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What’s Up With Cement Plant Permitting?

What’s Up With Cement Plant Permitting?. What’s BACT? Presented by A. A. Linero, P.E. Adminstrator New Source Review Section June 27, 2001. Overview. Kiln Construction is Back Focus on Preheater/Calciner Process Formation and Control of Pollutants What’s Going on in Europe

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What’s Up With Cement Plant Permitting?

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

  2. Overview • Kiln Construction is Back • Focus on Preheater/Calciner Process • Formation and Control of Pollutants • What’s Going on in Europe • Some BACT and LAER Ranges • Look at a Current Project • What Next? Questions?

  3. Views are Author’s ! • Not Opinions of Florida DEP • We do Case-by-Case Reviews • Literature Search, Not a Technical Paper • As Seen by a Permitting Engineer • There are Very Diverse Opinions • Greatly Simplified

  4. Dry Process Preheater Calciner Kilns

  5. Limited to New Dry Process Preheater Calciner Kilns Rinker Photo By FDEP

  6. From Top of Preheater Devil’s Slide Photos by FDEP

  7. Leaning Tower of Polysius? Florida Rock Photo by A. Linero

  8. Lot’s of Projects • Production is up Nationwide. 80 Million TPY • Florida Rock – First New Kiln in a Dozen Years • New Plants – CO, FL, MS, NY, TX • Modernizations and Expansions • AL, AZ, CA, CO, FL, IN, MS, SC, TX, UT • Most Require PSD Review and BACT (or LAER) • Others “Net Out” – Switch Wet to Dry Process

  9. Pollutant Formation - NOX • Thermal NOX • Temp. > 1200 OC • Kiln Burner ~ 2000 OC • Oxidizing Conditions • Calciner ~ 1000 OC • Fuel NOX • Kiln and Calciner Devils’ Slide Photo by FDEP

  10. Pollutant Control - NOX • Minimize T and Raw Materials Fluctuations • Optimum Process and Raw Mix Control • Intelligent Systems – Linkman, PyroExpert • Minimize Primary Air from Coal Mill • Maximize Hot Air From Clinker Cooler • All New Projects Do These Things

  11. Graphic Source: F.L.Smidth/Fuller Multi-channel Burner Pyrojet, Swirlax, Duoflex, GyroTherm, Rotoflam Flame Shaping and Localized Reducing Conditions High Momentum Primary Air Envelope Compatible with Low NOX. All New Projects Do. Kiln Burner NOX

  12. SC Calciner • Staged Combustion (SC) • Lower Stage – Reducing Zone • Tires (15%), TDF, DDF, Bottle Caps • Tertiary Air and Fuel • Upper Stage – Top Air • Florida Rock Installing • Maybe 30 – 45% Reduction • All New Projects Do This Graphic Source: Polysius

  13. Diaper Derived Fuel? Devil’s Slide Filmed by FDEP

  14. Tire Gasification and SC • Whole Tires • Maybe 40% Tires • Jura Cement - Wildegg • Possible at Suwannee, FL Graphic Source: Polysius

  15. SNCR • Ammonia or Urea Injection • High T, Near Calciner • 15+ Kilns in Europe • Taiwan • Most Without SC • Zero in U.S. Graphic Source: Fueltec

  16. SNCR – Problems? Graphic Source: EnviroCare • Much Resistance in U.S. • “Slip” and Possibility of Detached Plume • Often Occurs Even w/o SNCR • Ammonia Sulfates and Chlorides • Compatibility Question With SC

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

  18. SNCR – SC Compatibility • For SNCR to Work, Need High T and O2 • In SC Calciner, T is High where O2 is “Low” • Outside of Calciner, O2 is “High” and T is “Low” • Is Lower End of Window 800 or 900 OC • Jura Zement Has SC and SNCR and Gasification! • “No Effect on (Pre-SNCR) Excellent Plume Opacity” • No Ammonia Slip (Low Removal Objective?) Graphic Source: Jura Zement

  19. Selective Catalytic Reduction • Catalyst and Low T Ammonia Injection • Demonstration Stage at Solnhofen • Extremely Dusty Environment • Or Need to Re-heat Stack Gas • Maybe Exotic Compared to Other Options • Better to See What SC, SNCR, Achieve First

  20. European Emission Limits Polysius Graphic Modified by A. Linero

  21. SNCR at Leimen Plant - Germany 3.7 lb/ton 2.3 lb/ton ~1.3 ? Graphic Source: Heidelberger

  22. What is BACT? • 2.5 lb/ton at Kiln Built Circa 1980! • Slug of 2.3 – 2.9 lb/ton BACTs, e.g. FRI 2.8 in 1996 • ~ 1 lb/ton in Slite, Sweden (80% Reduction) • ~ 1 lb/ton in Taiwan by SNCR • ~ 1 lb/ton in 1994 Ash Grove SNCR Test • ~ 1.2 lb/ton Annual Limit at Holnam Midlothian • European IPPC BAT (200 – 500 mg/m3) • Equals 0.9 to 2.3 lb/ton • LAER? Must Be Near 1 lb/ton. Lower if SCR Photo Source: RMC Lonestar

