The industry-wide investment costs
4»
for control of particulate emissions from these facilities through 1982
are projected to be approximately $3.18 million. The fifth-year incremental
annualized costs, including depreciation and interest, are estimated at
approximately $4.97 million.
The Environmental Protection Agency has determined that this document
does not contain a major proposal requiring preparation of an Economic
Impact Analysis under Executive Orders 11821 and 11949 and OMB Circular A-107.
1-6
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2. INTRODUCTION
Standards of performance under section 111 of the Clean Air Act are proposed
following a detailed investigation of air pollution control methods available
to the affected industry and the impact of their costs on the industry. This
document summarizes the information obtained from such a study of the lime
manufacturing industry. Its purpose is to explain in detail the background and
basis of the proposed standards and to facilitate analysis of the proposed
standards by interested persons, including those who may not be familiar with
the many technical aspects of the industry. To obtain additional copies of
this document or the Federal Register notice of proposed standards, write to
Public Information Center (PM-215), the Environmental Protection Agency,
Washington, D. C. 20460 (specify Standards Support and Environmental Impact
Statement, Volume 1: Proposed Standards of Performance for Lime Manufacturing
Plants.)
2.1 AUTHORITY FOR THE STANDARDS
Standards of performance for new stationary sources are developed under
section 111 of the Clean Air Act (42 U.S.C. 1857c-6), as amended in 1970. Sec-
tion 111 requires the establishment of standards of performance for new stationary
sources of air pollution which "... may contribute significantly to air
pollution which causes or contributes to the endangerment of public health
or welfare." The Act requires that standards of performance for such sources
reflect ". . . the degree of emission limitation achievable through the application
2-1
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of the best system of emission reduction which (taking into account the cost
of achieving such reduction) the Administrator determines has been adequately
demonstrated." The standards apply only to stationary sources, the construction
or modification of which commences after regulations are proposed by publication
in the Federal Register.
Section 111 prescribes three steps to follow in establishing standards of
performance.
1. The Administrator must identify those categories of stationary sources
for which standards of performance will ultimately be promulgated by
listing them in the Federal Register.
2. The regulations applicable to a category so listed must be proposed
by publication in the Federal Register within 120 da&s of its listing.
This proposal provides interested persons an opportunity for comment.
3. Within 90 days after the proposal, the Administrator must promulgate
standards with any alterations he deems appropriate.
Standards of performance, by themselves, do not guarantee nrotection of
health or welfare; that is, they are not designed to achieve any soecific
air quality levels. Rather, they are designed to reflect best demonstrated
technology (takinq into account costs) for the affected sources. The overriding
purpose of the collective body of standards is to maintain existing air quality
and to prevent new pollution problems from developing.
Previous legal challenges to standards of performance have resulted in
1 2
several court decisions * of importance in developing future standards. In
those cases, the principal issues were whether EPA: (1) made reasoned decisions
and fully explained the basis of the standards, (2) made available to interested
parties the information on which the standards were based, and (3) adequately
considered significant comments from interested parties.
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Among other things, the court decisions established: (1) that preparation of
environmental impact statements is not necessary for standards developed under
section 111 of the Clean Air Act because, under that section, EPA must consider
any counter-productive environmental effects of a standard in determining what
system of control is "best;" (2) in considering costs it is not necessary to
provide a cost-benefit analysis; (3) EPA is not required to justify standards
that require different levels of control in different industries unless such
different standards may be unfairly discriminatory; and (4) it is sufficient
for EPA to show that a standard can be achieved rather than that it has been
achieved by existing sources.
Promulgation of standards of performance does not prevent State or local
agencies from adopting more stringent emission limitations for the same sources.
On the contrary, section 116 of the Act (42 USC 1857-D-l) makes clear that States
and other political subdivisions may enact more restrictive standards.
Furthermore, for heavily polluted areas, more stringent standards may be required
under section 110 of the Act (42 USC 1857c-5) in order to attain or maintain
national ambient air quality standards prescribed under section 109 (42 USC 1857c-4^
Finally, section 116 makes clear that a State may not adopt or enforce less
stringent new source standards than those adooted by EPA under section 111.
Although standards of performance are normally structured in terms of
numerical emission limits where feasible,!' alternative approaches
are sometimes necessary. In some cases nhysical measurement of emissions from
- "'Standards of performance,1 . . . refers to the degree of emission centre"
which can be achieved through process changes, operation changes, direct emissic
control, or other methods. The Secretary [Administrator] should not make a
technical judgment as to how the standard should be implemented. He should
determine the achievable limits and let the owner or operator determine the most
economical technique to apply." Senate Report 91-1196.
2-3
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a new source may be impractical or exorbitantly expensive. For example,
emissions of hydrocarbons from storage vessels for petroleum liquids are
greatest during tank filling. The nature of the emissions (high
concentrations for short periods during filling and low concentrations for
longer oeriods during storage) and the configuration of storage tanks make
direct emission measurement impractical. Therefore, a more practical
annroach to standards of performance for storage vessels has been equioment
soecification.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 directs the Administrator to publish and from time to time revise
a list of categories of sources for which standards of performance are to be
proposed. A category is to be selected ". . . if [the Administrator] determines
it may contribute significantly to air pollution which causes or contributes to
the endangerment of public health or welfare."
Since passage of the Clean Air Amendments of 1970, considerable attention
has been given to the development of a system for assigning priorities to various
source categories. In brief, the approach that has evolved is as follows. Specific
areas of interest are identified by considering the broad strategy of the Agency
for imDlementing the Clean Air Act. Often, these "areas" are actually pollutants
which are nrimarily emitted by stationary sources. Source categories which emit
these pollutants are then evaluated and ranked by a process involving such
factors as (1) the level of emission control (if any) already required by
State regulations; (2) estimated levels of control that might result from
standards of performance for the source category; (3) projections of growth
and replacement of existing facilities for the source category; and (4) the
2-4
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estimated incremental amount of air pollution that could be orevented, in a pre-
selected future year, by standards of performance for the source category. An
estimate is then made of the time required to develop a standard. In some
cases, it may not be feasible to develop a standard immediately for a source
category with a high priority. This might occur because a program of research
and development is needed to develop control techniques or because techniques
for sampling and measuring emissions may require refinement. The schedule of
activities must also consider differences in the time required to complete the
necessary investigation for different source categories. Substantially more
time may be necessary, for example, if a number of pollutants must be investigated
in a single source category. Further, even late in the development process the
schedule for completion of a standard may change. For example, inability to
obtain emission data from well-controlled sources in time to pursue the development
process in a systematic fashion mav force a rhanoe in sch°Hulino.
Selection of the source category leads to another major decision: determination
of the tyoes of facilities within the source category to which the standard will
apply. A source category often has several facilities that cause air pollution.
Emissions from some of these facilities may be insignificant or very expensive
to control. An investigation of economics may show that, within the costs that
an owner could reasonably afford, air pollution control is better served by applying
standards to the more severe pollution problems. For this reason (or perhaps
because there may be no adequately demonstrated system for control!inq emissions
from certain facilities), standards often do not apply to all sources within
a category. For similar reasons, the standards may not apply to all air
pollutants emitted bv such sources. Consequently, although a source category
may be selected to be covered by a standard of performance, not all pollutants
or facilities within that source category may be covered by the standards.
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2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Congress mandated that sources regulated under section 111 of the Clean
Air Act be required to utilize the best system of air pollution control
(considering costs) that has been adequately demonstrated at the time of their -
design and construction. In so doing, Congress sought to.
1. Maintain existing high-quality air,
2. Prevent new air pollution problems, and
3. Ensure uniform national standards for new facilities.
Standards of performance, therefore, must (1) realistically reflect
best demonstrated control practice; (2) adequately consider the cost of
such control; (3) be applicable to existing sources that are modified as well
as new installations; and (4) meet these conditions for all variations of
operating conditions being considered anywhere in the country.
The objective of a nrogram for development of standards is to identify
the best system of emission reduction which "has been adequately demonstrated
(considering cost)." The legislative history of section 111 and the court
decisions referred to earlier make clear that the Administrator's judgment
of vhat is adequately demonstrated is not limited to systems that are in
actual routine use. Consequently, the search may include a technical assess-
ment of control systems Which have been adequately demonstrated but for which
there is limited operational experience. In most cases, determination of
the "degree of emission limitation achievable" is based on results of tests
of emissions from existing sources. This has required worldwide investigation
and measurement of emissions from control systems. Other countries with heavily
populated, industrialized areas have sometimes developed more effective systems
of control than those used in the United States.
2-6
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Since the best demonstrated systems of emission reduction may not be in
widespread use, the data base upon which standards are developed may be
somewhat limited. Test data on existing well-controlled sources are
obvious starting points in developing emission limits for new sources.
However, since the control of existing sources generally represents retrofit
technology or was originally designed to meet an existing State or local regulation,
new sources may be able to meet more stringent emission standards. Accordingly,
other information must be considered and judgment is necessarily involved in
setting proposed standards.
Since passage of the Clean Air Amendments of 1970, a process for the development
of a standard has evolved. In general, it follows the guidelines below.
1. Emissions from existing well-controlled sources are measured.
2. Data on emissions from such sources are assessed with consideration
of such factors as: (a) the representativeness of the source tested
(feedstock, operation, size, age, etc.); (b) the aqe and maintenance of
the control equipment tested (and possible degradation in the efficiency
of control of similar new equipment even with good maintenance procedures);
(c) the design uncertainties for the type of control equipment being
considered; and (d) the degree of uncertainty that new sources will be
able to achieve similar levels of control.
3. During development of the standards, information from pilot and
prototype installations, guarantees by vendors of control equipment,
contracted (but not yet constructed) projects, foreign technology, and
published literature are considered, especially for sources where
"emerging" technology appears significant.
4. Where possible, standards are develooed which permit the use of
more than one control technique or licensed process.
2-7
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5. Where possible, standards are developed to encouraqe (or at least permit}
the use of process modifications or new processes as a method of control
rather than "add-on" systems of air pollution control
6. Where possible, standards are developed to permit use of systems capable of
controlling more than one pollutant (for example, a scrubber can
remove both gaseous and particulate matter emissions, whereas an
electrostatic precipitator is specific to particulate matter).
7. Where appropriate, standards for visible emissions are developed in
conjunction with concentration/mass emission standards. The opacity
standard is established at a level which will require proper operation
and maintenance of the emission control system installed to meet the
concentration/mass standard on a day-to-day basis, but not require the
installation of a control system more efficient or expensive than that
required by the concentration/mass standard. In some cases, however,
it is not possible to develop concentration/mass standards, such as with
fugitive sources of emissions. In these cases, only opacity standards
may be developed to limit emissions.
2.4 CONSIDERATION OF COSTS
Section 111 of the Clean Air Act requires that cost be considered in developing
standards of performance. This requires an assessment of the possible economic
effects of implementing various levels of control technology in new plants within
a given industry. The first step in this analysis requires the generation of
estimates of installed capital costs and annual operating costs for various
demonstrated control systems, each control system alternative having a different
overall control capability. The final sten in the analysis is to determine the
economic impact of the various control alternatives upon a new plant in the Indusf
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The fundamental question to be addressed is whether or not a new plant would be
constructed if a certain level of control costs would be incurred. Other issues
that are analyzed are the effects of control costs upon product prices and product
supplies, and producer profitability.
The economic impact upon an industry of a proposed standard is usually
addressed both in absolute terms and by comparison with the control costs that
would be incurred as a result of compliance with typical existing State control
regulations. This incremental approach is taken since a new plant would be
required to comply with State regulations in the absence of a Federal standard of
performance. This approach requires a detailed analysis of the impact upon the
industry resulting from the cost differential that exists between a standard
of performance and the typical State standard.
i The costs for control of air pollutants are not the only costs considered.
Total environmental costs for control of water pollutants as well as air pollutants
\
are analyzed wherever possible.
A-'thorough study of the profitability and price-setting mechanisms of the
industry is essential to the analysis so that an accurate estimate of potential
adverse economic impacts can be made. It is also essential to know the capital
requirements placed on plants in the absence of Federal standards of performance
so that the additional capital requirements necessitated by these standards can
be placed in the proper perspective. Finally, it is necessary to recognize any
constraints on capital availability within an industry as this factor also influences
the ability of new plants to generate the capital required for installation of
the additional control equipment needed to meet the standards of performance.
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2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(c) of the National Environmental Policy Act (NEPA) of 1969
*
(PL 91-190) renuires Federal aqencies to orenare detailed environmental statements
on proposals for legislation and other major Federal actions significantly
affecting the quality of the human environment. The objective of NEPA is to
build into the decision-making process of Federal aqencies a careful consideration
of all environmental asnects of proposed actions.
As mentioned earlier, in a number of legal challenges to standards of
performance for various industries, the Federal Courts of Appeals have held
that environmental impact statements need not be prepared by the Aqencv for
proposed actions under section 111 of the Clean Air Act. Essentially, the Federal
Courts of Appeals have determined that "...the best system of emission reduction,"
"...require(s) the Administrator to take into account counter-productive environ-
mental effects of a proposed standard, as well as economic costs to the industrv..."
On this basis, therefore, the Courts "...established a narrow exemption from
1 ?
NEPA for EPA determinations under section 111." '
In addition to these judicial determinations, the Energy Suonly and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to section 7(c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969."
The Agency has concluded, however, that the preparation of environmental
impact statements could have beneficial effects on certain regulatory actions.
Consequently, while not legally required to do so by section 102(2)(c) of NEPA,
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environmental impact statements will be nrenared for various regulatory actions,
including standards of performance developed under section 111 of the Clean
A'ir Act. Thi'jJ voluntaryporeparation of environmental imoaqjt statements^ however, $
in no wav legally subjects the Agency to NEPA requirements.
To implement this policy, therefore, a separate section is included in
this document which is devoted solelv to an analysis of the potential environ-
$ f
mental imnacts associated with the pronosed standards. Roth adverse and beneficial
impacts in such areas as air and water nollution, increased solid waste disposal,
j>
and increased energy consumption are identified and discussed.
2.6 IMPACT ON EXISTING SOURCES
Standards of performance may affect an existing source in either O-F two
wavs. Section 111 of the Act defines a new source as "any stationary
source, the construction or modification of which is commenced after the
regulations are proposed." Consequently, if an existing source is modified
after proposal of the,-standards, with a subseouent increase in air pollution,
it is subject to standards of performance. [Amendments to the general provisions
of Subnart A of 40 CFR Part 60 to clarify the meaning of the term modification
were promulgated in the Federal Register on December 16, 1975 (40 FR 58416).]
Secondly, promulgation of a standard of performance requires States to
establish standards of performance for existing sources in the same industry
under section lll(d) of the Act if the standard for new sources limits emissions
of a pollutant for which air quality criteria have not been issued under section TOR
or which has not been listed as a hazardous pollutant under section 112. If a
State does not act, EPA must establish such standards. [General provisions
outlining procedures for control of existing sources under section lll(d) have
been promulgated on November 17, 1975 as Subpart B of 40 CFR Part 60 (40 FR 53340). ,
2-11
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2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable bv any
industry may improve with techno!ogical advances. Accordingly, section 111 of the
Act provides that the Administrator may revise such standards from time to time, .
Although standards proposed and promulgated by EPA under section 111 are designed
to require installation of the "... best system of emission reduction . . . (taking
into account the cost). . ." the standards will be reviewed periodically, Revisions
will be proposed and promulgated as necessary to assure that the standards continue
to reflect the best systems that become available in the future. Such revisions
will not be retroactive but will apply to stationary sources constructed or
modified after proposal of the revised standards.
REFERENCES FOR CHAPTER 2
1. Portland Cement Association vs. Ruckelshaus, 486 F. 2nd 375 (D.C. Cir.
1973).
2. Essex Chemical Corp. vs. Ruckelshaus, 486 F 2nd 427 (D.C. Cir. 1973).
2-12
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CHAPTER 3. THE LIME INDUSTRY
3.1 GENERAL
In the United States, the annual production of limestone ranks second
to sand and gravel in tonnage of all commodities, and in physical volume
exceeds such large tonnage materials as petroleum, coal, and iron ore. Since
lime exists in varying amounts in nearly every country, annual world production
is virtually incalculable but has been variously estimated at 2-2.5 billion
tons in the 1960's. Lime is the world's leading reagent for use in the
treatment of both water and air pollution, and is the second largest basic
2
chemical in commercial use.
Deposits of limestone exist in every state in the U.S. and usually are
found in very large amounts. It is estimated that 15-20 percent of the
physical surface of the U.S. is underlayed with limestone. It should be
noted that even though these deposits are extensive, they are frequently
so overburdened that quarrying or mining is not economical. Because product
quality is of high concern, only a small proportion of the total limestone
production is of a grade suitable to meet the requirements demanded by industrial
processes. The lower-grade limestones are generally suitable for use in the
agricultural and building fields where the chemical composition is not a limiting
factor in their use. The total production capacity of United States lime plants
is about 22 million tons per year (1975), produced in 179 lime plants in over
40 states. From the past trends in lime usage and anticipated increase in
the uses of lime, an annual growth rate of 5 percent is expected over the next
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ten years. Most of the production (80 percent) and anticipated growth in
production will occur in lime plants that have over 100,000 tons per year
production capacities.
There is one known lime plant in the U.S. where lime is derived from
the calcination of oyster shells obtained from coastal waters. The dredging
of oyster shells is concentrated in the Texas-Louisiana gulf area where no
limestone deposits of consequence are found within 200 miles of the coast.
The four traditional major uses of lime are in agriculture, construction,
chemical and metallurgical processes, and refractory applications. In 1974,
chemical and metallurgical processes accounted for 81 percent of all lime
consumption; construction uses for 10 percent; refractory application for
3
8 percent; and agricultural uses for only one percent.
The lime industry has steadily become more capital intensive, producing
more lime with less labor per unit of output. Table 3-1 shows the employment
in the mines and plants of the lime industry in recent years.
Table 3.1 EMPLOYMENT IN THE LIME INDUSTRY IN
RECENT YEARS3
Year 1970 1971 1972 1973 1974 (est.)
Employment 8,100 6,777 7,000 7,300 7,500
Although not a major employer, the lime industry is economically
essential because many other basic industrial processes rely on the use
of lime. Curtailment of future growth or the inability to supply changing
lime markets would have a large multiplier effect on U.S. employment.
However, these developments appear unlikely as large capital productive
companies enter the picture as captive or commercial producers of lime.
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3.2 PROCESSES AND THEIR EMISSIONS
The basic processes in production of lime are (1) quarrying the limestone
v' '? s»? $ % 9
raw material, (2) preparing the limestone for kilns by crushing and sizing,
(3) calcining the limestone, and (4) processing the quicklime further by
hydration. The quarrying, crushing and sizing of limestone is being considered
in another*document. The processes covered in the proposed standards are the
calcination and hydration of the lime product. These are shown schematically
in Figure 3-1. For the purposes of this document, "limestone" is considered
to mean both calcitic and dolomitic limestone. The pertinent emissions are
^particulates from the kiln and hydrator and sulfur dioxide from the calcining
process in the kilns.
3.2.1 Calcination and Its Emissions
Limestone is subjected to temperatures of about 1100°C (2000°F) to break
it down chemically to produce quicklime and release 003. The reaction can be
shown as follows:
» CaO + C02
Calcining at this temperature produces a soft, porous, highly reactive lime.
Heating beyond this stage can result in lumps of inert, semi -vitrified material
This unreactive material is known as over-burned or dead-burned lime and is
often used in the manufacture of refractory materials. If the raw material
is not calcined sufficiently, lumps of calcium carbonate are left in tre
finished product. This is known as "underburned" lime.
In the United States, calcination is done in a variety of kilns including
the long rotary kiln, the short rotary kiln with external stone preheater, the
vertical or shaft kiln, the rotary hearth or Calcimatic kiln, and the fluidize
bed kiln. Each type has its own advantages but the U.S. lime industry apparen
3-3
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favors rotary kilns. Almost 90 percent of the U.S. lime production is processed
in rotary kiln systems.4 Virtually all kilns built in 1974-1975 were rotary
kilns and $his trend |s expected to continue in the future. One factor that
makes the rotary kiln attractive for processing lime in the future is that it
is the only kiln that can presently use coal and still maintain product quality.
As natural gas and oil have become more expensive or unavailable, many
plants using rotary kilns have modified their kilns to use coal. It is
expected that the supply of low sulfur coal will not be able to meet the increased
demand, and inevitably many plants will be forced to use high sulfur content
coal. It is estimated that by 1986, 50 percent of the lime plant new capacity
will have high sulfur coal as the only fuel available.
3.2.1.1 Rotary Kiln -
The operation of long and short rotary kilns is basically identical.
These kilns are a furnace made of heavy steel plate lined with refractory brick.
They are fired by one or combination of any of three available fuels: natural
gas, pulverized coal, or oil. The largest kiln now in operation in the U.S.
has a production capacity of almost 1000 tons of lime per day. Kilns vary in
size, ranging from about 2 to almost 5 meters in diameter and from 18 to 137
meters in length.
The kilns are installed at a 3-5° inclination on four or six foundation
piers and revolve on trunnions at 30-50 sec/revolution. Limestone is fed
into the elevated end of the kiln and is discharged as quicklime at the lower
end into the cooling system. No more than 10 percent of the kiln is filled with
limestone or lime as it moves slowly through the long cylindrical furnace in
a gentle tumbling motion. Usually cooling air is induced into the discharge
end of the product cooler and into the kiln as secondary combustion air. The
3-5
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combustion gases flow countercurrently to the flow of the stone to the charging
end, where they are used to preheat the kiln feed. In the long rotary kiln,
the exhuast gas temperature range., between 593 and 760°C. In the external
limestone preheater in the short rotary kiln, the exhaust gas temperatures
range betweei 926 and 1148°C.
Rotary kilns can handle a range of stone feed sizes between 1/4 inch and
2 1/2 inches. When the feed size range is narrow and the minimum size is
above 1/2 inch, a high degree of mixing in the bed during calcination
produces a very uniform lime. A wide range of lime qualities can be produced
from unreactive or dead-burned lime to highly active limes with CaCC>3 conter|t
between 0.2 and 0.8 percent. Low sulfur lime, less than 0,035 percent sulfur,
used by the steel industry can easily be produced in rotary kilns.
Cooling equipment used with rotary kilns is generally of two types,
/
either satellite coolers for finer materials or contact-type coolers for
coarse lime. Satellite coolers have less heat recovery but less maintenance
and operating costs. Contact coolers have considerably more heat recovery
but higher operating costs and appreciable head room requirements. Rotary
coolers and grate type coolers are secondary choices in the lime industry.
The major heat losses in a rotary kiln system are the heat in the lime
c]i charged from the cooler, the radiation loss from the kiln itself, including
the preheater, cooler, and other accessories, and the heat in the exit gas.*
The heat that is used for calcination is transferred in three ways. The major
heat transfer in a rotary kiln is by gas radiation from the hot flame and
combustion gases. A much smaller amount of heat transfer results from brick
radiation. The third and minor portion of heat transfer is due to convection
when the hot gas stream comes in direct contact with the charge in the kiln.
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There is not much that can be done to increase radiation heat transfer,
but heat transfer by convection can be greatly increased by additional mixing.
if This mixini can be increased by dams, internal recuperators, trefoil § and
lifters. Some of the increased convection heat transfer is offset by slight
4 '
reduction .in the radiation heat transfer.
M
in
The addition of internal mechanical mixing devices insures against
horizontal stratification when the charge has a wide range of sizes. In
long rotary kilns without internal mixing devices, the center of the charge
in the kiln receives relatively little heat. This is because the fine
particles insulate the charge from the brick lining and the larger particles
roll over the top of the charge and receive most of the flame radiation.
Thus, a kidney-shaped core of unreacted limestone can be left in a medium-
sized feed. This problem can be solved by installing internal mixers,
reducing the loading to the kiln, or feeding a smaller size limestone.^
If a kiln is to be run at full capacity with wide-sized feed, internal mixers
must be added. However, the benefits of adding these devices will be offset
to some extent by increased maintenance costs, higher dust loads in the exit
gas, and larger amounts of fines in the product.
consumption of long rotary kilns generally averages 7.0 to 8.0 x
106 Btu per ton of lime produced while electric power consumption ranges from
24 to 32 kw hr per ton of lime produced. These calculations depend upon the type
of firing and dust collection systems used. It should be added that heat
transfer in rotary kilns is largely by radiation. Because long kilns have
high surface radiation losses as well as exit gas losses, reducing the kiln
length and replacing radiation heat transfer with direct gas contact and
convection heat transfer results in lower exit gas temperatures as well as
3-7
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lower fuel consumptions. Efficient short kilns with preheater systems operate
between 5.0 and 6.0 x 10 Btu per ton of lime; however, energy figures are
somewhat higher than for long rotary kilns: 32 to 36 kw hr per ton of lime
depending on the firing system used. Space requirements for preheater systems
are approximately 60 to 70 percent less than for long kilns. Preheater kiln
systems are particularly efficient when equipped with contact-type coolers.
The use of preheater systems is limited to feed materials which do not decrepitate
or degrade during calcination.
The capacity of the short rotary kiln is high, similar to that of the long
rotary kiln, but the size will presumably remain smaller because of preheater
designs.
Acceptable feed sizes for short kilns with preheaters are more limited
than for long rotary kilns. Usually the minimum is 3/8 of an inch and the
maximum is 1 3/4 inches. All available fuels and combinations can be used in
a short kiln and the quality of the product is comparable to that of long
rotary kiln limes. Mixing and bed motion in the calcination zone occurs to
the same degree as in long rotary kilns but the material is exposed to the
bed motion for a much shorter time. Feed is motionless on the grate-type
preheaters and only in very slow and gentle motion in the shaft-type preheater.
Therefore, material degradation and dust production is reduced in preheater
systems.
Dust collection in preheater systems is further reduced by lower gas
quantities being handled, which result from lower fuel consumption and lower
exit gas temperatures. The preheaters also act as dust filters. This is
particularly true of shaft type preheaters because of their generally higher
bed.6
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3.2.1.1.1 Model plant - A plant producing 500 tons of lime per day was chosen
to be the model plant for the industry. Table 3-2 shows the characteristics
of this plant. Defining a model plant is necessary in order to determine
the various impacts of the control options discussed in Chapter 6. The
expected growth in the lime industry is discussed in terms of the number of
additional affected model plants per year. The effect the control options
will have on the energy usage and emissions of the lime industry may be then
quantified.
3.2.1.1.2 Other considerations - There can be significant sulfur dioxide ($02)
emissions from rotary lime kilns. Sulfur is found in most limestone and in
all fuels used in the industry except for natural gas. During fuel combustion
and calcination, most of this sulfur is converted to SO^. Some of the S0£
will react with the lime product or with the lime dust and some will be emitted
with the kiln off-gas as S02. The amount of S02 that reacts with the lime
product or lime dust will depend on the chemical composition of the stone,
the temperature in the kiln, the amount of excess oxygen in the kiln and
4
the amount and particle size of the dust inside the kiln.
The sulfur in the limestone feed does not normally contribute to a substantial
portion of the total S02 emissions from a rotary kiln. Most of the limestone
sulfur remains in the lime product. The major concern with respect to S0?
emissions from rotary kilns is the sulfur content of the fuel. When natural
gas is fired, there are negligible S02 emissions. When coal or oil with
sulfur content less than 1.0 percent is used, up to 100 kilograms (220 pounds)
of S02 may be produced but only about 10 percent of the sulfur in the fuel
is vented to the atmosphere as S02. When high sulfur content coal is burned,
a smaller percentage of the S02 is removed before the gases are exhausted
3-9
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Table 3-2. UNCONTROLLED MODEL LIME PLANT3
Feed
Product
Heat required
Yearly operation
Coal heat content
Coal usage
Electric Power usage
Dust load to cyclonic separator
Dust load from cyclonic separator
Potential $03 from coal
1.0% coal
3.0% coal
NOX emissions
CO emissions
Gas flow to control
jas flow to control device per ton lime
1,000 tons stone/day
500 tons lime/day
6.5 x 106 Btu/ton lime
330 days per year
12,500 Btu/lb coal
130 tons coal/day
32 kw hr/ton lime
7,100 pounds/hr
2,130 pounds/hr
200 Ib/hr
650 Ib/nr
60 Ib/hr
20 Ib/hr
48,000 SCFM (13.7% H20)
41,000 DSCFM (8.2% 02)
138,000 SCF (13.7% H£0)
119,000 DSCF (8.2% 02)
aAssumes "uncontrolled" plant to use cyclonic separators except for systems
which use a baghouse.
bAssume an average dusting rate as percentage of lime produced of 17%.
3-n
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and the SC^ emissions can become significant. It is estimated that the
uncontrolled emission of S02 would be as high as 38 kg/hr (84 Ib/hr) for the
model 500 tons of lime/day plant when it is using 3.5 percent sulfur coal
(see EPA test data, Appendix C, Table C-2).
There are also carbon monoxide (CO) and nitrogen oxide (NOX) emissions
from rotary kilns. These emissions are shown for the model plant in Table 3-2.
The presence of oxygen and CO in the exhaust is not theoretically possible
but it occurs due to the incomplete mixing of the gases in the kiln. The
concentration of CO in the off-gas can vary widely, from 15 to 580 parts
per million in the EPA tests, depending mainly on the amount of excess oxygen
in the kiln. Most lime kiln operators will try to keep both the oxygen and
CO levels in the kiln off-gas below 0.5 percent during normal operations.
The formation of NOX also depends upon the excess oxygen in the kiln, but
it is the operating temperatures which determine the level of NOX. Operating
temperatures are normally fixed depending upon the type of product that
is being made. NOX emissions also vary widely, from 38 to 363 parts per million
in the EPA tests. (See Appendix C.)
3.2.1.2 Other Kilns -
3.2.1.2.1 Vertical kiln - At one time, the vertical kiln, or shaft kiln,
was the most widely used in the United States. Although may vertical kilns
remain in operation in the U.S., the total capacity of the vertical kiln
has fallen well behind that of the rotary kiln. This kiln design is basically
an upright heavy steel cylinder lined with refractory material. Kiln dimensions
may vary from about 3 to 8 meters in diameter and from about 11 to 31 meters
in height with an average size of 3.7 by 16 meters.
In principle, most modern vertical kilns are divided into four largely
imaginary zones that are often indistinguishable from each other. The
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proportioning and contouring of these zones constitute the "art" of vertical -
kiln design. These zones from top to bottom are:
1. Storage. This is located at the top of the kiln and acts as a
storage hopper or silo to receive the kiln feed.
2. Preheating. In this zone waste or recirculated exhaust gases
preheat the stone preparatory to calcination in the zone below.
3. Calcining. This is the calcination chamber where at least 95 percent
of lime burning occurs. The lower portion of this zone is often called the
finishing zone where calcination is completed.
4. Cooling. Cool air enters this zone from the base of the kiln or
discharge point and by natural or forced draft or by suction passes counter-
current to the lime descending down the kiln. The air cools the lime but
recoups much of the heat as secondary combustion air for the calcining zone
above. The cooled lime is discharged onto conveyors below the kiln.
Many variations of the shaft-type kiln have been designed and are
operating. Most of the more sophisticated and higher capacity kilns have
been developed in Europe because of the appreciably higher fuel costs.
A primary advantage of vertical kilns over rotary kilns is the higher
average fuel efficiency. The primary disadvantages of the vertical kiln are:
(1) its relatively low production rate as compared to the rotary or rotary
hearth kiln and (2) the inability to burn solid fuel (coal) without degradation
in the quality of the lime. Of the fourteen known lime kiln installations built
Q
in the U.S. since 1969, none were vertical kilns.
3.2.1.2.2 Rotary hearth kiln - The rotary hearth kiln, or Calcimatic kiln,
is a circular-shaped kiln with a slowly revolving donut-shaped hearth. The
circular refractory hearth is supported on two concentric tiers of rollers
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that can be operated at various speeds of 35-200 min/revolution. The remainder
of the kiln is stationary. The hearth is divided into zones, and through
instrumentation precise temperatures can be maintained at these different
zones. Heat is supplied by multiple natural gas or oil burners, and the
limestone is fed from a preheater chamber onto the hearth.
The hearth will accomodate a rather wide range of stone sizes, including
relatively broad graduations, such as 1/4 to 4 inches. The stone is distributed
in an even bed of one-to-six inch depth.
The finished lime is scraped off about 350° around the circle from the
point where the feed limestone is spread onto the hearth. The heated gases
from the calcination zone of the kiln are passed through the feed limestone
for preheat purposes, similar to the procedure in the vertical kiln. In
some cases, the cooling of the lime product is done in an indirect
heat exchanger where the burner combustion air is preheated, thus adding
to the fuel economy.
The rotary hearth kiln combines the advantages of the rotary kiln
and the vertical kiln in that a high production rate can be achieved with
low dust emissions. Here again, however, the kiln cannot be operated with
solid fuel.
3.2.1.2.3 Fluidized bed kiln - Fluidized bed kiln systems have found limited
application in the lime industry because of their narrow feed size requirements.
This patented kiln utilizes a very fine particulate kiln feed of No. 8 to
No. 65 mesh that is fluidized or air-floated by controlled air and combustion
gases as it descends through preheating and calcining zones. The finely
divided limestone is brought into direct contact with hot combustion air
in a turbulent zone, usually above a perforated grate. The stone is physically
tossed and bounced about by the turbulent air and quantities of dust are
carried out of the reaction zone by the combustion air.
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3.2.1.2.4 Kiln emissions comparison - A comparison of the four types of kilns
in terms of uncontrolled participate emissions reveals the fluidized bed kiln
to have the highest uncontrolled dust output. This is due primarily to the
very small feed size combined with the high air flow through the kiln. The
long rotary kiln is second to the fluidized bed kiln in uncontrolled parti-
culate emissions. This i$ attributed to the small feed size and dusting
caused by rolling of the feed through the kiln. Short rotary kiln with
external preheater and the rotary hearth or "Calcimatic" kiln rank third
in dust production, primarily because of their larger feed size combined
with the fact that the limestone remains in a stationary position during
calcining. The vertical kiln has the lowest dust emission during operation.
This is attributed to the large lump-sized feed and the slow movement of
the feed material through the kiln.^
3.2.2 Hydrationand Its Emissions
Although most lime produced is sold as lime, a small amount (10 percent
in 1974) is converted into slaked lime or hydrated lime. The reaction can
be shown as follows:
CaO + H20 + Ca(OH)2
In most hydration plants water Is added to the lime in a pug mill premixer
where there is thorough blending of the lime and water. The lime-water mix
then goes to the agitated hydrator where most of the chemical reaction takes
place. The reaction is exothermic and the heat of reaction converts part
of the water in the mix to steam. A fan maintains a slight negative pressure
in the hydrator and the steam is discharged to the atmosphere along with any
air that enters the hydrator through the charging port. Hydrator emissions
are normally controlled by the use of either water sprays in the hydrator
stack or by wet scrubbers. The resulting slurry or milk of lime is usually
3-14
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returned to the prenrixer as part of the slaking water. Virtually all hydrators
o
have this equipment integrally installed. Occasionally a rate retardent is
added to the mixture in order to control the heat of the reaction. The
amount of water added is critical. If too much water is added, it will
be impossible, or require costly drying, to produce the desired dry form.
If too little water is added, incomplete hydration will cause a lowering of
product quality. If the hydration is done properly, the resulting product
should be in the form of a fluffy, micron-sized, dry, white powder.
A plant that hydrates 14 tons of lime per hour and produces 17 tons per
hour of hydrate was chosen to be typical for the hydrate process. Table 3-3
presents a listing of the characteristics of this plant, which is used as
a base for assessing the impacts due to each control option discussed in
Chapter 6.
Table 3-3. TYPICAL LIME HYDRATE PLANT
Feed 14 tons of lime per hour
Yearly operation 4700 hours per year
Product 17 tons of hydrate per hour
Gas flow to scrubber 6,000 ACFM (85% H20 + 175°F)
700 DSCFM
Gas flow from scrubber 10,000 ACFM (47% H20 + 175°F)
4,400 DSCFM
Dust load to scrubber 1,200 pounds/hr
3.2.3 Fugitive Emissions
The uncontrolled fugitive particualte matter emitted from transfer points,
screens, and loading operations in lime plants have not been qualified, and
are thought to vary widely depending on individual plant practice. In an old
3-15
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plant there can be as many as 30 of these miscellaneous sources. A new,
well designed plant would probably have fewer than 15. The amount of
particulate in the uncontrolled emissions is estimated at about 5 pounds
per ton of lime. Based on this estimate, fugitive emissions may account
for as much as 10 percent of the total particulate emissions at typical
lime plants.
3-16
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REFERENCES FOR CHAPTER 3
1. "Environmental Impact Statement for Lime Plants," prepared by Midwest
Research Institute for the U. S. Environmental Protection Agency, Contract
No. 68-02-1324, Task No. 33, December 1975.
2. Minnick, L. John, "Control of Participate Emissions from Lime Plants-
A Survey" Air Pollution Control Association Journel, April 1971.
3. U. S. Bureau of Mines, January 1975, Commodity Data Summary.
4. Schwartzkoph, Florian, "Lime Burning Technology - A Manual for Lime Plant
Operators," Kennedy Van Saun, 1974.
