DAQ-2024-008120

6Lhoist UTAH DEPABTMENT OF
E}WIRONMEMTAL OI,IAUW
JAN - 2 ?A24
DIVTSION OF AIR QUALTTV
December 26,2023
Mr. Bryce Bird
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116
Re: Lhoist North America of Arizona, Ine - Grantsville Plant
Title V Permit No. 4500005004
S ub minal of RA CT A n alysis
Dear Mr. Bird,
Lhoist Norttr America of Arizona, Inc. (LNA) owns and operates the Grantsville Plant
(Facility) in Tooele County, Utah pursuant to Title V Permit No. 4500005004 (Permit). LNA
received a letter from the Division of Air Quality (DAQ) dated May 31,2023 stating that EPA
is expected to redesignate the Northem Wasatch Front for ozone to a serious classification in
2025. Subsequently, DAQ has requested the Facility prepare and submit a RACT Analysis,
including all sources of NOx and VOC. The purpose of this correspondence is to submit the
required information.
If you have any questions regarding this submittal, please contact me by phone at (702) 236-
| 409, or by e-mail at iustin. andrews@lhoist. com.
Director, Environmental Affain
CC: Duane Surman-LNA
UTAH DEPARTMENT OF
ENVIRONMENTAL OUALITY
JAN '2 cu24
DIVISION OF AIR QUALIW
UTAH DIVISION OF AIR QUALITY
RACT Analysis
QtLhoist
Lhoist North America - Grantsville Facility
Prepared By:
Trinity Consultants
Project Lead: Chantelle Russell
4525 Wasatch Boulevard, Srit" ZOO
Salt Lake City, UT 84124
801-272-3000
December 2023
P@ect 234502.0045
IJlniI"yb
TABLE OF CONTENTS
1.
2.
EXECUTIVE SUMMARY
INTRODUCTION
KILN SHAFT MOTOR
TANKS
1-1
2-L2.L Description of Facility ............2-1
2.1.1 Curent Operational5tate......... ...........2-12.2 Emission Profile ...................2-2
3. RACTBACKGROUND 3-13.1 RACT Methodology............ ...3-1
3.1.1 Step 1 - Identify All Reasonably Available Control Technologies. .................3-2
3.1.2 Step 2 - Eliminate Technically Infeasible Options ...... ...............3-2
3.1.3 Step 3 - Rank Remaining Control Technologies by Control Effectiveness .....3-2
3.1.4 Step 4 - Evaluate Most Effective Controls and Document Results. ...............3-2
3.1.5 Step 5 - Selst RACT. .........3-3
4. KILN SYSTEM RACTANALYSIS 4-l
5. PRESSURE HYDRATOR BAGHOUSE HEATER RACT ANALYSIS 5-15.1 Pressure Hydrator Baghouse Heater NOx RACT. .....5-1
5.1.1 Natural Gas Burner NOx Step 1........ .....5-I
5.1.2 Natural Gas Burner NOx Step 2........ .....5-2
5.1.3 Natural Gas Burner NOx Step 3........ .....9-4
5.1.4 Natural Gas Burner NOx Step 4........ .....5-4
5.1.5 NaturalGas Burner NOx Step 5........ .....5-55.2 Pressure Hydrator Baghouse Heater VOC RACT. ......5-5
5.2.1 Natural Gas Burner VOC Step I ............... ..............5-5
5.2.2 Natural Gas Burner VOC Step 2 ............... ..............5-5
5.2.3 NaturalGas Burner VOC Steps 3-5.........,.. .............5-6
5.
7.
6-1
7-L
8. CHEMICAL ADDITIVES 8-18.1 Chemical Additives VOC RACT ................8-1
8.1.1 ChemicalAdditives Step 1........ ............8-1
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9. DRILLING AND BI.ASTING
9.1 Blasting NOx and VOCs RACT Steps 1-5...........,r..,.....r.ra,..rr.,.,.,.r,.,..,
l0.coNcLUsIoNs
APPENDIX A. DETAITED COST CATCULATIONS
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9-1
9-1
10-1
A-1
1. EXECUTIVE SUMMARY
On May 31, 2023, the Utah Division of Air Quality (UDAQ) sent a letter to Lhoist North America of Arizona,
Inc. (Lhoist) which identified the Lhoist plant in Grantsville, Utah (Grantsville Plant) as a major stationary
source within the Northern Wasatch Front (NWF) Ozone Nonattainment Area (NAA). This letter indicated
that UDAQ anticipates that the U.S. Environmental Protection Agency (EPA) will reclassiff the NM as
serious by February 2025.In order to prepare for the reclassification UDAQ has requested that a
Reasonably Available ControlTechnology (RACT) analysis be submitted by January 2,2024. Section 110 of
the Clean Air Act (CeA) defines the requirements for the development of State Implementation Plans (SIPs),
and Section 75tla specifies the requirements of a serious nonattainment SIP, which includes a Reasonably
Available ControlTechnology (RACT) analysis for all major sources.
The precursors to ozone are oxides of nitrogen (NOx) and volatile organic compounds (VOCs). As a result,
the enclosed RACT analysis focuses on the emission sources at the Grantsville Plant that emit these
pollutants. Lhoist has the potential to emit 50 tons per year (tpy) or more of NOx classifuing it as a major
source subject to SIP requirements.
