What’s Up With Cement Plant Permitting? What’s BACT? Presented by A. A. Linero, P.E.
Download ReportTranscript 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 2 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 AWMA Conference, June 2001 4 Limited to New Dry Process Preheater Calciner Kilns AWMA Conference, June 2001 Rinker Photo By FDEP 5 From Top of Preheater AWMA Conference, June 2001 Devil’s Slide Photos by FDEP 6 Leaning Tower of Polysius? AWMA Conference, June 2001 Florida Rock Photo by A. Linero 7 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 8 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 9 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 10 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 11 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 12 Diaper Derived Fuel? Devil’s Slide Filmed by FDEP AWMA Conference, June 2001 13 Tire Gasification and SC Whole Tires Maybe 40% Tires Jura Cement - Wildegg Possible at Suwannee, FL Graphic Source: Polysius AWMA Conference, June 2001 14 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 15 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 16 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 17 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 18 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 AWMA Conference, June 2001 19 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 21 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 22 Pollutant Formation – SO2 Fuel Sulfur – Kiln/Calciner Roasting of Pyrites in PH Graphic Source: F.L.Smidth/Fuller AWMA Conference, June 2001 23 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 24 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 25 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 26 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 27 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 28 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 29 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 30 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 31 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 32 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 33 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 34 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 35 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. AWMA Conference, June 2001 36 AWMA Conference, June 2001 37