5. Bunyard, F. L., EPA Trip Report of visit with F. Schwartzkoph of Kennedy
Van Saun (September 29, 1975).
6. Schwartzkoph, Florian, "A Comparison of Modern Lime Calcining Systems,"
Rock Products, July 1970.
7, "Study of Technical Cost Information for Gas Cleaning Equipment in the
Lime and Secondary Non-Ferrous Metallurgical Industries," Industrial Gas
Cleaning Institute, Incorporated; December 1970.
8. "Screening Study for Emissions Characterization from Lime Manufacture,"
prepared by Vulcan-Cincinnati, Incorporated for the U. S. Environmental
Protection Agency, Contract No. 68-02-0299, Task No. 7, August 1974.
9. Schwartzkoph, Florian, "Heat Transfer in Rotary Lime Kilns," Pit and
Quarry, September, 1969.
3-17
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CHAPTER 4. EMISSION CONTROL TECHNOLOGY
The various devices that are used to control emissions from the calcination
and hydration processes at lime manufacturing plants are described in this
chapter. The presentation discusses the types of devices presently in service
in the industry, and the levels of emission reduction attainable by each. The
levels of emission reduction are derived from EPA tests, other tests performed
by state and local agencies, industry tests, and vendor guarantees.
4.1 CALCINATION EMISSION CONTROL TECHNOLOGY
Four types of emission control are used to control particulate matter
from rotary lime kilns. These devices are:
1. Baghouse
2. Electrostatic Precipitator (ESP)
3. Venturi scrubber
4. Gravel Bed Filter
All of these control devices can be designed to attain very high collection
efficiencies. There are advantages and disadvantages associated with the
use of eacn device.
The rotary kiln off-gas to these devices is the same as the one described
in Chapter 3. Table 3-2 gives the parameters of this off-gas stream for the
model plant.
4-1
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4.1.1 Baghouse
When baghouses are used for controlling dust emissions from rotary kilns,
tubetype, glass fiber bags with graphite and silicone finishes are specified.
Some form of gas cooling is required since these bags cannot withstand temperatures
above 288°C (550°F) and the kiln exhaust temperature is generally in excess of
538°C (1000°F). This cooling can be achieved by (1) evaporative water sprays,
(2) indirect radiation convection heat exchange, (3) ambient air dilution,
(4) external stone preheater, or (5) a combination of these. The fabric filter
bags are typically 5 to 12 inches in diameter, 10 to 30 feet long, and weigh
14 to 18 oz. per square yard. Generally a baghouse has from 4 to 12 individual
compartments containing 200 to 600 bags each.
The bags are used as a filter media to remove the dust from the gas stream.
As the dust-laden gas is forced through the fabric, the dust collects on the
fabric, forming a cake which also helps in the filtration. Fabric filter
effectiveness is primarily a function of kiln exhaust particle size distribution,
fabric type, fabric age, and maintenance history. Pressure drops of around
5 inches water column (IWC) are typical for fabric filters used in the lime
industry. At some preset time interval, one of the compartments is taken off
Tin; and a reverse gas flow is forced through the fabric, releasing the cake.
The cake of dust falls into a hopper where it is sent by pneumatic or screw
conveyor to eventual disposal.
When one compartment is off-line for cleaning, the total available filtration
area is reduced. Therefore, filter units are designed on the basis of air-to-
cloth ratios (cubic feet per minute of air per square foot of cloth) for the
total unit with one compartment off-line for cleaning. Air-to-cloth ratios
for lime kiln exhaust are nominally 2.2/1 when one compartment is off-line.
4-2
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Properly designed and operated baghouses will have a bag life of from 22 to
34 months.^
Baghouses have the primary advantage of offering the highest average parti-
culate collection efficiency for lime kiln exhaust gas treatment. They are also
tolerant of process upsets that lead to short-term heavy loadings. The dry
waste dust can potentially be used for a variety of purposes as described in
Chapter 6. The main disadvantages of the fabric filter collector are (1) large
physical size space requirement, (2) high capital cost, and (3) high maintenance
cost.
Of the lime plants tested by the EPA, the plants controlled by baghouses
averaged the lowest particulate emission rates. (See Appendix C, Table C-l.)
In tests performed at two separate lime plants, the average emissions were
0.041 and 0.111 kilogram of particulate per megagram of feed (0.082 and 0.222
Ib/ton). The particulate concentrations for the two plants were 0.01 and 0.05 grams
per dry standard cubic meter. At the low concentrations found in the EPA
tests, there are normally no visible emissions; the only visible emissions recorded
were those seen for a few seconds when a compartment went back on line after
cleaning. The visible emission readings taken during the particulate testing are
also summarized in Appendix C. The maximum six-minute average opacity that was
observed during the particulate testing normalized to a 3.0 meter stack
diameter was 7.0 percent; over 95 percent of the six-minute averages were
zero and all of the readings were less than 10 percent. In a non-EPA test of
three other baghouses, an average emission of 0.13 kilogram of particulate
per megagram of limestone feed (0.27 Ib/t) was found.3
The S02 emissions from rotary lime kilns controlled by baghouses are shown
in Figure 4-2 and in Appendix C. These data indicate a wide range of S0£ removal
efficiencies, which ranged from 82 to 93 percent removal. There appears to be a
relationship between the S02 removal efficiency and the percent sulfur in the CD.-...
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Generally the less sulfur there is in the fuel used to fire the kiln, the
better the percent S02 removal.
4.1.2 Electrostatic Precipitator
An electrostatic precipitator (ESP) is a device that utilizes electric
forces to separate suspended particles from gases. Two basic criteria must
be met before an ESP can be utilized: (1) the suspended particle must be
able to accept an electric charge and (2) the particle must th°n pass through
an electric field of sufficient strength to insure reMOval of the particulate
from the gas stream at the desired efficiency.
Precipitators for lime kiln application are of the dry, horizontal flow
type construction common to many other applications. Since they are constructed
of carbon steel, the kiln gas must be cooled to an acceptable temperature by
a method similar to those described for the baghouse. Evaporative cooling
is preferred because it results in a lower final gas flow and the moisture
added improves the dust precipitability. Precipitability is a function of
the chemical composition of the dust particles, and will vary with the different
kinds of material that make up the kiln exhaust dust (limestone, quicklime,
flyash, calcium sulfate, etc.).
The kiln gas enters the precipitator and flows through passages created
by parallel rows of grounded collecting plates. Discharge electrode wires,
supplied with high voltage negative direct current and centered in each passage
between a pair of the grounded plates, charge the particles negatively. The
ionized dust particles migrate toward the grounded collecting plates where
they lose their charge and fall by gravity into hoppers. Programmed rapping
of the electrodes is also required to keep the collector plates and discharge
electrodes clean.
4-6
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For an ESP to function optimally, the gas should be evenly distributed
across the collectors. These plates should have the maximum voltage and
power possible without sparking. The two main factors influencing the
efficiency of a precipitator are the gas velocity and treatment time. Thus,
higher efficiencies are attained in any process by increasing the precipitator
size. Although virtually any desired efficiency can be obtained, normally
precipitators operate in the range of 90 to 99 percent particulate removal.
The primary advantages of the electrostatic precipitator are apparent in
the cases where "dry" collector systems are required. In these instances,
electrostatic precipitators require amounts of space similar to that required
by a baghouse, although the operating costs are found to be lower. The
resulting waste is a dry dust which may be disposed of in a variety of ways
as described in Chapter 6. The major disadvantages of this collector are
its high capital cost and its relatively low collecting efficiency on submicron
particles. A high level of maintenance skill is needed to keep an ESP in
operation at design conditions. In addition, a potential fire hazard exists
during start-up periods if flammable dusts or fuels accumulate in the discharge
zone of the precipitator.
The results of EPA particulate emission testing at two lime plants utilizing
electrostatic precipitators are presented in Figure 4-1. The particulate
emissions in three tests of these two plants ranged from 0.015 to 0.082 g/dscm
(0.0068 to 0.036 gr/dscf). The emissions from plant C averaged 0.068 kg/Mg
of stone feed (0.135 Ib/ton). The emissions from plant D averaged 0.133 and
0.141 kg/Mg of stone feed (0.266 and 0.282 Ib/ton) in two separate emission
tests. Neither of the plants tested by EPA used coal for fuel; one burned
natural gas and the other operated on a mixture of oil and natural gas. A
third plant, not tested by EPA, that operates on coal and 20-30 percent natural
gas also has 99-plus percent collection efficiency.
4-7
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This plant uses an atomized water spray to cool the kiln gases and to assist
the dust precipitability. The dust-laden gases then enter a three-chamber
5
ESP where the dust is removed.
There ar
-------
separator, may be used for collection. Gas-water contact in the venturi is so
thorough that even the submicron particles are removed. The efficiency of par-
ti cul ate removal is a direct function of the energy input, measured by the
pressure drop across the venturi throat. Throat pressure drop can range from
8 to 40 inches of water column (IWC), depending upon the particle size and
the degree of cleaning required. For high removal efficiency of particulate
matter in emissions from rotary kilns, it is estimated that a pressure drop
of about 22 IWC is necessary. This number was derived from extrapolation of
known data and expert opinion.
The primary advantages of the venturi scrubber are its small space require-
ment and its low capital cost. However, the venturi scrubber also has several
disadvantages. Although low pressure drop scrubbers use less energy than
high pressure drop scrubbers, even a low efficiency scrubber with a 9 IWC
pressure drop requires more energy than any of the other high efficiency
control devices discussed in this chapter. Scrubbers require ponds for
separation of the collected particulate from the scrubbing water, which is
then reused. These ponds must be located so that they do not receive excessive
rainwater run-off, which could cause overflow into local navigable waters.
Such an overflow is prohibited by Federal regulation unless it occurs as a
result of a 25-year rainfall occurring over a 24-hour period. In such a
case only an amount of water equal to the rainfall excess can be legally
o
discharged. Some plants would not have suitable land area available for
these settling ponds, in which case the plants could use slurry settling tanks
to dewater the slurry product requiring minimal land area for water treatment
q
and solids disposal.
There are few high pressure drop scrubbers (22 IWC) in use on U.S. rotary
lime kilns. In a non-EPA test of a lime kiln operating at 100 percent of
4-9
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capacity, participate emissions averaged 0.134 kg/Mg of stone (0.267 Ib/ton).
The scrubber used to control emissions from this kiln was designed for 22 IWC
but was operating at only 17 IWC during testing.^ The results of EPA particu-
late emission tests on one kiln scrubber operating at 15 IWC are shown in
Figure 4-1. The emissions ranged from 0.048 to 0.72 g/dscm (0.021 to 0.32
gr/dscf) and aver?qed 0.062 g/dscm (0.0274 gr/dscf). The average process
weight emission rate was 0.216 kg of particulate per megagram of limestone feed
(0.431 Ib/ton). Few visible emission readings were teken during the particulate
tests on this kiln because the large steam plume made all possible readings
suspect. There did appear to be some visible emissions, but they could not
be quantified.
In two other tests, one on the same scrubber at a lower (11-12 IWC)
pressure drop and another on a similar scrubber with a 15 IWC pressure
drop,12 average process weight particulate emission rates of 0.232 and 0.163
kg/Mg of stone feed (0.463 and 0.326 Ib/ton), respectively, were found.
Venturi scrubbers give excellent control of S02 emissions when applied
to lime kilns. EPA tests on three separate kilns show efficiencies of S02
removal in excess of 98 percent. (See Appendix C, Table C-2.) On a rotary
kiln burning 1.86 percent sulfur coal, the inlet S02 concentration averaged
162 ppm while the outlet concentration was near zero (Dynascience continuous
monitor used). On a lime kiln burning high sulfur coal (3.53 percent sulfur),
the inlet loading was 265 kg/hr (585 Ib/hr) of S02 while the outlet was
U3 kg/hr (2.9 Ib/hr), a reduction in excess of 99 percent. jQn _a dead-burned
jtoloirn'te-kiln burning high sulfur coal (2.96 percent sulfur), the emission
reduction due to the scrubber was measured as 160 to 3.5 kg/hr (350 to 7.8 Ib/hr),
a reduction of about 98 percent.
4-10
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Lime slurry scrubbers can also be used in series following baghouses or
ESP's to control the SC^ emissions from rotary lime kilns. These scrubbers
have different designs than scrubbers designed for particulate control. The
pressure drop required would be less and the residence time would be greater.
Although no combination device of this sort is now in operation on any U.S.
lime kiln, it is not uncommon in the utility industry. It is estimated that
such a combination would give S02 and particulate control with less energy
use than a high energy (22 IWC) scrubber alone. The combination device
would, however, have a capital cost almost double that of a single device
used alone.
4.1.4 Gravel Bed Filter
Gravel bed filters have only recently been applied to U.S. rotary lime
kiln emissions although they have been widely used in Europe. Gravel bed
filters clean exhaust gases in three steps.^First the gas enters the filter
and loses velocity so the large chips can settle out. The medium sized
particles are removed by cyclonic separation. Finally the smallest particles are
removed by agglomeration as they pass through a filter medium of crushed stone.
The cleaned gas is then vented to the atmosphere. Usually six to fourteen filters
are used in parallel. In some cases each of these filters is placed in series with
13
a second filter for greater economy and space saving.
Accumulated dust is removed by isolating one of the gravel beds and reversing
the air flow through it. After a short time lag the gravel bed is raked by a
mechanical stirring device. The dust laden cleaning air then goes to a cyclone
and a settling chamber where its velocity is reduced and most of the dust settles
out. The cleaning air is then sent to the other gravel beds for filtering. The
14
cleaned gravel bed is then put back on line and another filter is cleaned.
4-11
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There are several advantages to using the gravel bed filter for lime
kiln off-gas. There is no need t Change or repair the filter media, no
need for water, and the maintenance costs are small with little down time.
The waste dusu is dry and saleable assuming a market can be established.
The major disadvantage associated with the gravel bed filter is the high
operation costs due to the pressure drop which can be as high as 10 IWC.^
No EPA tests were performed on gravel bed filters. Seven source tests
on a plant using 8 gravel bed filters showed a parti cul ate process weight
emission rate that ranged from 0.243 to 0.5 kg/Mg of stone feed (0.487 to 1.00
Ib/ton) J4 In a second source test on a plant using 20 gravel bed filters
to control a 725 megagram (800 tons) of lime per day preheater kiln, an average
particulate process weight emission of 0.14 kg/Mg of limestone feed (0.28 Ib/ton)
was found. In this test there was a 1 s o a 93 pejxent removal j3f_S0 through the
system with an average emission of 17 parts per million of S02-
4.2 HYDRATION EMISSION CONTROL TECHNOLOGY
As stated in Chapter 3, uncontrolled hydration emissions consist of
particles of hydra ted lime in a very moist 99°C (210°F) gas stream. There
are no gaseous pollutants present. Hydration emissions have been shown to
be most effectively controlled by wet scrubbers, but a baghouse has been
used in at least one case. In order to use a baghouse, however, the exhaust
gas must be superheated in order to avoid condensation of the near saturated
gas stream. Therefore, wet scrubbers are the only system of emission reduction
considered for this facility.
The most common type of scrubber used on lime hydrators is the wetted
fan type with centrifugal separation. Water is sprayed into the center of
the draft fan and is thus forced to mix with the gas stream. More water is
4-12
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sprayed into the duct carrying this gas-water mixture just after the fan.
The dust-laden slurry water is then removed from the cleaned gas stream by
centrifugal separation. The water-saturated gas is then vented to the atmosphere.
The slurry water is returned to the hydrator pre-mixer as part of the slaking -
water. This utilization of the scrubber effluent eliminates the settling
ponds and waste sludge disposal problems usually associated with particulate
scrubbers.
The results of two EPA source tests and of one plant source test on lime
hydrators are presented in Figure 4-3 and summarized in Appendix C. The
average particulate process weight emission rates measured were 0.042 and 0.059
kg/Mg of lime feed (0.084 and 0.117 Ib/ton) for the EPA tests, and 0.034 kg/Mg
of lime feed (0.068 Ib/ton) for the plant test. The average concentrations
were 0.066 and 0.423 g/dscm (0.029 and 0.186 gr/dscf) for the EPA tests and
0.055 g/dscm (0.024 gr/dscf) for the plant test. A large steam plume made
visible emission readings very difficult; however, one hour of observation
was made and no visible emissions were noted.
4.3 FUGITIVE EMISSION CONTROL TECHNOLOGY
Many potential sources of fugitive particulate emissions exist at a lime
plant. They include transfer points, screens, and loading operations. Proper
design and layout of the lime plant, such as minimizing the height and number
of drop points and using enclosed elevators and screens will greatly reduce
emissions. To further control the fugitive emissions, hoods can be placed
over the exit sources. The dust-laden gases are then ducted to a control
device, usually a baghouse, where the particulates are removed. Since the
gas is at ambient temperature, no special bag fabric is needed although poly-
propylene appears to be best suited for this application. The dust from the
product handling operations can then be briquetted and returned to the system
or sold as dust for v/ater treatment.
4-14
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With adequate pickup velocity through a hood visible emissions from a
fugitive emission point should be very low. If the elevators and screens are
enclosed and vented to a control device they should also have very low visible
emissions. Little data or information is available, however, which identifies
to what extent the use of hoods or various other types of enclosures would
reduce visible emissions. Consequently, the performance of these emission
control techniques cannot be quantified.
4.4 STATE REGULATIONS
In most States, new lime plants are subject to (1) general process weight
regulations designed to limit particulate emissions from any source and
(2) regulations designed to limit S0£ emissions from all fuel-burning sources
and based on the Btu content of the fuel combusted expressed in millions of
Btu's per hour. For the 907 megagram (1000 ton) per day limestone feed model
kiln, the average State regulation will allow 0.5 kilogram of particulate
matter per megagram of stone feed (1.0 Ib/t) and 3.1 kilograms of S0£ emissions
per megagram of limestone feed (6.2 Ib/t). The average State regulation
for control of emissions from the typical hydrator is 0.5 kilogram of parti-
culate per megagram of lime feed (1.0 Ib/t).
4-15
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References
1. "Study of Technical Cost Information for Gas Cleaning Equipment in
the Lime and Secondary Non-Ferrous Metallurgical Industries," Industrial ,
Gas Cleaning Institute, Incorporated; December 1970.
2, Gage, Oames R., "Glass Bag Filters for Lime Kiln Exhaust," Journal of the Air
Pollution Control Association, January 1976.
3. Lime Kiln Atmospheric Emission Evaluation at United State Lime Company,
Henderson, Nevada, Clark County Health Department, Las Vegas, Nevada,
June 2, 1972.
4. "Screening Study for Emissions Characterization from Lime Manufacture,"
prepared by Vulcan-Cincinnati, Incorporated, for the U. S. Environmental
Protection Agency, Contract No. 68-02-0299, Task No. 7, August 1974.
5. "Ohio Lime Plant Initiates Use of Electrostatic Predpitators," Rock
Products, July 1971.
6. "Kinpactor Venturi Type Wet Dust Collector," American Air Filter Bulletin
Number 294-B.
7. "Fan Engineering," Buffalo Forge Company, Edited by R. Jorgenson, second
edition, 1970.
8. "Inorganic Chemicals Manufacturing Point Source Category," Federal Register
39 FR 9621 (March 21, 1974).
9. "Air Pollution Control Technology and Costs: Seven Selected Emission Sources,"
EPA publication 450/3-74-060, December 1974.
10. Stack Measurements at Austin White Lime, McNeil, Texas, State Department of
Health, October 13-14, 1971.
11. Dale, John, EPA Trip Report of Inspection of Lime Plants Using Wet Scrubbers
and a Gravel Bed Filter, May 1975.
4-16
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12. Alabama Air Pollution Control Commission Particulate Emission Test of
Facility Number 411-0017, May 1974.
13. "Gravel Bed Dust Collector," Rexnord Air Pollution Control Division.
14. "Gravel Bed Filters for Lime Kilns," Presentation at the convention of
the National Lime Association, J. A. Schuler, November 1972.
15. Hustvedt, K. C., and Evans, L. B., EPA Trip Report of visit with Bethlehem
Mines Corporation, Hanover, Pa., November 18, 1975.
16. "Impact of New Source Performance Standards on 1985 National Emissions
from Stationary Sources," prepared for the U.S. Environmental Protection
Agency by The Research Corporation of New England, Contract No. 68-02-1382,
Task No. 3, October 24, 1975.
17. "Environmental Impact Statement for Lime Plants," prepared by Midwest
Research Institute for the U.S. Environmental Protection Agency, Contract
No. 68-02-1324, Task No. 33, December 1975.
4-17
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5. MODIFICATION AND RECONSTRUCTION OF ROTARY LIME KILNS
AND LIME HYDRATORS
The proposed standards apply to all affected facilities constructed or
modified after the date of proposal of the proposed standards. Provisions
applying to modification and reconstruction were originally published in the
Federal Register on December 23, 1971. Clarifying amendments were proposed
in the Federal Register on October 15, 1974 (39 FR 36946), and final regulations
were promulgated in the Federal Register on December 16, 1975 (40 FR 58416).
Modification is defined as "any physical change in, or change in the
method of operation of, any existing facility which increases the amount of
any air pollutant (to which a standard applies) emitted into the atmosphere
by that facility or which results in the emission of any air pollutant (to
which a standard applies) into the atmosphere not previously emitted."
Reconstruction occurs when components of an existing facility are replaced to
such an extent that:
(1) The fixed capital cost of the new component exceeds 50 percent
of the fixed capital cost that would be required to construct a comparable
entirely new facility, and
(2) It is technologically and economically feasible to meet the
applicable standards.
In the case of reconstruction, the reconstructed facility is covered by the
standard whether or not an increase in emission occurs.
There are certain circumstances under which an increase in emissions
does not result in a modification. If a capital expenditure, that is less
5-1
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than the most recent annual asset guideline repair allowable published by
the Internal Revenue Service (Publication 534), is made to increase capacity
at an existing facility and also results in an increase in emissions to the
atmosphere of a regulated pollutant, a modification is not considered to have
occurred. However, all potential modifications have to be reported even
if it can be proven that there was no increase in emissions to the atmosphere.
Other cases under which an increase in emissions does not constitute a modifi-
cation occur when the increase is caused by an increase in capacity throughput
or a change in the type of fuel being used when these changes do not involve
a change in the original design of the facility. Additionally, if an increase
in emissions has occurred which could be considered a modification, the
amount of increased emissions, in kg per hour, may be traded off by reducing
emissions of the same pollutant from another facility within the same plant
as long as it can be shown that the total emissions of that pollutant from
the plant has not increased. This is referred to as the "bubble concept".
The purpose of this chapter is to identify some of the potential modifi-
cations and reconstructions of affected facilities, and any exemptions or
special allowances covering changes in existing facilities that should be
considered. Exemptions from the regulations may be based on availability
of technology and economic considerations;
The following physical and operational changes of rotary Time kilns were
considered:
(1) Conversion from natural gas or fuel oil to coal firing;
(2) Adding a limestone preheater to an existing kiln;
(3) Adding internal baffling to an existing kiln to increase mixing;
(4) Expanding the capacity of the production limiting component of the
facility (debottlenecking).
5r2
-------
There are no anticipated modifications for lime hydrators. If, however,
a process modification does occur that would potentially increase emissions
to the atmosphere, the increase in emissions could be controlled by either
increasing the pressure drop across the water scrubber or by adding additional
scrubbing water and maintaining the same pressure drop across the water scrubber.
5.1 CONVERSION FROM NATURAL GAS OR FUEL OIL TO COAL FIRING
An existing rotary lime kiln that burns natural gas or fuel oil may be
converted to burn coal. If the kiln was not originally designed to burn the
alternative fuel, the conversion will constitute a modification if there is
an increase in emissions to the atmosphere. Fuel conversion would cause an
increase in particulate emissions from the kiln and therefore is a potential
modification. Whether or not there would be any increase in emissions to
the atmosphere would depend on the type of control device used. A baghouse
has proven to be rather insensitive to small changes in the inlet loading.
In tests conducted at the Ideal Company Devil's Slide Cement Plant on a baghouse
controlling a rotary cement kiln, there was no increase in emissions when the
kiln was converted from fuel oil to coal firing. The effect of fuel conversion
on collection efficiency when an ESP is used to control particulate emissions
is not known. If there was an increase in emissions from a scrubber following
fuel conversion, either increasing the pressure drop or the amount of scrubbing
water will reduce the particulate emissions to the atmosphere to the pre-conversion
level.
5.2 ADDING A STONE PREHEATER TO AN EXISTING KILN
An existing rotary lime kiln may retrofit a stone preheater in order to
cool the exhaust gases before they enter the control device. The addition of
a preheater will also reduce the energy consumption per ton of lime and increase
the production rate. The stone bed in the preheater will act as a dust precleaner
5-3
-------
so that there will be no increase in dust loading to the control device. Even
though the production increases, the air flow to the control device will not
increase because of the lowered fuel consumption. Therefore, it appears that
when a stone preheater is added to an existing kiln there will be no increase
in particulate emissions from the control device to the atmosphere.
5.3 ADDING INTERNALS TO AN EXISTING KILN
The addition of internal baffling to an existing kiln is another way
to reduce the energy consumption per ton of lime. Dams, internal heat recuperators,
trefoils and lifters are used to increase mixing of the kiln charge so that
the heat will be more readily transferred to the stone. This increase in mixing
will also result in an increase in particulate emissions from the kiln. As in
Section 5.1, the effect this will have on emissions is dependent upon the type
of control device in service.
5.4 DEBOTTLENECKING
Expanding the capacity of the production limiting component of the facility
(debottlenecking) will increase the production of the facility. Such
alterations will have to be evaluated on a case by case basis to determine if
the ,ncrease in capacity resulted from a "capital expenditure" as described in
IRS Publication 534 and if there will be an increase in emissions to the
atmosphere. Normally the changes will be made to modernize the equipment and
will not result in substantial increases in production. Therefore, there will
likely be a small (if any) increase in particulate emissions from the kiln
and, again depending upon the type of control device in operation, potentially
no increase in emissions to the atmosphere.
5-4
-------
6.0 ENVIRONMENTAL IMPACT
The air pollution impact and the other environmental consequences of
the alternative systems of emission reduction presented in section 6.1.1 are
discussed in this chapter. The emission sources for which these alternative
systems are considered are the rotary lime kiln off-gas and the lime hydrator
off-gas. A comparison will be made between the emissions from the systems
required to meet State regulations for these two sources and the emissions
from other demonstrated systems. Both beneficial and adverse impacts which
may be directly or indirectly attributed to the operation of these alternative
systems will be assessed.
6.1 IMPACTS OF CONTROL TECHNOLOGY FOR ROTARY LIME KILNS
In Chapter 4 four different types of particulate emission control devices
for rotary lime kiln off-gas are discussed. Three of these devices, the bag-
house, electrostatic precipitator, and the venturi water scrubber, can be
designed to reduce the emission levels from lime kiln off-gas to 0.15 kilograms
of particulate per meqagram of limestone feed (0.3 pounds/ton).
Emissions of S02 in rotary kiln off-gas are also controlled to some
extent by these particulate control devices, Data from three tests show that
a medium pressure drop water scrubber can reduce the S02 exit gas concentration
from a kiln burning high sulfur coal to less than 100 ppm. Data fromarTEP/1
test show that kilns burning high sulfur coal and equipped with bagr;ou:es
have S02 exit gas concentrations of 200 ppm.
6-1
-------
6.1.1 A1ternative Emiss1 on Control Sys terns
In this chapter four alternative emission control systems for rotary
lime kilns are presented. Two systems (B-l and B-2) control S02 to 100 ppm
and two (A-l and A-2) have no SOg control. Two systems (A-l and B-l) control
particulate emissions to 0.15 kg/Mq of limestone feed (0.30 Ib/ton) and two "
(A-2 and B-2) control particulate emissions to 0.30 kg/Mg of limestone feed
(0.50 Ib/ton). These four systems are shown in Table 6-1. A fifth system (G),
that of no additional control, will also be presented. Under this system
owners or operators would be required to meet the typical State regulation,
described in section 4.4. Table 6-2 shows the conversion of the concentration
emission factors for particulate and 502 into other equivalent emission
factors. The conversions are exact for the model kiln described in chapter 3
and will vary slightly from kiln to kiln depending primarily on the kiln fuel
efficiency and the fuel used.
Table 6-1. ALTERNATIVE EMISSION CONTROL SYSTEMS FOR ROTARY LIME KILNS
Particulate
Control Levels
0.15 kg/Mq
(0.30 Ib/ton)
0.25 kg/Mq
(0.50 Ib/ton)
0.50 kg/Mq
(1.00 Ib/ton)
SOg Control Levels
No S02 Control 100 ppm
A-l
A-2
C
B-l
B-2
^
The control equipment required for each of the five alternative emission
control systems is described in the following section. An estimate is made of
the percentage of industry capacity that will be controlled by each of the
available devices so that the total energy required for emission control by
the industry can be calculated.
6-2
-------
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Control System A-0 ^
This system requires that particulate emissions be controlled to 0.15
kg per meaaqram of limestone feed (0.30 Ib/ton). No control of S02 is
required. The system would use a baghouse, high, energy electrostatic preci-
pitator or a water scrubber with an estimated pressure drop of 22 inches of
water column (22 IWC). Based on current sales trends it appears that most
operators are choosing to use baghouses due to the high operating costs of
scrubbers. It is estimated that 80 percent of new plants would comply with
this emission limit by using baghouses and that 20 percent would use ESPKs.
In those states which presently require control at a level slightly lower
than this most new plants are using baghouses. However the standard can be
met with high energy ESP's which have comparable energy requirements and
operating costs. Certain lime manufacturers favor the use of ESP's and will
continue to use them.
Control System A-2 -
This system requires that particulate emissions be controlled to 0.25
kilograms per megagram of stone feed (0.5 Ib/ton). This is below the level
of 0.50 kilograms per meaanram of stone feed (1.00 Ib/ton) reotuired by the
average State regulation. No control of SOp is required. This option could
be met by a baghouse, low energy ESP, or a water scrubber with a pressure
drop of about 15 IWC. It is estimated that 60 percent of U.S. lime manufacturers
would comply with this alternative by using a baghouse, 20 percent would use
the low energy ESP, and 20 percent would use a scrubber with 15 IWC. Certain
manufacturers that have a convenient area for ponding prefer to use scrubbers
when they will meet emission standards. Although more energy is required,
capital costs and maintenance are less.
6-4
-------
Control System B-1 -
This system requires both SCL control to 100 ppjn and parttculate control
to 0.15 kg per Mg of stone feed (0.30 Ib/ton). Plants burning low sulfur
coal (1.0 percent S and below) can normally meet this alternative by using
a baghouse, high energy ESP, or high pressure drop (22 IWC) water scrubber.
Plants burning higher sulfur coal may have to use a scrubber. It is expected
that 50 percent of the industry will use 22 IWC water scrubbers, 40 percent
will use baghouses and 10 percent wtll use high energy electrostatic precipi-
tators. Plants burning higher sulfur coal that have to use a water scrubber
may choose to use a combination baghouse and low pressure drop S0? scrubber
in order to comply with the S02 emission limit instead of using a 22 IWC water
scrubber.
Control System B-2 -
This system requires S02 control to 100 ppm and particulate control to
0.25 kg per megagram of stone feed (0.50 Ib/ton). Plants burning low sulfur
coal (1.0 percent S and below) can comply with this alternative by using a
baghouse, low energy ESP, or medium pressure drop (15 IWC) water scrubber.
It is expected that 60 percent of these plants would use 15 IWC water scrubbers,
30 percent would use baghouses, and 10 percent would use electrostatic preci-
pitators. Plants burning higher sulfur coal may have to use a 15 IWC water
scrubber to insure compliance with the S02 limitation, thus the high percentage
of plants using scrubbers.
Control System C -
Plants burning high sulfur or low sulfur coal can meet the average
present State regulation by using a baghouse, low energy ESP, low pressure
drop (9 IWC) water scrubber, or a gravel bed filter. It is expected that if
only State regulations remain in effect that 60 percent of the industry would
6-5
-------
use baghouses, 20 percent would use low energy ESP's, and 20 percent would
use low pressure drop 9 IWC water scrubbers.
6.1.2 Air Pollution Impact
To determine the actual emission reduction that would be achieved by
each of these alternative emission control systems, it is necessary to
estimate the reduction in air pollution beyond that which would otherwise
be achieved by State or local regulations.
It is assumed that by 1987 the entire lime industry will be using coal
as fuel and that one-half of the coal will have sulfur contents ranging from
1.0 to 4.0 percent. The average sulfur content of the high sulfur coal is
expected to be as high as 3 percent.
6.1.2.1 Estimated Emission Reduction in 1987 -
The values for the 1987 total lime and hydrate production and the
production subject to any control option are developed in Chapter 7, Economic
frnpact. Lime production capacity is expected to grow at a rate of 3.6
percent compounded with a base of 24,166,000 tons in 1977 and hydrate production
capacity is expected to grow at a rate of 1.6 percent with a base of 2,891,000
tons in 1978. It is predicted that the equivalent of eight new 500-ton-
per-day kilns will be built in 1977 and that the equivalent number built
per year will increase to twelve in 1987. The rotary kiln emission factors
for all applicable control devices are discussed in detail in Chapter 4 and
Chapter 7 and summarized in Table 6-3.
The results of these impact calculations for United States emissions in
1987 are shown in Table 6-4. When compared to Alternative C, all of the
remaining four alternative systems of emission reduction (described in 6.1.1)
show a reduction in 1987 particulate emissions (positive impact) ranging from
6-6
-------
Table 6-3. ROTARY KILN FACTORS
Uncontrolled (cyclone only)
Baghouse
Electrostatic precipitator
(high energy)
Electrostatic precipitator
(low energy)
Water scrubber 22 IWC
Water scrubber 15 IWC
Water scrubber 9 IWC
Gravel bed filter
Emission factors
Pounds parttculate
per ton stone
34.1
0.3
0.3
0.5
0.3
0.5
1.0
1.0
' Pounds S02
per ton stone
Low
sulfur
coal
-
1.0
-
-
0.1
0.1
0.1
-
High
sulfur
coal
-
2.0
-
-
0.1
0.1
0.1
-
Electrical
enerav factors
Kilowatt hours
per ton stone
16 /i
2.42
3.19
2.21
15.2
10.8
6.45
-
^-Electrical energy required for kiln and associated equipment.
6-7
-------
Table 6-4, REDUCTION OF PARTICIPATE AND SO? EMISSIONS OF
FOUR CONTROL SYSTEMS COMPARED TO STATE REGULATIONS
FOR ROTARY LIME KILNS IN UNITED STATES 1987
Control
sys tern
A-l
A-2
B-l
B-2
c/1
Control required
kq/Mg
0.15
0.25
0.15
0.25
0.5
Ib/ton
0.30
0.50
0.30
0.50
1.00
ppm S02
-
-
100
100
200
Parttculate^-
impact
tons
10,000
7200
10,000
7200
0
so/^-
impact
tons
0
0
7200
7200
0
^Particulate impact calculated by comparing system to state regulation.
12
S02 impact calculated by comparing emission limit (100 ppm) to amount
emitted from that half of industry burning high sulfur coal (200 ppm).
/3
'.State regulation.
6-8
-------
7200 to 10,000 tons a year. The impact on S02 emissions ranges from no
impact to a reduction of 7200 tons.
6.1.2.2 Impact on Model Plant ~
The effect of the various alternative emission control systems on the
emissions from the model rotary ktln ("1000 tons of stone feed per day,'500
tons per day of lime product) are shown in Table 6-5. Particulate emissions
are reduced by 50 percent under Alternatives A-2 and B-2 and by 70 percent
under Alternatives A-l and B-l. As discussed earlier, the reduction in S02
emissions would potentially occur only in plants burning coal with a sulfur
content of more than 1 percent. Alternatives B-l and B-2 would result in an
S02 emission reduction of 50 percent in plants burning 3 percent sulfur coal.
6.1.2.3 Impact on Air Quality -
A meteorological dispersion model has been used by the U. S. EPA Source -
Receptor Analysis Branch for the evaluation of the alternative systems of
emission reduction outlined in Section 6.1.1. The specific model employed
was the aerodynamic-effects version of the Single Source Dispersion Model
(CRSTER), that was developed by the Meteorology Division, EPA. This is a
Gaussian type model capable of considering multiple emission points and
complex aerodynamic effects. Assumptions made in this application of the
model include the following:
1. Emission rates are constant.
2. Pollutants are nonreactive and non-depleting.
3. Terrain is relatively flat.
The model is programmed to use a previously determined set of dispersion
conditions derived from the basic meteorological data for each hour of a
given year. The calculations simulate the interaction between the plant
characteristics and these dispersion conditions to produce a dispersion
6-9
-------
pattern for each hour. These computations are performed for each point in
an array of 180 receptors encircling the plant. Cumulative averages are
calculated at each of the receptors for any number of hours. In the case
of lime plants, the averaging periods of interest are 1 hour, 3 hours, 8 hours,
24 hours, and 1 year.
Lime plants are located throughout the United States, but for the
purposes of this dispersion analysis, Austin, Texas, was chosen as the
location for the model plant. It was felt that the meteorology at this
location was such that it represented an adverse condition for lime plants.
The meteorology data used are the actual hour by hour conditions that were
recorded at Austin over a one year period.