Based on further information provided by UDAQ the following elements have been requested for each MCT
analysis:
> A list of each of the NOx and VOC emission units at the facility;> A physical description of each emission unit, including its operating characteristics;
associated suppofting documentation;
> The proposed NOx and/or VOC RACT requirement or emission limitation (as applicable); and
Per UDAQ's request Lhoist is submitting this RACT analysis no later than January 2, 2024.
r Ozone SIP Planning MCT Analysis forms provided by Ana Williams, Utah Department of Environmental Quality on January 9,2023.
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2. INTRODUCTION
2.L Description of Facility
Lhoist owns a quarry and lime processing plant located nine miles northwest of Grantsville, Utah.
Operations at the plant are covered by Title V Operating Permit #4500005004 and approval order (AO)
DAQE-AN0707015-06, issued by UDAQ on January 13, 202L and August L4, 2006, respectively. Potential
emission sources for the facility include mining, limestone processing, lime hydration, bagging, and load out.
The Grantsville Facility is capable of producing a variety of products including quicklime, hydrate, aggregate
kiln grade limestone, overburden/low-grade limestone, and chat. This RACT analysis focuses on equipment
that emits NOx and VOC, which includes the following:
> Tanks;
Each of these emission sources will be discussed in a subsequent section. All correspondence regarding this
submission should be addressed to:
Mr. Justin Andrews
Lhoist North America of Arizona, Inc.
Director - Environmental Affairs
5600 Cleadork Main Street, Suite 300
Fort Worth, TX 76109
Phone: [phone]
Email : [e-mail]
z.L.L Current Operational State
Operations at the Lhoist Grantsville facility were placed in temporary care and maintenance mode on
November 14,2008. This means that the facility is still undergoing basic day-to-day activities such as
security, plant clean-up operations, maintenance, etc. to remain in compete "ready mode," but that there is
no lime being manufactured and the rotary kiln is not being operated (i.e., there is no fuel source being
fired to keep the kiln heated). However, the facility could resume operations at any time. As such, this RACT
analysis is based on the Grantsville Facility's potentialto emit (PTE).
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2.2 Emission Profile
Lhoist has established the following PTE profile. A full explanation of calculation methods and inputs can be
found within the permitting files.
Per the letter from UDAQ, NOx and VOC emissions from 2017 will be utilized in initial SIP planning. These
emissions are included as a reference in Table 2-2. Subsequent years are recorded within UDAQ's State and
Local Emission Inventory System (SLEIS).
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Table 2-1. Lhoist PTE
Table 2-2. Lhoist 2017 Actual Emissions
2-2
3. RACT BACKGROUND
Lhoist has organized the RACT analysis in accordance with EPA's "top-down" procedures per UDAQ
guidance.2 The analysis is further organized by emission unit group and addresses NOx and VOCs as ozone
precursors.
3.1 RACT Methodology
EPA has defined MCT as follows:
The lowest emission limitation that a particular source is capable of meeting by the
application of control technology that is reasonably auailable considering
technological and economic feasibility.3
RACT for a particular source is determined on a case-by-case basis considering the
technological and sonomic circumstances of the individual source.a
In EPA's State Implementation Plans; General Preamble for Proposd Rulemaking on Approval of Plan
Revisions for Nonattainment Areas - Supplement (on Control Tuhniques Guidelines), it provided a
recommendation to states which says:
...each [ControlTechnique GuidelineJ CTG contains recommendations to the States
of what EPA calls the "pr*umptive norm" for RAC-li, basd on EPA's current
evaluation of the capabilities and problems general to the industry. Where the States
finds the presumptive norm applicable to an individual source or group of sources,
EPA rrcommends that the State adopt requirements consistent with the presumptive
norm level in or to include MCT limitations in the 51P.5
Lhoist has referenced the published CTG's as well as Utah Administrative Code (UAC) for Air Quality (R307),
and proposed rules which establish a current presumptive norm specific to the NWF NAA. The preamble
goes on to state:
...rsommended controls are basd on capabilities and problems which are general
to the industry; they do not take into account the unique circumstances of each
facility. In many cases appropriate controls would be more or less stringent. States
are urgd to judge the feasibility of imposing the recommended control on particular
sourcet and adjust the controls accordingly.
Guidance provided by UDAQ for this RACT analysis states that this analysis is to be conducted using the
"top-down" method.6 In a memorandum dated December L, t987, the EPA detailed its preference for a
2 UOaq Ozone SIP Planning RACTAnalysis, obtained June 13,2023 during an informational meeting.
3 EPA articulated its definition of RACT in a memorandum from Roger Strelow, Assistant Administrator for Air and Waste
Management to Regional Administrators, Regions I-X, on Guidance for determining Acceptability of SIP Regulations in Non-
Attainment Areas," Section 1.a (December 9,1976).
a Federal Register/Vol.44. No. 181/Monday, September 17,L979lProposed Rules-State Implementation Plan; General Preamblefor
Proposed Rulemaking on Approval of Plan Revisions for Nonattainment Areas - Supplement (on Control Techniques Guidelines).
5 IBID.
5 UDAQ Ozone SIP Planning RACT Analysis, provided January 9,2023.
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"top-down" analysis which contains five (5) steps.T If it can be shown that the most stringent level of
control is technically, environmentally, or economically infeasible for the unit in question, then the next most
stringent level of control is determined and similarly evaluated. This process continues until the RACT level
under consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections. Presented below are the five basic steps of a "top-down" RACT review as identified by
the EPA.
