Plant Optimization During NOx RACT
Precompliance Certification for USEPA BIF Regulations
Trial Burn Programs
Background Monitoring for New Construction
Continuous Emission Monitoring Systems



Plant Optimization During NOx RACT
APCC assisted a major cement producer to optimize plant operating conditions during a NOx RACT baseline evaluation. APCC performed a month long continuous emission monitoring and manual emission measurement program on their precalciner cement kiln. Gaseous emission measurements were performed at the kiln exit, preheater exit, inlet and outlet ducts of a baghouse, ESP and wet scrubber, as well as the combined exhaust stack. Additional testing was performed to demonstrate compliance for particulate NOx, SO2 and CO emissions limits. Testing was also performed to determine emissions of CAAA Title III compounds including HCl, VOC and methane.

APCC proposed process adjustments allowed the plant to demonstrate NOx RACT without installing additional controls or adversely affecting production thereby saving the client significant expense.

Precompliance Certification for USEPA BIF Regulations

APCC assisted three Portland cement manufacturing facilities to prepare Precompliance Certifications for interim status for the firing of waste-derived fuels in kilns under the US EPA Boiler and Industrial Furnace (BIF) Regulations. Each project involved dispersion modeling, emissions estimations, and risk assessment to demonstrate the calculated acceptability of these facilities to fire waste fuels with minimal environmental impact.

Computer programs were used to estimate emissions and assess risk in accordance with the procedures outlined in the regulation. This allowed many "what if?" scenarios to be considered prior to establishing limitations on the use of waste fuels. APCC is presently preparing protocols for compliance testing required under status and trial burn programs required for the RCRA Permit to Operate. APCC also developed a CEM/ALARM package to monitor various process and emission parameters and automatically cut the feed of the waste fuel when limitations are reached.

Trial Burn Programs

APCC performed trial burn programs for two clients firing hazardous waste fuels. These projects involved air and hazardous waste permitting; process operational parameter measurements for permit verification; Trial Burn Program and Protocol preparation; negotiations with federal and state regulatory agencies; BACT analyses and air pollution control engineering; start-up and optimization of air pollution control devices; and preparation of the facility for the trial burn program. Emission measurements were performed to determine the destruction and removal efficiency (DRE) of each kiln for principal organic hazardous constituents (POHC), as well as emissions of PCDD/PCDF, particulate, HCI, CO, NOx, SO2, VOC and heavy metals. Testing was also performed to determine the fate of chlorides in the kiln and air pollution control systems. Continuous emission monitoring and CEMS Performance Specification Testing was conducted. Consultation was provided in the preparation of a health risk assessment related to plant emissions subsequent to the trial burn.

Background Monitoring for New Construction

APCC assisted a major manufacturer of Portland Cement to determine baseline plant emissions for an existing facility as part of a permitting process for a new facility on the same site. Continuous Emission Monitoring for SO2, NOx, CO, O2, CO2, temperature and flow-rate, as well as a detailed process and operational monitoring program was performed over a one week period to determine emission and process variations over time. The test program revealed significant process and emission variations, particularly for SO2 and NOx. In addition, permit exceedances for NOx were discovered. Further testing and the installation of a permanent CEM System are planned.

Continuous Emission Monitoring Systems

APCC designed and installed continuous emission monitoring systems for three kilns at two different facilities firing waste fuels as part of a compliance program to satisfy the USEPA BIF Regulations.

At the first facility, the two primary systems monitor carbon monoxide (automatic two range instrumentation) and oxygen emissions continuously from two kilns. A third system, designed as a complete backup, indexes between the two kilns continuously, providing a continuous data check. In the event of a primary system failure, the secondary system locks onto the kiln with the failed system, resulting in zero system down-time.

At a second facility, two systems (primary & backup) monitor total hydrocarbons, carbon monoxide (two range instrumentation) and oxygen emissions continuously from the by-pass of a preheater/precalciner kiln. The second system, designed as a complete backup and also including a NOx monitor, monitors concurrently and continuously, providing a continuous data check as well as an on-line back-up. In the event of a primary system failure, the secondary system locks on resulting in zero system down-time. The systems were certified in accordance with 40 CFR 266. APCC provided ongoing maintenance and audit services for the CEMS.



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