What’s Up With Cement Plant Permitting? What’s BACT? Presented by A. A. Linero, P.E.
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Transcript What’s Up With Cement Plant Permitting? What’s BACT? Presented by A. A. Linero, P.E.
What’s Up With Cement Plant
Permitting?
What’s BACT?
Presented by
A. A. Linero, P.E. Adminstrator
New Source Review Section
June 27, 2001
1
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?
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
3
Dry Process Preheater Calciner Kilns
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Limited to New Dry Process
Preheater Calciner Kilns
AWMA Conference, June 2001
Rinker Photo By FDEP
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From Top of Preheater
AWMA Conference, June 2001
Devil’s Slide Photos by FDEP
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Leaning Tower of Polysius?
AWMA Conference, June 2001
Florida Rock Photo by A. Linero
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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
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
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Kiln Burner NOX
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.
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
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Diaper Derived Fuel?
Devil’s Slide Filmed by FDEP
AWMA Conference, June 2001
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Tire Gasification and SC
Whole Tires
Maybe 40% Tires
Jura Cement - Wildegg
Possible at Suwannee, FL
Graphic Source: Polysius
AWMA Conference, June 2001
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SNCR
Ammonia or Urea Injection
High T, Near Calciner
15+ Kilns in Europe
Taiwan
Most Without SC
Zero in U.S.
Graphic Source: Fueltec
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
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SNCR – Opacity?
Siggenthal Photo by A. Linero
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
AWMA Conference, June 2001
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SNCR – SC Compatibility
Graphic Source: Jura Zement
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?)
AWMA Conference, June 2001
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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
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European Emission Limits
AWMA Conference, June 2001
Polysius Graphic Modified by A. Linero
20
SNCR at Leimen Plant - Germany
3.7 lb/ton
2.3 lb/ton
~1.3 ?
Graphic Source: Heidelberger
AWMA Conference, June 2001
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What is BACT?
Photo Source: RMC Lonestar
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
AWMA Conference, June 2001
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Pollutant Formation – SO2
Fuel Sulfur – Kiln/Calciner
Roasting of Pyrites in PH
Graphic Source: F.L.Smidth/Fuller
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
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Pollutant Control – SO2
Pfeiffer Raw Mill
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
AWMA Conference, June 2001
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Effect of Raw Materials
& Process on SO2
Florida Rock Photo By FDEP
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
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
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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.
AWMA Conference, June 2001
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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
AWMA Conference, June 2001
Graphic Source: KHD
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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
AWMA Conference, June 2001
Graphic Sources: Durr/Reeco
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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
AWMA Conference, June 2001
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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?)
AWMA Conference, June 2001
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European Rule 2000/76/EG
Pollutant
Dust
NOX
SO2
Mercury
Fluorides
TOC
CO
Concentration
30 mg/m3
500 mg/m3 *
800 mg/m3 **
50 mg/m3 ***
0,05 mg/m3
1 mg/m3
10 mg/m3 ***
_
Process Limit
~ 0.14 lb/ton
~ 2.3 lb/ton *
~ 3.7 lb/ton **
~ 0.23 lb/ton ***
~ 0.00023 lb/ton
~ 0.0046
~ 0.046 lb/ton ***
* New Sources
** Existing Sources (Swedish non-EU standard is 200 mg/m3 ~ 0.9 lb/ton)
*** Non Raw Material-Specific Emission
AWMA Conference, June 2001
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European Rule 2000/76/EG
Pollutant
Chlorides
Cd and Thallium
Sb+As+Pb+Cr+
Co+Cu+Mn+Ni+V
Dioxin and Furan
AWMA Conference, June 2001
Concentration
10 mg/m3
0.05 mg/m3
Process Limit
~ 0.046 lb/ton
~ 0.00023 lb/ton
0.5 mg/m3
0.1 ng ITEQ/m3
~ 0.0023 lb/ton
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Ozone Non-Attainment Area
Pollutant
Requirement
Top Limit
Technology
NOX
LAER
~1
SNCR
VOC
LAER
0.026
RTO
SO2
BACT
0.23
Varies
~0.74
Scrubbers
CO
BACT
0.37
RTO
~3.5
Materials?
(4121 tpy)
(129 tpy)
(850 tpy)
(3983 tpy)
1.
2.
3.
Draft
Limit
Proposed Control
3.61
SC
2.82,3 SC & SNCR(?)
~0.11
Materials?
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 ??)
AWMA Conference, June 2001
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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.
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AWMA Conference, June 2001
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