3.1.1 Step 1 - Identify All Reasonably Available Contro! Technologies
Available control technologies are identified for each emission unit in question. The following methods are
used to identify potential technologies: 1) researching the RACI/BACI/LAER Clearinghouse (RBLC)
database, 2) surveying regulatory agencies, 3) drawing from previous engineering experience, 4) surueying
air pollution control equipment vendors, andlor 5) surueying available literature. Additionally, current CTG's
as well as UAC R307, and proposed rules were reviewed to establish a current presumptive norm specific to
the NWF NAA.
3.L.2 Step 2 - Eliminate Technically Infeasible Options
To ensure the presumptive norm established applies to the emission source in question a full review of
available control technologies is conducted in the second step of the RACT analysis. In this step each
technology is reviewed for technical feasibility and those that are clearly technically infeasible are
eliminated. EPA states the following with regard to technical feasibility:8
A demonstration of technical infeasibility should be clearly documented and should
show, based on physical, chemical, and engineering principles, that technical
difficulties would preclude the successful use of the control option on the emissions
unit under review.
3.1.3 Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Once technically infeasible options are removed from consideration, the remaining options are ranked based
on their control effectiveness. If there is only one remaining option or if all the remaining technologies could
achieve equivalent control efficiencies, ranking based on control efficiency is not required.
3.1.4 Step 4 - Evaluate Most Effective Controls and Document Results
Beginning with the most effective control option in the ranking, detailed economic, energy, and
environmental impact evaluations are performed. If a control option is determined to be economically
feasible without adverse energy or environmental impacts, it is not necessary to evaluate the remaining
options with lower control effectiveness.
The economic evaluation centers on the cost effectiveness of the control option. Costs of installing and
operating control technologies are estimated and annualized following the methodologies outlined in the
EPA's OAQPS Control Cost Manual (CCM) and other industry resources.e Note that the purpose of this
7 U.S. EPA, Office of Air and Radiation. Memorandum from J.C. Potterto the Regional Administrators. Washington, D.C. December 1,
1987.
8 U.S. EPA, New Source Review Workshop Manual (Draft): Prevention of Significant Deterioration and Nonattainment Area permitting,
October 1990.
e Office of Air Quality Planning and Standards (OAQPS), EPA Air Potlution Control Cost Manual, Sirth Edition, EpA 452-02-001
(https://www.epa.gov/economic-and-cost-analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution), Daniel C.
Mussatti & William M. Vatavu( January 2002.
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analysis is not to determine whether controls are affordable for a particular company or industry, but
whether the expenditure effectively allows the source to meet pre-established presumptive norms.
3.1.5 Step 5 - Select RACT
In the final step the lowest emission limitation is proposed as RACT along with any necessary control
technologies or measures needed to achieve the cited emission limit. This proposal is made based on the
evaluations from the previous step.
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4. KILN SYSTEM RACT ANALY$S
The kiln system was installed at the Grantsville Facility in 1960 and currently has a production rate limit of
100,000 tpy on a rolling 12-month basis (Condition II.B.3.d of Title V Operating Permit #4500005004). The
kiln system consists of pre-kiln limestone handling, a preheater, a rotary kiln, and a lime cooler. Either
natural gas, fuel oil, used oil, or tire derived fuel (TDF) can be used as fuel for the kiln system.
During pre-kiln limestone handling, limestone is conveyed from a kiln-feed stockpile through a series of
conveyors to a stone bin, which is located on top of the kiln preheater. Stone is gravity fed from the bin
through four discharge chutes which position the rock above and in front of four hydraulic rams in the
preheater. The rams are used to push the limestone into the rotary kiln.
In the kiln preheater the limestone is heated by hot gases that flow countercurrent to the flow of the
limestone. In the kiln, the limestone is heated to high temperatures in order to convert it to quicklime. From
the kiln the quicklime is passed through an air contact cooler where it is cooled and where kiln combustion
air is preheated. The quicklime produced in the kiln is either sold to customers directly from the kiln as
pebble lime, sized to customer specifications, or processed in the pressure hydrator.
The kiln system has the potential to emit NOx and VOCs (among other pollutants). The potential and actual
annual emissions from the system are presented in Table 2-1 and 2-2, respectively.
4.L Kiln NOx RACT
NOx emissions from the lime kiln result from the oxidation of molecular nitrogen present in the air (thermal
NOx) and the oxidation of nitrogen compounds in the fuel or feed materials (fuel/feed NOx). The calcination
of calcium carbonate is a highly endothermic reaction and requires a significant amount of heat input to
produce lime. The high temperatures required for the calcination reactions result in thermal NOx being the
dominant mechanism for NOx formation in lime kilns. The calcination process, recirculating load, and
temperature variations are normal and can produce significant variations in NOx emissions over short
averaging time periods.
Additional factors that may affect NOx formation and emis$ons are changes in feed rate, feed and fuel
chemical compositions, and moisture content of raw materials. This means that NOx emissions differ
significantly between kilns and make the comparison of specific emission limits, especially those based on
short-term stack tests, difficult.
4.L.L Kiln NOx Step I
In order to identiff control technologies available for lime kilns Lhoist reviewed the RBLC database and
recent permit applications. Additionally, Lhoist reviewed a variety of BACT/RACT databases maintained by
various other air quality districts and found no fufther information.l0
Available control technologies for kilns include the following:
10 Database accessed October 20,2023.
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4.L.2 Kiln NOx Step 2
LNB
The main principle of the LNB systems is stepwise or staged combustion and localized flue gas recirculation.
