PERMIT MEMORANDUM 98-174-TV DRAFT 26
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM July 27, 2007
TO: Phillip Fielder, P.E., Engineering Manager III, Air Quality Division
THROUGH: Matt Paque, Supervising Attorney, Air Quality Division
THROUGH: Kendal Stegmann, Senior Environmental Manager, Air Quality Division
THROUGH: Phil Martin, P.E., Engineering Section
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
THROUGH: Jian Yue, PhD., P.E., Engineering Section
FROM: Richard Kienlen, P.E., New Source Permits Section
SUBJECT: Evaluation of Operating Permit Application Number 98-174-TV
Lafarge Building Materials Inc. (Lafarge)
Portland Cement Manufacturing Facility
Sec. 22 – T20N – R14E, Rogers Co. (≈ Lat. 36.196o N, Long. 95.815o W)
Directions: I-44 to 129th East Ave, North 2 miles to Apache.
East 1 mile to 145th East Ave, North to entrance.
SECTION I. INTRODUCTION
This facility operates as a Portland cement manufacturing plant (SIC 3241). It was originally constructed / operated as Dewey Portland Cement Company in the early 1960s. Dewey merged with American Marietta and the facility was re-named Martin Marietta Cement. In 1983 Blue Circle Cement acquired and operated this facility until 2001 when it was sold to Lafarge. Blue Circle submitted a timely Title V operating permit application on June 26, 1998, for this major source.
SECTION II. PERMIT HISTORY
The facility continues to operate largely as a “grandfathered” facility, except for permit limits that were imposed as a result of facility modifications or statutory inclusion of existing sources, i.e., OAC 252:100-19, 25, and 31, (Control of Emissions of Particulate Matter, Visible Emissions, and Sulfur Oxides, respectively). Emission units constructed or significantly modified since 1972 are not considered grandfathered and are subject to the limitations established. The following paragraphs describe chronologically each issued permit. The pertinent emission limits and the operating conditions for each preceding permit have been incorporated into the Specific Conditions of this permit.
Permit 74-197-O (Issued May 4, 1978) authorized the facility to operate a handling and firing system to burn coal in addition to commercial grade natural gas. The facility has always had the ability to burn coal since its construction.
Permit 74-197-O (M-1) (Issued December 21, 1994) authorized the facility to burn a blend of coal and petroleum coke as a lower cost fuel as compared to straight coal. The test results show a decrease in emissions.
Testing:
In a letter from AQD dated June 1, 1994, Blue Circle was informed that this change would be approved if it could be shown by testing that there was no increase of emissions as a result of utilizing coke as the fuel. That testing was completed at comparable production rates. The results clearly indicate that at comparable production rates there was a distinct reduction of emissions with a coal/coke fuel blend compared to a 100% coal fuel.
Permit 74-197-O (M-2) (Issued June 23, 1995) authorized the facility to modify a production limitation of the permit without a resultant increase of emissions due to improved emissions control.
Permit 74-197-O (M-3) (Issued October 30, 1997) authorized the facility to burn alternate non-hazardous fuels as substitutes for coal only, a coal/coke blend, or natural gas without a resultant increase of emissions. This permit required an extensive program of pre-qualification, testing, and recordkeeping to confirm that each fuel accepted for burning in the kiln will not exceed the applicable maximum acceptable ambient concentration (MAAC) level. Ambient air impacts were computer modeled and determined to be within the applicable standards based on the following limits:
Substitution Rate Total Fuel Consumption
Hourly Yearly
Tire-derived fuel 25 % 4.0 tons 35,040 tons
Landfill gas 80 % 0.688 million ft3 6.028 million ft3
Used greases, oils, lubricants 50 % 1,494 gals 24,000 gals
Tire-Derived Fuel (TDF)
Tires are delivered to the Tulsa plant via covered trailers and are stored in a designated location near the kilns. As needed by the kiln system, trailers are tipped via hydraulic lift into a live-bottom hopper and conveying system. This system keeps the tires in motion and eliminates the factors that enable mosquito infestation.