Dispersion calculations were performed on two separate model plants,
one with a typical stack height of 30.5 meters and the other with a taller
stack of 51.0 meters. The two models are presented to show the affect on
ambient air quality of a typical plant and a plant designed to preclude
downwash.
In flat-to-gently rolling terrain, such as that assumed in this
analysis, experience indicates that the model estimates are reliable to
within a factor of about two. However, the direct extrapolation of the
results to actual plants should not be attempted. Such extrapolation
could lead to seriously erroneous estimates, since plants vary considerably
in their characteristics and in their location with respect to large and
small scale meteorological features. Actual plants should be modeled on
a case-by-case basis. Nevertheless, this dispersion analysis of the lime
industry gives a relative feeling for the effect that the different systems
of emission reduction will have on adr quality so that they can be compared
with each other and with the emission levels specified by State regulations.
6-10
-------
The National Ambient Air Quality Standards (NAAQS) establish the maximum
concentration of a pollutant that is to be found in the ambient air. The
Primary and Secondary AAQS are for health and welfare effects, respectively.
Since there are varying amounts of background pollution across the United
States, a lime plant in a "clean" area can emit more than one located in
"dirty" area without exceeding the AAQS. Another yardstick, the Significant
Deterioration Increment (SDI), has therefore received consideration. The SDI
specify the maximum additional pollutant concentration a single source can
add to the ambient air. The SDI are especially critical for lime plants
since they are normally located in rural areas where there is little background
pollution.
A summary of the results of the model kiln dispersion analysis is
shown in Table 6-6. In this table air quality impact is shown as the maximum
o
pollutant concentration in micrograms per cubic meter (pg/m ) and the distance
in kilometers from the stack at which this maximum was found. The pollutant
concentrations that result from kilns controlled to meet the five alternative
systems of emission reduction are compared to pollutant concentrations of the
Primary and Secondary AAQS and the SDI. Results are shown for both dry
(baghouse, ESP) and wet (water scrubbers) collectors. The pollutant concen-
trations resulting from all of the emission control alternatives fall below
the AAQS. When a typical kiln is not designed to preclude downwash, the
SDI for particulate and sulfur dioxide (SfL) may be threatened. The particulate
concentrations for alternatives A-l and B-l and the S02 concentrations for
alternatives B-l and B-2 are the only ones that are well below the SDI.
6-11
-------
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6.1.3 Hater Pollution Impact
None of the alternative emission control systems have an adverse impact
on water quality. Baghouses (.fabric filters), electrostatic precipitators,
and gravel bed filters have no water effluent. If water scrubbers are used"
for rotary kiln emission control, the plant may be required to discharge or .
treat a liquid stream. Normally, however, lime plants using water scrubbers
operate closed water systems with total recycle. In this method of operation,
the waste water system and solid waste handling system are integrated into
a single system. The entrained solids are removed from the water in a settling
pond (or settling tank). After a substantial portion of the solids have
settled out the water is returned to the process for further use or to storage
for additional solids settling and subsequent reuse. The accumulated solids
are removed periodically, at which time they become a solid waste problem
(see Solid Waste Impact, Section 6.1.4). Overflow from the ponds can be
prevented by preventing excess rain water or ground water from entering the
ponds.
The EPA Effluent Guidelines development document on waste water effluent
from lime plants concludes that zero waste water effluent should be the
standard for the industry.
6.1.4 Solid Waste Impact
When scrubbers, precipitators? fabric filters, or gravel bed filters
are used to control emissions from lime kilns, solid waste will be generated.
6.1.4.1 The Amount of Material Collected -
Table 6-7 shows the amount of solid waste collected for each of the
alternative emission control systems presented in this chapter. For the
purpose of this table it is assumed that a plant conforming to the State
regulations (Alternative C) will collect 340 pounds of dry solids per ton
6-14
-------
Table 6-7. SOLID WASTE IMPACT ON MODEL ROTARY KILN
Emission Control
Alternative
Emission Control
Device
Solid Waste
Collected (kq/hr)
* Increase Above
State Reg
A-l
B-l
A-2
B-2
ESP, Baghouse
Scrubber
ESP, Baghouse
Scrubber
ESP, Baghouse
Gravel Bed Filter
3220
4000
3210
3980
3200
25%
25%
State Regulations,
6-15
-------
of lime. The table shows that a dry collector used for Alternative A-l
increases the amount of solid wasta collected by very little, less than
1 percent. If a scrubber is used for Alternative B-l, then the amount of
solids produced will be greater because the water in the scrubber will react
with the CaO and other compounds to form hydroxides and hydrates. The pond
sludge which the scrubber produces also contains some water which is difficult
to remove and also increases the weight of the waste. No information is available
on the wet weight of the sludge produced by a scrubber, but if some assumptions
are made in regard to the composition of the dust it can be calculated that
the weight of sludge produced is about 25 percent more than the weight of
the equivalent dust. There will be no appreciable increase in solid waste
when dry collectors are used for Alternative A-2 but there will again be an
increase of about 25 percent when scrubbers are used for Alternative B-2.
6.1.4.2 The Uses of the Material Collected -
At the present time some lime producers that recover dry particulate
from the control devices are able to find uses for this material. At least
one plant briquettes the dust and feeds it back into the kiln to be converted
2
to product. Most lime producers cannot do this because the dust contains
much more sulfur than the lime product and recycling the dust may increase
the sulfur content so that the lime will not meet product specifications.
Some lime producers use the lime dust as a raw material in cement kilns.
This method of disposal can only be used i,f the lime plant and cement plant
are close together. The dust has little value as cement kiln feed and it is
not profitable to transport the material very far. Some manufacturers sell
4
the dust for agricultural liming but this market is seasonal and during most
of the year the dust must be disposed of in other ways. At least one manu-
facturer wets and granulates the dust and uses it for metallurgical purposes
6-16
-------
but the demand for material for tin's use is limited. Another manufacturer
plans to wet and granulate the material (from a kiln calcining a dolomitic
stone) and use it as a magnesium source in blended fertilizer. At least one
manufacturer uses the dust to neutralize acid water discharged from a steel
mill.7
No reliable data are available on what part of the dry material collected
by the lime industry is put to use. Many of the plants which collect dry
material dispose of the dust by dumping it back into a mined out quarry or
some other convenient location.
When scrubbers are used for emission control the solid waste produced
is in the form of a wet sludge dredged from the settling ponds. One of the
plants visited in the preparation of this work used this material for soil
o
stabilization. Other plants dispose of the sludge in landfills or in mined
out quarries. The material is not used for most of the purposes for which
the dry waste is used because it is difficult to handle when wet, expensive
to dry, often contaminated with the pond bottom and not available on a day
by day basis. (Ponds are dredged only periodically, the dust product of
dry collectors is available every day.)
6.1.4.3 Impact of the Alternative Emission Control Systems -
The impact of the four alternatives on the required amount of solid waste
disposal depends on how many plants would elect to use scrubbers. With either
Alternative B-l or B-2 all plants burning coal with a sulfur content over one
percent would probably use scrubbers. The amount of material collected would
increase significantly and there may be less use for the material collected.
The problem of disposing of this sludge to some extent is similar to the
problem of disposing of the sludge from lime slurry scrubbing systems for
coal-fired steam generators except that less sludge is generated from lime
6-17
-------
kiln scrubbers. The technology available for scrubber sludge disposal have
910
been studied thoroughly ' and the EPA has concluded that the sludge can be
disposed of in an environmentally acceptable manner by hardening the sludge
and using it for landfill.
With either Alternative A-l or A-2 no scrubbing would be required, a
maximum of 1.0 percent additional solids would be collected, and there
would not be a significant impact on the amount of solid waste disposal
required.
6.1.5 Energy Impact
All of the control devices used in the four alternative emission control
systems use electrical energy and with three of the alternatives there will
be an increase in the electrical energy required compared to that required by
State regulation. In this section there is a comparison of the energy increase
required by all affected U.S. lime plants in 1987 and the energy increase
required by a model lime plant for the four control systems.
6.1.5.1 Impact on 1987 U.S. Energy Use -
The impact calculations have been made for the year 1987 using the
Chapter 7 estimates of production subject to control. The energy values
required for each of the control devices are developed in Chapter 7 and
summarized in Table 6-3.
Table 6-8 compares the energy requirements of the five alternative
emission control systems in 1987. The values are millions of kilowatt hours
(kw hr) for that year and for that part of the Industry that would be subject
to any new emission limit. Alternative A~l shows a slight beneficial impact
(decrease in energy use) because with this system producers will tend to use
baghouses or ESP's rather than using scrubbers which require more energy.
Producers will use low pressure scrubbers to meet State regulation (Alternative
6-18
-------
because they have low capital costs that negate the cost of increased energy
consumption. Alternatives B-1 and B-2 require more electrical energy than
A-l and A-2 because scrubbers are required if sulfur removal is necessary
and the scrubbers require more energy than baghouses or ESPls.
Table 6-8. ELECTRICAL ENERGY IMPACT
Alternative Emission
Control System
1982
Impact
10G kwhr
1987
ImpacO
TO6 iRwEr
A-l Baghouse or ESP
A?2 Baghouse, ESP or -11 -25
15 IWC scrubber
B-1 22 IWC scrubber -75 -164
baghouse or ESP
B-2 15 IWC scrubber -59 -129
baghouse or ESP
C 9 IWC scrubber
baghouse or ESP
The percent controlled by each device given in Section 6.1.1 and the energy
required by each device given in Table 6-3.
^Positive impact shows that system uses less energy than plants controlled
to State regulations.
/3
State regulations.
6.1.5.2 Impact on Model Plant -
Table 6-9 shows how the energy requirement of a model plant (1000 tons
per day stone feed) would increase with each of the alternative emission
control systems. The electrical energy, including that used for the plant
and the control device, would increase very little for Alternatives A-l and
A-2, but would be more for Alternatives B-1 and B-2 which require scrubbers
6-19
-------
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6-20
-------
if sulfur removal is necessary. The table also shows how the total energy
required by the plant would increase for each of the alternatives. In this
comparison the electrical energy in kilowatt hours is converted to an
equivalent Btu value using a conversion efficiency typical of existing coal
fired power plants. Fuel required for the model kiln is 6.5 x 10 Btu per
ton of lime produced. The alternative with the maximum energy use (B-l)
requires only a 4 percent increase in total energy consumption when high
energy scrubbing is used for control. If a combination of low energy ESP
and 9 IWC scrubber is used for control there would be only a 2 percent
increase in total energy consumption.
The increased electrical energy required for the control systems would
probably be generated in coal burning power plants which themselves emit
particulate, SCL and NO . The amount of emissions generated by a power plant
b A
producing the electricity required to operate a control device can be calculated.
These power generation emissions can then be compared with the reduction in
emissions caused by the control device. For the 500 tons a day lime kiln,
the highest energy Alternative, B-l, with a 22 IWC scrubber, requires 13,000
more kilowatt hours per day than State regulations (Alternative C). If the
power plant generating this electricity is operating in conformance to New
Source Performance Standards then the power plant can emit no more than 2.1
i O
pounds of total emissions (particulate, S02> NO^) per million Btu heat input.1
If the power plant uses 10,000 Btu to produce one kilowatt hour then it may
emit 2.0 pounds total emissions per 1000 kilowatt hours of electricity. The
increase in electrical energy of 13,000 kilowatt hours per day is therefore
equivalent to an increase of 10.8 pounds of emissions per hour from the power
plant. For the model plant, Alternative B-1 reduces S02 emissions by 42 pounas
an hour and particulate emissions by 21 pounds an hour for a total reduction
6-21
-------
of 63 pounds an hour. (From Table 6.5) The increase in emissions from the
generation of the additional electrical energy required for control is small
compared to the kiln emission reduction which results from the control,
6.1.6 Other Environmental Concerns
6.1.6.1 Irreversible and Irretrievable Commitment of Resources
The first four alternative systems of emission reduction will require
equipment of higher efficiency than that required by alternative C (State
regulations). The additional steel and other materials and the amount of
additional space needed for the higher efficiency devices is expected to be
minor. The steel can eventually be salvaged and recycled.
The emission control devices used in the four alternative systems of
emission reduction will require increased usage of electrical energy which is
a limited resource. This energy is irretrievable but its use will result in
a significant reduction in the amount of particulate matter emitted from a
lime plant. Compared to the total pi ant"energy use, amount of electrical energy
used to operate these control devices is negligible.
6.1.6.2 Environmental Impact of Delayed Standards -
Delaying the proposal of one of the four alternative systems of emission
reduction will result in increasing the emissions of particulate matter from
lime plants. Based on the growth projections presented in Chapter 7, the
adverse environmental impact of delayed implementation of the emission limit
is shown in Table 6-10. The other environmental impacts of the alternative
systems of emission reduction are small so that delaying the proposal will
not result in an appreciable reduction in any negative impacts. Furthermore,
there does not appear to be any emerging emission control technology that could
achieve greater emission reductions or result in lower costs than that represented
6-22
-------
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6-23
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by the emission control alternatives under consideration here. Therefore, since
delaying the proposal to allow further technical developments appears to
present no potential benefit, and since it would increase the emissions of
particulate matter, delaying the proposal does not appear to be warranted.
6.1.6.3 Environmental Impact of No Standard
Based on the growth projections presented in Chapter 7, the adverse
environmental impact of no standard is summarized in Table 6-10. Since
there are little adverse water pollution and solid waste impacts, and only
moderate energy consumption impacts associated with each of the alternative
emission control systems which could serve as a basis for the standards, not
setting standards presents little trade off of potentially adverse impacts
in these areas against the resulting adverse impact on air quality.
6.2 IMPACTS OF CONTROL TECHNOLOGY FOR LIME HYDRATORS
In Chapter 4 there is a discussion of the use of water scrubbers to
control the particulate emissions from lime hydrators. (There are no S02
emissions from hydrators.) Although the off-gas stream from a hydrator can
be controlled by a baghouse, the water scrubber has several advantages which
make it more suited for this application. The water slurry from the scrubber
can be used as part of the make-up water required for the hydration. No
settling ponds are required and there is no solid waste impact or water impact.
The water scrubber is not effected by the condensation which Is apt to occur
in the high moisture hydrator off-gas.
There are two alternative levels of emission control, bpth of which
utilize a water scrubber, presented for the control of lime hydrator off-gas.
The scrubbers described in Chapter 4 which can be used for this application
reduce particulate to 0.15 pounds per ton lime feed (Alternative I). For the
6-24
-------
14 tons per hour (lime feed) model hydrator the average State regulation
Will allow 1.0 pound of particulate emissions per ton of lime feed
(Alternative II).13
6.2.1 Impact on 1987 U. S. Emissions
In Chapter 7, Economic Impact, it is projected that there will be
635,000 megagrams (775,000 tons) of hydrate production subject to the
emission limit in 1987. The reduction in particulate emissions from
this affected production is shown in Table 6-11. The table shows that
there will be a particulate emission reduction of 251 megagrams (276 tons)
for the year 1987.
Table 6-11. 1987 REDUCTION OF PARTICULATE EMISSIONS
FOR LIME HYDRATORS IN UNITED STATES
Alternative
emission control
system
I
u£
Emission
kg/Mg
lime feed
0.075
0.50
limit
Ib/ton
lime feed
0.15
1.00
Particulate
impact
tons
276/1
-
Assumes 1 pound lime yields 1.25 pound hydrate
State regulations.
6.2.2 Impact on Model Plant
The effect of each of the alternative emission control systems on the
emissions from the model hydrator (14 tons of lime feed per hour, 17 tons
per hour of product) are shown in Table 6-12. Alternative I reduces particulate
emissions by 85 percent over Alternative II (.State regulations).
6-25
-------
Table 6-12. PARTICULATE EMISSION FROM A MODEL LIME HYDRATOR
Alternative Allowed Decrease
emission control emission from State
system kg/hrIb/hr regs,
I 0.96 2.1 85%
6.4 14
State regulations.
6.2.3 Impact on Air Quality
The dispersion model described in Section 6.1.2.3 was also used to
determine the air quality impact of a typical lime hydrator. The results
of these calculations are shown in Table 6-13. Although none of the
concentrations approach the ambient air quality standards, the significant
deterioration increment may be exceeded for emission control alternative II
(average state regulations) if downwash is allowed to occur.
6-26
-------
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Table 6-14. ENVIRONMENTAL IMPACT OF DELAYED.OR NO STANDARDS
FOR LIME HYDRATORS/1
Year
1978
1979
1980
1981
1982
1987
Lime Hydrator Production
Affected by Standards
(1000 Mg/yr)^-
Yearly
55
56
56
57
59
63
Cumulative
55
111
167
224
283
590
Parti cul ate Impact
(Mg/yr)
18
56
113
V89
285
1076
The increase in particulate emissions caused by delaying the standards.
Z^Based on Table 7-6.
6-28
-------
6.2.4 Other Environmental Impacts
As previously stated there are no solid or liquid waste impacts of
Alternative I or II. There ts minimal additional electrical energy used in
Alternative I compared to Alternative II. No scarce resources will be
consumed. Table 6-14 shows the increase in particulate emissions that will
occur as a result of delaying the proposal of Alternative I. Since there
are no benefits to be derived from delaying the standards and since the
emissions of particulate matter will be greater if the standards are delayed,
postponing this standard does not appear to be justified.
REFERENCES FOR CHAPTER 6
1. "Inorganic Chemicals Manufacturing Point Source Category," Federal
Register 39 FR 9621 (March 21, 1974).
2. Evans, L. B., EPA Trip Report of Visit with Basic Corporation, Port
St. Joe, Florida, March 20, 1974.
3. Hustvedt, K. C., EPA Trip Report of Visit with Martin Marietta Corp.,
Calera, Alabama, Sept. 30, 1975.
4. Hustvedt, K. C., EPA Trip Report of Visit with Martin Marietta Corp.,
Woodville, Ohio, February 18, 1976.
5. Evans, L. B., EPA Trip Report of Visit with Bethlehem Mines Corp.,
Annville, Pa., November 7, 1973.
6. Evans, L. B., EPA Trip Report of Visits with Woodville Lime and Chemical
Company, Woodville, Ohio, March 20, 1974.
7. Hustvedt, K. C. EPA Trip Report of Visit with Bethlehem Mines Corp.,
Hanover, Pa., Nov. 18, 1975,
8. Dale, J. T., EPA Trip Report of Visit with Texas Lime Company,
Cleburne, Texas, May 2, 1975.
6-29
-------
9. "Sulfur Oxtde Throwaway Sludge Evaluation panel (SOTSEP); Vol. 1
Final Report, Executive Summary," April 1975 (EPA<-650/2r75-010-a).
10. "Evaluation of Lime/Limestone Sludge Disposal Options," Radian Corp., *
November 1973 (EPA-450/3-74-016).
11. "New Source Performance Standards for Fossil Fuel-Fired Steam Generators,"
Federal Register 40 FR 42045 (September 10, 1975).
12. "Standards of Performance for New Stationary Sources,11 Federal Register
36 FR 24876 (December 23, 1971).
13. "Environmental Impact Statement for Lime Plants," Prepared by Midwest
Research Institute for the U.S. EPA, Contract No. 68-02-1324, Task No. 33,
December 1975.
6-30
-------
7. ECONOMIC IMPACT
7.1 Industry Economic Profile
7.1.1 Introduction
This section provides background information on the character of the
firms engaged in the production of lime products, industry organization,
plant size and location, markets, production economics, capacity data, and
prices. This information will provide the basis for the underlying assump-
tions and data inputs for the economic analysis in Section 7.4.
7.1.2 Firm Characteristics
The commercial lime industry comprises a large variety of firms. Some
are large multi-plant firms whose major business is lime production. Others
are small, independent commercial producers. Both types of firms consti-
tute Standard Industrial Classification (SIC) 3274. According to the 1972
Census of Manufacturers, there were 68 companies with 103 plants under
SIC 3274. ' A large sector of the lime industry includes so-called
"captive" plants which are a part of vertically integrated operations.'2'
Many of the latter are firms whose primary lines of business are beet
sugar processing, alkali production, and metals manufacturing (steel, copper,
magnesium). As a consequence, information about the operating characteris-
tics of the captive lime industry is either closely held or else combined
with the operating data of other company divisions in publicly available
financial reports.
7.1.3 Plant Characteristics
As mentioned before, some 103 plants produced lime as a primary
product in 1972. The total lime industry comprised some 186 plants in 1972.^
7-1
-------
According to Bureau of Mines, some 170 plants were operating in 1975. '
Table 7-1 ' summarizes the location and characteristics of 177 plants
(5)
that were active in the first quarter of 1974. '
The total capacity of all lime plants (based on the assumption that
lime plants operate an average of 330 days per year), as shown in Table
7-1, is 65,859 tons per day or about 22 million tons per year. Of
this total, commercial plants account for about 78 percent and captive
plants for 22 percent. On the other hand, the number of plants (95
comnercial, 82 captive) is about evenly divided between the commercial
and captive sectors. The capacity available to produce dead-burned
dolomite (about 8 percent of the industry total) is not distinguished
according to the market status of the producing firms.
It is notable that the share of capacity represented by rotary
kilns differs substantially between the commercial and the captive
sectors of the lime industry. Within the commercial sector about 85
percent of total capacity consists of rotary kilns while in the captive
sector the corresponding statistic is roughly 54 percent. This dis-
parity is largely accounted for by the fact that many of the captive
lime plants are owned by beet sugar companies which generally employ
vertical kilns in beet sugar processing.
7.1.4 Industry Organization
The domestic lime industry is generally divided into two marketing
sectors: commercial and captive producers. The former group of firms
produces lime products primarily for resale to other firms or individual
users. (About 85 percent of the tonnage in this sector of the industry
is represented by the National Lime Association.) Captive plants, on
the other hand, produce lime largely for their own use on the plant
site, although some sell part of their output in the open, or commercial,
7-2
-------
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7-3
-------
market. The share of output accounted for by these producers effectively
measures the degree of forward vertical integration. This share has
remained relatively stable, between 34 and 40 percent of industry output
during tne past 10 years.
Many of these captive producers have lime kilns on the plant site.
These kilns are often essential because lime calcination is one of the
few practical means of generating a large volume of carbon dioxide gas
a co-product, with lime, of the calcination process. Both alkali
production and beet sugar processing are characteristic of processes
which require a large volume of (XL. These two industries alone account
for about 59 of the 177 domestic lime plants. ^ '
Other major lime consuming industries which maintain lime production
facilities include copper, steel, and calcium carbide manufacturers.
The market share trends accounted for by captive producers in each sub-
market are discussed more completely below.
The degree of backward vertical integration is more difficult to
quantify. However, a significant proportion of lime plants do have
associated primary and secondary limestone crushing facilities. In addition,
several lime producing firms have stone quarrying operations. Thus, it
appears that most lime plants are part of a fully integrated limestone
processing operation.
Among companies which produce lime productsthose with 3274 Standard
Industrial Classification (SIC) codesmost derive a large portion of their
sales from mineral product-related activities. The most important among
these are crushed and broken limestone (SIC 1422); hydraulic cement
(SIC 3241); quarrying of broken and crushed stone (SIC 1422); quarrying
7-4
-------
construction sand and gravel (SIC 1442); crushing and grinding of stone,
etc. (SIC 3295); clay, ceramic, and refractory minerals (SIC 1459); ready
mixed concrete manufacture (SIC 3273); and mining crushed and broken stone
(SIC 1429).(7)
Table 7-2 provides historical data on the degree of concentration
(8)
in the lime industry. The concentration ratios presented there measure
the percentage of total industry sales accounted for by the 4, 8, 20,
and 50 largest companies in the industry. These concentration ratios
are rather low by comparison to many industries. Also, it appears that
concentration in the industry peaked during the period from 1954 to 1958
and has generally fallen since then.
7.1.5 Production Economics
Each year since 1929 the Bureau of Mines has canvassed the lime
industry to determine the number of plants and the ouput of plants by
size category. Consequently, the shares of industry output accounted
(9)
for by each size class were analyzed directly. The analysis was
conducted for each of five size classes: plants producing less than
10,000 tons per year; 10,000 - 25,000 tons per year; 25,000 - 50,000
tons per year; 50,000 - 100,000 tons per year; and more than 100,000
tons annually. The output shares accounted for by the first three sizes
classes have declined markedly during the period 1930 - 1972. The fourth
size class (50 - 100,000 tons per year) has accounted for an erratic
share of output over time while the largest size class (greater than
100,000 tons per year) has clearly been growing steadily over time. A
conclusion from the analysis is that the trend is toward new plants
greater than 300 tons per day. Plant size has been increasing steadily
and should continue to do so.
7-5
-------
Table 7-2. HISTORICAL CONCENTRATION RATIOS IN THE COMMERCIAL LIME INDUSTRY
(SIC 3274)
Number of
Year companies
1972
1967
1966
1963
1958
1954
1947
68
78
NA
81
94
113
132
Value of shipments Primary
accounted for by product Coverage
4 8 20 50 specialization ratio,
largest companies, percent ratio, percent"
37
35
31
37
38
35
30
53
54
47
56
57
53
47
79
79
NA
82
80
80
69
99+
99
NA
99
98
NA
NA
percent9
89
87
NA
82
84
84
83
92
93
NA
94
95
97
97
NA: Not Available
Notes:
a. Specialization Ratio: Value of primary product shipments as a
percent of total value of shipments.
b. Coverage Ratio: Value of lime product shipments produced in the
lime industry as a percent of aggregate national lime product shipments.
Source: 1972 Census of Manufactures, Concentration Ratios in Manufacturing,
Part 1, Special Report.
7-6
-------
Table 7-3 shoves a breakdown for major components of lime production
costs in the commercial lime industry. Tfie actual data from the Census of
Manufacturers for 1972 was adjusted to project estimates for 1975. Whole-
sale price indices ^ ' were used to make the necessary adjustments in the
1972 expenditures for salaries and wages, materials, and energy. Bureau
of Mines production and price data (See Section 7.1.6) were used to estimate
value of shipments for 1975. The 1975 entry for depreciation, interests, etc,
(capital related and other fixed costs) was determined by deduction of all
other costs (percentages) from the 1975 value of shipments (100 percent).
The most significant aspect of the data presented in Table 7-3 is the
increase in the energy componentfrom 16.8 percent in 1972 to 28.4 percent
in 1975. This observation suggest that energy utilization will be one of
the most important forces that will influence future production and invest-
ment trends in both the commercial and captive lime industry.
Table 7-4 reports aggregate plant and equipment expenditures in the
commercial lime industry between 1958 and 1973. ' ' The substantial
increase in investment during 1972 was likely required to install air
pollution control devices and to install larger, more efficient kilns to
replace ones whose obsolescence was accelerated by the enforcement of air
pollution control regulations in the State Implementation Plans.
7.1.6 Lime Products Markets
The four traditionally identified major uses of all types of lime
products (quicklime and hydrated lime) are in agricultural, construction,
chemical and metallurgical, and refractory applications. However, as
shown in Figure 7-1 agricultural applications of lime can no longer be
(13}
considered significant. ' In 1971 chemical and metallurgical uses
counted for 79 percent of all lime consumption; construction uses, for
7-7
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-------
Table 7-4. PLANT AND EQUIPMENT EXPENDITURES IN THE COMMERCIAL LIME
INDUSTRY , MILLION CURRENT DOLLARS (SIC 3274)
Year
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
New structures
Total new and plant
expenditures additions
$ 6.4 $ 2.06
12.7
12.1
7.0
12.0
14.7 2.11
21.4
15.7
22.1
17.7 2.00
18.5
20.4
18.2
12.8
42.0 4.5
23.0
Used
New machinery plant and
and equipment equipment
$ 4.30 $ 0.39
12.62 0.35
15.6 0.20
37.6 0.5
Source: U.S. Department of Commerce.
7-9
-------
20,000
10,000
8,000
6.0OO
4.000
4/t
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o
t-
x 2,000
o
5
S
£ 1,000
uj" 80°
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" 600
200
100
80
CHEMICAL AND METALLURGICAL
REFRACTORY
60
1945
A
-A/
CONSTRUCTION
AGRICULTURAL
1950
1955
I960
1965
1975
Figure 7-1 Trends in the major uses of lime.
Source: Research Triangle Institute
7-10
U
-------
12 percent; refractory applicatton., for 8 percent; and agricultural uses,
for only one percent. Table 7-5 arrays overall consumption and production
of lime from 1960 to 1975 tn addition to representative prices for open
market lime.
The chemical industry is one of the largest single consumers of lime.
Lime serves as an important intermediate in the alkali and glass manu-
facturing industries. Lime also is important in production of acetylene
gas, pulp and paper manufacturing, sugar beet processing, and water and
waste treatment.
Alkali manufacturers require a large volume of carbon dioxide gas as
a basic input to the production of soda ash and bicarbonate of soda.
Since C0£ gas is a low cost by-product of calcination, lime is an obvious
choice as one of the industry's main raw materials. Among the four
chemical applications of lime, alkali production uses are by far the
largest. During the 1960s between 97 and 99 percent of all lime used in
alkali production was produced by captive lime plants. Overall these
applications account for about 50 percent of all captive lime production
and about 15 percent of total lime production. Nonetheless, lime consump-
tion in this sector remained virtually constant throughout the 1960s and
offers little future market potential for commercial producers. The reason
for this is that trona deposits are replacing the Solvay process as the source
of soda ash.
Calcium carbide is an important source of acetylene gas. In producing
this product, quicklime is mixed with coke and heated in electric furnaces
from which the molten carbide is removed. Total output for this use during
1971 was about 537 thousand tons or about 5.6 percent of all lime produced
although 43 percent of that was produced by captive plants. The demand
7-11
-------
Table 7-5 HISTORICAL LIME PRODUCTION, CONSUMPTION
AND REPRESENTATIVE PRICES (1000 tons)
Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
Consumption
12,906
15,200
13,812
14,609
16,200
17,057
18,223
18,080
18,680
20,383
19,936
19,811
20,542
21 ,429
22,029
19,433
Production
12,935
15,193
13,754
14,525
16,107
16,821
18,087
18,009
18,676
20,250
19,788
19,635
20,332
21,132
21 ,645
19,187
Price
C$/ton)
13.35
13.39
13.58
13.73
13.87
13.87
13.27
13.42
13,39
13.94
14.53
15.78
16,78
17.42
22,02
27.45
Source: Bureau of Mines
7-12
-------
for lime by calcium carbide producers fell at an annual rate of 1.1
percent during the 1960s, reflecting a decline in the demand for acetylene.
In the manufacture of glass, either lime or limestone can be used
as fluxing materials. The lime input is used to make glass less brittle
and stronger, to reduce its solubleness in contact with chemical solutions,
and to provide a more durable lustre in glass. During the 1960s the use
of lime in glass manufacture grew rapidly at an average annual rate of
9.8 percent and accounted for about 1.8 percent total lime production
during 1971.
Lime is an important water treatment chemical. In many muncipal-
ities it is used as a complement to chlorine treatment to condition water
for potable or industrial process uses. One of the major uses is in water
softening. In that application lime is used either by itself or with a
soda ash reagent, depending upon the degree of hardness of the water.
Another application of lime in water treatment is its introduction to
retention tanks to purify the water against bacteria. Other uses include
its application as a coagulant to remove suspended solids from turbid or
reused waste water; as a neutralizer in acidic water; and for silica ad-
sorption and the removal of other waters impurities. In 1970 water
treatment uses accounted for approximately 6.2 percent of all lime con-
sumption of which virtually all was purchased from commercial lime
plants. Though the annual rate of growth in the demand for lime in water
treatment has been erratic, averaging about 2 percent during the 1960s,
this market sector is the third largest commercial market for lime and has
grown substantially from a consumption level of 710 thousand tons in 1960.
The increasing, environmentally related emphasis on water treatment
facilities promises a strong demand for lime in this market sector during
the next several years.
7-13
-------
A related use of lime occurs in small sewage treatment plants which
use lime in chemical water treatment processes to coagulate suspended
solids. Lime is also used to condition sludge for more efficient disposal.
*
In addition, lime is used for neutralizing acid drainage from coal mines;
for treating acidic wastes from metal plating and fabrication and chemical
plants; and for coagulation in treating food canning wastes, etc. Although
total lime consumption in sewage and trade industrial waste treatment
was only about 2 percent of total lime demand in 1971, the annual rate
of growth in these applications has been substantial, about 18 percent for
the period 1962-71.
Another area which may be a promising potential market is the use of
lime for desulfurization of fluegases in power generation as a result
of combustion of fossil fuels. Environmental regulations limiting sulfur
emissions that have been promulgated as a result of the 1970 Clean Air
Act will have to be implemented by flue gas desulfurization because low
sulfur fuels may not just be economically available.
Lime demand in the pulp and paper industry is mainly associated
with the Sulfate (Kraft) Process wherein lime is used to causticize the
"green" liquor." Total lime consumption by these manufacturers in 1970
was 918,000 tons, most of which was purchased from commercial producers.
However, these purchases are not a good indicator of actual lime con-
sumption since more than 90 percent of thelime entering the process is
regenerated. The remaining ten percent that is purchased as "make-up"
lime represents the demand level that appears in statistical summaries of
lime consumption by this industry. During the 1960s the average annual rate
of growth in demand for lime by pulp and paper manufacturers was about 6.7 per-
cent.
7-14
-------
The economies of sugar beet processing operations are similar to
those associated with alkali plants in that both require large quantities
of lime and carbon dioxide gas. This essentially requires captive lime
kilns on the plant site, despite the fact that these kilns are often
operated only a small number of days per year. Basically, lime is used
to remove impuritiesphosphatic materials and organic acids--from the
crude sugar juices. This entire process, known as defecation and clarifi-
cation, is often repeated to improve the purity of the sugar solution.
Total lime production by sugar beet processors grew at about 3.8 percent
annually during the 1960s and represented approximately 4 percent of total
domestic lime production IB 1971. Nonetheless these captive plants repre-
sent about 30 percent of the total number of lime plants. This is due to
the fact that sugar beet processors operate on a seasonable basis and
their capacity requirements are small. For this reason, sugar beet pro-
cessors have used vertical kilns, which require lower investment and
lower fuel requirements than rotary kilns on a tonnage basis. This trend
should continue in the future.
Metallurgical uses of lime, especially as a steel flux, constitute
one of the largest and fastest growing market sectors for commercial lime
producers. The major uses of lime in metal production are in the manu-
facture of steel, copper, aluminum, and magnesium.
Lime is used as a flux to purify steel during the heating process. '
Lime is relatively fast reacting, and facilitates the fusion of the slag
and the removal of phosphorus, silica, silicates, etc. in the slag that is
tapped off from the molten metal. The widespread acceptance of the basic
oxygen furnace (BOF) in the steel industry was, and continues to be, a
great boon to the lime industry. As opposed to open hearth furnaces which
7-15
-------
can economically employ slower reacting limestone as a flux, BOFs, which
reduce steel heating periods to an hour or less (compared to as many as
8 to 10 hours for open hearths) require the fast reacting character-
istics of quicklime. Because the BOF has gained such popularity, it is
not surprising that the annual growth rate in lime consumption as a
steel flux exceeded 20 percent during the 1960s, accounting for more
than 5 million tons of lime usage by 1971. This total currently represents
more than 26 percent of all lime production. Unfortunately for commercial
producers, however, there has been a correspondingly rising proportion
of fluxing lime forthcoming from captive producers. For example, in
1962 that share was about 4 percent but by 1971 it had risen to 19
percent.
Among nonferrous metallurgical applications the use of lime in
copper production is the most significant. Generally, in all nonferrous
applications, lime is widely used in the flotation (or beneficiation) of
the basic ores. Specifically in copper flotation, lime helps to maintain
the proper degree of alkalinity. Growth in the rate of lime consumption
in cooper production was erratic during the 1960s, averaging about 3
percent annually. In 1971 lime consumption in this use was about 2.5
percent of domestic lime production of which about 55 percent was produced
by captive plants. The major share of this captive production principally
derives from large western copper companies withlime kilns at the
beneficiation mills.
In nearly all commercial magnesium producing processes lime is
required as a basic chemical input. The manufacture of aluminum by the
Bayer process is also accompanied in a few plants by the use of lime as
a caustisizing agent. As a share of total lime consumption neither of
7-16
-------
these uses, however, constitutes a significant share of lime consumption.
Together they account for something on the order of one percent of
total demand.
In construction applications, lime is used in masonry mortar, plaster
and stucco, and road construction. Each of these areas will be discussed
as follows.
Masonry mortar often contains lime in some varying proportion with
cement and sand. The proportions chosen depend in part upon the relative
prices and supplies of the alternative inputs. They also depend on the
desired degree of porosity and the texture of the brick in addition to
the desired degree of plasticity in the mortar. Masonry lime demand
declined by about 1.6 percent during the 1960s.
Finishing lime is a term generally applied to describe all lime
used in exterior plaster, known as stucco, and in interior plaster. As
is the case with masonry mortars, lime can be feasibly eliminated al-
together from finishing lime mixtures. This factor, coupled with the
increasing popularity of gypsum board or dry wall construction in in-
terior applications, has caused a very competitive market situation for
lime in finishing and masonry applications. The use of lime for finish-
ing applications declined at an annual rate of 10.8 percent during the
1960s.