These systems are designed to reduce flame turbulence, delay fuel/air mixing, and establish fuel-rich zones
for initial combustion. The longer, less intense flame resulting from the staged combustion lowers the flame
temperature and reduces thermal NOx formation. Manufacturer's each have their own proprietary LNB
design, one such design is the bluff body which allows for flame out and reignition regions.ll All LNB
systems require precise control of fuel/air mixture to lower the flame temperature while maintaining efficient
burner operation. The lower flame temperature may cause carry-over of unburned carbon into the limestone
which could have adverse effects on product quality.
A search of EPA's RBLC clearinghouse showed that LNBs have been used in conjunction with lime kilns.12
The use of a LNB has been demonstrated to result in an emission rate between 2.61 and 3.8 lb/ton of lime.
However, the implementation of this technology is not seen until 2004 as indicated by a detailed RBLC
search.13
The kiln was initially constructed in 1960, at the time of design LNB were not typically implemented. Given
the precise control of flame turbulence, delay fuel/air mixing, and designated fuel-rich zones the Grantsville
kiln would require a complete re-design to accommodate LNB. Fufthermore, Lhoist Grantville's kiln system is
equipped to burn natural gas, fuel oil, used oil, and tires. A detailed review of the literature and RBLC
indicate that LNBs typically use only one type of fuel and are designed to limit NOx from that specific fuel.
Optimization of an LNB would require that either the kiln burner use one type of fuel or the installation of an
adjustable system that could change the fuel handling system depending on which fuel is supplied to the
burner.
Historically, Lhoist has utilized the bluff body LNB design as this design was deemed the most compatible
with the kiln specifications utilized at Lhoist. When this LNB design was installed at another of Lhoist's
facilities the burner wore out in approximately six months, impacted production, caused brick damage, and
resulted in unscheduled shutdowns of the kiln. Lhoist has no evidence that to suggest an alternative
design, implemented on a kiln predating the establishment of this technology, will not result in the same
technical issues.
Due to the potential for poor product quality resulting from lower temperatures of LNBs, necessary
re-design of the kiln, inability of LNB to affectively control various fuel types, and the negative effects Lhoist
experienced with previous attempts at using a LNB, this control technology is considered technically
infeasible.
scR
SCR is an add-on controldevice utilizing an ammonia injection system in conjunction with a catalyst
impregnated grid to conveft NOx into nitrogen and water via a reduction reaction on the catalyst suface.
11 Aerospace Mechanical and Mechatronic Engineering - The University of Sydney (usyd.edu.au)
12 Database accessed November 9,2023,
13 RBLC Search conducted for process code 90.019 back to 1971 and the first mention of LNB is for RBLC ID MI-0383, the permit
issuance date is 1/30/2004.
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SCR systems have been effectively used to control NOx emissions from power plants and other sources and
can achieve very high removal efficiencies, particularly on steady-state systems.
However, SCR systems must operate in a specific temperature range [typically 480 degrees Fahrenheit (oF)
to 800"F] to effectively remove NOx.1a If the temperature is too low, the reduction reaction will not proceed
to completion resulting in higher NOx emissions and the escape of NH: (i.e., ammonia slip). If the
temperature is too high, ammonia can be oxidized to nitrogen oxide (NO) resulting in higher NOx emissions.
The stack temperature of the lime kiln is in the range of 345oF which is too low for effective SCR operation.
Furthermore, the kiln has the potential to emit 24.78 lblhr of PMro during normal operation, this emission
rate has the potential to foul the catalyst with clogged pores, shortening the catalyst lifespan and further
reducing the control potential of the technology.
For this technology to be used, it would necessitate the installation of a secondary PM control device in
addition to a heat exchange system to raise the exhaust stream temperature to the required range of
operation for a SCR system. Installation of a secondary PM control device and heat exchange system would
greatly increase the cost and reduce the emission reduction potential of an SCR system.
An RBLC search for lime kilns indicates that no SCR systems have been installed to control NOx emissions.ls
In addition, Prevention of Significant Deterioration (PSD) permitting decisions have determined that SCR is
technically infeasible for a lime kiln16. For these reasons, Lhoist Grantsville considers the installation of a
SCR system for NOx controls to be technically infeasible.
SNCR
SNCR is based on the chemical reduction of the NOx molecule into nitrogen and water with the help of a
reducing agent such as ammonia or urea. At temperatures between 1600 and 2100oF the NOx reduction
reaction is favored over other chemical reactions and SNCR can achieve 30-50 percent control efficiency of
NOx.17 Due to the lack of a catalyst, SNCR systems have the potential to inject the reducing agent directly
into the rotating section of the kiln and have the reactions occur along with those necessary for product
production. Lhoist has determined that SNCR is technically feasible.
Good Combustion Practices
The use of good combustion practices includes the following components: (1) proper fuel mixing in the
combustion zone; (2) high temperatures and low oxygen levels in the primary zone; (3) overall excess
oxygen levels high enough to complete combustion while maximizing burner efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through burner design
as it relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen
levels. This technology is considered technically feasible.