Landfill Gas
Landfill gas will be piped directly to the kilns and raw mills for combustion fuel. As with natural gas systems, vector control problems are unlikely to occur. Safety practices associated with the utilization of natural gas will be applied in this situation.
Used Greases, Oils, and Other Lubricants
This material will be exclusively generated at the Lafarge facility and stored in a covered tank within a secondary containment structure conforming to applicable federal, state, and local regulations. The enclosed system will discourage the infestation of insects or rodents.
Alternate fuel source requirements
1. Must contain a minimum heat input of 5,000 BTU/pound as generated
2. Cannot meet the criteria of a RCRA hazardous waste according to 40 CFR 261
3. Cannot be a medical waste according to 40 CFR 259 or Oklahoma Solid Waste Rules
4. Must be determined acceptable by the Alternate Fuels Management Program (AFMP)
Permit 95-290-O (Issued April 10, 1998) authorized the operation of a new cement finish mill, which began full operation on December 18, 1997. The new finish mill has a rated capacity of 63 TPH. The total clinker production limitation (96 TPH) for the plant was not modified. The resultant increase of particulate emissions was offset by a reduction of emissions from the clinker cooler system.
SECTION III. PROCESS DESCRIPTION
The facility produces Portland and masonry cements, and other cement products using the dry process. The raw materials include limestone (oxides of calcium), aluminum, iron and silica, which are first ground to a powder. Next they are calcined at temperatures of around 2,600oF in a rotary cement kiln to produce “clinker.” The clinker is then finely ground and mixed with approximately 5% gypsum to produce cement. At maximum capacity, a feed rate of approximately 4,369 tons per day of raw materials may be fed to two kilns to produce a maximum total (both kilns) of 96 TPH of clinker. Approximately 43% by weight of the raw materials are lost in the calcining process. Each rotary kiln is 425 feet long and 12 to 14 feet in diameter. Originally fired by natural gas, the facility was converted to coal commencing in 1974.
The Finish Mill system is a rotating ball mill used to grind the clinker, gypsum, and fly ash into the final cement product. The three finish mills have a design capacity to produce 141 TPH of cement.
The Clinker Cooler System consists of the #1 and #2 Clinker Coolers, which have been modified in order to increase their heat transfer efficiency and which were involved in PSD netting analysis for Permit No. 95-290-O. The purpose of the clinker cooler is to cool the hot clinker from the kiln so that it may be handled by the transport system and to recoup heat from the clinker in order to utilize less fuel in the kiln process.
The final step in the process is storing, handling, and packaging to ship the final products by truck and rail. Particulate emissions from each step of these processes (as well as the grinding, calcining and cooling) are controlled by air systems with fabric filters. In many cases the fabric filters have a primary purpose of product recovery or separation.
SECTION IV. EQUIPMENT
The process rates of all equipment, grandfathered and permitted, is shown in the Emissions section.