A rapidly growing application of lime is in the stabilization of
soils in road construction. The two main uses of lime in road construction
are subbase stabilization, involving fine-grained soils, and base
stabilization, involving clay-gravel type soils. These uses of lime
grew at an annual rate of 10.8 percent during the 1960s. The product
was mainly produced by commercial lime plants.
7-17
-------
Two formerly important uses of lime has been in agriculture, as a
soil conditioner, and in steel manufacturing, as a refractory material.
The most important reason for decline in agricultural applications has
been the substition of limestone as a soil conditioner and heavy use of
fertilizers. The decline of lime for refractory material is related
to the decline of the open-hearth furnace in steel making. The type
of lime used here has been dead-burned dolomite, which is rammed into
the furnace to conserve the life of refractory brick. Dead-burned dolomite
will still remain a necessary requirement for electric arc furnaces in
the future even though open hearth furnaces mostly have been displaced
by the BOF.
7.1.7 International Trade
Because of its low value to weight ratio, lime is not an important
component of international trade. For example, the value of both exports
and imports of lime during 1971 constituted less than a thousandth of a
percent of the total value of exports and imports during the year. In
spite of environmental regulations confronting the lime industry, it is
doubtful whether foreign competition will be a major factor in domestic
markets in the foreseeable future.
7.1.8 Growth Trends
Historically, the long-term (since 1930) annual rate of growth in lime
production has been approximately 5 percent. Over the 1963-1972 period,
demand for quicklime has increased annually at about 4.9 percent; hyorated
lime, about 2.2 percent; and dolomite has declined about 8 percent.^5^' Overall,
total lime industry output has grown at about 3.4 percent. In consideration
7-18
-------
of future strong markets and ttxe fact that in-roads substitution has
probably been complete in certain traditional uses (dolomite and agri-
culture), a resumption of the historical growth rate of 5 percent seems
possible for total lime production in the years ahead.
Chemical and metallurgical industry uses are likely to remain impor-
tant components of the growth of demand for lime products. However, most
of that growth within the chemical industry is likely to remain captive to
that industry. On the other hand, metallurgical uses of lime, especially
as a steel flux, will be one of the largest and fastest growing market
sectors for commercial lime producers. These include lime applications
in the manufacture of steel, copper, aluminum, and magnesium.
Other strong future markets for lime products include waste treat-
ment applications and paper and sugar beet processing operations. Among
these, the waste treatment applications of lime promise the strongest
future market for commercial lime. These applications include water
treatment and sewage treatment plant commercial lime. In addition, there
is a strong potential market for lime products in sulfur dioxide stack
gas scrubbing.
7.1.9 New Sources
Projections for the number of new kilns and hydrators were determined
in the following manner. A time series regression of historical capital
expenditures (See Table 7-4,) appropriately discounted for inflation by
use of the Chemical Engineering Plant Index, was used to predict annual
rate of investment in new capacity. ' A conclusion from this regression
is that industry invests in new and replaced capacity at a rate approxi-
mately equal to 5.6 percent of existing capacity. This further breaks
down to about 3.6 percent for net additions and 2,0 percent for replacement.
7-19
-------
The 3.6 percent growth rate is consistent with, total industry lime produc-
tion trends over the 1960 to 1975 period.. These estimates were used to
project new kiln construction for the 1977 to 1987 time pertod. See
Table 7-6, Demand projections have been made on the basis of a 5,0
percent growth rate, the base production of 1975 and a derived capacity
utilization of 84 percent. The year of 1975 represents a lull period be-
cause of general recessionary conditions. These demand projections are
shown in Table 7-6 for comparison purposes. The effective capacity
utilization for 1987 turns out to be 93 percent which may be high but not
impossible. In 1974, capacity utilization was almost TOO pexuterit
Projections for hydrators were made in the same manner as for kilns.
Existing hydrator capacity is estimated on the basis of reported Bureau
of Mines production of 2,353,000 tons per year for 1975, capacity utili-
zation of 84 percent, and a growth rate of 2.2 percent for hydrate. The
capacity utilization which is assumed to be the same as for kilns, is
derived from lime production and kiln capacity data for 1977. See Table
7-6 for projected hydrators.
7r20
-------
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7.2 P.nST ANAl YSIS Of ALTERATIVE EMISSION CONT^ni SYSTEMS
7.2.1 New Factlities
7.2.1.2 Introductton
This section discusses the development of cost estimates for each of
the alternative emission control systems outlined in Chapter 6. While
these costs will be based on controlling affected facilities in new plants,
the basic cost information presented in this section will also provide
the foundation for the analysis of modified and reconstructed facilities
in the following section.
The determination of incremental costs for the various control alterna-
tives over state regulations for new sources is a most important element in
this section. The incremental control costs are then analyzed for their
economic impact upon the viability of the lime industry. All control
alternatives must be capable of meeting the no-discharge requirement for
water-borne contaminants under EPA effluent guidelines.
7.2.1.2 Model Plants
The economic analysis will focus on plants utilizing rotary kilns for
the following product rates: 125 tons per day, 250 tons per day, and 500
tons per day of quicklime. The most representative model plant for new
plants being built is the 500 TPD. However, in a few situations small
rotary kilns may be built either to satisfy a very small regional market
or regeneration requirements for a sugar refiner. The typical hydrate plant
can produce 250 TPD of the product.
With today's business environment facing the high cost and unknown
availability of clean fuelr, lime burning technology is changing to accommo-
date coal, as the fuel, with high energy utilization. New kilns of short
7-22
-------
lengths [to reduce radiation losses) combined with stone pre4ieater
systems, with kiln exit gases heating incoming limestone, are becoming
more popular. Long rotary kilns, without preheaters, are being built
with better refractory and heat transfer internals. Either way, the trend
is toward reduced fuel consumption and the complementary reduced gas
cleaning requirements.
The parameters for model plants which are important in the cost
analysis are shown in Table 7-7. These parameters are representative
of those plants tested in the field (see Appendix C), most of which do not
have pre-heater systems. These kilns on the whole would require more com-
bustion air and hence, have higher flow rates than the more fuel-efficient
kilns with pre-heaters. As such, control costs in this sense in the report
will be representative of recently built plants but may overstate require-
ments for well-designed fuel efficient kilns in the future.
The model hydrate plant has a design capacity of 17 TPH hydrate with
6000 acfm at 85 percent moisture and a temperature of 210°F. The gas
volume for the hydrator is based on reported field data. '
7.2.1.3 Control Device Costs
The control technology for this analysis includes baghouses, gravel
bed filters, electrostatic precipitators, and venturi scrubbers for the
rotary kiln and a centrifugal wet fan scrubber for control of hydrator
emissions. The basis for developing control costs were the following
sources:
(1) Kiln
(a) Baghouses^18' 19' 20>
(b) Electrostatic Precipitators^21'22^
(c) Venturi Scrubbers^23'24)
(d) Gravel Bed Filters r25'26)
7-23
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7-24
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C2) Hydrator
(27}
(a) Centrifugal wet fan scrubber^ L
The costs for venturi scrubbers include a lined settling pond which
will handle the bleed pump discharge, which is a slurry containing about
5 percent solids at a rate of 300 gallons per minute (on the basis of the
500 TPD model plant). Periodically, solids will be removed by dredging
and trucked to a nearby landfill site. Water in the settling pond is
assumed to be recycled for the scrubber. The size of the pond is assumed
to be 2 acres for the 500 TPD plant.
The capital costs presented in this chapter are based on turnkey bids
for new systems on new plants. Direct costs which are based on vendors'
quotations include materials and labor in fabrication and erection of the
flange-to-flange control hardware, induced draft fans, ductwork, stack,
screw conveyor for dust handling, storage for collected dust, pumps,
settling pond, freight, sales, taxes, engineering, field supervision, con-
struction labor fringe benefits, vendors' administrative overhead costs,
performance tests, and start-up costs. A charge equal to 35 percent of
the direct costs was added for indirect costscontingency, overtime,
administrative overheads incurred by the owner of the new source, interest
on construction loans, and site preparation. -All capital cost? have been,
indexed tp Jyly 1976 via the Chemical Engineering Plant Index.
The annualized costs have been developed along the following assumptions.
Capital charges have been calculated on the basis of 100 percent debt financing
and recovery of capital by uniform periodic payments (capital recovery factor).
For all equipment except scrubbers, equipment life assumed is 20 years;
7-25
-------
scrubbers, 10 years. Rate of interest for Institutional lending is 10
percent. Electricity costs were assessed on 3<£ per ktlowatt-hour basis.
Maintenance and labor costs in general were adopted from the Industrial
Gas Cleaning Institute^18'22' and CARD, IncA24^ The only exception here -
was high efficiency precipitators.
The maintenance costs for high efficiency precipitator was assumed
to be twice (or 2 percent of investment) as great as similar costs for
moderate efficiency precipitators. A diligent maintenance program con-
sisting of more frequent cleaning, more frequent replacement of wires,
greater attention to operation of rappers, and similar vigilance should
result in a higher tuned precipitator and increased performance. Mainte-
nance costs for gravel bed filters have not been documented but are claimed
by the manufacturer to be low relative to other control devices; accordingly,
an estimate of 1 percent of capital investment was assigned.
Property taxes and insurance and administrative overhead costs--
operating and maintaining the control equipment and records keeping for
emissions tests, monitoring, etc,are assessed at a rate of 4 percent of
capital investment.
Charges for solids disposal have been assessed at $3 per ton for dry
solids and $4 per ton for wet solids. These values are based on discussion
(28) (29)
with the National Lime Association, 'for dry materials; and TVA studiesv '
for flue gas desulfurization systems, for wet solids.
Table 7-8 presents the summary of cost estimates for control devices
on rotary kilns. For baghouses on the 125 ton-per-day unit, much of the
control device is factory assembled; for other applications, field erected.
7-26
-------
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This explains why baghouses appear to be relatively less expensive on the
125 ton-per-day unit than other devices, for example precipitators. Three
levels of scrubbing efficiency are represented in the 9 inch, 15 inch and
22 inch pressure drop scrubbers. Two levels of electrical precipitation are ^
represented.
The parameters used to calculate energy costs and solid disposal costs
are summarized in Table 7-9. These parameters are also presented in
Chapter 6.
The centrifugal wet fan scrubber required on the hydrator is estimated
to cost $10,000 in capital. Normally, the hydrator will have simple water
sprays for capturing the valuable product. Hence, items such as ductwork,
piping, and pumps that return the collected materials to the hydrator are
parts of the process system. The annualized costs for the packed scrubber
are approximately $3000 and amount to only 4 cents per ton hydrate, which is
considered negligible.
7.2.1.4 Analysis of Control Alternatives
The purpose of this section is to analyze the cost of each of the alter-
native emission control syptems presented in Chapter 6 and to determine the
incremental costs of these alternatives over requirements with state regulations,
A summary of these alternative emission control systems is presented in
Table 7-10. The typical state regulation can be met with use of the 9-inch
pressure drop scrubber or the medium efficiency electrostatic precipitator.
The latter is chosen as the baseline for the cost analysis because of its
lower annualized costs, as shown in Table 7-8.
7-28
-------
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A summary of the incremental control costs for each alternative
emission control system is presented for the three model plants in
Table 7-11. Thp inrrempntal rnsts are the measure of costs between the
rpgiiirpd control device for each alternative emission control system and
the lowest cost device, capable of achieving the state regulationsin^
J;erms of .unit_cp_st per ton product. The most representative or the most
appropriate of available control devices was selected for each system. In
some cases the particular system shows a negative incremental capital
requirement despite the positive incremental annualized cost incurred for this
system. This is predominant for scrubber systems under alternatives B-l and B-2.
For the A-2, B-2 (low sulfur fuel] system, no costs are incurred because this
level is achievable by a control device designed to meet state regulations.
No intent has been made to differentiate fuel prices in the analysis.
The results in Table 7-11 indicate that the incremental annualized
costs for the A-l and B-l (low sulfur fuel) alternative systems are about
$.53 to $.57 per ton, except for the 125 TPD plant. For the latter, the
availability of modular construction and factory assembly are responsible
for the lower costs on a baghouse. Higher maintenance and bag replacement
are the major factors for the incremental annualized costs. The A-2 and
B-2 (low sulfur fuel) alternatives are equivalent to the C alternative.
For the B-l (high sulfur fuel) alternative, the incremental annualized
costs are $1.21 to $1.42 per ton for the use of scrubbers. For the B-2
(high sulfur fuel) alternative, these costs are $0.92 to $1.06 per ton
for scrubbers. Although capital costs for scrubbing systems are less than
similar costs for baghouses and precipitators, significant costs in energy
consumption and waste disposal more than offset savings in capital charges.
7-31
-------
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7.2.2 Modified/Reconstructed Facilities
7.2.2.1 Introduction
As discussed In Chapter 5, the primary alteration foreseen during the
1978 to 1987 period at many existing lime plants that might be considered a
modification will be conversion of gas or oil-fired kilns to coal, A kiln
undergoing such a change in operations ordinarily could utilize the same
control system and still comply with state standards. However, under the
modification provisions associated with standards of performance, the kiln
may become subject to compliance with these standards. If so, the kiln would
have to upgrade, or replace in entirety, the control system.
In this section, cost information is presented for lime plants if this
alternation is considered a modification. The aspects of the regulation of
both particulate and sulfur dioxide emissions will be analyzed.
7.2.2.2 Control Costs for Modified Sources
The basic control costs were developed in Section 7.2.1 The same
information can be used to analyze the economic impact on individual plants
if fuel switching is considered a modification.
The cost analysis is structured for four model plant cases. (See Table
7-12). The first case is for a recently built 500 TPD plant with a baghouse;
the second, a relatively old plant (125 TPD) with a cyclone device; the third,
a 500 TPD plant with an electrostatic precipitator; and the fourth, a 500 TPD
plant with a scrubber. All of these plants are assumed to be meeting state
regulations. Each of these cases is analyzed for the cost impact under each-of
the alternative emission control systems discussed in Section 7.2.1.
7-33
-------
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7-34
-------
The type of alterations that could occur with a fuel conversion would
include fuel switching to a low or high sulfur coal and possibly the addition
of a stone pre-heater.. Consistent wfth the discussion fn Chapter 5, plants
with existing cyclones or low energy scrubbers are assumed to require up-
grading these devices for a potential increase in either particulate or
sulfur dioxide emissions. Plants with existing baghouses or precipitators
are assumed to upgrade for sulfur dioxide emissions only.
Control costs for the Case 2 plant reflect the addition of a baghouse
for the A-l and A-2 alternatives, as well as the B-l and B-2 alternatives
for low sulfur fuel applications. The control costs for the case 2 plant
under the B-l and B-2 alternatives with high sulfur fuel are based on the
addition of a complete 22 IWC scrubber system. The costs for cases 1 and
3 for the B-l and B-2 alternatives with high sulfur fuel are determined
in the same fashion as case 2. The case 4 plant costs estimates include
only the upgrading of the venturi-separator section, the fan, motor and
starter. The main difference in case 4 plant costs shown in Table 7<-12
for the various alternatives reflect the use of corrosion resistant materials
in the venturi and the fan for high sulfur fuel applications.
An assumed retrofit penalty of 30 percent was included in the cost
estimates for the modified sources. This means that a retrofitted system
on an existing source would require 30 percent more capital than for a brand
new source. The 30 percent factor is a reasonable engineering judgment for
inclusion of such items as the removal of existing systems, additional
engineering to design the retrofit system, and minor changes in the offsite
utilities, such as electrical distribution.
The incremental annualized costs shown in Table 7*-12 are in addition to
the costs incurred by existing plants to comply with state regulations.
7-35
-------
The incremental annualized costs include capital charges for the retrofit
capital, and cost increases incurred for power, disposal, maintenance, taxes,
and insurance.
According to the results in Table 7-12, the most expensive situations
occur for the modified sources involved with switching from a low sulfur to
high sulfur fuel. For an existing 500 TPD plant, with a baghouse the
annualized costs for the B-l alternative are $1.92 per ton and $1.58 per ton
for the B-2 alternative. For an existing 500 TPD plant with a precipitator,
these annualized costs increase to $2.37 and $2.04 per ton, respectively. For
the existing 500 TPD with a scrubber, annualized costs for upgrading the
scrubber are $0.88 and $0.57 per ton, respectively.
For other modified sources that are concerned only with increase in
particulates, annualized costs are significant for existing sources with
low efficiency controls. For example, a 125 TPD plant with a cyclone would
incur a cost of $2.79 per ton for a baghouse for either A-l or A-2 alternative.
The 500 TPD plant with a 9 IWC scrubber in compliance with a state regulation
would incur costs of $0.81 per ton for the A-l alternative and $0.49 for the
A-2 alternative to upgrade the scrubber. Existing sources with baghouses or
precipitators are assumed not to incur any costs specifically for particulate
controls.
7-36
-------
7.3 OTHER COST CONSIDERATIONS
The scope of this analysis included the development of standards
for air emissions from lime kilns. In addition, the lime industry is
anticipated to be affected by new source performance standards for the
crushed stone and aggregate industry, which include the preparation of
limestone rock. The costs of controls for this process step have not
been analyzed in this chapter.
In addition to the air controls for rock preparation, the lime
industry must also comply with EPA's water effluent guidelines for existing
facilities and new source performance standards for new facilities. For
both, the limitation is a zero discharge of contaminants into streams,
The only source of water effluents from lime plants is derived from water
used in scrubbers to control air particulates emissions.
The control technology required to achieve this limitation for water
effluents is a closed-loop water system. Such a system can be achieved by
a well-constructed, holding basin [pond, lagoon) sufficient in size to
handle water overflows during periods of heavy rainfall. The alternative
control system is a mechanical clarifier-filtration system. The latter
would be preferred where space limitation, terrain, or soil conditions would
render construction of a holding basin prohibitively expensive or unfeasible.
An attempt was made to recognize these water costs in Section 7.2 by inclusion
of ponding in the scrubber system cases,
,rCapital and operating costs for continuous monitoring of visible emissions
a-nd su]fur dioxide are reported in Appendix D. The magnitude of these costs
is small in relation to the incremental control costs as detailed in
Section 7.2. There is no discernible impact that can be foreseen with the
7-37
-------
requirement of monitoring either or both visible emissions and sulfur
dioxide.
As far as OSHA costs are concerned, EPA is unaware of any major
problems encountered in the health and safety aspects of lime plant
operations.
7 a rrnNOMTr TMPflri nr ALTERNATIVE EMISSION CONTROL SYSTEMS FOR NEW AND
MODIFIED SOURCES
7.4.1 Introduction
The purpose of this section is to discuss the economic impact of the
incremental control costs for each alternative emission control system
identified in Chapter 6 in terms of industry growth, product prices, and
balance of trade considerations. Capital requirements for incremental
controls are also discussed.
The following assumptions are used to analyze the economic impacts of
emission control alternative systems on new and modified sources. The
first assumption is that competition among lime producers wtll limit unit-
lateral attempts to increase prices to pay for incremental control costs^
This assumption is more critical for commercial lime producers than for
captive plants, which probably can pass on the increased costs. Consequently,
/
^control costs will be addressed for two situationsone in the absence of
/
a price increase, the other in the absence of a change in profitability.
The second assumption is that product differentiation characterized by more
than a single price for lime is not a major factor in the industry. Although
there is reason to believe that product quality requirements may command a
higher price for metallurgical lime than for, let us say, sewage treatment
lime, not enough information is available to substantiate a schedule of
7-38
-------
multiple prices. As a result, only a single price will be used for the
product in the analysis.
As indicated in Section 7.1 there is a continuing trend in lime
industry toward larger plants. This is partially due to the economies of
scale associated with the mechanization of the industry, and perhaps also
due to the economies of scale associated with environmental controls.
Besides the environmental control requirements specifically addressed in
this document, the lime industry has recently faced another important shock:
the energy crisis. Dramatic recent increase in prices of all fuels and
diminished availability of natural gas have forced many plants in the
industry to convert to coal-burning facilities, utilizing stone pre-
heaters in many cases. This includes many existing plants which have
retrofitted their kilns to provide a coal-firing capability. The con-
version of a plant to utilize a switch in fuels is the type of plant
alteration that will be analyzed as a modified source.
7.4.2 New Sources
7.4.2.1 Profitability Impact Analysis
In this section, the impact of incremental costs associated with each
alternative emission control system is measured in terms of a new plant's
profitability. The incremental annualized control costs from Section 7.2
are assimilated into the plant's cost structure to calculate profit after
7-39
-------
tax (PAT) on a unit ton basis without a price increase. Similarly, price
increases necessary to maintain historical returns are calculated. The
PAT is determined by assuming a 6 percent profit margin (after-tax) on
»
sales. Profit margins for this industry have been reported to range from
4 to 6 percent sales. ' A sales estimate for a model plant is taken as
$27.50 per ton, which is the approximate reported Bureau of Mines price
for lime in 1975. ' The tax rate on income is assumed to be 50 percent.
The calculated PAT, which is $1,65 per ton, is then related to the capital
investment for a baseline grass roots plant, Such a plant is assumed to
be meeting state standards for control of air emissions. This plant should
f32^
cost about $35 per ton annual capacity.^ ' The derived PAT of $1.65 per
ton yields a after-tax ROI of 4,8 percent. The percent declines in ROI
and required price increases to maintain baseline ROI are then calculated
for each alternative emission control system. See Table 7-13 for results.
Interpretation of the results leads to the conclusion that none of
the alternative emission control systems preclude new plant investment.
The price increase required to maintain ROI for alternative A-l is 2.6
percent; and for alternative A-2, no increase in price is required. In the
judgment of EPA, prir.e inrrpa<;p<; rm t.hP nrdpr nf 3 ppyipp.n.t- are considered
as having minimal adverse impact:,. A new source, in either the commercial
or captive sectors, can probably offset increased control cost of this mag-
nitude by achieving economies of scale in building a larger plant. Further-
more, for most captive plants, such price increases would be much smaller
in terms of the price of the end product, such as steel, copper, or magnesium,
7^40
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7-41
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Considering alternatives B-l and B-2, kilns burning low sulfur coal
would resemble plants meeting participate standards under alternative A-l
and A-2. Only plants burning high sulfur coal would appear to incur a
somewhat higher impact under alternatives B-l and B-2, The price increase
under alternative B-l is 4.8 percent compared with the 2.6 percent under
alternative A-l. The less stringent alternative involving a sulfur limi-
tation, B-2, requires a price increase of 3.6 percent versus no increase
for the corresponding alternative A-2.
The relative differences in impacts between the A and B alternatives
are analytical results derived without any consideration of fuel price
differences between low and high sulfur fuels. According to industry
opinion, ' fuel use trends are toward metallurgical (low sulfur) coal
for the purpose of producing sulfur-free lime. High sulfur fuels cannot
be considered then as a substitute fuel for technical reasons in such cases.
Where high sulfur fuels can be burned for some applications, the new source
probably will find little difficulty in handling the relatively higher
costs for alternatives B-l and B-2. In those lime markets where sulfur
content of lime is not critical, the high sulfur fuel user, despite
relatively higher control costs, can probably compete with low sulfur users
from the standpoint of lower fuel costs.
7.4.2.2 Capital Requirements and Availability
This portion of the economic analysis addresses itself to the impact
of the new source performance upon the capital requirements and financial
resources of the industry. The question arises whether the increased capital
requirement for meeting standards of performance will pose any problem for
raising capital in the industry.
7-42
-------
Since the trend in plant construction will be toward 500 TPD units,
incremental capital requirements for a 500 TPD unit have been derived for
each of the alternative emission control systems. The baseline plant is
assumed to install a low efficiency precipitator to meet state regulations-
x * -
The capital for such a plant including the precipitator, is-$5,798^0067- -
u
jafhich corresponds to the $34,40 per ton annual capacity shown in Table 7-13.
Using this baseline, the incremental capital requirements are derived for
each of the alternativesA-1, A-2, B-l, and B-2. The calculations are
shown in Table 7-14. Only the A-l alternative shows any additional capital
requirement over the baseline case, a 2,1 percent increase. Capital require-
ments for the B-l and B-2 alternatives are less than the baseline case.
Judging from the results shown in Table 7-14,there would
not appear to be any problem toward raising additional capital for any of
the alternative emission control systems,
7.4.3 Mod ified Sources
7.4.3.1 P rof i tab i11ty Impac t Ana1y s is
Just as for new sources, the impact of incremental costs associated
with each alternative emission control system is measured in terms of
the impact upon the profitability of new plant investment. The type of
investment to be analyzed in this section is that associated with conversion
of a gas-fired kiln to coal. This type of fuel conversion appears to be
the only plant alteration incurring a significant cost impact with the
alternative emission control system under investigation, that is, alterna-
tives B-l and B-2 limiting sulfur.
7-43
-------
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The profit impact analysis is based on a 500 TPD plant that is
assumed to undergo a marginal investment of $1.5 million for converting
a gas-fired facility to coal. This estimate represents the installed costs
(34)
for coal handling and preparation facilities, as well as burner changes.
The plant undergoing this modification is assumed to continue the use of
the same control system for the kiln, in the absence of new source perfor-
mance standards, without additional costs. The marginal return for this
investment is calculated to be an 18.2 percent profit after tax (PAT). This
is derived from the following assumptions: (1) a sales price of $27.50,
| ,'*'' l ^ '-
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i
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i
plant investment is treated as a sunk cost. These are the same assumptions
that would confront many existing sources in the industry today faced with
a cut-off of a fuel supply. No attempt has been made to factor in higher
fuel prices which would necessitate prediction of higher lime prices.
The incremental annualized costs for alternatives A-l, A-2, B-l, and
B-2 from Section 7.2 are assimilated into the cost structure of the model plant
to determine the impact on PAT and the required price increases to maintain
the expected 18.2 percent return. Two types of model plant situations are
analyzedone existing plant with efbaghouse and another with a 9 IWC"
scrubber. The resultant declines in profit and expected price increases
(sufficient to maintain profitability) are shown in Table 7-15.
7-45
-------
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Interpretation of the results leads to the conclusion that the
alternatives B-l and B-2 would most probably preclude the marginal invest-
ment for existing plants with baghouses. The decline in ROI under B-l
is 74 percent; for B-2, 66 percent. Required price increases are 14.1
percent and 12.5 percent, respectively. In the judgment of EPA, price
increases of this magnitude are sufficient to preclude investment.
For plants presently using scrubbers, the declines in ROI are 38 percent
for the B-l alternative, and 29 percent for the B-2 alternative. Price
increases are 514 percent and 4.0 percent, respectively. In the judgment
of EPA, plants presently using scrubbers would not necessarily be deterred
from undergoing the marginal investment. From the standpoint of ranking
various investments, modification of an existing plant still offers a higher
return than for a new source. The returns are approximately 12 percent
(after tax) for both B-l and B-2 on the modified source versus approxi-
mately the 3.4 to 4 percent (after tax) for B-l and B-2 on new sources.
Within this context, it cannot be concluded that plants with scrubbers
would shutdown.
For the A-l and A-2 alternatives, the results in Table 7r.l5 indicate
declines in ROI of 33 percent and 24 percent, respectively for modified
kilns that may have to upgrade scrubbers for increased particulates.
Price increases are 4.5 percent and 3.2 percent, respectively. In the
judgment of EPA, these impacts are not of sufficient magnitude to preclude
investment. Existing kilns with baghouses prior to modification are not
considered to incur any adverse impact.
7-47
-------
7.4.3.2 Capital Requirements
Based on the assumption of conversion to coal, the capital for
modifying an existing plant [500 TPD) is $1,500,000.^35^ Using this
estimate as a baseline, the incremental capital requirements are deter-
mined for the cases analyzed in the profit impact analysis. The results
are shown in Table 7-16.
Of all four alternatives, the B-l and B-2 alternatives stand out as
the most restrictive, in particular for plants with baghouses Cor preci-
pitators). The existing plant with a baghouse woulld have to incur an
additional 59 percent capital for B-l and 56 percent for B-2, Plants with
scrubbers that would have to upgrade these scrubbers incur a capital
increase in the range of 12 to 18 percent, depending upon the alternative.
Lastly, plants with baghouses (or precipitators) would not have to incur
any capital requirements if increased particulates are the only concern,
The conclusions drawn from Section 7,4..3..1 on the profitability
analysis would apply here. For a sulfur limitation, plants with baghouses
most probably cannot afford the modification; plants with scrubbers pro-
bably can afford to modify
7.4.3.3 Impact on the Industry
From the previous discussion on profitability and capital requirements,
it is clear that sulfur limitation under new source performance standards
would have a major adverse impact on some plants switching to high sulfur
coal. An analysis of the impact in the industry has to consider the
following questions:
(1) How many plants within the industry do not have coal firing
capability?
(2) How many of these would likely switch to coal?
7-48
-------
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7-49
-------
(3) For those plants that would switch to coal, how many would use
high sulfur coal?
Based on a survey of major fuel burning installations by the Federal
Energy Administration, ' some 43 of 47 kilns owned by 21 responding
plants have reported to have coal firing capability. The scope of coverage
includes plants with a heat input greater than 100 million BTU per hour.
The scope of the survey is the SIC 3274 sector. An analysis of fuel use
by the respondents was conducted to determine the coverage of the industry
by the FEA survey. The results are shown in Table 7-17. According to the
Table, the fuel use by the respondents was 60 percent of the total fossil
fuel consumption by the SIC 3274 sector. The respondents in the FEA
survey burned 77 percent of the coal and 32 percent of the gas consumed by
the SIC 3274 sector. These data show that conversion to coal is nearly
complete for large users, and perhaps to a great extent for all kilns that
could viably burn coal. This would include potentially all kilns with
output greater than 250 TPD, according to a designer of lime plant technology.
A conclusion based on interpretation of the FEA survey is that approximately
90 percent of large plants presently have coal firing capability, Of the
remaining 10 percent, most of these would shift to low sulfur, metallurgi-
cal grade coal. This would be consistent with previous industry trends.
Consequently, the impact of the B-l and B-2 alternatives is expected to be
small on the industry.
As far as small plants, those producing less than 250 TPD, they will
probably use some combination of natural gas, synthetic gas, distillate,
or crude oil. None of these fuels are likely to contribute to an increase
in sulfur emissions (or particulates) from a fuel switch away from natural
7-50
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7-51
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gas. Consequently, no impact from new source performance standards is
foreseen for these plants.
7.4.4 Summary
The conclusions of the economic impact analysis are stated as
follows. The market for lime is expected to be healthy with an annual
compound growth rate in consumer demand projected to be 5 percent. Some
8 to 10 new kilns and 1 to 2 new hydrators are projected to be installed each
year for the next ten years. Most modifications for the next ten years
will likely be kilns switching from gas to oil. Conversion from gas to
coal has been occurring for the past few years and seems nearly complete
for the industry.
The cost impact of the A-l and B-l alternatives will be 2.6 percent
in terms of a price increase (to maintain ROI) for most new kilns, which
will be burning low sulfur coal. Similarly, price increase to maintain ROI
for B-l and B-2 is 4.8 percent and 3.6 percent, respectively, for high
sulfur fuel burning new kilns. However, there is not expected to be any
significant adverse impact for these sources in the judgment of EPA.
The capital requirements are expected to be minimal for new sources
for all proposed alternatives, Yhe most stringent alternative, A^-l,
would require an increase in capital of 2.1 percent. In the judgment of
EPA, this is considered to be reasonable.
The cost impact and capital requirements were analyzed for various
types of modified sources. For certain modifications, such as plants
switching from gas to high sulfur coal, the economic impact could be
adverse. However, there are very few modifications of this nature expected
to occur. No economic impact is foreseen to occur for the plants switching
7-52
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to oil; such modifications are not expected to incur any incremental
costs associated with the proposed alternatives*
Lastly, the economic impact on hydrators is expected to be very small
The cost impact for these sources is very small, on the order of a tenth
of 1 percent.
7r53
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REFERENCES FOR CHAPTER 7
1. Census of Manufacturers, 1972 Preliminary Reports, U. S. Department
of Commerce.
2. Annual Mineral s Yearbooks , U. S. Bureau of Mines, U. S. Department
of the Interior, U. S. Government Printing Office, Washington, D. C.,
1965-1973.
3. Miedema, Allen K. , et a!., An Economic Analysis of Pollution Control
Standards in the Lime Indutury, Research Triangle Institute, Report to
Environmental Protection Agency, Contract No. 68-02-0607, May 1974.
4. Minerals Industry Surveys, Division of Nonmetallic Minerals, Bureau of
Mines, U. S. Department of the Interior, Washington, D. C. 1929-1976.
5. Miedema, Ibid.
6. Miedema, Ibid.
7. Miedema, Ibid.
8. U. S. Department of Commerce. Concentration Ratios in Manufacturing,
Part 1 , Special Report of the 1972 Census of Manufactures. Washington,
D. C.: U. S. Government Printing Office.
9. Miedema, Ibid.
10. Monthly Labor Review, Bureau of Labor Statistics, U. S. Department of
Labor/August 1976.
11. Census of Manufactures, U. S. Department of Commerce, 1958, 1963, 1967,
_
12. Annual Survey of Manufactures, U. S. Department of Commerce, Various
years.
13. U. S. Bureau of Mines. Minerals Yearbook. Washington, D. C.: U. S.
Government Printing Office, 1973.
14. Boynton, Robert S. Chemistry and Technology of Lime and Limestone.
New York: Interscience Publishers, 1966.
15. Miedema, I bi d .
16. Miedema, Allen K. , "Standards Support Document Executive Summary of the
Economic Analysis of Standards for the Lime Industry." Research
Triangle Institute, Report to Environmental Protection Agency, Contract
68-02-0607, February 1976.
7-54
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17. Dale, John T., Trip Report: The Allied Products Company Facility,
Montevallo, Alabama, May2, 1975~.
18. "Updating Fabric Filter Costs for Lime Plants" by Industrial Gas
Cleaning Institute, EPA Contract 68-02-1473, Task No. 3, December 17,
1974.
19. Private Communication, letter from H. W. Campbell, Bethlehem Mines
Corp. to D. R. Goodwin, ESED, OAQPS, EPA, May 14, 1974.
20. Private communication, letter from C. P. Jorgensen, Marblehead Lime Co.,
to D. R. Goodwin, ESED, OAQPS, EPA, October 23, 1974.
21. Dale, John T., Trip Report: Woodville Lime and Chemical Co., Woodville,
Ohio, April 11, 1975.
22. "Study of Technical and Cost Information for Gas Cleaning Equipment in
the Lime and Secondary Non-Ferrous Metallurgical Industries" by the
Industrial Gas Cleaning Institute for National Air Pollution Control
Administration, U. S. Department of Health, Education, and Welfare.
APTD 0642, December 31, 1970.
23. "Development Document for Proposed Effluent Limitations Guidelines and
New Source Performance Standards for the Significant Inorganic
Products Segment of the Inorganic Chemicals Manufacturing Point Source
Category", General Technologies Corporation, EPA Contract No. 68-01-1513,
December 1973.
24. "Capital and Operating Costs of Selected Air Pollution Control Systems",
GARD, Inc., EPA Contract 62-02-2072, EPA Report No. 450/3-76-014, May
1976.
25. Private communication, letter from William McCandlish, Flintkote Co.,
to D. R. Goodwin, ESED, OAQPS, EPA, July 21, 1975. .
26. Private communication, letter from Steve B. Ray, Rexnard, Inc. to
F. L. Bunyard, SASD, OAQPS, EPA, August 21, 1975. '
27. Private communication, letter from William McCandlish, Flintkote,
Co., to D. R. Goodwin, ESED, OAQPS, EPA, October 14, 1974.
28. Technical Comments submitted to OAQPS, EPA by National Lime Association
Air Quality Committee, May 24, 1976.
29. McGlamery, G. G., et al., "Detailed Cost Estimates for Advanced Effluent
Desulfurization Processes," Tennessee Valley Authority, Contract Report
for Environmental Protection Agency, Report EPA-600/2-75-006, January
1975.
30. Economic Analysis of Effluent Guidelines for the Inorganic Chemicals
Industry. Arthur D. Little, Inc. prepared for Environmental Protection
Agency, EPA Report No. 230/2-74-015, National Technical Information
Services No. PB 234-457. Springfield, Va., April 1974.
7^55
-------
31. Mineral Indust ry S u rvey s, June 28, 1976.
32. Bunyard, F. L,, Private conmunication with Florian Schwarzkopf, Kennedy
Van Saun Co., Danville, Pennsylvania, September 1975 (Trip Report).
33. Private Communication, Letter from George Ziegler, National Lime
Association, to F. L. Bunyard, OAQPS, EPA, September 17, 1976.
34. Private Communication, Phone call from F. L. Bunyard, OAQPS, EPA, to
Florian Schwarzkopf, Kennedy Van Saun Co., October 19, 1976.
35. See Reference 34.
36. Major Fuel Burning Installation Coal Conversion Data, Form FEA C-
602-S-O, Federal Energy Administration, under authority from Energy
Supply and Coordinating Act, 1976.
37. See Reference 32.
7-56
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8. RATIONALE FOR THE PROPOSED STANDARDS
8.1 SELECTION OF SOURCE FOR CONTROL
The lime manufacturing industry has been identified as a significant
nationwide source of air pollutant emissions which cause or contribute to
the endangerment of the public health or welfare. Emissions from lime
plants include particulate matter, sulfur dioxide (S02), carbon monoxide
(CO), and nitrogen oxides (NOX). In 1975 there were 170 lime plants operating
in 40 states producing approximately 20 teragrams (22 million tons) of lime
per year. Since 1930, the lime industry has experienced a growth rate of
about 5 percent per year. This rate is projected to continue through 1985.