4.L.3 Kiln NOx Steps 3-5
Lhoist Grantsville proposes MCT to be the use of an SNCR and good combustion practices. As discussed in
Section L,2,4, the Grantsville Facility is currently in temporary care and maintenance mode. Resumption of
operations of the facility depends upon market conditions such that a ceftain restart date cannot be
14 EPA Air Pollution Control Technology Fact Sheet SCR
15 Database accessed November 9,2023.
16 PSD Review of Weyerhauser - Flint River Operations Located in Macon County, Georgia. Preliminary Determination, State of
Georgia DNR. March 2003. Project Summary for an Application for a Construction Permi(PSD Approval from Mississippi Lime
Company for a Lime Manufacturing Plant in Prairie Du Rocher, Illinois. Illinois EPA. 2010.
17 EPA Air Pollution Control Technology Fact Sheet, SNCR
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estimated at this time. In accordance with the State Implementation Plan for PMz.s nonattainment, Lhoist
will install SNCR and implement good combustion practices upon start-up of the kiln system and NOx
emissions will not exceed 56 pounds per hour (lb/hr) on a 3-hour rolling average.18
4.2 Kiln VOC RACT
4.2.t Kiln VOC Step 1
The kiln system consists of pre-kiln limestone handling, a preheater, a rotary kiln, and a lime cooler. In the
kiln preheater the limestone is heated by hot gases that flow countercurrent to the flow of the limestone. In
the kiln, the limestone is heated to high temperatures (in excess of 1,500oF) whereby it is convefted to
quicklime. From the kiln the quicklime is passed through an air contact cooler where the quicklime is cooled
and where kiln combustion air is preheated.
In order to identify control technologies available for lime kilns Lhoist reviewed the RBLC database and
recent permit applications. Additionally, Lhoist reviewed a variety of BACT/MCT databases maintained by
various other air quality districts and found no fufther information.
While the RBLC indicates only good combustion practices for the control of VOC, Lhoist has considered the
following technologies in order to ensure a complete review is conducted:
> Oxidizers
> Good Combustion Practices
4.2.2 Kiln VOC Step 2
Oxidizers
Thermal oxidation, regenerative thermal oxidation, and catalytic oxidation all destroy VOC'S by raising the
temperature of the material above its auto-ignition point in the presence of oxygen, and maintaining it at
high temperature for sufficient time to complete combustion to carbon dioxide and water.le However, due
to the high operating temperatures of a lime kiln (in excess of 1,500oF), this process already occurs within
the combustion chamber of the kiln. Therefore, there would be little expected reduction in VOC. Therefore,
oxidizers are not considered further.
Good Combustion Practices
The use of good combustion practices usually includes the following components: (1) proper fuel mixing in
the combustion zone; (2) high temperatures and low oxygen levels in primary zone; (3) overall excess
oxygen levels high enough to complete combustion while maximizing burner efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through burner design
as it relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen
levels. This technology is technically feasible.
18 PMz.s State Implementation Plan, November 20,2Ot9
1e Thermal Incinerator, Air Pollution Control Technology Fact Sheet, EPA452|F-03-022
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4.2.3 Kiln VOC Steps 3-5
Lhoist utilizes good combustion practices during kiln operation to reduce VOC emissions which are, currently
estimated at 0.06 lb/ton (or 3.00 tpy). As this is the only technically feasible controltechnology Lhoist
proposes that the current emission rate meets MCT.
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5. PRESSURE HYDRATOR BAGHOUSE HEATER RACT ANALY$S
The pressure hydrator at the Grantsville Facility is used to conveft quicklime into hydrated lime (i.e., calcium
hydroxide). Once the pressure hydrator reaches the operating temperature range, the outlet valve opens to
allow the hydrated quicklime to blow out into a collector where it is separated from the superheated steam.
The steam is vented from the top of the collector into a heated baghouse. No direct NOx and VOC emissions
come from the pressure hydrator.
The baghouse is heated by a seven (7) million British thermal units per hour (MMBtu/hr) natural gas-fired
burner. The burner is used on an as-needed basis to maintain the temperature of the flue gas above the
dew point of water to keep the steam from condensing on the bags. The baghouse process heater has the
potentialto emit NOx and VOC emissions (among other pollutants). The potential and actual annual
emissions from the pressure hydrator baghouse heater are presented in Table 2-1 and 2-2, respectively.
5.1 Pressure Hydrator Baghouse Heater NOx RACT
The NOx that is formed during combustion is from two major mechanisms: thermal NOx and fuel NOx. Since
natural gas is relatively free of fuel-bound nitrogen, the contribution of this second mechanism to the
formation of NOx emissions in natural gas-fired equipment is minimal, leaving thermal NOx as the main
source of NOx emissions. Thermal NOx formation is a function of residence time, oxygen level, and flame
temperature, and can be minimized by controlling these elements in the design of the combustion
equipment.
5.1.1 Natural Gas Burner NOx Step 1
In order to identify control technologies applied to natural gas burners the following sources were reviewed:
> SCAQMD Example Permits;
> TCEQ's BACT Combustion Workbook; and
Available control technologies for natural gas burners include the following:
> scR
> Good combustion practices
The control efficiencies, as well as technical and economic feasibility are compared to the closest available
presumptive norm for naturalgas burners as established in UDAQ rule R307-3L6 NOxEmission Controls for
Natural-Gas Fird Boilers greater than 5 MMBtu/hn However, the pressure hydrator baghouse heater is not
a boiler and is not subject to rule R307-316. The standards included in R307-316 are as follows:
20 Database accessed November 9,2023.
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> Operation and maintenance (O&M) in accordance with manufacturer's emissions related instructions.2l
5.1.2 Natural Gas Burner NOx Step 2
To demonstrate a complete analysis, Lhoist has evaluated the following technologies including both
replacement burners and add-on controls.