Grandfathered Units
EUG 1 Raw Material Crushing and Transfer
EU ID# / Point ID# / EU Name/Function / Installation Date101 / EP01 / Primary/secondary crushing system / 1961
102 / EP02 / Junction house / 1961
EUG 2A Raw Mills and Auxiliary Equipment
EU ID# / Point ID# / EU Name/Function / Installation Date
211 / EP03 / #1 Discharge chute, separator, bucket elev. / 1961
221 / EP04 / #2 Discharge chute, separator, bucket elev. / 1964
EUG 2B Raw Mills Auxiliary Equipment
EU ID# / Point ID# / EU Name/Function / Installation Date
212 / EP06 / Raw mill FK pump hoppers / 1961
213 / EP06 / Raw mill #1 weigh meters and feed belts system / 1961
222 / EP05 / Raw mill M pump hopper / 1964
223 / EP05 / Raw mill #2 weigh meters and feed belts / 1964
EUG 3 Raw Blending and Raw Silos
EU ID# / Point ID# / EU Name/Function / Installation Date
301 / EP07 / Blend silos #1 and #2 / 1961
302 / EP10 / Raw silo #3 / 1961
303 / EP11 / Raw silo #4 / 1961
304 / EP11 / Raw silo #6 / 1961
EUG 4A Kiln Feed Pumps
EU ID# / Point ID# / EU Name/Function / Installation Date
401 / EP08 / Kiln feed pumps #1,2,3 / 1961
EUG 4B Kiln Feed X-Pump
EU ID# / Point ID# / EU Name/Function / Installation Date
402 / EP09 / Kiln feed x-pump / 1961
EUG 4C Kiln Feed Systems
EU ID# / Point ID# / EU Name/Function / Installation Date
403 / EP12 / Kiln #1 feed system / 1961
404 / EP13 / Kiln #2 feed system / 1964
EUG 5A Kiln #1 System
EU ID# / Point ID# / EU Name/Function / Installation Date501 / EP14 / Kiln, screw conveyor, & bucket elevator / 1964
EUG 5B Kiln #2 System
EU ID# / Point ID# / EU Name/Function / Installation Date502 / EP15 / Kiln, screw conveyor, & bucket elevator / 1964
EUG 6B Clinker Handling
EU ID# / Point ID# / EU Name/Function / Installation Date
603 / EP18 / #3 Hot belt / 1961
604 / EP19 / #4 Hot belt / 1961
605 / EP20 / Transfer to clinker storage (clinker belts) / 1961
606 / EP57 / Clinker elevators / 1961
EUG 7A Finish Mill #1 System
EU ID# / Point ID# / EU Name/Function / Installation Date
703 / EP21 / #1 Bucket elevator and separator / 1961
702 / EP22 / Finish mill #1 / 1961
EUG 7B Finish Mill #2 System
EU ID# / Point ID# / EU Name/Function / Installation Date
706 / EP24 / #2 Bucket elevator and separator / 1964
705 / EP26 / Finish mill #2 / 1964
EUG 7D Finish Mills #1 and #2 Feed Belts
EU ID# / Point ID# / EU Name/Function / Installation Date
701 / EP23 / Finish mill #1 feed belt / 1961
704 / EP25 / Finish mill #2 feed belt / 1964
EUG 8 Rail Loading
EU ID# / Point ID# / EU Name/Function / Installation Date
811 / EP48 / Silo 8 rail loading spout / 1961
812 / EP47 / Silo 10 rail loading spout / 1961
813 / EP46 / Silo 12 rail loading spout / 1961
814 / EP45 / Silo 14 rail loading spout / 1961
815 / EP44 / Silo 18 rail loading spout / 1961
EUG 9 Truck Loading
EU ID# / Point ID# / EU Name/Function / Installation Date
901 / EP41 / West truck loading spout / 1961
902 / EP40 / East truck loading spout / 1961
EUG 10 Packhouse /
EU ID# / Point ID# / EU Name/Function / Installation Date /
1001 / EP29 / Packing system #1 / 1961
1002 / EP30 / Packing system #2/2A / 1961
1003 / EP32 / Packing system #3 / 1961
1004 / EP33 / Packing system #4 / 1961
1005 / EP31 / Packhouse bag cleaner / 1961
EUG 12A Dust Handling
EU ID# / Point ID# / EU Name/Function / Installation Date
1202 / EP42 / Dust unloading / 1961
1203 / EP10 / Silo #5 / 1961
EUG 13A Rail Cement Storage Silos
EU ID# / Point ID# / EU Name/Function / Installation Date
1301 / EP34 / Rail silo 7 (masonry) / 1961
1302 / EP35, 54 / Rail silo 8 / 1961
1304 / EP35, 54 / Rail silo 10 and interstice C* / 1961
1306 / EP35, 54 / Rail silo 12 / 1961
1308 / EP35, 54 / Rail silo14 and interstice E* / 1961
1310 / EP35 / Rail silo 16 / 1961
1303 / EP35 / Rail silo 9 / 1961
1305 / EP35 / Rail silo 11 and interstice D* / 1961
1307 / EP35 / Rail silo 13 and interstice E* / 1961
1309 / EP35 / Rail silo 15 / 1961
* An interstice is a storage space constructed between two adjacent silos. This creates additional storage space by using existing structures with minimal extra wall material.