The typical lime manufacturing plant used in this document to base the
impacts of the proposed standards on is one that produces 454 megagrams
(500 tons) per day of lime from 907 megagrams (1000 tons) of limestone
feed in the rotary kiln. About 10 percent of the lime produced is further
treated by hydration in a lime hydrator. The typical lime hydrator produces
227 megagrams (250 tons) per day of hydrated lime from 182 megagrams (200
tons) of lime feed. The typical state standards for lime plants require
control of particulate emissions from lime kilns and hydrators to 0.5 kilogram
per megagram (1.0 pound per ton) of feed. The typical state standards also
require control of S02 from lime kilns to 1.0 kilogram per megagram (2.0
pounds per ton) of stone feed.
A lime manufacturing plant conforming to the level of the typical state
control standards and operating an average of 330 days per year would emit about
150 megagrams (165 tons) per year of particulate matter from the lime kiln
and 30 megagrams (33 tons) per year from the hydrator. If the kiln burns
coal which contains a low sulfur content, the emissions of SOo are about
150 megagrams (165 tons) per year. If high sulfur content, about three percent,
coal is burned, S02 emissions are about 300 megagrams (330 tons) per year
from the kiln. 8-1
-------
In a study performed for EPA by Argonne National Laboratory in 1975,
the lime industry ranked seventh on a list of the 56 largest particulate
source categories in the U.S. The list contains all of the stationary
sources of particulate matter for which control technology exists which
is capable of reducing emissions to a level below that required by state
standards and for which no significant economic impacts would be encountered
as a result of the application of such control technology. In addition, the
study ranked the lime industry fifth on a list of seven domestic SC^ source
categories.
A second study,2 performed for EPA in 1975 by The Research Corporation
of New England (TRC), ranked the lime industry 13th on a list of 112 stationary
source categories which emit particulate matter. In this study, lime plants
were also placed 21st on a list of 41 stationary sources emitting SOg.
In addition, in the prevention of significant deterioration regulations
published in the Federal Register on December 5, 1974 (39 FR 42510), lime
plants were included on the list of industrial processes which are sources
of particulate matter and S02 that are capable of contributing to the
deterioration of existing air quality. Under the provisions of these
regulations, construction of new lime plants or modification of existing
plants can be denied unless the Administrator determines that the operation
of the facility will not cause a violation of the allowable air quality
increments which are applicable to the area affected by the emissions.
The lime manufacturing industry which would be covered by the proposed
standards includes both commercial and captive operations. Presently about
22 percent of the lime used in this country is produced by captive manufacturers
for whom the manufacture of lime is an intermediate step. Examples of these
types of manufacturers are the steel industry, for use with the basic oxygen
furnace (BOF), and the sugar beet processing industry, for use in removing
impurities from the crude sugar juices.
8-2
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The proposed standards would not apply to lime kilns that process
wet lime sludqes, such as in kraft pulp mills. Standards of performance
covering emissions from these sources were proposed in the Federal Register
on September 24, 1976 (41 FR 42012).
Based on the large number of existing lime plants, the current and
projected growth rate in the industry, the wide range of plant location
across the United States, and the reduction impacts on mass emissions
that are achievable, the source category of lime manufacturing plants has
been selected for control through the development of standards of performance.
8-3
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8.2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
8.2.1 Pollutants
Emissions from lime plants include particulate matter, sulfur dioxide
(S02), carbon monoxide (CO), and nitroqen oxides (NOX). The lime kiln
has been identified as an emitter of all four pollutants. The hydrator
is a source of particulate matter only. In addition, fugitive emissions
of particulate matter may occur from transfer points, screens, and loading
operations.
Emission tests on presently operating sources have indicated that NOX
concentrations are normally in the range of 200 ppm in the exit gas from
the particulate control device. This is equivalent to an NOX emission
rate of about 0.45 pound of NOX per million Btu heat input. Assuming adverse
meteorological conditions and the occurrence of aerodynamic downwash,
an ambient air quality dispersion model of NOX emissions from the typical
lime kiln controlled to level of a typical state standard shows a
maximum concentration of about 10 yg/m3. This is 10 percent of the EPA
primary and secondary ambient air quality standard of 100 ug/m3 (.05 ppm)
annual arithemtic mean for NOX. Since the NOX emission reduction that
can be achieved through combustion modification or other control techniques
has not been demonstrated for Vme kilns, NOX emissions from lime kilns
have not been selected for control.
Emission tests on the exit gas from the particulate control device
indicate that CO emissions from lime kilns are normally in the ranqe of
100 ppm. Assuming adverse meteorological conditions and the occurrence
of aerodynamic downwash, an ambient air quality dispersion model of CO
emissions from a typical well controlled kiln shows a maximum concentration
of about 30 ug/m3 (eight-hour average). This is less than 1.0 percent of the
8-4
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EPA primary ambient air quality standard of 10,000 yg/m3 (9 ppm) maximum
eight-hour average, not to be exceeded more than once per year, and the
secondary standard of 40,000 yg/m3 (35 ppm) maximum one-hour average, not
to be exceeded more than once per year. The most effective control method
that has been demonstrated for reducing CO emissions from rotary lime kilns
is incineration of the off-gases. The use of this technique would cause a
severe fuel penalty with very little environmental benefit. Consequently,
CO emissions from lime plants have not been selected for control by standards
of performance.
Emissions of particulate matter from the model 907-meqaqrams-per-day
(1000-tons-per-day) lime kiln, controlled to meet a typical state standard,
amount to about IP kg per hour (42 Ib per hour). The maximum ground level
concentration under adverse meteorological conditions resulting in aerodynamic
downwash for a dry control system (e.g. a baghouse) is about 26 yg/m3 (24-
hour average). When a scrubber is used to control emissions, the maximum
ground-level concentration increases to about 42 yg/m3 (24-hour average)
because the cooler exhaust gases cause poor dispersion characteristics. Under
conditions of no downwash from the stack, the maximum particulate concentrations
from a dry control system and from a scrubber are approximately 3 yg/m3 and
6 yg/m3, respectively.
Particulate emissions controlled to meet the level of the proposed standard,
which requires an incremental reduction of 70 percent more than a typical state
standard, result in corresponding reductions in the load to the ambient air
particulate concentration. The 24-hour average concentration, when the stack
is designed to prevent aerodynamic downwash and produce optimum dispersion,
is less than 2 yg/m3, when either a dry system or a scrubber is used.
8.5
-------
Particulate matter emissions from the hydrator controlled to meet a
typical state standard amount to about 6.4 kilograms (14 pounds) per hour.
This emission rate assumes that the lime hydrator is operated about
14 hours per day to process 182 megagrams (200 tons) of lime into 227 megagrams
(250 tons) of hydrated lime. Almost all existing hydrators are controlled by
scrubbers of varying efficiencies. With the application of the best type
of wet fan scrubbers, the particulate emissions from hydrators could be
reduced by 85 percent compared to a typical state standard of 0.5 kg/Ng.
Since significant reductions in the mass emissions of particulate
matter from lime kilns and hydrators are possible, standards of control
of these emissions are being proposed. The levels of the proposed emission
limits are discussed in section 8.5.
The lime kiln is the only source of SO? emissions at a lime manufacturing
plant, excluding any power generating facilities that may also be present.
The S02 is principally due to the presence of sulfur compounds in the fuel
used to heat the kiln. Emissions of S02 from the 907 Mg/d (1000 tpd) model
plant controlled to the level of a typical state standard, emitting about
37 kilograms (82 pounds) per hour when using 3 percent sulfur coal,
will cause a maximum ground level concentration of about 85 ug/m3 (24-hour
average) under adverse meteorological conditions and aerodynamic downwash.
Therefore, emissions of S02 from lime plants under the most adverse conditions
would account for about 25 percent of the 24-hour national ambient air quality
standard of 365
As discussed in chapters 3 and 4, a significant reduction in SOg emissions
is achieved by the presence of the lime dust in the kiln and at the outlet
point. The amount of S02 removal depends on several factors including the
chemical composition of the stone, the temoerature in the kiln, the amount of
excess oxygen in the kiln, and the amount and particle size of the lime dust
8-6
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present in the kiln.4 When dry control systems such as a baghouse or an ESP
are used, about 88 percent of the S02 remains in the lime and 12 percent is
emitted to the atmosphere. When a scrubber is used, about 6 percent of the
S02 is emitted to the atmosphere. These values are based on the results of
the EPA source tests, presented in Appendix C.
An analysis of the available control alternatives yields the following
comparisons:
(1) Compared to baghouses, scrubbers would reduce S0£ emissions
from a model 907 Mg per day (1000 tpd) kiln by 150 Mg per
year (165 tons per year). A scrubber with a pressure drop
of 22 IWC requires about six times more energy to operate
than a baghouse and is equivalent to a total plant energy
increase of 4 percent. If this energy is produced in a
coal-fired power plant, an additional 23 tons of S02 per
year would be produced, assuming that the power plant con-
forms to the standard of performance of 0.52 gram per
meqajoule heat input (1.2 pounds of S02 per million Btu's
heat input). The power source would also produce additional
emissions of particulate matter and nitrogen oxides while
generating the additional energy.
(2) The temperature of the stack gas following a scrubber is lower
than that following a dry control device. Consequently, the
dispersion characteristics of the emissions are not as
favorable, and the maximum predicted concentration of S02
in the ambient air is only slightly less from the scrubber
even though the S02 emission rate is one-half that of the
dry control system. Under conditions of no aerodynamic down-
wash, there is no predicted difference in the maximum ambient
concentrations resulting from the two control systems.
8-7
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(3) EPA published effluent guidelines for the lime industry on
March 21, 1974 (39 FR 9621), which require zero discharge
or water. If scrubbers are required on kilns in order to
meet an S02 standard, existing lime plants could have difficulty
in meeting this level.
(4) The capital costs of installing a scrubber are les.^ than for
a baghouse. The annualized operating or .s, however, are twice
as high for a scrubber than for the dry control devices. The
costs are presented in Chapter 7.
In summary, an incremental reduction in SC^ emission rates (94 percent
control versus 88 percent) is achievable with scrubbers compared to dry
control systems. This reduction, however, would be accomplished with
corresponding adverse environmental and economic impacts that do not
appear to be reasonable. EPA has therefore determined that requiring a
standard of performance for control of S02 from lime plants is not justified
at this time, and no standard is being proposed.
8.2.2 Affected Facilities
The significant sources of particulate emissions at a lime plant are
the lime kiln and the hydrator unit. Additional secondary sources which
produce fugitive emissions are product transfer points and screening
and loading operations.
There are several types of kiln designs that are currently used by
the lime industry in this country. As discussed in chapter 3, the major
types are the rotary kiln, the verticle kiln, the rotary hearth kiln,
8-8
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and the fluidized bed kiln. Approximately 90 percent of the lime produced
in the U.S. today is calcined in rotary kilns. Virtually all of the new
kilns installed in the last two years have been rotary kilns,^ and this
trend is expected to continue in the future. In addition, rotary kilns
are the only type of kiln that can utilize coal as fuel and still maintain
acceptable product quality. It is expected that as supplies of natural
gas and oil become more expensive or unavailable, all new kilns would be
rotary lime kilns designed to burn coal.
Of the estimated ten percent of the industry which are non-rotary
type kilns, the majority are small operations and do not constitute a
significant source of emissions. Since the future need in the industry is
to have coal burning capabilities, the current trend is to replace existing
kilns with rotary kilns. The facilities that would be affected by the
proposed standards would therefore tend to be of the rotary design.
About ten percent of the lime produced in this country is also treated
by hydrators and converted to slaked or hydrated lime. Uncontrolled parti-
culate emissions from hydrators may be as high as 545 kilograms (1200 pounds)
per hour, a higher emission rate than has been estimated for a typical
lime kiln controlled with a cyclone. The typical state standard requires
that particulate emissions from a hydrator are controlled by a low efficiency
scrubber to attain a level of about 0.5 kg/mg (1.0 Ib/ton).
Since the rotary lime kiln and the lime hydrator are both significant
sources of particulate matter, they are selected as the affected facilities
for which the proposed standards will apply.
The potential points of fugitive particulate emissions at a lime plant
are at product transfer points and screening and loading operations. These
sources produce an unquantified amount of dust. Although various emission
control techniques have been identified which could reduce emissions from
8-9
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these fugitive dust sources, insufficient data concerning the effectiveness
of these techniques are available to determine achievable emission reductions.
Consequently, these sources are not covered at this time by the proposed
standards.
Definition of the Affected Facilities
8.2.2.1 Rotary lime kilns
The rotary lime kiln is the only type of kiln design that is regulated
by the proposed standard. Virtually all of the ex sting and all of the
new kilns used in the industry are rotary design. Each kiln operates
independently of the other kilns in a lime plant, with no interaction between
kilns. Kilns that process lime from a sludge, such as those at kraft pulp
mills, are Covered by a separate standard. The affected facility is therefore
defined as, "a unit with an inclined rotating drum which is used to produce
a lime product from limestone by calcination."
8.2.2.2 Hydrator
The hydration process consists of blending the lime with water in
a pre-mixer and agitating this mixture to obtain a complete chemical reaction.
The hydrator operates as a separate system from the lime kiln and is
controlled by its own control devices. At plants where there are multiple
hydrators, each operates independently. Therefore, the affected facility
is defined as "a unit used to produce a hvdrated lime oroduct."
8-10
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8.3 SELECTION OF THE BEST SYSTEM OF EMISSION REDUCTION CONSIDERING
COSTS
The purpose of the proposed standards Is to require that the best
emission control technology, considering costs, for participate matter
be installed and operated at new and modified lime plants. The affected
facilities to be controlled by the standards are rotary lime kilns and the
hydrator units. The proposed standards are based on data on emission
control systems and methods of process operation received through (1) on-
site observations of plant processes and control equipment, (2) consultation
with industry representatives and control equipment vendors, (3) emission
tests conducted by EPA on presently operating rotary lime kilns and hydrators,
and (4) meetings with the National Air Pollution Control Techniques Advisory
Committee (NAPCTAC).
The selection of the best system of emission reduction, considering
costs, is based on an evaluation of the incremental impacts, as compared
to a typical state standard, on air emissions, ambient concentrations,
air pollution control costs, energy requirements, water pollution problems,
and solid waste problems. The first step is to select the most effective
emission reduction methods for each affected facility. The impacts of
the individual methods are then compared to determine the best emission
reduction method. The best system to control particulate matter from
lime plants is a combination of the best emission reduction method or methods
for the kiln and the hydrator, since the emissions from each facility
at a lime plant are independent of emissions from other facilities.
8.3.1 Lime Ki1ns
The rotary lime kiln is the principal source of the emissions of parti-
culate matter at a lime plant. Three emission reduction methods were
8-11
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considered during the development of the proposed standards. These three
are fabric filters (baqhouses), electrostatic precipitators (ESP), and
venturi scrubbers. EPA performed source tests on rotary kilns controlled
by each one of the three control devices which show that all are capable
of meeting the particulate emission level of 0.15 kilogram per megagram
(0.3 pound of limestone feed using system A-l or B-l, which were previously
discussed in Chapter 6.
The results of source tests on the scrubber-controlled rctary kiln
show that the system did not meet the level of the proposed particulate
standard. The system, however, was operating at a relatively low pressure
drop. In EPA's judgment, an increase in the pressure drop through the
scrubber would increase the collection efficiency of the device sufficiently
to meet an emission rate of 0.15 kg/Mg.
The tests that were performed on the ESP-controlled kilns are not
indicative of normal operation since the current trend in the lime manu-
facturing industry is toward the use of coal as fuel and the kilns that
were tested were fired by oil and natural gas. It is expected that this
use of coal would produce a more difficult control problem. However,
with proper design of the ESP, it is EPA's judament that the system could
easily meet the level of the p. /posed standard.
Another current trend in the industry is toward the use of dry control
systems rather than scrubbers. EPA has published effluent guidelines for
the lime manufacturing industry that require that no discharge of water be
made from the operation. Fabric filters and ESP's have additional advantages
over scrubbers; scrubbers require about six times more energy to operate
and produce a sludge rather than the dry solid collected by fabric filters
and ESP's. This sludge is more difficult to handle and properly dispose.
8-12
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Additionally, the temperature of the gases emitted from the scrubber is lower
than that from either of the dry systems, and the dispersion of emissions is
not as efficient. EPA estimates that approximately 80 percent of the new
and modified facilities subject to the proposed standards would use a baghouse
to control particulate emissions, with the remaining 20 percent employing
an ESP. Since no scrubbers are projected to be used in the future by the
lime manufacturing industry, the proposed standard is not based on the use
of scrubbers.
The control costs associated with the use of a baghouse, an ESP, and
a 22-inch venturi scrubber are presented in chapter 7. EPA has determined
that these costs are affordable by the industry. However, the control
costs incurred with the use of a 22-inch venturi scrubber are higher than
the costs associated with the use of either a baghouse or an ESP.
8.3.2 Hydrators
Hydrators are another significant source of particulate emissions at
a lime manufacturing plant. Approximately 10 percent of the lime produced
in the U.S. is further treated by hydration. The particulate emissions
from this operation consist of particles of h.ydrated lime in a very moist
gas stream. In the domestic industry, scrubbers are generally used to collect
the emissions. The captured particulate can be returned to the hydrator
8-13
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along with the scrubbing water and successfully reused. The most common
type of scrubber used is a wet fan scrubber with centrifugal separation,
although venturi scrubbers could also be used. These scrubbers are not used,
however, because of the additional energy requirements and operational costs.
Baqhouses have been used at a few plants with varyinq degrees of success.
To allow the use of a baghouse, the exhaust gas must be superheated in order
to avoid condensation of the near saturated gas stream. This has been shown
to be very energy intensive and costly. EPA feels that all hydrators that
will be affected by the proposed standards would be likely to use a wet fan
scrubber to control particulate emissions.
The control costs associated with the use of scrubbers are presented
in Chapter 7, and are found to be very small. The annualized control costs
amount to 4 cents per ton of hydrated lime, and are considered to be negligible.
Because of the significant reduction in particulate emissions and the
relatively minor associated environmental and economic impacts, EPA concludes
that the best system of emission reduction, considering costs, for control of
particulate emissions from hydrator units at lime manufacturing plants is
a low pressure wet fan scrubber with centrifugal separation.
8-14
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8.4 SELECTION OF THE FORMAT OF THE PROPOSED STANDARDS
8.4.1 Rotary Lime Kilns
The two options available for use as the format of the proposed participate
standard are a concentration standard or a mass-per-unit-of-feed standard. The
format most widely used in the domestic lime manufacturing industry and bv
State and local control agencies is the mass-per-unit-ofrfeed standard. A
concentration standard would penalize the more energy efficient kiln operations.
Since reduced fuel consumption results in smaller exhaust gas volumes, a
concentration standard would require the most efficient kiln operators to
achieve a higher degree of control. Normally concentration standards are
easier to enforce than mass standards. The feed rate of the limestone into
the kiln, however, is routinely measured, allowing the emission rate in kilograms
of particulate per megagram of limestone feed (kg/Mg) to be calculated directly.
EPA has determined, therefore, that since the mass-per-unit-of-limestone
feed format is more eauitable for the lime producers, this format will be
used for the proposed standard.
8.4.2 Hydratorsv
The options for the format of the proposed standard for the lime hydrator
are also a concentration standard or mass per-unit-of-feed standard. A concen-
tration format would not be accurate for this facility, since the gas volume
from the hydrator scrubber is not proportional to the production rate and it
1s not possible to prevent dilution by correcting to any specified percent
oxygen and water. The format chosen, therefore, is the mass-per-unit-of-feed
format, expressed in the units of kilograms of particulate per megagram of
lime feed (kg/Mg).
8-15
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8.5 SELECTION OF EMISSION LIMITS
The emission limits for control of participate matter from lime kilns
and hydrators at lime manufacturing plants are based on the emission levels
attainable by application of the best system of emission reduction, considering
costs. The rationale for the selection of the emission limits of the proposed
standards is presented in this section.
8.5.1 Rotary Lime Kilns
Lime kilns were tested for particulate emissions at six , .roe manufacturing
plants. Three of the facilities were controlled b> baghouses, two by
electrostatic precipitators, and one by a venturi scrubber.
Kiln A, controlled by a baghouse, was source tested by EPA. Each of
the six stacks that follow the baghouse was tested once over a three-day
period. The sum of the particulate eaten totalled about 0.23 kg/Mg (0.47
Ib/T) at an average concentration of 0.034 g/std m^-dry basis (0.015 gr/
dscf). The average oxygen concentration measured during the tests was
17.5 percent.
Kiln B, controlled by a baghouse, was tested three times. The average
particulate concentration measured was 0.08 g/std m3-dry basis (0.033 gr/
dscf) at 7.7 percent 02- The corresponding emission rate averaged 0.13
kilogram per megagram (0.26 'pounl per ton).
Kiln C, controlled by an electrostatic precipitator, was tested by
EPA three times. The precipitator has two stacks and the data are presented
as the average of the two. The average particulate concentration measured
was 0.02 g/std m3-dry basis (0.0068 gr/dscf) at 10.8 percent Oe, which is
equivalent to a mass rate of 0.068 kg/Mg (0.135 Ib/ton).
Kiln D, which also uses an electrostatic precipitator for control, was
tested by EPA on two separate occasions. The first test had only two
successful runs. The average concentration of the particulate emissions
8-16
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was 0.08 g/std m3-dry basis (0.036 gr/dscf) at 10.0 percent 0£. This is
equivalent to a mass rate of 0.133 kg/Mg (0.266 Ib/ton). Three test
runs were performed during the second test. The average particulate
concentration was 0.07 g/std m3-dry basis (0.0303 gr/dscf) at 7.3 percent
Og which is equivalent to a mass rate of 0.141 kg/Mg (0.282 Ib/ton).
Kiln E, which employs a baghouse for particulate control, has three
stacks each of which was tested twice. The average particulate concentration
recorded for all three stacks was 0.014 g/std m3-dry basis (0.006 gr/dscf)
at 13.5 percent 0£. The equivalent mass rate is 0.041 kg/Mg (0.081 Ib/ton).
Kiln F, which is controlled by a venturi scrubber with a pressure
drop of 3.7 kilopascals (15 inch water gauge), was also tested three times.
The average particulate concentration during the three runs was 0.06 g/
std m^-dry basis (0.027 gr/dscf) at 11.6 percent 02. The corresponding mass
emission rate averaged 0.216 kg/Mg (0.431 Ib/ton).
Kilns A, B, and E, which were controlled by baghouses, are considered
to be the most representative of the facilities that were tested because
they were burning coal as fuel. The dust generation rates measured for
these three facilities (pounds of dust collected per pound of lime produced)
ranged from 22 to 25 percent. These are higher than the industry reported
averaqe of about 17 percent, and therefore represent difficult control
situations.
Plant A had the highest emission rate of the six that were tested.
The measured oxygen concentration was also highest for this plant. For
the kilns tested that were controlled with baghouses, plant A had an
average mass emission rate of 0.23 kg/Mg while plant B and plant E had
average mass emission rates of 0.13 kg/Mg and 0.041 kg/Mg, respectively.
EPA believes that plant A does not represent best technology (considering
costs) since the three plants were tested under similar conditions and
8-17
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two plants had much lower emissions than plant A. The data from the source
test on plant A, therefore, are not used in the selection of the proposed
particulate standard, which is based on the best system of emission reduction.
The scrubber used on Kiln F is also not considered by EPA to represent
best technology. The low pressure drop (15 inches water gauge) of this device
reduces the collection efficiency, and the data do not support a low particulate
standard.indicative of the best systen of emission reduction.
Considering, therefore, the test data from the two baghouses and two
ESP's that represent best control technology for particulate emissions
from rotary lime kilns, the average emissions ranged from 0.041 to 0.141
kg/Mg (0.08 to 0.28 Ib/T). It is EPA's judgment that the best control
technology is capable of achieving an emission level of 0.15 kilograms
per megagram of limestone feed, and the particulate standard is proposed
at this level.
8.5.2 Hydrators
)
Two hydrator units were tested for particulate emissions by EPA. Both
units were controlled with wet fan scrubbers of the type discussed in
Chapter 4 (Emission Control Technology). Scrubbers were identified as the
best system of emission reduction, considering costs, in section 8.3.
Emissions from unit H-A rang-'' from 0.033 to 0.053 kg/Mg (0.065 to
0.107 Ib/ton) and averaged 0.043 kg/Mg (0.084 Ib/ton). Emissions from
unit H-B ranged from 0.033 to 0.087 kg/Mg (0.066 to 0.173 Ib/ton) and
averaged 0.058 kg/Mg (0.117 Ib/ton).
Based on these data, EPA's judgment is that a well designed and operated
scrubber would be able to meet a particulate emission rate of 0.075 kg per
megagram (0.15 Ib/ton). This standard is supported by five of the six
test runs performed on the two hydrator units. The one test run that exceeds
this level, when averaged with any two of the remaining five runs, would
not cause an average that exceeds 0.075 kg/Mg.
8-18
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8.6 VISIBLE EMISSION STANDARDS
The opacity level of visible emissions is an indication of the mass
concentration of a particular pollutant. Various studies have shown
that opacity varies directly with mass concentrations of particulate
matter. The applicability and enforcement of opacity standards related
to participate matter have been established in several court cases for
facilities subject to new source performance standards (NSPS) under
section 111 of the Clean Air Act.
Opacity standards help to assure that emission control systems are
properly maintained and operated so as to comply with mass emission
standards on a continuous basis. Opacity test methods are quicker,
easier to apply, and less costly than concentration/mass tests for particu-
late matter. Since EPA considers opacity standards to be a necessary
supplement to particulate mass emission standards, opacity levels are
established as independent enforceable standards.
Where both opacity and concentration/mass standards are applicable
to a given source, EPA establishes opacity standards for new source
performance standards that are not more restrictive than the corresponding
concentration/mass standard. The opacity standard is generally achievable
if the source is in compliance with the concentration standard. In specific
cases where it can be demonstrated that the opacity standard is being
violated while the particulate standard is being met, provisions for
individual review are included in Method 9 (39 FR 39872).
Visible emission data were obtained during the development of the
proposed standards at seven lime kilns, and at two hydrator units during
the time that particulate mass/concentration tests were being performed.
8-19
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8.6.1 Lime Kilns
Visible emissions data were obtained during participate tests on lime
kilns at five plants. Two of the plants used baghouses for control, two
used electrostatic precipitators, and one used a scrubber. All of the
1056 six-minute averages were obtained as specified in EPA Reference
Method 9. The diameters of the stacks that were observed and tested
varied from 1.3 to 2.7 meters and the recorded data were normalized
to a 3.0 meter stack diameter to take this variation into account. The
averages range from a low of zero percent opacity at a mass concentration
of 0.011 q/std. m3-dry basis (0.005 gr/dscf), corrected to zero percent oxygen
concentration, to a high of 10.6 percent opacity at a mass concentration
of 0.24 q/std. m3-dry basis (0.105 gr/dscf) (zero percent 0?). A summary of the
distribution of the normalized visible emissions data is presented in
Table 8-1. Over 67 percent of the six-minute averages were equal to
zero and over 82 percent of the averages were less than or equal to
five percent opacity. Only 0.4 percent of the normalized averages exceeded
10 percent opacity. The highest single average read was 10.6 percent
opacity. EPA therefore believes that the best system of emission reduction
that is achieving a particulate level of 0.15 kg/Mg would easily meet
a visible emissions level of 10 p rcent opacity.
The purpose of proposing an opacity standard is to ensure continuous
compliance with the particulate standard. The level should therefore be
selected to reflect the use of the best control technology. The best control
system was identified in section 8.3 to be a baghouse or an electrostatic
precipitator. The use of one of these control devices would limit particulate
emissions to below 0.15 kg/Mg (0.3 Ib/ton). At an average volumetric
flow rate and zero percent oxygen concentration, this emission level would
produce a concentration of about 0.14 g/std. m3-dry basis (0.06 gr/dscf) and
result in consistently low opacity levels.
8-20
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8-21
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The proposed visible emissions standard of 10 percent opacity takes into
account the range of the data base and would require that the best control
devices be properly installed, maintained, and operated on a continuous basis.
Although EPA projects that baghouses and ESP's will probably be used, a
scrubber with a sufficiently high pressure drop could also be used to meet
the level of the proposed parti oil ate standard. When a scrubber is used,
however, the opacity of the emissions from the stack must be observed at a
portion of the plume where condensed water vapor is not present. EPA believes
that due to enforcement difficulties an opacity standard would not be effective
in this case, and therefore is excluding rotary lime kilns controlled with
scrubbers from the proposed opacity standard.
8.6.2 Kydrators
Observation of visible emissions were attempted during particulate
testing on two hydrators. Due to the presence of large steam plumes
from the scrubber stacks, only one hour of readings could be taken from
one unit and no readings were taken on the second. The readings that
were observed are not considered to be accurate enough upon which to base
an opacity standard for this facility because of the dispersion due to the
trailing steam plume. EPA believes that a standard would be ineffective
due to enforcement difficulties, and is therefore not at this time proposing
an opacity standard for hydrators.
8-22
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8.7 MODIFICATION AND RECONSTRUCTION CONSIDERATIONS
The proposed standards apply to all rotary lime kilns and hydrators
at lime plants which are constructed or modified on or after the date of
proposal. Provisions for modification and reconstruction are discussed
in Chapter 5 along with the various physical and operational changes that
are expected to occur at lime plants.
Four cases were considered for possible modifidation and reconstruction
of lime kilns. These are:
(1) Conversion from natural gas or fuel oil to coal firing;
(2) Addition of a st6ne preheater to an existing kiln;
(3) Addition of internal bottles to an existing kiln to improve fuel efficienc
and (4) Expanding the capacity of the production limiting component
of the facility (debottlenecking).
There appears to be no technical basis for excluding any of the
above cases from the modification and reconstruction provisions of the
regulations. In all cases, the costs and economic impacts associated
with the control of the increased emissions have been judged to be
affordable. The basis for judging the affordability of each case is
presented in detail in chapter 7, Economic Impact. No special allowances
or exemptions are proposed for the cases considered.
No cases of modification of hydrators have been considered since it
is assumed that the units would either be reconstructed or replaced entirely
at the end of the service life. Should the addition of replacement parts
which cost more than 50 percent of the cost of a new unit be made, then the
reconstruction provisions would apply, and the proposed standard of 0.075
kg/Mg (0.15 Ib/ton) would be applicable.
8-23
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8.8 SELECTION OF MONITORING REQUIREMENTS
Under section 114(a) of the Clean Air Act, the Administrator
may require the owner or operator of any stationary emission source
to install, use, and maintain monitoring equipment or methods. EPA has
exercised this authority in the standards of performance for several
source categories by requiring the monitoring of pollutant emissions
or parameters that are indicators of pollutant emissions. The requirements
for continuous monitoring are necessary to determine if a control device
is being properly operated and maintained. It also aids in determining
when and if a performance test should be required. The costs of purchasing,
Installing, and operating the monitoring devices must be considered
reasonable and affordable.
8.8.1 Lime Kilns
Particulate emissions from rotary lime kilns at lime plants are controlled
with baghouses, electrostatic precipitators, or scrubbers. All three
devices have been identified as representing the best control technology,
considering costs, and capable of meeting the proposed standard of 0.15
kq/Mq (0.3 Ib/ton). Opacity monitorinq systems are well demonstrated on
sources using these types of control systems as beinq effective for insuring
proper operation and maintenance and the costs are considered reasonable for
lime plants; therefore, the use of a continuous opacitv monitor is required
for lime kilns.
Visible emissions are more difficult to record on facilities using
scrubbers for control due to the presence of entrained water droplets in
the stack and the corresponding steam plume. This causes an error in
measurement which cannot be quantified and which would make the recorded
data questionable. Therefore, continuous monitoring of plume opacity
from the lime kiln will not be required when a scrubber is used as the
8-24
-------
control device. There are, however, other methods of monitoring the proper
operation and maintenance of the scrubber. The pressure drop across the
scrubber and the liquid flow rate are indicators of the scrubber performance.
The proposed regulations, therefore, require the use of monitoring devices
to continuously record the pressure drop and the scrubbing liquid supply
pressure to the control device. The performance of the scrubber could
then be judged at any time by comparing the values of the pressure parameters
with the values at the time the performance test was performed.
8.8.2 Hydrators
Particulate emissions from hydrators will be controlled with a scrubber
to meet the proposed standard of 0.075 kg/Mg (0.15 Ib/ton). Due to the
large attached steam plume from the scrubber stack, visible emissions
readings could not be accurately recorded during the source tests. There-
fore, no opacity standard is proposed for hydrators. Monitoring of the
operating parameters of the scrubber, however, presents a good indication
of scrubber performance. The proposed regulations therefore require the
monitoring of the water flow rate to the scrubber and of the electric
current in amperes used by the scrubber. The operation of the scrubber
may then at any time be compared to the operation during the original
performance test.
8.8.3 Excess Emissions
As specified in sections 60.7(b) and (c) of the regulations (Notification
and Recordkeeping), the operator of any source subject to the proposed
standards would be required to maintain records of the occurrence and
duration of any periods of start-up, shutdown, or malfunction in the
operation of an affected facility, any malfunction of the air pollution
8-25
-------
control equipment, or any periods during which a continuous monitoring system
or monitoring device is not operating. All excess emissions as defined
in the applicable subpart must be reported to EPA for each calendar quarter.
Generally, excess emissions are defined in terms of the applicable standards
as discussed be'iow.
Lime Kilns
Excess emissions of opacity from a lime kiln are defined as all six-
minute average opacity values that exceed the proposed standard of 10 percent
opacity, except those occurring during s-tart-up, shutdown, or malfunction
of the facility or control device. The analysis of the opacity data
recorded by EPA indicates that less than 0.5 percent of all six-minute
average opacities will exceed 10 percent when the particulate standard
is being met. Where scrubbers are used, owners or operators are required
to maintain records of the pressure drop in the gas stream and water supply
pressure to the scrubber for a period of two years; however, excess emission
reports are not required.
Hydrators
No definition of excess emissions from hydrators is included in the
proposed regulations since no opacity standard has been developed.
8-26
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8.9 SELECTION OF PERFORMANCE TEST METHODS
The test methods for the measurement of particulate matter from lime
kilns and hydrators at lime manufacturing plants are specified for determining
compliance with the proposed standards. EPA Reference Method 5 was used to
gather the particulate emissions data from the six kilns and the two
hydrators that were tested. EPA Reference Method 9 was used to gather the
1056 six-minute average opacity values that were used to support the proposed
visible emission standard for rotary lime kilns. In addition, EPA Reference
Method 2 for velocity and volumetric flow rate, Reference Method 3 for gas
analysis, Reference Method 4 for the determination of stack gas moisture,
Reference Method 6 for S02, Reference Method 7 for NOX, and Reference Method
10 for CO were used to develop the data base. All of these standard
Reference Methods have been applied to other stationary source categories
for which standards of performance have been promulgated, and have been
published in Appendix A to Part 60 of the Federal Code.
Method 5 and Method 9 are sufficient to determine compliance with the
proposed particulate and opacity standards. Therefore, they are specified
in the regulations as the required performance test methods. Method 1,
Method 2, Method 3, and Method 4 are also required to supply the additional
data necessary to determine compliance with the proposed standards.
8-27
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REFERENCES FOR CHAPTER 8
ft
1. "Impact of New Source Performance Standards on 1985 National Emissions
from Stationary Sources," prepared for the U. S. Environmental Protection"
Agency by The Research Corporation of New England, Contract 68-02-1382,
Task No. 3, October 24, 1975.
2. "Priorities and Procedures for the Development of Standards of Performance
for New Stationary Sources of Atmospheric Emissions," prepared for the
U. S. Environmental Protection Agency by Argonne National Laboratory,
Contract No. IAG-04-0463, Project No. 2, 1974.
3. "Prevention of Significant Air Quality Deterioration," Federal Register 39
FR 42510 (December 5, 1974).
4. Bunyard, F. L., EPA Trip Report of visit with F. Schwarzkoph of Kennedy
Van Saun (September 29, 1975).
8-28
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APPENDIX A. EVOLUTION OF THE PROPOSED STANDARDS
A.I LITERATURE REVIEW
Available literature was reviewed to gather background information on
the industry and its progress in control of its air pollution emissions.
A prime literature source was the Air Pollution Technical Information Center,
EPA, which routinely abstracts and catalogues literature related to air
pollution. Other sources were periodicals on air pollution and the industry,
meetings of technical societies and pertinent textbooks.
A.2 SELECTION OF PLANTS FOR SOURCE SAMPLING
As a consequence of reviewing the literature and contacting several
representatives of the lime industry several plants were identified which
were reported to effectively control emissions from rotary lime kilns and
lime hydrators. Thirty nine plants were subsequently visited by the EPA
and its contractors. During the visits, the visibility of emissions was
evaluated and information was obtained on the process and the equipment used
to control emissions. Six of these plants were deemed to employ best systems
of emission reduction for rotary lime kilns and two plants had lime hydrators
with similar well-controlled emissions. All of these plants were source tested
and the results of these tests are found in Appendix C. Two additional plants
burning high sulfur coal in five rotary kilns were located and source tested
for S02 emissions. The results of these tests can also be found in Appendix C.