LNB/ULNB
LNB/ULNB technology uses advanced burner design to reduce NOx formation through the restriction of
oxygen, flame temperature, and/or residence time. There are two (2) general types of LNB: staged fuel and
staged air burners. In a staged fuel LNB/ULNB, the combustion zone is separated into two regions. The first
region is a lean combustion region where a fraction of the fuel is supplied with the total quantity of
combustion air. Combustion in this zone takes place at substantially lower temperatures than a standard
burner. In the second combustion region, the remaining fuel is injected and combusted with leftover oxygen
from the first region. A staged air burner begins with full fuel but only partial combustion air, and then adds
the remaining combustion air in the second combustion region.
Given the age of the unit, approximately 60 years, the original combustion chamber was not designed to
accommodate LNB or ULNB, as this technology is first listed in the RBLC between 2013 and 20L4.22 Removal
and replacement of the combustion chamber may cause additional technical issues such as limited space
availability (as LNB burners are typically larger than traditional burners installed pre-1990), platform
modifications, and modification of fuel supply, instrumentation, and valves. Furthermore, due to the age of
the unit the insulation used may contain asbestos, fufther increasing the difficulty of working with the unit.23
Therefore, due to the age of the burner and the need to re-design the combustion chamber, LNB is likely
technically infeasible. However, an economic feasibilty analysis has been included for completeness.
Additionally, ULNB often requires additional fan capacity to accommodate the internal flue gas recirculation
incorporated within the design. The process heater is located within the pressure hydrator building. It is
unlikely the additional equipment and ductwork required would fit within the current building footprint, as
seen in Figure 5-1.
21 R307-316 does not require the retrofit of existing units to meet the established standards.
22 RBLC Search conducted back to 1971 for process code 13.31 first listed ULNB/LNB in 2013 or 2OL4 with RBLC IDs TX0656 and
MI0410.
23The Ins and Outs of Low NOx Burner Retrofits (power-eng.com)
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 5-2
-Figure 5-1. Location of Pressure Hydrator Baghouse Heater
Due to the age of the burner and the need to re-design the combustion chamber, along with insufficient
space requirements ULNB is considered technically infeasible.
FGR
FGR is frequently used with both LNB and ULNB burners, however it can also be utilized as a standalone
technology outside of the combustion chamber. FGR involves the rerycling of post-combustion air into the
air-fuel mixture to reduce the available oxygen and help cool the burner flame.
Implementation of external FGR requires several physical modifications including tapping the exhaust duct
to draw flue gas and recirculate it back to the fan. Additionally minor modifications will also be needed for
damper controls.2a These physical modifications for the exhaust duct are often made to the outside of the
unit to eliminate fufther modifications to the combustion chamber. The inclusion of additional duct work
and associated fans all requires enough space for the additional equipment as well as sufficient space
around the equipment to ensure proper maintenance.
The process hydrator baghouse heater is located inside a building, as noted above, surrounded by other
equipment, The physical location of the heater does not allow for the additional duct work required to tap
into the exhaust stream and redirect it back to the combustion chamber, thus FGR is technically infeasible.
scR
SCR has been applied to stationary sources, fossil fuel-fired, combustion units for emission control since the
early 1970s. It has been applied to large (>250 MMBtu/hr) utility and industrial boilers, process heaters, and
combined cycle gas turbines. SCR can be applied as a stand-alone NOx control or with other technologies
such as combustion controls. The reagent reacts selectively with the flue gas NOx within a specific
temperature range and in the presence of the catalyst and oxygen to reduce the NOx into nitrogen and
24 NOx Control on a Budoet: Induced Flue Gas Recirculation (power-enq.com)
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 5-3
water.2s The optimum operating temperature is dependent on the type of catalyst and the flue gas
composition. Generally, the optimum temperature ranges from 480oF to 800oF. In practice, SCR systems
operate at efficiencies in the range of 70 to 90 percent.26
The control effectiveness of SCR for a unit less than 250 MMBtu/hr is highly dependent on the configuration
of all controls involved.
A search of EPA's RBLC showed that no burners less than or equal to 13 MMBtu/hr have installed SCRs as
control equipment, therefore SCR is not considered technically feasible as it is not commercially available.2T
Good Combustion Practices
The use of good combustion practices includes the following components: (1) proper fuel mixing in the
combustion zone; (2) high temperatures and low oxygen levels in primary zone; (3) overall excess oxygen
levels high enough to complete combustion while maximizing boiler efficiency, and (4) sufficient residence
time to complete combustion. Good combustion practices are accomplished through burner design as it
relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen levels.
This control technology is technically feasible.
5.1.3 Natural Gas Burner NOx Step 3
The technically feasible control technologies evaluated above are ranked based on which technology can
achieve the lowest emission rate.
