Modeling/Emissions

Did the facility perform their own modeling analysis?
Are the methods comparable to EPA’s methods and acceptable?
Did the facility fully explain any differences in modeling results?
Did the facility use EPA emission rates?
If not, did the facility explain the revised emission rates?
Are the revised emission rates acceptable?
Has the facility identified all emission points, pollutants, and processes?

Identification of Controls

SO2 Controls
Does the analysis identify the most stringent control?
Fuel Substitution
Substitute low-sulfur coal for high-sulfur coal or coke[1]
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Substitute natural gas for high- or low-sulfur coal
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Substitute low-sulfur oil for high- or low-sulfur coal
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Process Optimization
Raw Material Substitution1
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Balance O2 Content[2]
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Use raw materials with lower pyritic sulfur content1
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Retrofits
Absorbent addition (i.e., slaked lime, quicklime, or activated fly ash2
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Wet Scrubber2
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Lime Spray Dryer1
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility? Y N
Rank Technically Feasible SO2 Control Options
Does the analysis document where they obtained control efficiencies?
Does the source list accurate reduction efficiencies for feasible controls?
NOX Controls
Does the analysis identify the most stringent control?
Process Modification/Optimization
Proper kiln design and operation
Efficiency:
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Increase thermal efficiency
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Low-NOX burner
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Mid-klin fuel injection
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
CemStar
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Retrofits
SNCR
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
SCR
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Cement kiln dust insufflation
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
LoTOx
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Flue gas recirculation
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Rank Technically Feasible NOX Control Options
Does the analysis document where they obtained control efficiencies?
Does the source list accurate reduction efficiencies for feasible controls?
PM Controls: Clinker Cooler
Does the analysis identify the most stringent control?
Retrofits
Electrostatic Precipitator
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Fabric Filter
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Multiclone
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Gravel bed filter
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
PM Controls: Wet Kiln
Retrofits
Electrostatic Precipitator
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Fabric Filter
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Multiclone
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Proper kiln design and operation
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
PM Controls: Fugitive Dust Sources
Retrofits
Baghouse
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Local Ventilators
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Entire building enclosure/evacuation
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Drop height reduction techniques
Is it technically feasible? Y N If not, did the source give a thorough explanation for its infeasibility?
Rank Technically Feasible PM Control Options
Does the analysis document where they obtained control efficiencies?
Does the source list accurate reduction efficiencies for feasible controls?
Does the source list accurate reduction efficiencies for feasible controls?

Evaluate Impacts of Controls

Step 4a: Economic Impact
Did the source consider all cost parameters when calculating costs? (Should we list the parameters here?)
Are costs comparable with the national average?
If not, did the source explain special circumstances?
Did the source use an appropriate interest rate and equipment life to calculate capital recovery costs?

[1] Ash Grove.

[2] Techniques to consider in the determination of BAT. Cement and Lime Industry BREF.