A-f
-------
The capacities of the rotary lime kilns tested ranged from 240 to 720
tons of product per day. This size range is typical for the lime industry.
The hydrators that were tested were also typical of the industry, ranging
from 17 to 22 tons per hour of product. Although many of the facilities
were rather old, the long rotary lei Ins and hydrators tested are the same
as ones that would be built today.
In addition to the information provided by the ETA source tests, this
report also includes emission data from other tests. These plants were
sampled in accordance with EPA techniques. This data is included to further
prove the effectiveness of the control techniques.
A.3 CHRONOLOG
Date
October 31, 1973
November 8, 1973
January 22-24, 1974
January 31, 1974
February 8, 1974
February 12, 1974
February 13, 1974
Activity
Visit to Bethlehem Mines lime plant in
Annville, Pennsylvania.
Visit to Pfizer lime plant in Gibsonburg,
Ohio.
Emission testing at Bethlehem Mines Corpor-
ation, Annville, Pennsylvania, lime plant.
Visit to Basic lime plant in Port St. Joe,
Florida.
Visit to Woodville Lime and Chemical Company
plant in Woodville, Ohio.
Visit to the Flintkote Company lime plant in
Industry, California.
Visit to the Flintkote Company lime plant
in Henderson, Nevada.
A-2
-------
February 20, 1974
February 21, 1974
March 18, 1974
April 9, 1974
April 15-18, 1974
April 22-25, 1974
April 30-May 3, 1974
May 14, 1974
May 20-21, 1974
June 10-13, 1974
July 2, 1974
July 8-10, 1974
August 6-8, 1974
Visit to Dow Chemical Company lime plant
in Freeport, Texas.
Visit to Alcoa lime plant in Port Comfort,
Texas.
Section 114 letter sent to Mr. Leedecker of
Bethlehem Mines Corporation.
Visit to Marblehead Lime Company plant in
Gary, Indiana.
Emission test at The Flintkote Company lime
plant in Industry, California.
Emission test at The Flintkote Company lime
plant in Henderson, Nevada.
Emission test at Dow Chemical lime plant
in Freeport, Texas.
Section 114 response received from Mr. Leedecker
of Bethlehem Mines Corporation.
Emission test at Woodville Lime and Chemical
Company plant in Woodville, Ohio.
Emission test at Marblehead Lime Company
plant in Gary, Indiana.
Section 114 letter sent to Mr. Mathew of
The Flintkote Company.
Emission test at Woodville Lime and Chemical
Company plant in Woodville, Ohio.
Emission test at Woodville Lime and Chemical
Company plant in Woodville, Ohio.
A-3
-------
September 4, 1974
September 4, 1974
October 8, 1974
October 14, 1974
October 23, 1974
February 28, 1975
March 12, 1975
March 13, 1975
March 14, 1975
March 17, 1975
March 27, 1975
April 4, 1975
April 11, 1975
Section 114 letter sent to Mr. Jorgensen
of Marbleheaii Lime Company.
Section 114 letter sent to Mr. Laman of
Dow Chemical Company.
Section 114 response received from Mr. Laman
of Dow Chemical Company.
Section 114 response received from Mr. Mathew
of The Flintkote Company.
Section 114 response received from
Mr. Jorgensen of Marblehead Lime Company.
Section 114 letter sent to Mr. Campbell of
Bethlehem Mine Corporation.
Visit to Allied Products Company lime plant
in Montevallo, Alabama.
Visit to Austin White Company lime plant in
McNeil, Texas.
Visit to Texas Lime plant in Cleburne,
Texas.
Visit to The Flintkote Company lime plant
in Nelson,, Arizona.
Section 114 response received from
Mr. Campbell of Bethlehem Mines Corporation.
Section 114 letter sent to Mr. Jorgensen
of Marblehead Lime Company.
Meeting with Woodville Lime and Chemical
Company to discuss results of emission
testing.
A-4
-------
May 12, 1975
May 27, 1975
June 19, 1975
June 23, 1975
June 26, 1975
June 25, 1975
July 21, 1975
August 6, 1975
September 8-14,17, 1975
September 15-17, 1975
September 23, 1975
November 4, 1975
November 5, 1975
Section 114 letter response received from
Mr. Jorgensen of Marblehead Lime Company.
Section 114 letter sent to Mr. Tadsen of
Woodvilie Lime and Chemical Company.
Section 114 letter sent to Mr. Wilson of
Allied Products Company.
Section 114 letter sent to Mr. McCandlish
of The Flintkote Company.
Visit to Allied Products Company lime
plant in Montevallo, Alabama.
Visit to Martin Marietta Chemicals Calera,
Alabama lime plant.
Section 114 response received from
Mr. McCandlish of The Flintkote Company.
Visit to Huron Lime Company lime plant in
Huron, Ohio.
Emission testing at Martin Marietta Chemicals
Calera, Alabama, lime plant.
Emission testing at Allied Products Company
Montevallo, Alabama lime plant.
Meeting with Florian Schwartzkoph of
Kennedy Van Saun.
Visit to Bethlehem Mines Corporation lime
plant in Hanover, Pa.
Visit to Warner Company lime plant in
Bellefonte, Pa.
A-5
-------
November 11, 1975
November 12, 1975
December 2-9, 1975
January 27, 1976
January 27-31, 1976
February 4, 1976
February 11, 1976
March 9, 1976
March 18, 1976
April 30, 1976
May 19, 1976
June 30, 1976
December 21, 1976
February 11-18, 1977
Visit to J. E. Baker Company lime plant in
Mi.Hersville, Ohio.
Visit to Martin Marietta Chemicals Woodville,
Ohio lime plant.
Emission test at J. E. Laker Company
Millersville, Ohio lime plant.
Section 114 response received from Mr. Wilson
of Allied Products Company.
Emission test at Martin Marietta Chemicals
Woodville, Ohio lime plant.
Section 114 response received from Mr. Tadsen
of Woodville Lime and Chemical Company.
Meeting with the National Lime Association
in Durham, North Carolina.
Working Group Meeting held in Durham, N.C.
National Air Pollution Control Techniques
Advisory Committee Meeting.
Meeting held with National Lime Association.
Meeting held with the National Lime
Association in Washington, D.C.
Meeting held with the National Lime
Association, Marblehead Lime Company,
and Pfizer Lime Company in Durham, N.C.
EPA Working Group reviewed the proposal
package in Durham, N.C.
Review of the standards package by the EPA
Steering Committee in Washington, D.C.
A-6
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system, cross-indexed with
the October 21, 1974, Federal Register (39 FR 37419) containing the
Agency guidelines concerning the preparation of Environmental Impact
Statements. This index can be used to identify sections of the
document which contain data and information germane to any portion
of the Federal Register guidelines.
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-------
APPENDIX C. SUMMARY OF PARTICULATE
AND GASEOUS EMISSION TEST RESULTS
A program was undertaken by EPA to evaluate the particulate control
techniques available for installation on new or substantially modified rotary
lime kilns and lime hydrators. Information was obtained from the literature,
contacts with companies which manufacture lime, and control agencies. The
results of particulate and gaseous emission tests at five plants which produce
lime in rotary kilns are included in this section. An additional two plants
burning high sulfur coal were tested for S02 emissions only. The results
of particulate emission tests on two lime hydrators tested by EPA and one
tested by plant personnel are also included. All of these plants were typical
of modern installations and used best technology for control of particulate
emissions. The rotary lime kiln control devices sampled for particulates
were also tested for carbon monoxide, nitrogen dioxide, sulfur dioxide,
and visible emissions. The rotary kiln test results are summarized in
Table C-l through C-3 and the complete results are in Tables C-4 through
C-51. The hydrator emission tests are summarized in Table C-52 and the
complete results are in Tables C-53 through C-55. Emission tests performed
on the Plant A baghouse are included at the end of Appendix C because the
test results (Table C-56) seem questionable. Visible emission results are
in Table C-57 to C-63.
C-l
-------
Plant B
The exhaust gases from the rotary kiln are cooled by water sprays prior
to entering an American Air Filter Co. baghouse. The kiln is coal fired and
has a rated lime production of 650 TPD. Two of four baghouse stacks were tested
three times on consecutive days by the EPA contractor. Plant personnel tested
the other two stacks during the same time periods. EPA Method 5 was used during
testing. Results of the plant personnel tests were contained in a 114 letter
response. The complete results of the EPA testing are shown in Table C-4 and
these results are averaged with the plant personnel results to arrive at the
total emissions (Table C-5). Kiln production remained steady at 720 tons/day
during the sampling period and the baghouse pressure drop was from 4.1 to 4.4
IWC. This production rate is 111 percent of the rated capacity for the kiln.
Results of the tests showed that the baghouse is an effective control device
even when a plant is operated over rated capacity. Visible emissions averaged
zero throughout each test with only a few opacity readings of 5. The complete
visible emissions results are shown in Tables C-6 through C-ll.
Plant B Baghouse -
Type - Pressure Baghouse
Manufacturer - American Air Filter
Bag Material - Silicon & graphite finished fiberglass fabric
No. of Compartments - 14 compartments with 60 bags in each compartment
No. of Stacks - 4
Design Pressure Drop - 8 I.W.C. maximum
Cloth Area - 80,108 ft2
Bag Cleaning - Reverse air flow (one compartment at a time)
Cloth Area (operating) - 74,386 ft2
Fan Design - 126,000 ACFM @ 550°F
Design Air to Cloth Ratio - 1.7:1
C-2
-------
Plant C
Three rotary kilns process dolomitic limestone into quicklime which is
then slaked to the hydrate and used to precipitate magnesium hydroxide from
sea water. The ultimate product which is derived after additional processing
is magnesium metal. The kilns are fired by natural gas and have a design
capacity of 250 tons per day each. During normal operation only two of the
kilns are used. Exit gas from the kilns is cooled fay water sprays, enters a
common plenum, and is then distributed to the two chambers of an electrostatic
precipitator.
The two stacks from the ESP were sampled simultaneously. Production from
the two kilns controlled by the ESP was steady at about 485 tons/day which is
97 percent of toe maximum design production of 500 tons/day. Each of the three
tests yielded fairly consistent results which shows that the ESP is achieving
excellent particulate emission control. These results are summarized in Table
C-12. Visible emissions data obtained throughout the test periods are shown
in Tables C-13 through C-24. The opacities were less than 5 percent throughout
most of the testing.
Plant C Electrostatic Precijn'tator -
Type - Positive Pressure
Manufacturer - Western Precipitation Division
Plate Area - 72,576 ft 2 total
No. of Chambers - 2
No. of Fields - 3
Design Residence Time (For 3 kilns) - 7.06 sec.
Pressure Drop - 2 I.W.C. (Maximum including inlet and stack)
Flow Design - 225,000 ACFM @ 500°F with' 3 kilns operating
Cleaning - NAVCO pneumatic rappers
C-3
-------
Guaranteed Efficiency - 99%
Design Plate Area per 1,000 ACFM - 323 ft2/!,000 ACFM
Operating Residence Time (For 2 kilns) - 7.59 sec.
Operating Plate Area per 1,000 ACFM - 347 ft2/1,000 ACFM
Plant D
This facility's rotary lime kiln processes dolomitic stone and operates
on a mixture of Number 6 fuel oil and natural gas. A majority of the lime is
used in BOF furnaces. The kiln has a design production rate of 350 tons per
day. Exit gas is cooled using a combination of water injection and tempering
air before entering a Buell electrostatic precipitator.
The first test attempted on this lime kiln ESP occurred on May 20 and
21, 1974. Process operational problems and ESP maintenance difficulties
resulted in high emissions and cancellation of the test program. Opacity
readings were taken and ranged between 10 and 40 percent. A Lear Sieqler
in-stack continuous visible emission monitor was used and measured opacities
ranging from 10 to 20 percent.
The second group of tests was conducted on July 8, 9, and 10. Testing
problems on July 8 made the results of the test highly questionable (a probe
glass liner tip was found to be broken which may have resulted in obtaining
emission values that were too high). The second and third tests encountered
no difficulties and opacity readings normally ranged from 0 to 5 percent. A
test data is shown in Table C-^25 and the opacity data is shown in Table C-26
through C-31. The plant was operating at 106 percent of capacity during
testing. A fourth test, intendhd to replace the questionable values obtained
during the first test, was attempted on July 10 and 11. This test was never
completed because stack opacities rose to the 15 and 20 percent range. The
kiln was shut down and an inspection of the ESP revealed that the charge plates
were covered with 1 inch of a substance which was reducing the collection
C-4
-------
efficiency. Cleaning the plates would require shutdown of the kiln for a week
so testing was stopped.
The last test program was performed on August 6, 7, and 8, 1974. Emissions
» from the first run were greater than the second and third runs. This was
attributed to some process adjustments which were made during the first test.
These results are summarized in Table C-32. During the first test run most
opacity readings were 5 percent with some readings of 10 percent. During the
last two tests no problems occurred and the opacity values were 0 to 5 percent.
The opacity data are summarized in Table C-3 and all of the opacity data is
shown in Tables C-33 through C-38.
Lime production during the three test programs was as follows:
Tests 5/20-21 350 tons/day
Tests 7/8-10 370 tons/day
Tests 8/6-8 300 tons/day
The production drop (to 86 percent of capacity) during the last test was not
realized until after testing has been completed. Average emission concentrations
from the July and August test programs are about the same.
Plant D Electrostatic Precipitator -
Type - Positive Pressure
Manufacturer - Buell Engineering Company
Plate Area - 28,800 ft?
No. of Chambers - 1
No. of Fields - 2
Design Residence Time - 10.0 sec.
Pressure Drop - 0.3 I.W.C.
Flow Design - 64,984 ACFM @ 600°F
Cleaning - Buell electromagnetic rappers
Guaranteed Efficiency - 99.7%
C-5
-------
Design Plate Area per 1,000 ACFM - 443 ft2/!,QOO ACFM
Operating Residence Time - 9.4 sec.
Operating Plate Area per 1,000 ACFM - 437 ft2/!,000 ACFM
«
Plant E
This facility's rotary lime kiln was source"~tested. The kiln has a nominal'
design capacity of 264 tons per day of high calcium lime, which is used in the
paper and pulp industry. The kiln off-gas is cooled by an atomized water spray
and then ducted to the American Air Filter baghouse.
Each of the three baghouse stacks was tested twice. During the testing
the kiln production was a steady 240 tons per day, or 91 percent of the rated
capacity. Visible emission readings were taken during the testing and they
were almost always zero. These results are shown 1i> Tables C-40 through C-47.
Simultaneous sulfur dioxide tests were performed wtth EPA Method 6 at the inlet
and outlet to the baghouse in an attempt to determine the effect the baghouse
had on S02- These tests proved inconclusive since only one outlet test yielded
results. Tests performed with Dynascience continuous gas monitor showed an
approximately 40 percent reduction in S02 across the baghouse. A complete
summary of the emission test results is shown in Table C-39.
Plant E Baghouse -
Type - Pressure Baghouse
Manufacturer - American Air Filter Corporation, in operation March 1975
Bag Material - Silicon & graphite finished fiberglass fabric
No. of Compartments - 6 compartments with. 72 bags in each compartment
No. of Stacks - 3
Design Pressure Drop - 2.5 I.W.C.
Cloth Area - 41,196 ft2
Bag Cleaning - Reverse air flow (one compartment at a time)
Cloth Area (operating) - 34,330 ft2
-------
Fan Design - 65,000 ACFM (250 Hp @ 880 RPM)
Design Air to Cloth Ratio - 1.89:1
Plant F
The rotary lime kiln was source tested. The kiln has a rated
production capacity of 650 tons of high calcium lime per day. Emissions are
controlled by 12 Buell cyclones and dual ASE, Incorporated venturi water
scrubbers. The kiln off-gas is cooled by an atomized water spray. The exhaust
from the dual venturi scrubbers is sent to cyclonic separators and is then
reunited and vented to the atmosphere through a single stack. This stack
was tested three times using EPA Method 5.
The stack was tested over a 3 day period. The kiln production
was steady at 620 tons/day which is 95 percent of the maximum design capacity
for the kiln. The results of this test show the particulate removal efficiency
of a 15 I.W.C. water scrubber. Three simultaneous inlet and outlet S0£ tests
were attempted but problems were encountered in the S02 testing and only one
of the six tests yielded any results. A summary of the emission tests is
shown in Table C-39. Visible emission readings were attempted during the
particulate testing but the large steam plume made it impossible to make any
meaningful readings. A summary of the opacity readings is shown in Table C-49.
Plant F Venturi Scrubber -
Type - Dual Venturi Water Scrubbers
Manufacturer - ASE, Inc. installed Nov. 1973
Design Pressure Drop - 15 I.W.C.
Design Throat Water Flowrate - 800 gallons per minute per throat
Air Flow Rate - 91,000 ACFM @ 650°F per venturi throat
Type Precleaners - 12 Buell cyclones
C-7
-------
Plant G
This facility has 2 rotary lime kilns, one designed to produce 350 tons of
lime per day and another designed to produce 280 tons of dead burned dolomite
(DBD) per day. The fuel for these kilns is. high, sulfur (3.53 and 2.96% S)
coal. Both kilns are controlled by identical Air Pollution Industries water
scrubbers and their products are used in the steel industry. There is no
cooling or precleaning of the kiln off-gas before it reaches the scrubbers.
Six EPA Method 6 tests were run at the inlet and outlet of each kiln.
The tests on the DBD kiln were run simultaneously. The lime kiln was producing
320 tons of lime per day during the outlet testing and the DBD kiln was producing
280 tons per day during its testing. No visible emission readings were performed
during the testing. A complete summary of the S02 testing is found in Table
C-40.
Plant G Venturi Scrubber -
Type - Venturi Water Scrubber
Manufacturer - Air Pollution Industries, Inc.
Design Pressure Drop - 15 I.VI.C.
Design Throat Flow Rate - 2200 gpm
Design Air Flow Rate - 62000 ACFM @ 160°F
Precleaners - None
Guaranteed Efficiency - 0.39 gr/DSCF e 70°F
Plant H
This facility has three rotary kilns whose off-gas is ducted to one 22
compartment baghouse. Two of the kilns process dolomitic limestone to produce
720 and 960 tons of lime per day, respectively, for use in the steel industry.
Each has a Kennedy Van Saun stone preheater and 2V Research Cottrell Multiclones.
C-B
-------
The preheater and cyclones cool the off-gas sufficiently for cleaning in the
baghouse. The third kiln produces 4QO tons per day of DBD. There is no preheater
but there are Western Precipitation cyclones, and tempering air can be added to
the kiln off-gas before it enters the baghouse. All of the kilns are fired
by high sulfur (2-3% S) coal.
Inlet S02 testing was attempted by both EPA Method 6 and continuous
instrumental S02 analyzers. Most of the results obtained were questionable
due to lime dust interference, but the indication from the tests was that
most of the S02 was from the Number 6 (DBD) kiln. EPA Method 6 testing
on the DBD kiln gave 833, 74 and 78 parts per million (ppm) S02, and the continuous
monitor gave concentrations ranging from 580 tc 1300 ppm. During the baghouse
testing, the concentration at the DBD inlet ranged from 373-416 ppm. The
highest recorded S02 from either of the lime kilns was 200 ppm, and the
concentration averaged around 130 ppm. During the outlet testing, the inlet
S02 concentrations from the lime kilns was negligable according to the
instruments, but this was probably due to lime interference with the instruments.
Based on the limited amount of inlet data available, the indication is that
over half of the S02 in the baghouse came from the DBD kiln and the rest was
from the two lime kilns.
Simultaneous EPA Method 6 S02 tests were performed on six of the 22
baghouse stacks during each outlet sampling period. Six of these runs were
performed over a two day period while the plant was operating normally for a
total of 36 S02 tests. Sampling difficulties invalidated 2 of the 36 tests.
At least one test was performed on each baghouse stack. The results were
averaged to arrive at the S02 emission rate for the three kiln-baghouse systems.
A summary of these tests is shown in Table C-51. The three kilns operated at
\
over 93 percent of capacity during testing. No visible emissions were seen
from the baghouse during the entire week of the testing.
C-9
-------
Plant H Baghouse -
Type - Pressure Baghouse
Manufacturer - Western Precipitation, in operation June 1975
Bag Material - Graphite, silicon and teflon coated glass
No. of Compartments - 22 compartments with 672 bags in each compartment
No. of Stacks - 22
Design Pressure Drop - 3 I.W.C.
Cloth Area - 214,368 ft2
Bag Cleaning - Reverse air flow [one compartment at a time)
Cloth Area (operating) - 194,880
Design Air to Cloth Ratio - 2.04:1 cleaning 2.24:1
Fan Design 2 - 115,000 ACFM, 1000 Hp @ 5QO°F
22 - 19,600 ACFM, 100 Hp @ 550°F
C.2 LIME HYDRATION FACILTLES
Plant H-A
This facility produces calcium hydroxide in a calcitlc lime atmospheric
hydrator. The plant is designed so that 14 tons per hour of lime is
hydrated into 17 to 18 tons of hydrated lime. The entrained particulate is
scrubbed out of the gas stream in a Ducon UW-4 Dynamic Water Scrubber. Twenty
gallons of water per minute are used to scrub the particulate out of the off-
gas stream and are then fed into the pug mill prenrixer as part of the slaking
water. The gases out of the scrubber have 40 percent moisture content.
Three particulate tests were performed at the hydrator stack. Tests 1
and 2 were of four hour duration and test 3 was two hours long. The plant
was operating at capacity throughout the testing. Visible emission data were
C-10
-------
recorded for one hour during the third test but no visible emissions were
discernable due to the large steam plume. The emission data is shown in Table
C-53 and the opacity data is shown in Table C-54.
. Plant H-B
This facility is designed to produce 22 tons per hour of high calcium
hydrated lime from 18 tons of lime feed in an atmospheric hydrator. The
hydrator off-gas is scrubbed in a Ducon UW-4 Dynamic Water Scrubber. Twenty
gallons of water per minute is fed to the scrubber fan to remove the particulate.
The off-gas of the scrubber has a 78 percent moisture content.
Three 128 minute EPA Method 5 particulate tests were performed on the
hydrator stack. During testing the plant was operating at capacity. The
results of the emission testing are shown in Table C-55. The large steam plume
and the overcast background during the particulate testing made it very difficult
to discern visible emissions. For this reason no visible emission data were
C-ll
-------
Table C-l
Rotary Lime Kilns
Summary of Parttculate Test Results
Plant
Stone Feed Rate-
tons/yr
Product TPD
Control Equipment
Fuel
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol %
COg-Vol % dry
02-Vol % dry
CO-Vol % dry
No & other gases
Vol % dry
Particulate Emissions
Probe & Filter Catch
gr/ACF
gr/DSCF
Ib/hr
Ib/ton of feed
kg/Mg ton of feed
B
60
720
Baghouse
Coal
133,700
72,400
372
15.3
19.3
8.1
0
72.6
0.012
0,022
13.3
0.222
0.111
C
40.4
485
ESP
Gas
180,000
92,500
394
18.0
9.5
10.8
0
79.7
0.0035
0.0068
5.47
0.135
0.068
DO)
32.6
370
ESP
Oil &
68,800
28,000
672
11.8
20.3
10.0
0
69.7
0.015
0.036
8.7
0.266
0.133
DC2)
26.3
300
Gas
65,900
28,000
642
10.5
20.7
7.3
0
72.0
0.0129
0.0303
7.42
0.282
0.141
E
19
226
Baghouse
Coal
48,100
30,900
270
10.5
9.2
13.5
0
77.3
0.0038
0.0059
1.56
0.081
0.041
F
51.6
620
Scrubber
Coal &
Gas
137,000
95,100
149
19.8
12.9
11.6
0
75.5
0.0190
0.0274
22.26
0.431
0.216
C-12
-------
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Run No.1
Date
Test Time-Minutes
Stone Feed Rate-
tons/hr
Table C-4
Summary of EPA Test Results
Plant B
Fuel - 0.63! S Coal
Control Equipment - Baghouse
1A IB
1/22/74 1/22/74
192 192
60
2A 2B
1/23/74 1/23/74
144 144
60
3A 3B
1/24/74 1/24/74
144 144
60
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol %
C02-Vol % dry
02-Vol % dry
CO-Vol % dry
N2 and other
gases-Vol % dry
N0x-ppm
S02-ppm
CO-ppm
Parti cul ate Emissions
Probe and Filter Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
23,894
13,241
362
14.3
16.6
6.8
0
76.6
216
15
20
0.0204
0.0113
2.318
0.039
20,109
16,973
372
16.4
17.8
6.8
0
75.4
275
8
0.0318
0.0268
4.622
0.077
28,621
11,081
352
15.6
19.4
8.2
0
72.4
198
30
0.0209
0.0081
1.982
0.033
31,753
22,481
358
18.0
18.7
8.0
0
73.3
288
20
10
0.0359
0.0254
6.923
0.115
42,289
15,718
372
14.6
19.0
8.1
0
72.9
179
12
0.0210
0.0078
2.783
0.046
30,442
16,206
378
16.7
18.8
8.2
0
73.0
267
23
10
0.0477
0.0253
6.623
0.110
C-15
-------
Table C-4 (continued)
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
0.0244
0.0135
2.767
0.046
0.0353
0.0298
5.133
0.086
0.0237
0.0092
2.247
0.037
0.0407
0.0288
7.834
0.131
0.0250 0.0505
0.0093 0.0269'
3.394 7.011
0.057 0.117
Test data from two stacks of four.
C-16
-------
Table O5
Plant Personnel & EPA Test Results
Plant B
Fuel-0.6% S Coal
Control Equipment - Baghouse
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol.%
C02-Vol.2 dry
Op-Vol .% dry
CO- Vol. « dry
Hy and other gases-
^Vol.% dry
N0x-ppm
SOp-ppm
CO-ppm
Particulate Emissions
Probe & Filter Catch
gr/DSCF
gr/ACF
Ib/hr
lb/tona
Total Catch
gr/DSCF
gr/ACF
Ib/hr
lb/tona
Plant Personnel Tests
(Stacks C and D)
Number
of
Tests
3
5
4
3
3
Average
Total
Emission
74700
40500
378
14.6
20.2
8.5
0
71.3
54
8
10
0.014
0.007
4.9
-
0.018
0.010
6.2
EPA Tests
(Stacks A andxB)
Number
of
Tests
3
6
6
3
r 3
Average
Total
Emission
59000
31900
366
15.9
18.4
7.7
0
73.9
236
18
13
0.030
0.016
8.4
-
0.033
0.018
9.5
Average
Total
Plant
Emissions
133700
72400
372
15.3
19.3
8.1
0
72.6
145
13
12
0.022
0.012
13.3
0.22
0.026
0.014
15.7
0.26
JStone feed rate - 60 TPH
C-17
-------
Date: 1/22/74
Type of Plant: Lime Kiln
Type of Discharge: Stack
Location of Discharge: Baghouse Outlet
Height of Point of Discharge: 100 ft.
Description of Background: Hill: Brown
Description of Sky: Overcast
Wind Direction: Variable
Color of Plume: None
Duration of Observation: 60 min.
TABLE C-6
FACIirY B
Summary of Visible Emissions
Observer # 1
Distance from Observer to Discharge Point: 75 ft.
Height of Observation Point: 70 ft.
Direction of Observer from Discharge Point: S
Wind Velocity: 5-10 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Set Number
1
2
3
4
5
6
7
8
9
10
T
Start
1341
1347
1353
1359
1405
1411
1417
1423
1429
1435
ime
End
1346
1352
1358
1404
1410
1416
1422
1428
1434
1440
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
C-18
-------
TABLF t-7
FACILH/ B
Summary of Visible Emissions
Observer # 2
Date: 1/22/74
Type of Pldnc: Lime Kiln
Type of Discharge: Stack
Location of Discharge: Baghouse Outlet
Height of Point of Discharge: 70 ft.
Description of Background: Hill (Brown)
Description of Sky: Overcast
Wind Direction: Variable
Color of Plume: None
Duration of Observation: 60 min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:75 ft.
Height of Observation Point: 70 ft.
Direction of Observer from Discharge Point: S
Wind Velocity: 5-10 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20 -
Start
1341
1347
1353
1359
1405
1411
1417
1423
1429
1435
End
1346
1352
1358
1404
1410
1416
1422
1428
1434
1440
Opacity
Sum
0
0
0
0
0
0
0
0
0
5
Average
0
0
0
0
0
0
0
0
0
0.2
Time Opacity
Set Number Start End Sum Average
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-19
-------
Date: 1/23/74
Type of Plant: Lime Kiln
Type of Discharge:Stack
Location of Discharge: Baghouse Outlet
Height of Point of Discharge: 75 Ft.
Description of Background: Hill (brown)
Description of Sky: Partly Cloudy
Wind Direction: Variable
Color of Plume: White
Duration of Observation: 60 min.
SUMMARY OF AVERAGE OPACITY
TABU: c-8
FACILIIY B
Summary of Visible Emissions
Obserber # 1
Distance from Observer to Discharge Point:100 Ft.
Height of Observation Point: 75 Ft.
Direction of Observer from Discharge Point: S
Wind Velocity: 5 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
2Q - -
T
Start
1042
1048
1054
1100
1106
1112
1118
1124
1130
1136
ime
End
1047
1053
1059
1105
1111
1117
1123
1129
1135
1141
Sum
0
0
0
0
0
0
0
0
0
0
Opacity
Average
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Opacity
Sum Average
C-20
-------
1ACLL C-9
FACILITY B
Surr.piar.;, o,'-" Visible Emissions
Observer # 2
L\, ie: 1/23/74
«
ly., o,' rlcir.i.: Lime Kiln
]yo: 07" Discharr,o: Stack
Lcrutio.i of Cischc >"<>;: Baghouse Outlet
Height c,' Point of Discharqo: 75 Ft.
Descrip' ':-',\ of Ekc^-ground: Hill (brown)
Descrip: :on of S'-.y: Partly Cloudy
Wi nd Di t.?-tion: Variable
Color of Plume: White
Duration of Observe ticii: 60 Min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Puint: 100 Ft,
Height of Observation Point: 75 Ft.
Direction of Observer from Discharge1 PC
Wind Velocity: 5 MPH
Detached Plume: Mo
SUMMARY OF AVERAGE OPACITY
ii!.'3 Opacity
C ,; 4- f ' . ' ,
OC L Ul'll ' . .
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16 "
17
18
19
20
S^art
1042
1048
1054
1100
1106
1112
1118
1124
1130
1136
"
tnd
1047
1053
1059
1105
1111
1117
1123
1129
1135
1141
Sum
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
Time Opaci ly
Set iiumoer Start End Sum Aver?g^
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-21
-------
D?te:1/24/74
Type of Plant:Lime Kiln
Type of Discharge: Stack
Location of Discharge: Baghouse Outlet
Height of Point of Discharge: 75 Ft.
Description of Background: Hill (brown)
Description of Sky: Partly Cloudy
Wind Direction: Variable
Color of Plums: White
Duration of Observation: 60 Min.
SUMMARY OF AVERAGE OPACITY
TABLE C-10
FACILITY B
Summary of Visible Emissions
Observer # 1
Distance from Observer to Discharge Point: 100 Ft.
Height of Observation Point: 75 Ft.
Direction of Observer from Discharge Point: S
Wind Velocity: 5-10 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Set Number
1
2.
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
t
Start
916
922
928
934
940
946
952
958
1004
1010
*
ime
End
921
927
933
939
945
951
957
1003
1009
1015
Opacity
Sum
0
0
0
0
0
0
0
25
0
0
Average
0
0
0
0
0
0
0
1.0
0
0
Time Opaci ty
Set Number Start End Sum Average
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
.38
39
40
C-22
-------
TABLE C-11
FACILITY B
Summary of Visible Emissions
Observer # 2
Date: 1/24/74
Type of Plant: Lime Kiln
Typo of Discharge: Stack
Location of DiscL.rge: Baghouse Outlet
HeicJ.t of Point of Discharge: 75 Ft.
Description of Background: Hill (brown)
Description of Sky: Partly Cloudy
Wind Direction: Variable
Color of Plume: White
Duration of Observation: 60 Min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:100 Ft.
Height of Observation Point: 75 Ft.
Direction of Observer from Discharge Point: S
Wind Velocity: 5-1 o MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Set Nurr.jer
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
Start
916
922
928
934
940
946
952
958
1004
1010
Mine
End
926
927
933
939
945
951
957
1003
1009
1015
Opaci
ty
Sum Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
lime Opacity
Set Number Start End Sum Average
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-23
-------
Table C-12
Summary of Test Results
Plant C
Fuel - Gas
Control Equipment - Electrostatic Precipitator
Run No.
Date
Test Time-Minutes
Stone Feed Rate-
tons/hr
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol .%
COo-Vol.% dry
02-Vo>.% dry
CO-Vol.% dry
N2 and other gases-
Vol.% dry
NO^-ppm
SOo-ppm
CO-ppm
Particulate Emissions
Probe & Filter Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
,(1)
4/30/74
126
40.6
191,429
96,978
411
17.8
9.4
11.6
0
79.0
129
0
41
0.0114
0.0058
9.51
0.234
0.0200
0.0101
16.68
0.411
2(D
5/2/74
200
40.0
170,711
88,856
386
17.7
10.1
10.5
0
79.4
96
0
54
0.0031
0.0016
2.37
0.0591
0.0101
0.0053
7.73
0.193
3
5/3-4/74
200
40.6
179,451
92,011
385
18.4
9.1
10.2
0
80.7
96
0
255
0.0058
0.0030
4.55
0.1118
0.0101
0.0052
8.0
0.197
Average
175
40.4
180,530
92,615
394
18.0
9.5
10.8
0
79.7
107
0
117
0.0068
0.0035
5.466
0.135
0.0134
0.0069
10.8
0.267
(1)
Test data from two stacks.
-------
TABLE C-13
FACILITYC
Sunniary of Visible Emissions
Observer: 1
D--iie:3Q April 1974
i
Type of Pic'nc: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: South Stack
Height of Point of Discharge: 100 Ft.
Description of Background: White-gray clouds
Description of Sky: Overcast
Wind Direction: SE Wind Velocity: 6-10 MPH
Color of Plume: None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 Ft.
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point: SW
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
Start
1605
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1741
1747
1753
1759
End
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1741
1747
1753
1759
1805
Opacity
Sum
0
0
0
0
Q
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Set Number
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Time
Start
1805
1811
1817
1823
1829
1835
1841
1847
End
1811
1817
1823
1829
1835
1841
1847
1853
Opacity
Sum
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
o
0
0
C-25
-------
TABLE C-14
FACILITY C
Summary of Visible Emissions
Date: 30 April! 974 Observer : 2
Type of Plant: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: South Stack
Height of Point of Discharge: 100 Ft.
Description of Background: white-gray clouds
Description of Sky: Overcast
Wind Direction:SE Wind Velocity: 6-10 MPH
Color of Plume:None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 Ft.
Height of Observation Point:0 Ft.
Direction of Observer from Discharge Point: SW
SUMMARY OF AVERAGE OPACITY
Time
Opacity
Time
Opacity
Set Number Start End Sum Average Set Number Start End Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
1605
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1741
1747
1753
1759
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1741
1747
1753
1759
1805
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
1805
1811
1817
1823
1829
1835
1841
1847
1811
1817
1823
1829
1835
1841
1847
1853
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-26
-------
TABLE C-15
FACILITY C
Summary of Visible Emissions
Observer: 3
Date: 30 April 1974
*
Type of Plant: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: North Stack
Height of Point of Discharge: 100 Ft.
Description of Background: white-gray clouds
Description of Sky: Overcast
Wind Direction: SE Wind Velocity: 6-10 MPH
Color of Plume: None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:525 Ft.
Height of Observation Point:0 Ft.
Direction of Observer from Discharge Point:SW
SUMMARY OF AVERAGE OPACITY
Time
Dpacity
TTme
Opacity
Set Number Start End
Sum
Average Set Number Start
End
Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20 .'
1605
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1741
1747
1753
1759
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1741
1747
1753
1759
1805
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
1805
1811
1817
1823
1829
1835
1841
1847
1811
1817
1823
1829
1835
1841
1847
1853
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-27
-------
TABLF C-16
FACILITY C
Summary of Visible Emissions
. -, -,*-,, Observer: 4
Date: 30 April 1974
Type of Plant: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: North Stack
Height of Point of Discharge: 100 Ft.
Description of Background: white-gray clouds
Description of Sky: Overcast
Wind Direction: SE Wind Velocity: 6-10 MPH
Color of Plume: None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 Ft
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point: SW
SUMMARY OF AVERAGE OPACITY
Time
Opacity
Time
Opacity
Set Number Start End
Sum
Average Set Number Start End Sum Average
1
2
3
4
5
6
7
8
9
10 .
11
12
13
14
15
16
17
18
19
20 -'
1605
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1736
1742
1748
1754
1800
1611
1617
1623
1629
1635
1641
1647
1653
1659
1705
1711
1717
1723
1729
1735
1742
1748
1754
1800
1806
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
1808
1814
1820
1826
1832
1838
1844
1850
1814
1820
1826
1832
1838
1844
1850
1856
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
C-28
-------
Observer: 1
TABLE C-17
FACILITY C
Summary of Visible Emissions
Date: 2 May 1974
Type of Fldnc: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: South Stack
Height of Point of Discharge: 100 Ft.
