Portland Cement NESHAP

Compliance Requirements for Hg and HCl

Desirea Haggard, Environmental Manager

 Overview
• Background / History of NESHAP
• Current NESHAP requirements
• Installing control devices
• CEMS
• DAS
• Moving forward

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 CalPortland Oro Grande Cement Plant

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 Background / History
• 1999 EPA implemented first NESHAP/ PC-
MACT
– Required monitoring of dust (VEE or COMS)
limits 10-20%
– Dioxin Furan testing and control of baghouse
temperature limit 0.20 ng/dscm (TEQ)

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 Dust Monitoring
Continuous Opacity Monitor
or
Visible Emissions Evaluations

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 Baghouse Inlet Temperature Monitoring
Testing every 30 months to set Temperature limit based on 0.2 ng/dscm

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 September 2015 NESHAP
• Limits for existing kilns:
– Hg 55 lbs/million ton clinker
– HCl 3 ppmvd @ 7% Oxygen
– THC 24 ppmvd @ 7% Oxygen
– PM 0.07 lb/ ton clinker (kiln and clinker cooler)
Opacity or COMS not required on Kiln/Cooler
• New kilns have lower Hg and PM

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 Chemistry of controlling
pollutants
• Hg controlled by activated carbon
– Activated carbon physically absorbs mercury
from gas streams in the micropores
• HCl controlled by hydrated lime
– Ca(OH)2 + 2HCl → CaCl2 + 2H2O

• Reaction time limited

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 New equipment installed for compliance

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 Activated Carbon system

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 Carbon injection point

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 Lime System

This is just the beginning.

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 September 9 deadline
• 1 year extensions granted for most
facilities
• HCl gases were not available
• RATA
• Troubleshooting operations to achieve
compliance
(Just to name a few)

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 Trouble with hot gases
and wet material

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 Version 2: A test for blowing it upstream
into the tower (Larger duct and more air)

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 Version 3: still under construction – easier
to clean

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 Blowers for lime injection

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 Injection point 1 – Top of the main duct
from Kiln ID fan leading to the baghouse

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 Injection point 2 – Downcomer of the PH/PC
tower

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 Injection point 3 – Risers of stage 5 before downcomer. Testing is
showing that injecting it into the baghouse is not best. Best guess
is that reaction is occurring better in gas stream versus filter cake
(forming channels), more contact surface area.

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 Lesson learned – Order early

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ABB analyzer (secondary)
Measures Dry: CO2, CO, O2, NOX
Wet:THC
FTIR analyzer (primary)
Measures Wet: NO, NO2, SO2,
CO, HCL, O2, CO2

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 Sick flow analyzer (top) Tekran air/water
Ametek O2 wet analyze (Bottom) filtration system

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 Sick SO2 (top)
ABB CO2 (middle)
Apex Mercury sorbent trap
Tekran Mercury analyzer (Secondary, bottom)
(primary)

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 CEMS PLC and I/O hardware
connections

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 DAS Overview

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 Challenges elsewhere
• Employee knowledge from other industries
(doesn’t always apply to cement kilns)
– training of control measures
• SOx and HCl do not always react the
same with lime injection. Different
injection points for each pollutant.
• How do we handle dust build up when raw
mill is down
– IPA bins hold dust goes to finish mills.

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 Moving Forward
• Reporting problems with ERT
– Baghouse temperature data (rolling 3 hour
average)
– Uploading attachment files
• Analyzer failure
– No data replacement in NESHAP
– Running lime and carbon systems

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 Moving Forward
• Cost – Carbon system runs all the time
• Operational changes:
– Lime system runs when needed which is
usually when the raw mill is down.
– Lower raw mill production to keep up with kiln
– Specialty clinker products need lime injection

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