1. LNB = 30 ppm or 0.036 lb/MMBtu
2. Good Combustion Practices
5.1.4 Natural Gas Burner NOx Step 4
Lhoist conducted a cost analysis for a LNB following the method described in EPA Cost Control Manual
Chapter 2, Concepts and Methodology. Key to this analysis is the NOx emission rate reductions and interest
rate. For this analysis Lhoist has used a reduction rate of 50 percent from EPA Alternative Control
Technology Guidelines. 28
Since the actual nominal interest rate for a project of this type is not readily available to Lhoist, additional
resources were reviewed to determine appropriate nominal interest rates for this industry sector and project
type. One such resource was the Office of Management and Budget (OMB). For economic evaluations of the
impact of federal regulations, the OMB uses an interest rate of 7o/o.2e A nominal interest rate of 7o/o has
been referenced in EPA's Cost Manual and has been commonly relied upon for control technology analyses
for several decades as a representative average over time.
Using a manufacture supplied total equipment cost and 7o/o interest rate, it would cost $73,335/ton of NOx
removed. Calculations are shown in Appendix A and are based on EPA Cost Control Manual Section 1,
Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4.
2s EPA Air Pollution Control Technology Fact Sheet, SCR
26 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPAl424lB-02-001 (https://www.epa.9ov/economic-and-cost-analysis-
air-pollution-regulations/cost-reports-and-guidance-air-pollution)); January 2002
28 EPA Technical Bulletin, Nitrogen Oxides (NOx) Why and How They Are Controlled, Table 16. Unit Cost for NOx Control Technologies
for Non Utility Stationary Sources, Source Type - Process Heaters - Natural Gas - LNB
2e OMB Circular A-4, https://obamawhitehouse.archives.gov/omb/circulars_a 004-a-41
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 5-4
The cost per ton of NOx removed is beyond acceptable cost control effectiveness levels and therefore Lhoist
considers this burner technology economically infeasible for the process hydrator baghouse heater.
5.1.5 Natural Gas Burner NOx Step 5
Lhoist has installed units which met the most stringent emission standards possible at the time of
installation. Additionally, the retrofit of technologies reviewed have been established as technically or
economically infeasible. As a result, Lhoist proposes the implementation of good combustion practices as
RACT.
Additionally, NOx emissions will be limited by: (a) the baghouse burner only being used when necessary to
maintain the temperature of the flue gas above the dew point; and (b) Condition II.B.4.c of Title V
Operating Permit #4500005004, which limits the production of hydrate in the Pressure Hydrator to 126,000
tons/year (rolling 12-month total).
5.2 Pressure Hydrator Baghouse Heater VOC RACT
5.2.L Natural Gas Burner VOC Step 1
In order to identify control technologies applied to natural gas burners the following sources were reviewed:
> TCEQ's BACT Combustion Workbook; and
Available control technologies for natural gas burners include the following:
> Good combustion practices
5.2.2 Natural Gas Burner VOC Step 2
Oxidizers
The search of EPA's RBLC showed that no burners less than or equal to 7 MMBtu/hr have installed oxidizers
(thermaloxidizer/afterburner, RTO, catalytic oxidation) as control equipment. As such, Lhoist considers
oxidizers as technically infeasible for the pressure hydrator baghouse heater.
Good Combustion Practices
The use of good combustion practices usually includes the following components: (1) proper fuel mixing in
the combustion zone; (2) high temperatures and low oxygen levels in primary zone; (3) overall excess
oxygen levels high enough to complete combustion while maximizing burner efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through burner design
30 Database accessed November 9,2023.
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 5-5
as it relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen
levels. This technology is technically feasible.
5.2.3 Natural Gas Burner VOC Steps 3-5
Good combustion practices is the only control technology listed for pressure hydrator baghouse heater and
has no specified control efficiency. As such, good combustion practices are determined to be RACT for
Lhoist's pressure hydrator baghouse heater.
Additionally, VOC emissions are limited by: (a) the baghouse burner only being used when necessary to
maintain the temperature of the flue gas above the dew point; and (b) Condition II.B.4.c of Tltle V
Operating Permit #4500005004, which limits the production of hydrate in the pressure hydrator to 126,000
tons/year (rolling 1 2-month total).
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 5-6
6. KIIN SHAFT MOTOR
The kiln shaft motor is gasoline fired and rated at 100 horsepower. It is an auxiliary unit used for backup
power for the rotary kiln system during outages as well as to maintain an appropriate rotation rate during
start-up and shutdown. It does not typically run for more than 100 hours per year. The potential and actual
annual emissions from the kiln shaft motor are presented in Table 2-1 and 2-2, respectively.
This unit has reached the end of its useful life and therefore Lhoist is proposing to replace this unit with a
diesel unit of equivalent power prior to resuming operation. Since the new kiln shaft motor will need to be
permitted and undergo a BACT analysis prior to resuming operations, Lhoist is proposing that RACT is
replacing the existing motor with a new motor that meets BACT at the time of permitting.
Lhoist / Ozone Nonattainment SIP - RACT Analysis
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7. TANKS
7.L Tanks VOC RACT
Emissions from fixed roof storage tanks result from displacement of headspace vapor during filling
operations (working losses) and from diurnal temperature and heating variations (breathing losses).31 Lhoist
maintains several storage tanks as listed below for kiln operation, which are currently empty or almost
empty.
> One (1) fuel oil tank with a capacity of 42,000 gallons,
> One (1) fuel oil tank with a capacity of 9,000 gallons
> One (1) diesel tank with a capacity of 10,000 gallons, and
In addition, Lhoist has the following tanks that fuel mobile equipment and auxiliary sources. These tanks are
in use, but typically have approximately one turnover per year.
> Two (2) small petroleum tanks with capacities of 1,000 gallons or less.
The potential and actual annual emissions from the Tanks are presented in Table 2-1 and 2-2, respectively.