Description of Background: Scattered clouds
Description of Sky: Partly cloudy Blue/white
Wind Direction: S-SW Wind Velocity: 4-6 MPH
Color of Plume: None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 Ft,
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point:SW
Time
Opacity
Time
Opacity
Set Number Start End
Sum
Average Set Number Start
End
Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
1152
1158
1204
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1158
1204
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
1352
1358
1404
1410
1416
1422
1428
1434
1440
1446
1452
1458
1504
1510
1516
1522
1528
1534
1540
1546
1358
1404
1410
1416
1422
1428
1434
1440
1446
1452
1458
1504
1510
1516
1522
1528
1534
1540
1546
1552
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
D
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-29
-------
TABLE C-18
FACILITY C
Summery of Visible Emissions
Observer: 2
Date: 2 May 1974
Type of Plant: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: South Stack
Height of Point of Discharge: 100 Ft.
Description of Background: Scattered Clouds
Description of Sky: partly Cloudy Blue/White
Wind Direction: s-SW Wind Velocity: 4-10 MPH
Color of Plume: None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 F
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point: SW
SUMMARY OF AVERAGE OPACITY
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
1
Start
1352
1358
1404
1410
1416
1422
1428
1434
1440
1446
1452
"1458
1504
1510
1516
1522
1528
1534
1540
1546
ime
End
1358
1404
1410
1416
1422
1428
1434
1440
1446
1452
1458
1504
1510
1516
1522
1528
1534
1540
1546
1552
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End Sum Average
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-30
-------
Observer: 2
T/.ULE C-19
FACILITY C
Summary of Visible Emissions
Note: 2 May 1974
Type of Plane: Lime Kiln
Type .-of Discharge: ESP Outlet
Location of Discharge: North Stack
Height of Pont of Discharge: ,100 Ft.
Description of Background: Scattered Clouds
Description of Sky: Partly Cloudy Blue/White
Wind Direction: S-SW Wind Velocity: 4-6 MPH
Color of Plume: None Detached Plume: None
Duration of Observation:
SUMMARY OF AVERAGE OPACITY SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 Ft.
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point: SM
Time
Set Number
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16 '
17
18
19
20
Start
1152
1158
1204
1210
1216
1222
1228
1234
1240
1246
1252
T258
1304
1310
1316
1322
1328
1334
1340
1346
End
1158
1204
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End Sum Average
21
22
23
24
75
iw
29
30
31
32
33
34
35
36
37
38
39
40
U-3!
-------
TABLE C-20
FACILITY C
Summary of Visible Emissions
Observer: 4
Date: 2 May 1974
Type of Plant: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: North Stack
Height of Point of Discharge: 100 Ft.
Description of Background: Sky
Description of Sky: Partly Cloudy Blue/white/grey
Wind Direction: S-SW Wind Velocity: 4-6 MPH
Color of Plume: N0rie Detached Plume: None
Duration of Observation:
SUMMARY OF AVER/AGE OPACITY . SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 525 F1
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point: SW
Time
Opacity
Time
Opacity
Set Number Start End
Sum
Average Set Number Start End Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
1152
1158
1204
1210
1216
1222
1228
1234
1240
1246
1252
'1258
1304
1310
1316
1322
1328
1334
1340
1346
1158
1204
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
C
C
C
C
(j
C
0
0
0
0
0
20
120
120
120
110
120
120
120
120
0
0
0
0
0
0
0
0
0
0
0
0.8
5.0
5.0
5.0
4.6
5.0
5.0
5.0
5.0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
1352
1358
1404
1410
1416
1422
1428
1434
1440
1446
1452
1458
1504
1510
1516
1522
1528
1534
1540
1546
1358
1404
1410
1416
1422
1428
1434
1440
1446
1452
1458
1504
1510
1516
1522
1528
1534
1540
1546
1552
115
120
120
120
120
120
120
120
120
120
115
120
120
120
120
115
120
120
120
120
5.0
5.0
5.0
5.0
5.0
5.0
5.0
4.8
.0
.0
.0
.0
4.8
4.8
4.8
4.8
4.8
5.
5.
5.
5.
Note: Sets 12 thru 40, Observer reported all
readings as either "0" 'or "less than 535" . Fo
purposes of this summary, the latter was
at:
C-32
-------
TABLE C-21
FACILITY C
Summary of Visible Emissions
Date: 3 May 1974 Observer:!
i
Type of Plant: Lime Kilns
Type of Discharge: ESP Outlet
Location of Discharge: South Stack
Height of Point of Discharge: 100 ft.
Description of Background: Sky
Description of Sky: Partly cloudy, Hazy Blue
Wind Direction: S-SE Wind Velocity: 5-10 mph
Color of Plume: Yellowish Detached Plume: none
Duration of Observation:
Distance from Observer to Discharge Point: 450 ft.
Height of Observation Point:0 ft.
Direction of Observer from Discharge Point: NE
SUMMARY OF AVERAGE OPACITY SUMMARY OF AVERAGE OPACITY
Set Number
Time
Start End
Opacity Time
Sum Average Set Number Start End
Opacity
Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
10:10
10:16
10:22
10:28
10:34
10:40
10:46
10:52
10:58
11:04
11:10
11:16
11:22
11:28
11:34
11:40
11:46
11:52
11:56
10:16
10:22
10:28
10:34
10:40
10:46
10:52
10:58
11:04
11:10
11:16
11:22
11:28
11:34
11:40
11:46
11:52
11:56
12:04
12:04 12:10
35
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.5
0.8
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-33
-------
Date: 3 May 1974
Type of Plant: Lime Kiln
Type of Discharge: ESP outlet
Location of Discharge: South Stack
Height of Point of Discharge: 100 ft.
Description of Background: sky
Description of Sky: partly cloudy
Wind Direction: S-SE
Color of Plume: White
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
TABLE C-22
FACILITY C
Summary of Visible Emissions
Observer: 4
Distance from Observer to Discharge Point:450 ft
Height of Observation Point: 0 ft.
Direction of Observer from Discharge Point: NE
Wind Velocity: 10-15 mph
Detached Plume: no
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
"9
10
n
12
13
14
15
16 '
17
18
19
20
Start
10:09
10:15
10:21
10:27
10:33
10:39
10:45
10:51
10:57
11:03
11:09
11:15
11:21
11:27
11:33
11:39
11:45
11:51
11:57
12:03
End
10:15
10:21
10:27
10:33
10:39
10:45
10:51
10:57
11:03
11:09
11:15
11:21
11:27
11:33
11:39
11:45
11:51
11:57
12:03
12:09
Opacity
Sum
160
135
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
Average
6.7
5.6
5.0
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Set Number
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Time
Start
12:09
12:15
12:21
12:27
12:33
12:39
12:45
12:51
12:57
13:03
13:09
13:15
13:21
13:27
13:33
End
12:15
12:21
12:27
12:33
12:39
12:45
12:51
12:57
13:03
13:09
13:15
13:21
13:27
13:33
13:39
Opacity
Sum
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
Average
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Note: Observer reported readinas of "less than
%" have been considered'as "5%" in this summary
C-34
-------
TABLE C-23
FACILITY C
Summary of Visible Emissions
n . _ .. ,-,. Observer: 1
^Date: 3 May 1974
Type of Plant: Lime Kiln
Type of Discharge: ESP outlet
Location cf Discharge: north stack
Height of Point of Discharge: 100 ft.
Description of Background: sky
Description of Sky: Partly cloudy, hazy blue
Wind Direction: S-SE Wind Velocity: 5-10 mph
Color of Plume: Yellowish Detached Plume: none
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 450 ft.
Height of Observation Point: 0 ft.
Direction of Observer from Discharge Point: NE
SUMMARY OF AVERAGE OPACITY
Time
Opacity
Time
Opacity
Set Number Start End
Sum
Average Set Number Start
End
Sum
Averace
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
10:10
10:16
10:22
10:28
10:34
10:40
10:46
10:52
10:58
11:04
11 :10
'11:16
11:22
11:28
11:34
11:40
11:46
11:52
11:58
12:04
10:16
10:22
10:28
10:34
10:40
10:46
10:52
10:58
11:04
11:10
11:16
11:22
11:28
11:34
11:40
11:46
11:52
11:58
12:04
12:10
35
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.5
0.2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-35
-------
TABLE C-24
FACILITY C
Summary of Visible Emissions
Observer: 4
Date: 3 May 1974
Type of Pldnt: Lime Kiln
Type of Discharge: ESP Outlet
Location of Discharge: North Stack
Height of Point of Discharge: 100 Ft.
Description of Background: Sky
Description of Sky: partly cloudy
Wind Direction: S-SE
Color of Plume: White
Duration of Observation:
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:450 Ft.
Height of Observation Point: 0 Ft.
Direction of Observer from Discharge Point: NE
Wind Velocity: 10-15 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
'9
10
11
12
13
14
15
16 '
17
18
19
20
Start
1009
1015
1021
1027
1033
1039
1045
1051
1057
1103
1109
1115
1121
1127
1133
1139
1145
1151
1157
1203
End
1015
1021
1027
1033
1039
1045
1051
1057
1103
1109
1115
1121
1127
1133
1139
1145
1151
1157
1203
1209
Opacity
Sum
135
130
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
Average
5.8
5.4
5.0
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Set Number
" 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Time
Start
1209
1215
1221
1227
1233
1239
1245
1251
1257
1303
1309
1315
1321
1327
1333
End
1215
1221
1227
1233
1239
1245
1251
1257
1303
1309
1315
1321
1327
1333
1339
Opacity
Sum
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
-
Average
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Note: Observer reported readings of "less thar
55K" have been considered as "5%" in this
summary.
C-36
-------
Table C-25
Summary of Test Results
Plant D(l)
Fuel - Gas & Oil (1.05% S)
Control Equipment - Electrostatic Precipitator
Run No.
Date
Test Time-Minutes
Stone Feed Rate-
tons/hr
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol.%
C02-Vol.% dry
02-Vo1.% dry
CO-Vol.% dry
N? and other gases-
Vol.% dry
N0x-ppm
S02-ppm
Particulate Emissions
Probe and Filter Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
1*
7/8/74
240
32.7
64,390
27,620
621
11.3
21.7
8.0
0
70.3
299
70
0.051
0.022
12.0
0.367
0.111
0.047
26.2
0.802
3
7/9/74
240
32.5
67,300
27,390
669
12.1
21.0
8.7
0
70.3
340
11
0.046
0.019
10.9
0.335
0.064
0.026
15.0
0.462
5
7/10/74
240
32.6
70,330
28,660
674
11.4
19.6
11.4
0
69.0
380
53
0.026
0.011
6.4
0.196
0.055
0.022
13.6
0.417
Averagi
-
240
32.6
68,800
28,000
672
11.8
20.3
10.0
0
69.7
340
45
0.036
0.015
8.7
0.266
0.060
0.024
14.3
0.439
*Particulate test data questionable - not used in averages.
C-37
-------
TABLE C-26
FACILITY D
Summary of Visible Emissions '
Date: 7-8-74 Distance from Observer to Discharge Point: 200 Ft.
Typo of Plant: Lime Height of Observation Point: TOO Ft.
Type of P'scharce: Stack Direction of Observer from Discharge Point:NW
Location of Discharge: ESP Wind Velocity:
Height 01" Point of Discharge: 110 Detached Plume: No
Description cf Backrrpund: Sky Observer No. 2
Description of Sky: Partly Cloudy
Wind Din:ction:
Color of I'lume: White
Duration of Observation: 228 min.
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18-34
35
36
37
Start
1713
1719
1725
1731
1737
1743
1749
1755
1801
1307
1813
1819
1825
1831
1837
1843
1849
1855
2050
2056
2102
End
1718
1724
1730
1736
1742
1748
1754
1800
1806
1812
1818
1824
1830
1836
1842
1848
1854
2049
2055
2101
2103
Opaci ty
Suin
0
30
75
55
70
55
30
115
5
30
125
120
60
35
15
5
5
0
20
100
0
Average
0
1.2
3.1
2.3
2.9
2.3
1.2
4.8
0.2
1.3
5.2
5
2.5
1.5
0.6
0.2
0.2
0
0.8
4.2.
0
038
-------
Date: 7-8-74
Type or PU'iit: Lime
Iyp2 of Ohcharge: stack
Location of Oischaryr-: ESP
Height of Point of Discharge: 110 Ft.
Description of Background: Sky
Description of Sky: Partly Cloudy
l,'"nd Direction:
Color of Plume: White
Duration of Observation: 247 min.
TABLE C- 27
FACILITY D
Sui,;;riary of Visible Emissions
Distance frcm Observer to Discharge Point: 250 Ft
Height of Observction Point:100 Ft.
Direction of Observer from Discharoe Point: NW
Wind Velocity:
Detached Plume: No
Observer No. 1
S'jf'IvVY OF AVfRAGt OPACITY
Set Number
1-18
19
20
21-24
25
26-39
40
41
42
Tii
Start
1715
1903
1908
1915
1939
1945
2109
2115
2121
,10
End
1902
1908
1914
1939
1944
2108
2114
2120
2123
Op
Sum
0
5
5
0
5
0
275
0
0
aci ty
Average
0
0.2
0.2
0
0.2
0
11.5
0
0
C-39
-------
Date: 7-9-74
Type of Plant: Lime
Type of Discharge: Stack
Location of Discharge: ESP
Height of Point of Discharge: 110 Ft.
Description of Background: Sky
Description of Sky: Light Blue
Wind Direction:
Color of'Plume: White
Duration of Observation:245 Min.
SUMMARY OF AVERAGE OPACITY
TABLE C-28
FACILITY D
Summary of Visible Emissions
Distance from Observer to Discharqe Point: 200 F
Height of Observation Point: 50 Ft.
Direction of Observer from Discharqe Point:
Wind Velocity:
Detached Plume: No
Observer No. 1
SUMMARY OF AVERAGE. OPACITY
Time
Set Number
1-8
9
10-16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
Start
840
928
934
1016
1022
1028
1034
1040
1046
1052
1058
1104
1110
1116
1122
1128
1134
1140
1146
1152
End
927
933
1015
1021
1027
1033
1039
1045
1051
1057
1103
1109
1115
1121
1127
1133
1139
1145
1151
1157
Opacity
Sum
0
15
0
15
0
30
0
20
0
15
0
35
15
15
15
60
5
20
15
0
Average
0
0.6
0
0.6
0
1.2
0
0.8
0
0.6
0
1.5
0.6
0.6
0.6
2.5
0.2
0.8
0.6
0
Set Number
34
35
36
37
38
39
40
41
Time
Start
1158
1204
1210
1216
1222
1228
1234
1240
i
End
1203
1209
1215
1221
1227
1233
1239
1245
Opacity
Sum
40
45
40
40
20
15
35
30
Average
1.7
1.9
1.7
1.7
0.8
0.6
1.5
1.2
C-40
-------
Date: 7-9-74
Type of I'lcmt: Lime
Type oi Discharge: Stack
Lccc.11 on of Pise!;: , JG: ESP
Heigiu. of Point ; T rmciv.rgo: 100 Ft.
Descri \A ion of B'"'e i..;',i md: Sky
Description of bky: Hazy Blue
K'ind Di. c-ction: NW
color i.f Plume: White
Du'.-et,'. n or Ohscrv. ; rj,i: 195 Min.
TABLE C- 29
FACILITY D
Summary of Visible Emissions
Distance from Observer to Discharge Point: 200 Ft.
Height of Observation Point: 0 Ft.
Direction of Observer fro.Ti Discharge Point: NW
Hind Velocity: 3 MPH
Detached Plurne: No
Observer No. 2
SUMMARY OF AYEUAGE OPACITY
r. fir.! -r
1
2
3*
4*
5
6
7*
8*
9
10
11
12
13*
14*
15*
16
17
18
19
20
-<-iu
Eta,-
843
849
855
901
907
913
919
925
931
937
943
949
955
1001
1007
1013
1019
1025
1031
1057
Ic!
r 10
848
854
900
906
912
918
924
930
936
942
948
954
1000
1006
1012
1018
1024
1030
1036
1102
Oi
SUM
80
55
50
45
80
75
70
85
85
40
115
65
35
-
105
115
100
100
120
105
jdci ty
Average
3.3
2.3
2.5
4.5
3.3
3.1
3.5
5.3
3.5
1.7
4.8
2.7
2.9
-
5.2
4.8
4.2
4.2
5.0
4.4
Set Number
21
2?
23
24
25*
26*
27*
28*
29
30
31
32
33
34
35
36
37
38*
Tim
Start
1103
1109
1115
1121
1127
1133
1139
1145
1151
1157
1203
1209
1215
1221
1227
1233
1239
1245
p
End
1108
1114
1120
1126
1132
1138
1144
1150
1156
1202
1208
1214
1220
1226
1232
1238
1244
1249
Of
Sum
105
95
95
95
75
-
-
85
120
105
120
120
120
120
30
90
80
40
jacity
Average
4.4
4.0
4.0
4.0
3.7
-
-
5.5
5.0
4.4
5
5
5
5
1.2
3.8
3.3
2.5
*Not complete 6 min. average.
C-41
-------
TABLE C-30
FACILITY D
«
Summary of Visible Emissions
Date- 7-10-74 Distance from Observer to Discharge Point: 290 F
Type of Plc-nt: Lime Height of Observation Point: 50 Ft.
lype of Discharge: Stack Direction of Observer from Discharge Point: ESE
Location of Discharge: ESP Wind Velocity: * nil
Height of Point of Discharge: 110 Ft. Detac'-'.od Plume: No
Description of Backn,^imd: Sky Observer No. 1
Description of Sky: Overcast
Wind Direction: N
Color of Pluue: White
Duration of Observation: 272 Win.
SUMMARY OF AVERAGE OPACITY
Set Number
1 ^20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36-45
46
Time
Start
890
1020
1026
1032
1038
1044
1050
1056
1102
1108
1114
1120
1126
1132
1138
1144
1150
1250
End
1019
1025
1031
1037
1043
1049
1055
1101
1107
1113
1119
1125
1131
1137
1143
1149
1249
1252
Op
Sum
0
10
5
0
20
0
25
5
35
20
10
10
0
20
0
10
0
0
a city
Average
0
0.4
0.2
0
0.8
0
1.0
0.2
1.4
0.8
0.4
0.4
0
0.8
0
0.4
0
0
C-42
-------
TABLE C-31
FACILITY D
Summary of Visible Emissions
^
Date; 7-10-74 Distance from Observer to Discharge Point: 200 Ft.
Typo? of Plant: Lime Height of Observation Point: 0 Ft.
Tyoa of nisclvirne: Stack Direction of Observer from Discharge Point: NE
Location of Discharge: ESP Wind Velocity:
Height of Point of Discharge: 110 Ft. Detached PI we: No
Description of Background: Sky Observer No. 2
Description of Sky: Overcast
',,'iiiii Direction:
Color of i'H'iwj: White
Duration of Observation: 212 Min. \
SUMMARY OF AVERAGE OPACITY
x
Set Number
1
2
3
4
5
6
7-10
11
12-23
24
25
26-27
28
29
30-36
Time
Start
838
844
850
856
937
943
949
1013
1019
1131
1137
1143
1155
1201
1207
End
843
849
855
858
942
948
1012
1018
1130
1136
1142
1154
1200
1206
1249
Opaci
ty
Sum Average
25
30
70
0
85
10
0
20
0
20
20
0
35
45
0
1.0
1.2
2.9
0
3.5
0.4
0
0.8
0
0.8
0.8
0
1.5
1.9
0
C-43
-------
Table C-32
Summary of Test Results
Plant D
Fuel - Gas & 011(0.78% S)
Control Equipment - Electrostatic Precipitator
Run No. 1
Date 8/6/74
Test Time-Minutes 192
Stone Feed Rate- 26-3
tons/hr
StaxkJffhJent
Flow Rate-ACFM 65,320
Flow Rate-DSCFM 28,986
Temperature-0 F 611
Water Vapor-Vol % 9.6
1 (\ f\
C09-Vol % dry 19-u
C-
Q 1
(VVol % dry 8
-------
Table C-32 (continued)
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
0.0971
0.0431
24.118
0.918
0.0304
0.0127
7.226
0.275-
0.0225
0.0094
5.312
0.201
0.0500
0.0213
12.219
0.465
C-45
-------
TABLE C-33
FACILITY D-
Summary of Visible Emissions
Observer # 1
Date: 8/6/74
Type of Plant: Lime Kiln
Type of Discharge: Stack
Location of Discharge: ESP # 1
Height of Point of Discharge:^ 90 Ft.
Description of Background: Sky
Description of Sky: 30% clouds against blue sky
Wind Direction: SW Wind Velocity: 5-15 MPH
Color of Plume: White Detached Plume: No.
Duration of Observation: 197 Min.
SUMMARY OF AVERAGE OPACITY . SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:^ 100 Ft
Height of Observation Point: % 70 Ft.
Direction of Obser.-er from Discharge Point: East
Time
Set Number
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16 '
17
18
19
20
Start
1525
1531
1537
1543
1549
1555
1601
1607
1613
1636
1642
1648
1654
1700
1706
1712
1740
1746
1752
1758
End
1530
1536
1542
1548
1554
1600
1606
1612
1618
1641
1647
1653
1659
1705
1711
1717
1745
1751
1757
1803
Opacity
Sum>
60
55
35
85
70
85
75
5
5
0
0
0
0
0
0
0
20
20
120
100
Average
2.5
2.3
1.5
3.5
2.9
3.5
3.1
0.2
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.8
0.8
5.0
4.2
Set Number
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1804
1810
1816
1822
1828
1842
1848
1854
1900
1906
1912
1918
fime
End
1809
1815
1821
1827
1833
1847
1853
1859
1905
1911
1917
1923
Opacity
Sum
115
95
0
5
55
20
25
35
80
0
20
70
Average
4.8
4.0
0.0
0.2
2.3
0.8
1.0
1.5
3.3
0.0
0.8
2.9
C-46
-------
TABLE C-34
FACILITY D
Summary of Visible Emissions
Observer # 2
B;te: 8/6/74
Type of Pldnu: Lime Kiln
Type of Discharge: Stack
Location of Discharqa: ESP # 1
Height of Point of Discharge: 80 Ft.
Description of Background: Sky
Description of Sky: Partly Cloudy (grey to blue)
Wind Diiection:SW Wind Velocity: 5-15 MPH
Color of Plume:White Detached Plume: No
Duration of Observation: 213 Min.
SUMMARY OF AVERAGE OPACITY SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 100 Ft.
Height of Observation Point: 75 Ft.
Direction of Observer from Discharge Point: SE
Time
Opacity
Time
Opacity
Set Number Start End
Sum
Average Set Number Start
End
Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
1525
1531
1537
1543
1549
1555
1601
1607
1613
1619
1625
T631
1637
1643
1649
1655
1701
1707
1713
1740
1530
1536
1542
1548
1554
1600
1606
1612
1618
1624
1630
1636
1642
1648
1654
1700
1706
1712
1718
1745
125
120
125
125
130
120
120
130
130
125
120
105
120
115
90
120
100
70
45
120
5
5.2
5.0
5.2
5.2
5.4
5.0
0
5.4
5.4
5.2
5.0
4.4
5.0
4.8
3.8
5.0
4.2
2.9
1.9
5.0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
1746
1752
1758
1804
1810
1816
1822
1828
1842
1848
1854
1900
1906
1912
1918
1751
1757
1803
1809
1815
1821
1827
1833
1847
1853
1859
1905
1911
1917
1923
30
70
125
140
135
120
30
80
45
40
75
100
80
75
60
5.2
5.8
5.6
5.0
1.3
3.3
1.9
1.7
3.1
4.2
3.3
3.1
2.5
C-47
-------
TABLE C-35
FACILITY D
Summary of Visible Emissions
Observer # 1
Date: 8/7/74
Type uf Plant: Lime Kiln
Type of Discharge: Stack
Location of Discharge: ESP I 1
Height of Point of Discharge: 80 Ft.
Description of Background: Sky
Description of Sky: Hazy
Win . Direction: S-SW
Color of Plume: White
Duration of Observation: 194 Min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: ^100 Ft
Height of Observation Points 70 Ft.
Direction of Observer from Discharge Point: E at
start, moved to W et 13:20
Wind Velocity: 3-5 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16 '
17
18
19
20
Start
1143
1149
1155
1201
1207
1213
1219
1225
1231
1237
1246
1252
1258
1307
1345
1351
1357
1403
1409
1415
End
1148
1154
1200
1206
1212
1218
1224
1230
1236
1242
1251
1257
1303
1312
1350
1356
1402
1408
1414
1420
Opacity
Sum
65
70
75
55
60
90
65
85
60
45
30
55
20
20
45
10
10
15
35
20
Average
2.7
2.9
3.1
2.3
2.5
3.8
2.7
3.5
2.5
1.9
1.3
2.3
0.8
0.8
1.9
0.4
0.4
0.6
1.5
0.8
Set Number
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Time
Start
1421
1427
1433
1439
1445
1451
1457
1503
1509
1515
End
1426
1432
1438
1444
1450
1456
1502
1508
1514
1520
Opaci ty
Sum
5
5
15
20
10
15
5
10
0
0
Average
0.2
0.2
0.6
0.8
0.4
0.6
0.2
0.4
0.0
0.0
C-48
-------
TABLE C-36
FACILITY D
Summary of Visible Emissions
Observer # 2
Date: 8/7/74
Type of PI dm: Lime Kiln
Type of Discharge: Stack
Location of Discharge: ESP- # 1
Height of Point of Discharge:100 Ft.
Description of Background: Sky
Description of Sky: Hazy
Wind Direction: S
Color of Plume: White
Duration of Observation: 193 Min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:100 Ft.
Height of Observation Point: 75 Ft,
Direction of Observer from Discharge Point: E at
start, moved to W at 13:20
Wind Velocity: 8-10 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
Start
1143
1149
1155
1201
1207
1213
1219
1225
1231
1237
1243
T249
1255
1301
1307
1313
1345
1351
1357
1403
End
1148
1154
1200
1206
1212
1218
1224
1230
1236
1242
1248
1254
1300
1306
1312
1318
1350
1356
1402
1408
Opacity
Sum
15
0
0
10
15
80
65
5
0
20
0
0
35
55
65
0
5
5
30
10
Average
0.6
0.0
0.0
0.4
0.6
3.3
2.7
0.2
0.0
0.8
0.0
0.0
1.5
2.3
2.7
0.0
0.2
0.2
1.3
0.4
Set Number
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
lime
Start
1409
1415
1421
1427
1433
1439
1445
1451
1457
1503
1509
1515
tnd
1414
1420
1426
1432
1438
1444
1450
1456
1502
1508
1514
1520
Opacity
Sum
30
15
0
0
0
0
0
0
0
0
0
0
Average
1.3
0.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
-------
Date: 8/8/74
Type of Fldnt: Lime Kiln
Type of Discharge: Stack.
Location of Discharge: ESP I 1
Height of Point of Discharge:100 Ft.
Description of Background: Sky
Description of Sky: Partly Cloudy
Wind Direction: S-SW
Color of Plume: White
Duration of Observation:196 Min.
SUMMARY OF AVERAGE OPACITY
TABLE C-37
FACILITY D
Summary of Visible Emissions
Observer # 1
Distance from Observer to Discharge Point: 100 Ft
Height of Observation Point: 80 Ft.
Direction of Observer from Discharge Point: E
Wind Velocity: 5_iQ MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Set Number
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16 '
17
18
19
20
T
' Start
1026
1032
1038
1044
1050
1056
1102
1108
1114
1120
1126
T132
1138
1144
1150
1156
1220
1226
1232
1238
ime
End
1031
1037
1043
1049
1055
1101
1107
1113
1119
1125
1131
1137
1143
1149
1155
1201
1225
1231
1237
1243
Opacity
Sum
5
20
20
20
35
5
5
25
15
25
10
5
0
10
0
5
5
0
5
0
Average
0.2
0.8
0.8
0.8
1.5
0.2
0.2
1.0
0.6
1.0
0.4
0.2
0.0
0.4
0.0
0.2
0.2
0.0
0.2
0.0
Set Number
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
.38
39
40
Time
Start
1244
1250
1256
1302
1308
1314
1320
1326
1332
1338
1344
1350
End
1249
1255
1301
1307
1313
1319
1325
1331
1337
1343
1349
1355
Opaci ty
Sum
30
0
0
0
5
5
0
5
0
0
20
65
Average
1.3
0.0
0.0
0.0
0.2
0.2
0.0
0.2
0.0
0.0
0.8
2.7
C-50
-------
TABLE C-38
FACILITY D
Summary of Visible Emissions
Observer # 2
Date: 8/8/74
Type of Plant: Lime Kiln
Type of Discharge: Stack
Location of Discharge: ESP # 1
Height of Point of Discharge: 100 Ft.
Description of Background: Sky
Description of Sky: Partly Cloudy
Wind Direction: S
Color of Plume: White
Duration of Observation: 193 Min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point: 100 Ft.
Height of Observation Point: 80 Ft.
Direction of Observer from Discharge Point: E
Wind Velocity: 12-15 MPH
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16 '
17
18
19
20
Start
1026
1032
1038
1044
1050
1056
1102
1108
1114
1120
1126
1132
1138
1144
1150
1156
1220
1226
1232
1238
End
1031
1037
1043
1049
1055
1101
1107
1113
1119
1125
1131
1137
1143
1149
1155
1201
1225
1231
1237
1243
Opacity
Sum
35
5
10
85
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
1.5
0.2
0.4
3.5
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Set Number
" 21
22
23
24
25
26
?J
t.
o
30
31
32
33
34
35
36
37
38
39
40
Start
1244
1250
1256
1302
1308
1314
1320
1326
1332
1338
1344
1350
Time
End
1249
1255
1301
1307
1313
1319
1325
1331
1337
1343
1349
1355
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
10
0
Average
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.9
0.0
0.0
0.4
0.0
C-51
-------
Wijle C-39
Summary rf Test Results
Plant E
Fuel - 0.92% S Coal
Control Equipment - Baghouse
Run No.
(stack, run)
Date. (1975)
Test Time-Minutes
Stone Feed Rate-
tons/hr
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor- Vol. %
C02-Vol.% dry
02-Vol.% dry
CO-Vol.% dry
N2 & other gases-
Vol.% dry
N0x-ppm
CO-ppm
Particulate Emissions
Front Half
gr/DSCF
gr/M-F
Ib/hr
Ib/ton of feed rate
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
1-1
9-9
132
20
14,138
9,809
267
4.45
8.8
13.8
0
77 .4
208
15
0.0099
0.0068
0.829
0.041
0.0171
0.0118
1.436
0.072
2-2
9-40
132
20
16,670
10,356
288
11.87
9.6
13.6
0
76.8
113
0.0040
0.0025
0.351
0.018
0.0074
0.0046
0.658
0.033
1-2
9-10
132
20
16,058
10,379
261
1 1 ,60
9.6
13.6
0
76.8
0.0061
0.0040
0.546
0.027
0.0106
0.0068
0.942
0.047
3-1
9-10
132
19
17,859
10,649
294
14.71
9.6
13.6
0
76.8
0.0049
0.0029
0.449
0.024
0.0123
0.0073
1.124
0.059
3-2
9-11
132
20
17,599
11,115
278
11.22
9.6
11.7
0.2
78.5
166
21
0.0072
0.0045
0.682
0.034
0.0127
0.0080
1.210
0.061
2-3
9-12
132
15
13,895
9,513
233
9.25
8.2
14.4
0
77 A
288
57
0.0033
0.0023
0.271
0.018
0.0073
0.0050
0.593
0.040
Plant
Average
-
132
19
48,108
30,909
270
10.5
9.2
13.5
0
77.3
216
52
0.0059
0.0038
1.564
0.081
0.0225
0.0072
2.964
0.156
-------
TABLE C- 40
FACILITY E
Summary of Visible Emissions
Date: 9/9/75 Distance from Observer to Discharge Point: 150 Ft
Type of Plant: Lime and Cement Height of Observation Point: Ground Level
Type of Discharge: Stack Direction of Observer from Discharge Point: East
Locatipn,,pf Discharge: Baghouse Outlet #3, Wind Velocity: 2-5 miles/hr
Stack #1, Run #T 3
Height of Point of Discharge: 80 Ft. Detached Plume: No
Description of Background: Sky (blue background) Observer No. 1
Description of Sky: Clear to Partly Cloudy
Wind Direction: East
Color of Plume: White
Duration of Observation: 3 hrs.
SUMMARY OF AVERAGE OPACITY
Time Opacity
Set Number
1-4
5
6-12
13(4)
14(1)
15-25
Start
1130
1154
1200
1242
1305
1306
End
1153
1159
1241
1245
1305
1408
Sum
0
75
0
0
0
0
Average
0
3.1
0
0
0
0
C-53
-------
TI^BLE C -41
F CILITY E
Summary of Visible Emissions
Date: 9/9/75 ~_
Type of Plant: Lime and Cement
Type of Discharge: Stack
Location of Discharge: Baghouse #3,
Run #1,*
Height of Point of Discharge: 80 Ft.
Description of Background: Blue sky
Description of Sky: Clear
Wind Direction: SE
Color of Plume: White
Duration of Observation: 3 hrs.
Distance from Observer to Discharge Point: 60 F
Height of Observation Point: Ground Level
Direction of Observer from Discharge Point: Sou
*From 1131-1257 Stack #2 was read for visible
emissions, however, the particulate run on
Stack #2 was voided at the halfway point in t
run, so observer #2 switched to read Stack #1
from 1306-1400 hours.
Wind Velocity: 5-10 mph
Detached Plume: No
Observer #2
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1(5)
2-4
5
6-7
8
9-14
15(4)
16-26
27(4)
Start
1131
1136
1154
1200
1212
1218
1254
1306
1406
End
1135
1153
1159
1211
1217
1253
1259
1405
1409
Opacity
Sum
0
0
110
0
5.0
0
0
0
10
Average
0
0
4.6
0
0.2
0
0
0
0.6
C-54
-------
TABLE C-42
FACILITY E
Summary of Visible Emissions
Date: 9/10/75 Distance from Observer.to Discharge Point:150 Ft.
Type of Plant: Lime and Cement Height of Observation Point: Ground Level
Type of Discharge: Stack Direction of Observer from Discharge PointCast
Location of Discharge: Outlet Baghouse #3, Wind Velocity: 2-5 mph
Stack #1, Run #2
Height of Point of Discharge: 80 Ft. Detached Plume: No
Description of Background: Sky, blue background
Description of Sky:Clear, blue sky Observer No. 1
Wind Direction: East
Color ofvPlume: White
\
Duration of Observation: 3 hrs.
SUMMARY OF AVERAGE OPACITY
Time Opacity
Set Number
1(5)
2-6
7
8-16
17(2) f
18(3)
19-29
Start
0819
0824
0854 -
0900
0954
1015
1018
End
0823
0853 -
0859
0953
0955
1017
1123
Sum
0
0
30
0
0
0
0
Average
0
0
1.3
0
0
0
0
C-55
-------
TAdLE C-43
FACILITY E
Summary of Visible Emissions
Date: 9/10/75 Distance from Observer to Discharge Point:60
Type of Plant: Lime and Cement Height of Observation Point: Ground Level
Type of Discharge: Stack Direction of Observer from Discharge Point:
Southeast
Location of Discharge: Baghouse #3 Outlet, Wind Velocity: 0-TO mph
Stack #1, Run #2
Height of Point of Discharge: 85 Ft. Detached Plume: No
Description of Background:Blue sky . Observer No. 2
Description of Sky: 80% Clear
Wind Direction: East
Color of Plume: White
Duration of Observation: 3 hrs.
SUMMARY OF AVERAGE OPACITY
Time
Set Number
H5)
2-6
7
8-13
14
15-25 -
26
27-31
Start
0819
0824
0854
0900 "
0936
- 0942
1048
1054.
End
0823
0853
-0859 '
0935
0941
1047
1053
1122
Opacity
Sum
0
0
40
0
10
0
10
0
Average
0
0
1:7
0
0.4
0
0.4
0
C-56
-------
TABLE C-44
FACILITY E
Summary of Visible Emissions
*
Date: 9/10/75 Distance from Observer to Discharge Point:150 Ft.
Type of Plant: Lime and Cement Height of Observation Point: Ground Level
Type of Discharge: Stack Direction of Observer from Discharge PointCast
Location of Discharge:Baghouse #3 Outlet, Wind Velocity: 2-5 mph
Stack #3, Run #1
Height of Point of Discharge: 80 Ft. Detached Plume: No
Description of Background:Clear to partly : nhsprvpr No 1
_ . / i i i i _i_ N I wUOCIVCIIiU.I
cloudy (blue to white) sky
Description of Sky: clear to Partly Cloudy
Wind Direction: East
Color of Plume:White
Duration of Observation: 2 hr. 42 min.