  23. Pollutant Formation – SO2 • Fuel Sulfur – Kiln/Calciner • Roasting of Pyrites in PH Graphic Source: F.L.Smidth/Fuller

  24. Pollutant Control – SO2 • Raw Material Selection (Avoid Pyrites!) • Fine CaO in Calciner Scrubs Kiln ~ 100% • Move CaO by P to Upper Preheater • Can Reduce Pyritic Emissions ~ 20-30% • Capitol Cement and Ash Grove Chanute • Need More Fuel, Balance Heat • Capital Investment Looks Low Graphic Source: F.L.Smidth/Fuller

  25. Pollutant Control – SO2 • CaCO3 and Moisture on Raw Mill Surface • Some of the CaO from D-SOX • Maybe Together 70+ Percent of Residual SO2 • When Raw Mill Out – Control Gas Temperature • Spray Fine Ca(OH)2 Mist into Conditioning Tower • Not Enough - More Conventional Scrubbers • Achieve as much as 90 Percent Removal Pfeiffer Raw Mill

  26. Effect of Raw Materials & Process on SO2 • PH/Calciner Kilns in TX – 1000’s of TPY of SO2 • High Pyrites in Raw Materials • Wet Kilns in Florida – 1000’s of TPY of SO2 • Fuel Sulfur, No Calciner - less Self Scrubbing • PH/Calciner Kilns in Florida – << 100 TPY • No Pyrites in Raw Materials • Florida Rock Kiln, Rinker Modernization • From 1000+ TPY to ~ 20 TPY Florida Rock Photo By FDEP

  27. What is BACT? • < 0.23 (or Better) in Florida With No Controls • ~ 0.05 at Siggenthal by (Incidental) Coke Filter • ~ 1.3 lb/ton at TXI Midlothian to Avoid PSD • < 1 lb/ton at Slite, Sweden (90% Reduction) • European IPPC BAT (200 – 400 mg/m3) • Equals 0.9 to 1.8 lb/ton • D-SOx & Lime Mist With Moderate Pyrites • 90 % Scrubber Control With Very High Pyrites

  28. Pollutant Formation - CO & VOC • CO From Incomplete Combustion • Very Little VOC From Kiln and Calciner • Evolution in Preheater • Organic Carbon from Raw Materials • Carbon from Coal Ash • VOC from Mill Scale, etc.

  29. Pollutant Control - CO & VOC • Hot Excess Air, Mixing • Tertiary Air After Calcining • E.G. Pyrotop after SC • Raw Material Selection – e.g. Millscale • ~ 70% VOC Reduction at Florida Rock • Must Install Continuous Monitor • Grind and Introduce Directly into Kiln Graphic Source: KHD

  30. Regenerative Thermal Oxidation • Texas Cement Midlothian • About 10 Modules • Area of a Football Field • Enter Market at Earliest Date • Avoid PSD Delays “up to 3 Years” • $17,500,000 for RTO • $13,000,000 for SO2 Scrubber Graphic Sources: Durr/Reeco

  31. Active Coke Filter • Siggenthal Switzerland • In Conjunction with Dried Sludge Burning • $15,000,000 Partly Funded by Zurich • “Environmentally Friendly Dried Sludge Burning” • Concern Was Thallium and Mercury (on Cows?) • Also Cleans up, SO2, dioxin/furan, and Ammonia • With SNCR Constitutes POLVITEC by Polysius

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

  33. PollutantConcentrationProcess Limit Dust 30 mg/m3 ~ 0.14 lb/ton NOX 500 mg/m3 * ~ 2.3 lb/ton * 800 mg/m3 ** ~ 3.7 lb/ton ** SO2 50 mg/m3 *** ~ 0.23 lb/ton *** Mercury 0,05 mg/m3 ~ 0.00023 lb/ton Fluorides 1 mg/m3 ~ 0.0046 TOC 10 mg/m3 *** ~ 0.046 lb/ton *** CO _ * New Sources ** Existing Sources (Swedish non-EU standard is 200 mg/m3 ~ 0.9 lb/ton) *** Non Raw Material-Specific Emission European Rule 2000/76/EG

  34. PollutantConcentrationProcess Limit Chlorides 10 mg/m3 ~ 0.046 lb/ton Cd and Thallium 0.05 mg/m3 ~ 0.00023 lb/ton Sb+As+Pb+Cr+ Co+Cu+Mn+Ni+V 0.5 mg/m3 ~ 0.0023 lb/ton Dioxin and Furan 0.1 ng ITEQ/m3 European Rule 2000/76/EG

  35. Ozone Non-Attainment Area • Initial Limit is 3.6 lb/ton during first two years by Staged Combustion 12-Month Average • Limit is stepped down from 3.6 to 2.8 lb/ton between years 2 and 3 • Company proposes LAER after 38 months of operation. Department sets LAER (2007 ??)

  36. Final Thoughts • 4000 TPY of NOX equates to • 50 Gas-fired Combined Cycle Plants = to 12,500 MW • At 3 million Btu/ton of Clinker • 3.6 lb NOX /ton limit equates to • 1.2 lb NOX/million Btu heat input • Order of magnitude > than new coal power plant • Two orders > greater than gas-fired power plant • Some low hanging fruit to pick here.

  37. Thank you, Any Questions?

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