7.L.L Storage Tanks Step 1
In order to identifo control technologies applied to storage tanks the following sources were reviewed:
> TCEQT BACT Combustion Workbook;
Vessels (Including Petroleum Liquid Storage Vessels).
On October 4,2023, EPA proposed NSPS Subpart Kc for storage tanks between 20,000 and 40,000 gallons
which store liquids with a maximum true vapor pressure greater than or equal to 1.5 psia as well as storage
tanks with capacity greater than or equal to 40,000 gallons which store liquids with a maximum true vapor
pressure greater than or equal to 0.5 psia. This subpart establishes new requirements which broaden the
definition of modification for storage tanks, introduce more stringent emission control requirements for
ceftain tanks, require annual Lower Explosive Limit (LEL) monitoring within Internal Floating Roof (IFR)
tanks, require control of degassing events, and make several other technical and administrative changes.33
While no new requirements would be instituted for the tanks at the Grantsville Plant, as they are not being
modified or reconstructed, the controls required by this regulation set a presumptive norm.
Specifically, Subpart Kc is proposing that fixed roof tanks which store liquids with a maximum true vapor
pressure less than 11.1 psia are not required to install a closed vent system or associated controldevice.
Lhoist's storage tanks are either below 20,000 gallons capacity or greater than 40,000 gallons capacity with
3r EPA, Emission Factor Documentation for AP-42 Section 7.1 Organic Liquid Storage Tanks, September 2006.
32 Database accessed November I0,2023.
33 Federal Register/ Vol. 88, No. 191/Wednesday, October 4, Z1l3lproposed Rules
Lhoist / Ozone Nonattainment SIP - RACT Analysis
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a true vapor pressure less than 0.5 psia.3a Thus Lhoist proposes that the implementation of a closed vent
system and/or associated control device goes beyond RACT requirements and is not further evaluated.
Evaluated control technologies for storage tank include the following:3s
7.1.2 Storage Tanks Steps 2-4
Good Ooeratino and Maintenance Practices
As demonstrated by the emission calculations, losses due to changes in temperature or barometric pressure
are minimal for these tank. The plant is not currently operating and as such, most of the tanks are empty
or almost empty.The only tanks that have material in them store fuel and the throughput in these tanks is
low which minimizes the frequency of filling, and the associated emissions. Lhoist uses good operating and
maintenance on all tank.
Submeroed Fillino
During submerged loading, the fill pipe opening is below the liquid sufface level and liquid turbulence is
controlled significantly, resulting in much lower vapor generation than encountered during splash loading.36
Due to the very low emission rate it has been assumed that the retrofit of this technology will be
economically infeasible.
7.1.3 Storage Tanks Step 5
Lhoist proposes that good operating and maintenance practices meets MCT.
3a Tank ESP gives an average true vapor pressure of 0.00136 psia
3s Use of ultra-low sulfur fuel was evaluated and found that it does not affect NOx or VOC emissions.
36 EPA AP<2 Section 5.2 Transportation and Marketing of Petroleum Liquids
Lhoist / Ozone Nonattainment SIP - RACT Analysis
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8. CHEMICAL ADDITIVES
8.1 Chemical Additives VOC RACT
Minimal amounts of fugitive VOC emissions (2.51 tpy) result from chemical additives. VOC emissions from
chemical additives result from mixing operations.
The potential and actual annual emissions from chemical additives are presented in Table 2-L and 2-2,
respectively.
8.1.1 Chemical Additives Step 1
In order to identify control technologies applied to chemical additives the following sources were reviewed:
Available control technologies for chemical additives include the following:38
> Good Operating and Maintenance Practices
8.1.2 Chemical Additives Step 2
Oxidizers
The search of EPA's RBLC showed that no chemical additive processes of simihr size have installed oxidizers
(thermal oxidizer/afterburner, RTO, catalytic oxidation) as control equipment. As such, Lhoist considers
oxidizers as technically infeasible for the chemical additive processes at the Grantsville Facility.
Good Ooeratino and Maintenance Practices
The chemical additives used at the Grantsville Facility are specifically designed for the function they serve
and the VOC compounds are often critical to the functionality of the solution. Therefore, reducing the VOC
content of a solution is technically infeasible. Lhoist will continue to evaluate other potential solutions and
purchase low VOC solutions, when possible.
8.1.3 Chemical Additives Steps 3-5
Lhoist proposes that good operating and maintenance practices meets RACT.
37 Database accessed November 75,2023.
38 Use of ultra-low sulfur fuel was evaluated and found that it does not affect NOx or VOC emissions.
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 8-1
9. DRILLING AND BLASTING
9.1 Blasting NOx and VOCs RACT Steps 1-5
Blasting operations incorporate combustion of compounds containing ammonium nitrate in order to
pulverize material in the mining area. Blasting operations will produce fugitive NOx and VOC emissions. The
potential and actual annual emissions from drilling and blasting are presented in Table 2-L and 2-2,
respectively. The only methodology that can be used to mitigate the emissions associated with blasting is
minimizing the amount of blasting agent (ANFO) used in the detonation process. Lhoist utilizes experienced
blasting professionals to ensure blasting is conducted as efficiently as possible. Since there are no other
known control methods for this process, reduction in the use of ANFO is considered MCT.
Lhoist / Ozone Nonattainment SIP - RACT Analysis
Trinity Consultants 9-1
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