EUG 13B Truck Cement Storage SilosEU ID# / Point ID# / EU Name/Function / Installation Date
1311 / EP37, 39 / Truck silo interstice A / 1961
1313 / EP37, 39 / Truck silo 1 / 1961
1315 / EP37, 39 / Truck silo 3 / 1961
1317 / EP37, 39 / Truck silo 5 / 1961
1318 / EP37, 39 / Truck silo5A / 1961
1312 / EP38 / Truck silo interstice B / 1961
1314 / EP38 / Truck silo 2 / 1961
1316 / EP38 / Truck silo 4 / 1961
1319 / EP38 / Truck silo 6 / 1961
1320 / EP38 / Truck silo 6A / 1961
EUG 14 Plant Fugitive Sources
EU ID# / Point ID# / EU Name/Function / Installation Date
1401 / NP01 / Unpaved roads / 1961
1402 / NP02 / Stockpiles, crane storage / 1961
1403 / NP03 / Paved roads / 1961
1404 / NP04 / Heavy equipment travel / 1961
1405 / NP05 / Quarry operations / 1961
Permitted Units
EUG 1A Raw Material Crushing and Transfer
EU ID# / Point ID# / EU Name/Function / Installation Date82 / EP82 / Raw Material Screening System / 2007
EUG 3A Raw Blending and Raw Silos
EU ID# / Point ID# / EU Name/Function / Installation Date1203 / EP61 / Clinker additives silo / 2005
1204 / EP62 / Clinker additives silo / 2005
EUG 6A Clinker Coolers
EU ID# / Point ID# / EU Name/Function / Installation Date
601 / EP16 / Clinker cooler #1 / 1961 / 1995
602 / EP17 / Clinker cooler #2 / 1964 / 1997
EUG 6C Plant Fugitive Sources
EU ID# / Point ID# / EU Name/Function /
Installation Date
63 / EP63 / Raw Material Feed hopper / 200564 / EP64 / Raw Material stockpile conveyor / 2005
EUG 7C Finish Mill #3 System
EU ID# / Point ID# / EU Name/Function / Installation Date
707 / EP52 / Finish mill #3 clinker/gypsum transfer belt / 1997
708 / EP50 / Finish mill #3 / 1997
709 / EP51 / Finish mill #3 bucket elevator / 1997
711 / EP51 / Finish mill #3 cement conveyor / 1997
710 / EP49 / Finish mill #3 separator / 1997
712 / EP53 / Finish mill #3 six-ton bin / 1997
EUG 9A Truck Loading
EU ID# / Point ID# / EU Name/Function / Installation Date
65 / EP65 / NewCem Conveyor No. 1 / 2005
EUG 11 Coal/Coke Handling
EU ID# / Point ID# / EU Name/Function / Installation Date
1101 / EP27 / Coal/coke unloading / 1974
1102 / EP28 / Coal/coke drag conveyor, bucket elevators / 1974
1103 / EP28 / Coal/coke crusher / 1974
1104 / EP55 / Coal silo #1 / 1997
1105 / EP56 / Coal silo #2 / 1997
EUG 12B Dust Handling
EU ID# / Point ID# / EU Name/Function / Installation Date
1201 / EP43 / T-10 Dust silo / 1994
1202 / EP60 / Flyash silo / 2004
EUG 15 Miscellaneous Sources
EU ID# / Point ID# / EU Name/Function /
Installation Date
66 / EP66 / 66.4-hp Diesel engine / 200580 / EP80 / 66.4-hp Diesel engine / 2005
81 / EP81 / 74-hp Diesel engine / 2007
SECTION V. EMISSIONS