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----------------------------------------------------------------------------- Departmental Findings of Fact and Order
Dragon Products Company, Inc.
II. EMISSION UNIT DESCRIPTION
Due to technology improvements that are part of the modernization project, the project does not result in a significant net emission increase. DEP found that federal New Source Review (i.e. PSD and Non attainment NSR) permits were not required for this project. The PSD avoidance and minor modification provisions of air license A-326-71-U-A/R are incorporated into this Part 70 license. As part of the review for issuance of license A-326-71-U-A/R, DEP determined that the proposed new and modified emission units, including the new cement kiln, will meet Best Available Control Technology (BACT) requirements. As part of Dragon's application for the modernization project , refined modeling was performed to show that emissions from Dragon's new plant configuration, in conjunction with other sources, would not cause or contribute to violations of Maine's Ambient Air Quality Standards (MAAQS) for sulfur dioxide (SO2), Particulate Matter (PM10), Nitrogen Dioxide (NO2) and Carbon Monoxide (CO). The modernization project will convert the existing wet process cement kiln to a dry process (preheater/precalciner type), convert the existing (wet) raw mill to a pregrinding finish cement mill, and improve other ancillary operations within the -------------------------------------------------------------------------------------- Departmental Findings of Fact and Order
Dragon Products Company, Inc.
facility. The planned annual production rate of the new facility is approximately 766,500 tons of clinker. The new dry cement manufacturing process can be divided into three main sections: 1) kiln feed preparation, 2) clinker production, and 3) finish cement operations. 1) Kiln Feed Preparation
2) Clinker Production
In the new kiln, the clinker formation process occurs in a series of stages that correlate with the temperature of the raw materials and in a unit called a calciner or precalciner. These stages and precalciner are located in a structure called a preheater tower. In the preheater, uncombined water evaporates from raw materials. Material temperature increases to the point where calcination begins. As calcination occurs, carbon dioxide is liberated from the carbonate component. Sintering of the oxides occurs in the burning zone of the kiln. The sintering (or clinkering) reactions chemically combine calcines material with silica, alumina, and iron to form tricalium silicate (Ca3SiO5), dicalcium silicate (Ca2SiO4), tricalcium aluminate (Ca3Al2O6), and tetracalcium alumino-ferrite (Ca4AlFeO7). Following the sintering reactions, clinker is quickly cooled by contact with ambient air. Some heat transferred to the cooler air is recouped back into the process. 3) Finish Cement Operations
B. New Portland Cement Kiln System
And may use the following raw materials:
Dragon may also utilize alternate fuels and raw materials which meet the requirements of Condition 14(C) of this license. Particulate emissions in the exhaust from the kiln and alkali bypass are controlled by a fabric filter baghouse. The previously licensed NOx RACT requirements for Dragon's existing wet process cement kiln shall not apply to the new kiln system. The new kiln system is subject to more stringent BACT requirements. Streamlining
2. Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1343 (MACT) is more stringent so that only the MACT limit identified in Condition 14(H) in the Order section of this license is applicable. During periods of kiln preheat and start up, condensation in the kiln exhaust causes false positive readings by the opacity monitor. For this reason, when the exhaust, as measured at the kiln ID fan, is less than 250 oF, monitored opacity readings greater than 20% as measured on a six (6) minute block average basis are not considered an excess emission. ------------------------------------ Departmental Findings of Fact and Order
Dragon Products Company, Inc.
3. 40 CFR Part 63.1350(c) and Chapter 117 require the use of Continuous Opacity Monitors (COM). However, Chapter 117 is at least as stringent as 40 CFR Part 63.1350(c) so that only the Chapter 117 requirement is identified in the Order section of this license. 4. 40 CFR Part 63.8 and Chapter 117 detail the sampling frequency of the CEM and COM. However, Chapter 117 is at least as stringent as 40 CFR Part 63.8 so that only the Chapter 117 requirement is identified in the Order section of this license Periodic Monitoring
Continuous Monitoring
C. Existing Portland Cement Kiln System
1. A coal/coke blend of fuel,
In addition to the basic raw materials used in the manufacture of clinker (sources of calcium, iron, silica, and alumina), Dragon may also use one or a combination of the following raw materials in the production of clinker: 1. Petroleum-contaminated soils,
--------------------------------------------------- Departmental Findings of Fact and Order
Dragon Products Company, Inc.
Dragon may also utilize alternate fuels and raw materials which meet the requirements of Special Condition 14(C) of the license. Particulate emissions on the existing Kiln are controlled by a fabric filter baghouse referred to as the kiln baghouse NOx RACT for the existing kiln was previously determined to be: improvements to the kiln's chain hanging pattern, revisions to the clinker cooler, firing a blend of coal and petroleum coke as the primary fuel source, and low NOx burners. Streamlining
2. Chapter 101 is applicable for visible emissions. However, 40 CFR Part 63.1343 (MACT) is more stringent so that only the MACT limit identified in Condition 16(G) in the Order section of this license is applicable. During periods of kiln preheat and start up, condensation in the kiln exhaust causes false positive readings by the opacity monitor. For this reason, when the exhaust, as measured at the kiln ID fan, is less than 250 oF, monitored opacity readings greater than 20% as measured on a six (6) minute block average basis are not considered an excess emission. 3. 40 CFR Part 63.1350(c) and Chapter 117 require the use of Continuous Opacity Monitors (COM). However, Chapter 117 is at least as stringent at 40 CFR Part 63.1350(c) so that only the Chapter 117 requirement is identified in the Order section of this license. 4. CFR Part 63.8 and Chapter 117 detail the sampling frequency of the CEMs and COM. However, Chapter 117 is at least as stringent as 40 CFR Part 63.8 so that only the Chapter 117 requirement is identified in the Order section of this license. Periodic Monitoring Stack testing for dioxin/furans every 2.5 years. Daily records of fuel use including: gallons of #2 fuel oil, gallons of #4 fuel oil, fuel sulfur content, gallons of specification and/or non-specification waste oil, tons of tires/tire chips, tons of coal, tons of petroleum coke, tons of fly ash or other alternative fuel. Continuous Monitoring Documentation that the COM, SO2, and NOx CEMs are continuously accurate, reliable and operated in accordance with Chapter 117, 40 CFR Part 51 Appendix P, and 40 CFR Part 60 Appendices B and F. |