SUMMARY OF AVERAGE OPACITY
Time Opacity
Set Number Start End Sum Average
1-28 1300 1547 0 0
C-57
-------
TABLE C-45
FACILITY E
«
Summary of Visible Emissions
Date: 9/10/75 Distance from Observer to Discharge Point: 90 Ft
Type of Plant: Lime and Cement Height of Observation Point: Ground Level
Type of Discharger stack Direction of Observer from Discharge Point:
Southeast
Location of Discharge: Outlet Baghouse #3, Wind Velocity: 0-5 mph
Stack #3, Run #1
Height of Point of Discharge: 80 Ft. Detached Plume: No
Description of Background: 50% Clear sky, white
and blue background ' Observer No. 2
Description of Sky: Partly cloudy
Wind Direction: East
\
Color ofvPlume: White
\
Duration of Observation: 2 hr. 41 min.
SUMMARY OF AVERAGE OPACITY
Time Opacity
Set Number Start End Sum Average
T27 1300 T541 0 0
C-58
-------
TABLE C-46
FACILITY I
Summary of Visible Emissions
Date: 9/11/75 Distance from Observer to Discharge Point: 150 Ft.
Type of Plant:Lime and Cement Height of Observation Point: Ground Level
Type of Discharge: Stack Direction of Observer from Discharge PointCast
Location of Discharge: Outlet Baghouse #3, Wind Velocity: 2-5 mph
Stack #3, Run #2
Height of Point of Discharge: 80 Ft. Detached Plume: No
Description of Background:Blue sky background
f * Observer No. 1
Description of Sky: Blue, clear skys; white background
0908-0954, 1005-1006, 1018-1034
Wind Direction: East
Color of Plume: White
Duration of Observation: 2 hrs. 34 min.
SUMMARY OF AVERAGE OPACITY
Time Opacity
Set Number Start End Sum Average
1-26 0800 1034 0 0
C-59
-------
'^LEC-47
F..CILITYE
Summary of Visible Emissions
Date: 9/11/75
Type of Plant:Lime and Cement
Type of Discharge:Stack
Location of Discharge: Outlet #3 Baghouse,
Stack #3, Run #2
Height of Point of Discharge: 80 Ft.
Description of Background:Blue to White Sky.
Description of Sky: 95% Clear
Wind Direction: East
Color of Plume: White
Duration of Observation: 2 hr. 33 min.
Distance from Observer to Discharge Point:90 Ft.
Height of Observation Point:Ground Level
Direction of Observer from Discharge Point:
Southeast
Wind Velocity: 0-10 mph
Detached Plume: No
Observer #2
SUMMARY OF AVERAGE OPACITY
Time
Set Number
KD
2-4
5
6
7
8-23
24
25
26(4)
Start
0805
0806
0824 .
0830
0836
0842
1018
1024
1030
End
0805
08.23 .
D829
0835
0841
1017
1023
1029
1033
Opacity
Sum
0
0
35
5
30
0
10
0
0
Average
0
0
1.5
1.5
1.3
0
0.4
0
0
C-60
-------
Table C-48
Summary of Test Results
Plant F
Fuel - 1.86% S Coal
Control Equipment - 15 IWC Scrubber
Run No.
Date (1975)
Test Time -Minutes
Stone Feed Rate-
tons/hr
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Tempera ture-°F
Water Vapor-Vol.%
C02-Vol.* dry
02-Vol . % dry
CO-Vol. % dry
N2 & other gases-
Vol.fc dry
N0x-ppm
CO-ppm
Particulate Emissions
Front Half
gr/DSCF
gr/ACF
3-b/hr
Ib/ton of feed rate
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton of fedd rate
1
9/15
120
51.6
139,222
97,037
148
19.81
12.7
11.8
0
75.6
121
34.9
0.0296
0.0206
24.626
0.477
0.0360
0.0251
29.952
0.580
2
9/16
120
51.6
137,890
97,021
147
18.73
12.3
11.8
0
75.9
100
17.5
0.0211
0.0148
17.510
0.339
0.0259
0.0182
21.497
0.417
3
9/16
120
51.6
133,885
91,216
151
20.96
13.6
11.2
0
75.2
89
103.7
0.0315
0.0215
24.628
0.477
0.0375
0.0256
29.292
0.568
Average
120
51.6
136,999
95,091
149
19.80
12.9
11.6
0
75i5
103
52
0.0274
0.0190
22.255
0.431
0.0331
0.0230
26.914
0.522
C-61
-------
TABLE C-49
FACILITY F
Summary of Visible Emissions
Date: 9-16-75
Type of Plant: Lime
Type of Discharge: #3 Kiln Venturi Scrubber Stack
Height of Point of Discharge: 85 Ft.
Distance from Observer to Discharge Point: 300~Ft.
Height of Observation Point: Ground Level
Direction of Observer from Discharge Point: ESE
Description of Background: Sky
Description of Sky: Partly Cloudy
Wind Direction: NE
Wind Velocity: 5 MPH
\Color of Plume: White (Steam)
Detached Plume: No
Duration of Observation: 1 hr.
SUMMARY Of AVERAGE OPACITY
Observer No. 2
Time
Set Number
1
2
3-10
Start
1500
1506
1512
End
1505*
1511*
1559
Opaci ty
Sum
10-
0
0
Average
0.4
0
9
Observer No. 3
Opaci ty
Sum
10
0
0
Average
0.4
0
0
*0bserver No. 1
C-62
-------
Table C-50
Summary of Test Results
Plant G
Fuel: Lime-3.53% S Coal, DBD-2.962 S Coal
Control Equipment: 15 IWC Scrubber
Kiln
Test Location
Date (1975)
Number of Tests
Stone Feed Rate-
TPH
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol.%
C02-Vol.% dry
02-Vol.% dry
CO- Vol.* dry
N2 & other gases-
Vol .% dry
S02- EPA Method 6
Ib/hr
ppm
Dynascience
ppm
CO-ppm
Lime
Inlet
12/8
6
33.7
92,510
59,180
980
5.65
19.7
10.0
0
70.3
272
450
435
no
Lime
Outlet
12/3-6
6
31.2
91,970
57,674
153
22.7
17.0
11.8
0
71.2
2.9
5.0
-
321
DBO
Inlet
12/9
6
23.4
82,200
50,450
1500
8.4
18.8
9.5
0
71.7
179
347
310
72
DBD
Outlet
12/9
6
23.4
82,200
50,450
160
26.7
17.4
10.7
0
71.9
7.8
15
37
92
-------
Run No.
Date (1976)
Number of Tests
Stone Feed Rate-
TPH
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-0F
Water Vapor-Vol.
C02-Vol.% dry
02-Vol.% dry
CO-Vol.% dry
N?& other gases-
Vol.% dry
S02-,ppm
Table C-51
Summary of Test Results
Plant H
Fuel: 2.97% S Coal
Control Equipment; Baghouse
4
1/29
5
170
240,022
161 ,740
290
4.88
-
-
-
_
5
1/29
6
170
248,451
167,420
290
4.88
12.0
13.8
0
74.2
8
1/31
6
170
249,045
167,820
290
4.87
16.8
11.2
0
72.0
9
1/31
6
172
262,698
177,020
290
4.89
-
-
-
_
10
1/31
6
172
240,616
162,140
290
4.89
17.1
10.8
0
72.1
11
1/31
5
172
288,148
194,170
290
4.85
15.3
12.3
0
72.4
Average
171
248,451
167,420
290
4.88
15.3
12.0
0
72.7
256
121
284
194
143
196
199
C-64
-------
Table C-52
Atmospheric Hydrator
Summary of Particulate Test Results
Plant H-A H-B
Control Equipment
Lime Feed Rate-tons/hr
Water Feed Rate-gal s/min
Hydrated Lime Production
tons/hr
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-°F
Water Vapor-Vol . %
C02-Vol. % dry
02-Vo1. % dry
CO-Vol. % dry
No and other gases-
Vol. % dry
Parti cul ate Emissions
Probe & Filter Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton feed
kg/i>ig ton feed
Wet
Scrubber
14
28
17-18
10,980
4,824
176
46.7
0
20.42
0
79.57
0.0286
0.0125
1.17
0.084
0,042
Wet
Scrubber
17-18
34
22
7,646
1,338
201
77.9
0
21.0
0
79.0
0.1856
0.0325
2.084
0.117
0.059
Wet
Scrubber
14
45
17
10,320
4,560
175
47
0
21.0
0
79.0
0.024
0.011
0.950
0.068
0.034
*Plant test results using EPA Method 5.
C-65
-------
Table C-53
Summary of Test Results
Plant H-A
Atmospheric Hydrator
Control Equipment - Ducon Scrubber
Run No .
Date
Test Time-Minutes
Lime Feed Rate-tons/hr
Water Feed Rate-tons/hr
Hydrated Lime Production
tons/hr
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-0 F
Water Vapor-Vol .%
COe-Vol .% dry
02-Vol .35 dry
CO-Vol.% dry
N? and other gases-
Vol .% dry
Parti cul ate Emissions
Probe & Filter Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
i
i
4/16/74
240
14
7
17-18
10,701
4,901
174
44.5
20.43
79.57
0.0216
0.0099
0 °1
W *i \
0 065
\J \J\J w
0.0269
0.0123
1 1-3
1 . 1 O
0 081
V * WW 1
2
4/17/74
240
7
17-18
11,154
4,775
178
48.0
o
\j
20.43
o
\j
79.57
0.0269
0.0115
1.10
0.079
0.0346
0.0148
1 .42
0.101
3
4/18/74
125
14
7
17-18
11,084
4,797
177
47.5
0
20.43
0
79.57
0.0366
0.0158
1.50
0.107
0.0403
0.0175
1.66
0.119
Average
"
7
/
17-18
10,980
4,824
176
46.7
0
20.43
0
79.57
0.0286
0.0125
1.17
0.084
0.0342
0.0149
1.40
0.100
C-bb
-------
TABLE C-54
FACILITY H-A
Summary of Visible Emissions
te: 4/18/74
*
pe of Plant: Lime Hydration
pe of Discharge: Stack
cation of Discharge: Hydrator Exhaust
ight of Point of Discharge:^ 100'
scription of Background: Sky
scrlption of Sky: Overcast
id Direction: s
lor of Plume: Steam Plume
ration of Observation: 1 hour
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:^ 200
Height, of Observation Point: Ground Level
Direction of Observer from Discharge Point:E
Wind Velocity: 0-10
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
t Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
Start
10:13
10:19
10:25
10:31
10:37
10:43
10:49
10:55
11:01
11:07
*
End
10:19
10:25
10:31
10:37
10:43
10:49
10:55
11:01
11:07
11:13
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End Sum Average
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-67
-------
Table C-55
Summary of Test Results
Plant H-B
Atmospheric Hydrator
Control Equipment - Ducon Scrubber
Run No.
Date (1975)
Test Time-Minutes
Lime Feed Rate-
tons/hr
Hydrated Lime
Producti on-
tons/hr
Water to Hydrator-gpm
Water to Scrubber-gpm
Stack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Temperature-0 F
Water Vapor-Vol %
C0?-Vol.% dry
09-Vol.X dry
CO-Vol .% dry
N£ & other gases-
Vol.% dry
Parti cu late Emissions
Probe & Filter Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
Total Catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
1
9-12
128
18
22
13.3
20
7291
1207
201
79.1
0
21.0
0
79.0
0.1139
0.0189
1.179
0.0655
0.1320
0.0219
1.365
0.0758
2
9-17
128
17.2
21
15.3
19
8191
1576
200
75.7
0
21.0
0-
79.0
0.1439
0.0299
1.944
0.113
0.1487
0.0286
2.008
0.117
3
9-17
128
18
22
16.5
19
7455
1232
203
79.0
0
21.0
0
79.0
0.2962
0.0489
3.128
0.173
0.3097
0.0512
3.271
0.182
Average
_
128
17.7
21.7
15
19
7649
1338
201
77.9
0
21.0
0
79.0
0.1856
0.0325
2.084
0.117
0.1968
0.0344
2.215
0.125
C-68
-------
Plant A
The facility tested was a rotary lime kiln which produces a high calcium
metallurgical lime. Emissions are controlled by a baghouse which receives
the kiln off-gas after it is cooled by a combination of water spray and
tempering air. Each of the six stacks from the baghouse was tested once
using EPA Method 5.
The kiln production was steady at 460 tons/day during the test period,
which is 92 percent of the rated production capacity of 500 tons/day. Because
of the low particulate concentrations, the testing was performed during
four hour periods. A summary of the complete testing results is shown in
Table C-56. Visible emissions were negligible throughout the test periods.
(See Table C-57 through C-63.)
The plant A baghouse is not typical of those in use in the lime
industry. Large quantities of dilution air infiltrate through the corrugated
asbestos siding and doors into the clean air side of the baghouse. It is
unknown how this affects the performance of the baghouse, but this baghouse
did not perform as well as the two other baghouses (plants B and E) that
were source tested in conjunction with this study.
Plant A Baghouse -
Type - Pressure Baghouse
Bag Material - Fiberglass fabric
No. of Compartments - 12 compart/nent with 78 bags in each compartment
No. of Stacks - 6
Design Pressure Drop - 2 1/3 to 3 l,W.C
Cloth Area - 87,048 ft2
Bag Cleaning - Reverse .air flow (one compartment at a time)
Cloth Area (operating) - 79,794 ft2
C-69
-------
Fan Design - 140,000 ACFM @600°F
Design Air to Cloth Ratio - 1.75:1
C-70
-------
Table C-56
Summary of Test Results
Plant A
Fuel-1.28% S Coal
Control Equipment - Baghouse
jn No.^1'
ate
est Time-Minutes
tone Feed Rate-
tons/hr
tack Effluent
Flow Rate-ACFM
Flow Rate-DSCFM
Tempera ture-°F
Water Vapor- Vol. %
C0?-Vol.% dry
Op-Vol.% dry
CO-Vol.% dry
No and other gases-
Vol.% dry
N^-ppm
S02-ppm
CO-ppm
articulate Emissions
Probe & Filter Catch
gr/DSCF
3fc/ACF
Ib/hr
Ib/ton
Total Catch
gt/DSCF
gr/ACF
Ib/hr
Ib/ton
1
6/11/74
240
37.7
37,049
23,797
290
6.5
6.8
19.5
0
73.7
41.8
80.9
15
0.0223
0.0143
4.55
0.121
0.0361
0.0232
7.36
0.195
2
6/11/74
240
37.7
33,032
22,407
263
4.8
6.8
19.5
0-
73.7
77.4
0.0216
0.0146
4.06
0.108
0.0404
0.0274
7,76
0.206
3
6/12/74
240
38.6
35,532
23,162
284
6.3
7>,0
16.5
,0
76.5
38.1
106.0
580
0.0098
0.0064
1.96
0.058
0.0320
0.0208
6.36
0.165
4
6/12/74
240
38.6
32,375
21 ,247
269
7.5
7.0
16.5
0
76.5
90.7
0.0109
0.0072
1.98
0.051
0.0254
0.0167
4.62
0.12Q
5
6/13/74
240
38.2
38,024
24,878
272
7.4
7.0
16.5
0
76.5
72.9
100.0
30
0.0125
0.0082
2.67
0.070
0.0257
0.0168
5.47
0.143
6
6/13/74
240
38.2
35,078
23,156
273
6.5
7.0
16.5
0
76.5
94.8
0.0116
0.0076
2.30
0.060
0.0319
0.0211
6.33
0.166
240
38.2
275
6.5
6.9
17.5
0
75.6
50.9
91.7
208
0.0148
0.0097
0.0319
0.0209
(1)
One test on each of 6 stacks,
C-71
-------
Observer # 1
TABLE C-57
FACILITY A
Summary of Visible Emissions
Date:6/11/74
Type of Pidnt: Lime
Type of Discharge: -;tack '
-------
TABLE C-58
FACILITY A
Summary of Visible Emissions
Observer # 2
ite: 6/11/74
«
ipe of Plant: Lime
'pe of Discharge: Stack #1 & #2
>cation of Discharge: #5-Kiln
light of Point of Discharge: ^ 80'
ascription of Background: Sky
iscription of-Sky: Partly Cloudy
nd Direction: SE
lor of Plume: White
ration of Observation: 2 hours
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Points IOC
Height of Observation Point: Ground Level
Direction of Observer from Discharge Point:
Wind Velocity: 5-10
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
;t Number
1
2
3
4
5
6
7
8
'9
10
n
12
13
14
15
16 '
17
18
19
20
Start
16:01
16:07
16:13
16:19
16:25
16:31
16:37
16:43
16:49
16:55
17:01
17:07
17:13
17:19
17:25
17:31
17:37
17:43
17:49
17:55
End
16:07
16:13
16:19
16:25
16:31
16:37
16:43
16:49
16:55
17:01
17:07
17:13
17:19
17:25
17:31
17:37
17:43
17:49
17:55
18:01
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End Sum Average
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-73
-------
te: 6/12/74
'pe of Plant: Lime
rpe of Discharge:Stack #3 & #4
Dcation of Discharge:#5 Kiln
eight of Point of Discharge: ^ 80'
ascription of Background: Sky
)escription of Sky:Clear to Partly Cloudy
Jind Direct!on:SW
-olor of Plume:White
Duration of Observation:^ 4 hours
SUMMARY OF AVERAGE OPACITY
TABLE C-59
FACILITY A
Summary of Visible Emissions
Observer # 1
Distance from Observer to Discharge Point: \
AM * 25' PM * 100'
Height of Observation Point:AM * 70' PM-Grouni
I
Direction of Observer from Discharge Point:
Wind Velocity:^ 20
Detached Plume:No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
Start
10:53
10:59
11:05
11:11
11:17
11:23
11:29
11:35
11:41
11:47
11:53
11:59
12:05
12:11
12:17
12:23
12:29
12:35
12:41
13:42
End
10:59
11:05
11:11
11:17
11:23
11:29
11:35
11:41
11:47
11:53
11:59
12:05
12:11
12:17
12:23
12:29
12:35
12:41
12:47
13:48
Opacity
Sum
0
30
5
0
5
0
0
0
0
0
0
0
25
0
0
0
0
0
0
0
Average
0
1.3
0.2
0
0.2
0
0
0
0
0
0
0
1.0
0
0
0
0
0
0
0
Set Number
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Time
Start
13:48
13:54
14:00
14:06
14:12
14:18
14:24
14:30
14:36
14:42
14:48
14:54
15:00
15:06
15:12
15:18
15:24
15:30
15:42
End
13:54
14:00
14:06
14:12
14:18
14:24
14:30
14:36
14:42
14:48
14:54
15:00
15:06
15:12
15:18
15:24
15:30
15:36
15:48
Opaci ty
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-74
-------
TABLE C-60
FACILITY A
Summary of Visible Emissions
Observer # 2
te: -6/12/74
pe of Plant:Lime
rpe of Discharge:Stack #3 & #4
cation of Discharge:#5 Kiln
n'ght of Point of Discharge: ^ 80'
iscription of Background: Sky
Ascription of Sky: Clear to Partly Cloudy
nd Direction: SW
lor of Plume: White
ration of Observation: 4 hours
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
AM ^ 25' PM ^ 100'
Height of Observation Point:
AM * 70' PM-Ground Level
Direction of Observer from Discharge Point:
Wind Velocity:^ 20
Detached Plume:No
SUMMARY OF AVERAGE OPACITY
Time
it Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
f
16
17
18
19
20
Start
10:53
10:59
11:05
11:11
11:17
11:23
11:29
11:35
11:41
11:47
11:53
11:59
12:05
12:11
12:17
12:23
12:29
12:35
12:41
12:47
End
10:59
11:05
11:11
11:17
11:23
11:29
11:35
11:41
11:47
11:53
11:59
12:05
12:11
12:17
12:23
12:29
12:35
12:41
12:47
12:53
Opacity
Sum>
0
20
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
10
Average
0
0.8
0
0
0
0
0
0
0
0
0
0
0.4
0
0
0
0
0
0
0.4
Set Number
" 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
-38
39
40
Time
Start
13;05
13:11
13:17
13:23
13:29
13:35
13:41
13:47
13:53
13:59
14:05
14:11
14:17
14:23
14:29
14:35
14:41
14:47
14:53
14:59
End
13:11
13:17
13:23
13:29
13:35
13:41
13:47
13:53
13:59
14:05
14:11
14:17
14:23
14:29
14:35
14:41
14:47
14:53
14:59
15:05
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-75
-------
TABLE C-61
FACILITY A
Summary of Visible Emissions
Observer # 1
Date:6/13/74
"! ,*e of "Idnt: Lime
Type of Discharge:Stack #5
Location of Discharge: #5-Kiln
Height of Point of Discharge: ^ 80'
Description of Background: Sky
Description of Sky: Partly Cloudy
Wind Direction: S
Color of Plume: White
Duration of Observation: 2 Hours
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
.Height of Observation Point: ^ 70'
Direction of Observer from Discharge Point:
Wind Velocity: ^ 20
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
1
Start
9:31
9:37
9:43
9:49
9:55
10:01
10:07
10:13
10:19
10:25
10:31
TO: 37
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
Fime
End
9:37
9:43
9:49
9:55
10:01
10:07
10:13
10:19
10:25
10:31
10:37
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
11:31
Opacity
Sum Average
0
30
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Set Number
' 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Time Opacity
Start End Sum Averag
C-76
-------
TABLE C-62
FACILITY A
Summary of Visible Emissions
Observer #1
ate:.6/13/74
*
fpe of Plant: Lime
^pe of Discharge:Stack #6
Dcation of Discharge: #5-kiln
sight of Point of Discharge:^ 80'
ascription of Background: Sky
Ascription of Sky: Overcast
md Direction: S SW
)lor of Plume: White
jration of Observation: 2 hours
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:^ 10
Height of Observation Point: Ground Level
Direction of Observer from Discharge Point:
Wind Velocity: 5-10
Detached Plume: NO
SUMMARY OF AVERAGE OPACITY
Time
Opacity
lime
Opacity
Number Start End
Sum
Average Set Number Start
End
Sum Average
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 '
17
18
19
20
11:46
11:52
11:58
12:04
12:10
12:16
12:22
12:28
12:34
12:40
12:46
12:52
12:58
13:04
13tlO
13:16
13:22
13:28
13:34
13:40
11:52
11:58
12:04
12:10
12:16
12:22
12:28
12:34
12:40
12:46
12:52
12:58
13:04
13:10
13:16
13:22
13:28
13:34
13:40
13:46
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-77
-------
TABU C-63
FACILITY A
Summary of Visible Emissions
Observer #2
Date: 6/13/74
Type of Plant: Lime
Type of Discharge: Stack #6
Location of Discharge: #5 Kiln
Height of Point of Discharge:^ 80'
Description of Background: Sky
Description of Sky: Overcast
Wind Direction: S SW
Color of Plume: White
Duration of Observation: 1 hour 46 min.
SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
^ 100'
Height of Observation Point: Ground Level
Direction of Observer from Discharge Point:
Wind Velocity: 5-10
Detached Plume: No
SUMMARY OF AVERAGE OPACITY
Time
Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
12:10
12:16
12:22
12:28
12:34
12:40
12:46
12:52
12:58
13:04
13:10
13:16
13:22
13:28
13:34
13:40
13:46
13:52
End
12:16
12:22
12:28
12:34
12:40
12:46
12:52
12:58
13:04
13:10
13:16
13:22
13:28
13:34
13:40
13:46
13:52
13:56
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End Sum Avera<
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
C-78
-------
APPENDIX D
EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D. 1 Emission Measurement Methods
For the lime industry investigation, the Environmental Protection
Agency used Method 5 for participate emission measurement, Method 6
for sulfur dioxide emission measurement, and Method 9 for visible
emissions measurement. These have been established as reference
methods in Federal Register, v36 n247 December 23, 1971, and Federal
Register, v39 n219 November 12, 1974, respectively.
Method 5, as prescribed in the above reference, was conducted
without difficulty at all of the rotary kiln exhausts tested. Diffi-
culties were encountered when Method 5 was used at lime hydrator
exhausts. It was found that isokinetic sampling conditions could
not be maintained by using the average prevailing exhaust gas
parameters for the sampling nomograph described in APTD-0576. This is
due to the high water vapor content at saturation for the exhaust gas
temperatures and the large moisture content variations caused by rela-
tively small temperature changes. At Facility H-A, this difficulty
was countered by continually resetting the sampling nomograph by
assuming saturated conditions at the measured exhaust temperature.
At the moisture content levels present at this facility (44-48 percent),
this procedure was found adequate. Two of the three test runs met
the allowable isokinetic condition range of 90-110 percent, with the
third being only slightly high at 115 percent. At Facility H-B, the
D-l
-------
exhaust gas temperatures were such that the moisture content ranged
from 76-79 percent by volume. It was necessary to extend the moisture
content scale of the nomograph for use at these water vapor content
levels. The procedure for accomplishing this extension has been
described in "Adjustments in the EPA Nomograph for Different Pitot
Tube Coefficients and Dry Molecular Weights" (Stack Sampling News,
2:4-11 October 1974) by R. T. Shigehara. With this extended nomo-
graph, sampling was conducted in a like manner to that used at Plant H-A.
Of three tests performed, one met the allowable isokinetic condition
range at 99 percent, one was low at 89 percent, and one was high at
118 percent.
Testing was also performed at a third hydrator facility using
the extended nomograph where the exhaust gas moisture content ranged
from 76-86 percent. The resulting isokinetic conditions ranged from
140 to 190 percent and were regarded as unacceptable.
The variability of isokinetic conditions obtained at the last two
facilities is probably due to the fact that a +_ 3 volume percent error
in average moisture estimation at the 75 to 85% level will result in
isokinetic deviations greater than the allowable +_10%. This difficulty
was compounded at the last testing described by the variability of the
exhaust gas moisture content.
An alternate procedure that can be used when continuous temperature
monitoring and nomograph adjustment are not adequate to maintain isokinetic
conditions is the measurement of sampling rate prior to water vapor
condensation in the sampling train. An example of how this can be
D-2
-------
accomplished is the use of a calibrated orifice installed on the
sampling probe immediately following the nozzle. In this configuration,
the sampling rate necessary for isokinetic conditions can be directly
related to the exhaust gas velocity without a correction for moisture
content.
For the majority of the rotary kilns tested, visible emissions
determinations could be made with little or no difficulty, depending
on the prevailing weather conditions. An exception was encountered
at a facility that employed a water scrubber for emissions control.
The highly visible, attached water vapor plume and overcast weather
rendered detection of other possible visible emissions virtually
impossible.
At both hydrator facilities tested, water vapor plumes from the
scrubber control devices rendered visible emissions determination
either extremely difficult or impossible.
Method 6 for sulfur dioxide measurement was used with varying
degrees of success at sampling locations prior to and/or after emission
control devices at the various facilities tested in the investigation.
At Facilities A, B, and C, Method 6, as prescribed in the above
reference, was used after control devices. At Facility D, Method 6
procedures with larger impingers and proportionally larger amounts of
absorbing solutions were used after a control device to facilitate
longer sampling durations. At Facilities E, F, G, and H, Method 6
was used both before and after control devices. In addition, instru-
mental ?02 analyzers were operated to obtain independent comparative
measurements.
D-3
-------
No testing problems were reported at Facilities A, B, C, or D and
the results are not unreasonable for the type fuels used at the
facilities. Difficulties were encountered at Facilities E, F, G, and H.
At Facility E, five of the six tests at the baghouse inlet resulted
in SOo concentrations comparable to those obtained with an instrument
during a non-simultaneous period. The sixth result was a i?ro S02
concentration. At the baghouse outlet, five of th- six runs resulted
in zero concentration, with the sixth result comparable to non-
simultaneous instrumental results.
At Facility F three tests were performed at the inlet and outlet
of the scrubber. Two of the tests at the inlet resulted in zero
concentration while the third yielded a result that was approximately
one-half that yielded by a simultaneously operated instrument.
At the scrubber outlet, all measurements by Method 6 and the
instrument resulted in zero S02 concentrations. Since the emission
control device was a scrubber, it is reasonable to conclude that the
S02 concentrations in this case were less than the minimum detectibla
levels for both Method 6 ?.nd the instrument, which is about 10 ppmv.
At Facility G, six tests were performed before and after the
scrubbers on each of two kilns. At the outlet locations, Method 6 was
used with no particulate filtration (glass wool) in the sampling probes.
The results compared favorably with instrumental measurements in that
no response was obtained for Method 6 results that were at approximately
the instrument's minimum detection limit. Initial testing at the soft-
burned lime scrubber inlet were unsuccessful. When particulate filtra-
D-4
-------
tion at the gas stream temperature was used, or when visible accumu-
lations of particulates were observed in the probe-to-sampling-train
glassware, either zero or low (compared to instrumental measurements)
SOo concentrations were obtained. After the sampling interface system
was modified to incorporate a probe with shielded gas pickup ports
for particulate deflection, all Method 6 measurements were comparable
to instrument results.
At Facility H, tests were performed on each of three inlets to
the baghouse and at the baghouse outlet. At the inlet locations,
shielded gas probes were used for both Method 6 and instrumental
sampling. It was found that this was not adequate to prevent particu-
late accumulation in the Method 6 connection glassware or the instru-
ment sampling lines. No successful interface system could be developed
at the test site. Therefore, all measurements except those made during
the first test run are questionable. At the baghouse outlet, no
particulate filtration was used and the Method 6 data compare favorably
with instrument results. No particulate accumulations were observed
during outlet sampling.
Because of the questionable S02 results obtained at the above
facilities, the gas stream parameters and sampling procedures at
Facilities E, F, G, and H were reviewed in attempt to identify a
condition that would consistently yield low S02 results. It was
found that zero SC>2 concentration results were obtained under a
variety of temperatures, gas compositions, and particulate loadings.
The only consistent variable was that particulates were accumulated
D-5
-------
by either in-stack filtration or deposition in the Method 6 glassware.
From thermodynamic and kinetic considerations of the potential
particulate-SOp reactions under dry conditions/ ' ' ' the following
qualitative statements can be made:
1. The equilibrium conversion of gaseous SCL to solid sulfur
compounds will be increased by a) increased temperature
and b) the increased ratios of gas/solid rcactants versus
products.
2. The rate of conversion will be increased by a) increased solid
surface area for reaction (greater ratio of small particles),
and b) increased contact residence time.
No quantitative estimates of reaction can be made from theoretical
considerations because of the complexity and variability of the systems.
For reaction systems where water is present, the mechanisms could
be different depending on the amount present and physical state of the
water. The most reactive conditions would be expected when water is
present in the liquid state.
Laboratory tests have shown that dry, CaQ-SOp reactions at tempera-
tures up to 280°F do not occur to a detectible extent at the sampling
rate range used with Method 6 procedures. These data cannot be used
to estimate the degree of reactions at higher temperatures.
An additional series of tests are being conducted in order to
identify any possible conditions under which reaction will interfere
in a wet CaO-S02-
D-6
-------
An additional series of tests with known quantities of S02, CaO, and
stack moisture content have demonstrated that, under high moisture condi-
tions, significant gains in particulate weight can be experienced on the
filer of the Method 5 train. At temperatures up to 300°F, S02 concentra-
tions of about 600 ppm, and moisture content greater than 22 percent
by volume, the particulate weight gain ranged from 6 to 15 percent of a
100 to 120 mg total catch. As the CaO used for these tests was obtained
from products samples, there remains some question about how much of this
apparent CaO-SO£ reaction would occur in the stack prior to sampling.
Combining the theoretical considerations and experimental results
with general conditions present at Facilities E, F, G, and H result in
two possible causes for particulate interference with sulfur dioxide
determination. These are (1) dry CaO-SOg reaction and subsequent
filtration at temperatures greater than 280°F and (2) high gas
moisture reaction with CaO and SO^. While no absolute statement is
possible, in the cases where zero or low results were obtained either
one or both of the above causes were potentially present.
In order to avoid potential interference problems, particulate
entrainment should be prevented or minimized to the extent that no
solid accumulations are visible in the sample interface system. No
in-stack filtration should be used at gas temperatures greater than
280°F. If necessary, all connecting apparatus prior to the absorbing
solutions should be heated to prevent moisture condensation.
D-7
-------
D.2 Monitoring Systems
The visible emissions monitoring systems that are adequate for
other stationary sources, such as steam generators, covered by performance »
specifications contained in Appendix B of 40 CFR 60 (Federal Register,
~L~'~ "T~" *
October 6, 1975), should also be applicable to lime plants, except where
condensed moisture is present in the exhaust stream. When scrubbers
are used for emission reduction from rotary lime kilns and hydrators,
monitoring of visible emissions is not required.
Equipment and installation costs for visible emissions monitoring
are estimated to be about $18,000 to $20,000 per site. Annual operating
costs, which includes the recording and reducing of data, are estimated
at about $8,000 to $9,000 per site. Some economics in operating costs
may be achieved if multiple svstems are renuired at a aiven facility.
D.3 Performance Test Methods
The recommended performance test method for particulate matter is
Method 5 (Appendix A, 40 CFR 60, Federal Register, December 23, 1971).
In order to perform Method 5, Methods 1 through 4 must also be used.
Subpart A of 40 CFR 60 requires that affected facilities which are
subject to standards of performance for new stationary sources must be
constructed so that sampling ports adequate for the required performance
tests are provided. Platforms, access, and utilities necessary to perform
testing at those ports must also be provided.
Sampling costs for performing a test consisting of three Method 5
runs is estimated to range from $5,000 to $9,000. If in-plant personnel
are used to conduct tests, the costs will be somewhat less.
The recommended performance test method for visible emissions is
Method 9 (Appendix A, 40 CFR 60, Federal Register, November 12, 1974).
D-8
-------
REFERENCES
1. Schwarzkopf, F., Lime Burning Technology, Kennedy van Saun Corp.,
1974.
2. Turkdogan, E, T. and B. B. Rice, "Desulfurization of Limestone
and Burnt Lime1' Transactions AIME v254 p.28 March 1973.
3. Wrudt, H. A. and L. S. Darkin, "Equilibrium of Sulfur Bearing
Gases and Solids Revel ant to the Burning of Limestone; Transactions
AIME. v254 p.l March 1973.
D-9
-------
APPENDIX E
IMPACT CALCULATIONS
The additional control potential of new or revised standards of
performance stems from the application of emission standards that are more
stringent than those presently applied to construction and modification.
This (impact) for a specified time period, is expressed as
-------
I. For Rotary Lime Kilns -- Participate Emissions
From Chapter 7, Table 7-6
K = 0.893
B + C = 16,522,000 tons lime/year (1987)
B + C = 14,985,000 megagrams lime/year (1987)
1. For Options A-l and B-l (described in 6.1.1)
From Table 6-2
En = 0.030 kg/Mg lime (0.60 Ib/t lime)
Es = 1.00 kg/Mg lime (2.00 Ib/t lime)
Es - En = 0.70 kg/Mg lime (1.40 Ib/t lime)
Ts - Tn = K (B + C) (Es - En)
Ts - Tn = 0.893 (14,985,000) (0.70)
Ts - Tn = 9,370,000 kg/year
Ts - Tn = 9,370 megagrams/year (10,330 tons/year)
2. For Options A-2 and B-2 (described in 6.1.1)
From Table 6-2
En = 0.50 kg/Mg lime (1.00 Ib/t lime)
En = 1.00 kg/Mg lime (2.00 Ib/t lime)
Es - En = 0.50 kg/Mg lime 0.00 Ib/t lime)
Ts - Tn = K (B + C) (Es - En)
Ts - Tn = 0.893 (14,985,000) (0.50)
Ts - Tn = 6,690,000 kg/year
TS - Tn = 6,690 megagrams/year (7376 tons/year)
E-2
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II. For Lime Hydrators -- Partlculate Emissions
From Chapter 7, Table 7-6
K = 0.84
B + C = 775,000 tons hydrate/year* (1987)
B + C = 703,000 megagrams hydrate/year (1987)
For the Control Option described in 6.2.1
En = 0.06 kg/Mg hydrate (0.12 Ib/t hydrate)
Es = 0.40 kg/Mg hydrate (0.80 Ib/t hydrate)
Es - En = 0.34 kg/Mg hydrate (0.68 Ib/t hydrate)
Ts - Tn = K (B + C) (Es - En)
Ts - Tn = 0.84 (703,000) (0.34)
TS - Tn = 201,000 kg/year
Ts - Tn = 201 megagrams/year (221 tons/year)
E-3
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/2-77-007a
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Standards Support and Environmental Impact Statement,
Volume 1: Proposed Standards of Performance for Lime
^Manufacturing Plants
5. REPORT DATE
April 1977
6. PERFORMING ORGANIZATION CODE
7% AUTHOR(S)
'Emission Standards and Engineering Division
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of performance for the control of parti oil ate matter emissions from
affected facilities at new and modified lime manufacturing plants are being proposed
under the authority of sections 111, 114, and 301(a) of the Clean Air Act, as
amended. The standards would require that particulate matter emissions be reduced
by over 99 percent below the uncontrolled levels, and by about 70 percent below
the emission levels being achieved by existing sources controlled to meet typical
state standards. Volume 1 discusses the proposed standards, and an analysis of
the associated environmental and economic impacts is included in this document.
Volume 2, which will be published when the standards are promulgated, will contain
a summary of the public comments on the proposed standards and EPA's responses.
A discussion of any differences between the proposed and promulgated standards will
also be included.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Air pollution
Pollution control
Standards of performance
Lime manufacturing plants
Particulate matter
Air pollution control
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
328
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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