Holcim US Inc'

1
Holcim (US) Inc.

• Lee Island Project
• Ste. Genevieve, MO
• Air Permit
• Derek Honaas

2
Permit Application Process

• Majority of Environmental Permits
• Application (downloadable)
• Filing fee
• Supporting documentation
• Review Process

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Applications

• Available at www.dnr.mo.gov/oac/forms/index.html
• Requirements and procedures vary depending on the
  type of activity
• Permit application supplement
• DNR program checklist
• Environmental checklist

4
Filing Fees

• Amount varies with type of permit
• 100 - 1000

5
Supporting Documentation

• Engineering reports
• Plans or specifications
• Prepared by a registered professional engineer
• Geologic evaluations
• Reclamation plans

6
Review Process

• Reviewed by department staff
• Complex permits may require review by more than
  one program within a department
• If additional information is required
• Permit review suspended
• Public review and/or public hearing
• Public reviews range from 30-90 days

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Holcim (US) Inc.

• Draft/Construction Permit
• In compliance with DNR Air Pollution Control
  Program

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Special Conditions

• General requirements
• Availability of permit
• Approval of new installments
• Standards of performance for BACT
• Best Available Control Technology
• Standards of performance for ICT
• Innovative Control Technology

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Special Conditions cont...

• Conditions resulting from Ambient Air Quality
  Analysis
• Emission and operation limitations
• Emission standards for May 1st thru September
  30th
• 1,622 tons NOx during summer

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Special Conditions cont

• Conditions resulting from National Emission
  Standards for Hazardous Air Pollutants from the
  Portland Cement Manufacturing Industry PCMACT
• Emission limitations
• Operation requirements

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Special Conditions cont

• Performance Testing for New Source Performance
  Standards Subpart OOO
• Permitee shall submit a testing plan for all
  equipment subject to requirements

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Review Summary

• Holcim states
• What regulations dont apply
• What they will do regarding the regulations that
  do apply

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Technical Specifications

• Description of installation
• Illusive Emission Summary of Proposed Operation

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BACT Review

• Discusses the process of decision-making
• Identify all possibilities
• Eliminate technically infeasible options
• So on and so forth

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Applicable Requirements

• Not in Special Conditions
• Own legal authority
• Federal and/or State regulations
• New Source Performance Standards
• Start-up, Shutdown, and Malfunction Conditions
• Submission of Emission Data

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AAQIA

• Ambient Air Quality Impact Analysis
• If air contaminant emission rates exceed the De
  Minimus Level, an AAQIA is required

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Appendices

• Documentation required for this permit
• Map
• Table of location ID numbers
• Table of State rule applicability
• Extensive list of acronyms that run a muck in
  this document

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Holcim (US) Inc.

• Health and Air Quality Effects of Cement Plant
  Pollutants

Nathan McNurlen
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Cement Kiln Dust (CKD)

• Result of portland cement clinker production
• Composed of calcium compounds
• Tricalcium silicate
• Dicalcium silicate
• Tricalcium aluminate
• Tetracalcium aluminoferrite
• Exposure through inhalation, ingestion, dermal
  contact, and mucous membranes

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CKD Health Effects

• CKD becomes caustic (pH gt11) when introduced to
  moisture.
• Potential for third degree burns
• Eye Contact
• Irritation
• Inflammation of the cornea
• Chemical burning
• Blindness
• Ingestion
• General internal discomfort and ill effects from
  consumption of large quantities

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CKD Health Effects (cont.)

• Skin Contact
• Drying of the skin
• Mild irritation
• Allergic response
• Ranging from mild rash to severe skin ulcers
• Thickening, cracking, fissuring of the skin
• Chemical burns
• Inhalation
• Aggravation of pre-existing lung diseases
• Irritation of nose, throat, and upper respiratory
  system
• silicosis

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Mercury in the Atmosphere

• 3 forms of mercury elemental, inorganic, and
  organic
• Elemental
• 95-99 of mercury in the atmosphere
• Can be inhaled or passed through the skin
• Inorganic
• Low exposure potential due to product banning
• Can be inhaled or passed through the skin or
  stomach
• Organic
• Primarily in the form of methyl mercury
• Enters through all 3 routes lungs, skin, and
  stomach

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Mercury Health Effects

• Elemental
• Acute effects include damage to kidneys, CNS,
  gastrointestinal system, and respiratory systems
• Behavioral effects such as irritability,
  excessive shyness, insomnia, excessive
  salivation, tremors, increased excitability, and
  gingivitis
• Organic
• Acute exposure is rare but can result in severe
  CNS effects
• Chronic exposure usually results in damage to the
  CNS

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Nitrogen Oxides (NOX)

• Generic term for a group of highly reactive gases
• Occur when fuel is burned at high temperatures
• Sources include power plants, automobiles, and
  processes used by industrial and chemical plants
• Primary nitrogen oxides of concern are nitrogen
  dioxide (NO2) Nitric Oxide (NO)

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NOX Byproducts Their Health Effects

• Ground Level Ozone (Smog)
• Formed by NOx VOCs when reacted in sunlight
• Can easily be transported long distances by wind
• Causes damage to lung tissue and reduction in
  lung function
• Acid Rain
• Formed when NOx and SO2 combine with other
  substances in the air to form acids
• Can also travel long distances by wind
• No major human health effects

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Acid Rain Formation
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Nitrogen Dioxide (NO2)

• Main ingredient in ground level ozone
• Contributes to acid rain formation
• Reacts to form other toxic chemicals
• Contributes to global warming
• Causes formation of atmospheric particles

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Sulfur Oxides (SOx)

• 95 of pollution related sulfur oxides are in the
  form of sulfur dioxide (SO2)
• SO2 can combine with water vapor to form
  sulfurous acid (H2SO3)
• H2SO3 can then combine with oxygen to form
  sulfuric acid (H2SO4)
• Sources include those processes which burn sulfur
  containing fuels (coal and oil) and natural
  sources

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SOx Health Effects

• Most health effects attributed to exposure to
  sulfur dioxide
• High concentrations can increase mucous flow and
  constrict bronchi
• Irritation to lungs and throat
• Enhances harmful effects of ozone
• Can combine with other substances in atmosphere
  to form sulfate aerosols (fine particulate matter

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Ozone

• Hydrocarbons NOx Sunlight Ozone
• Highly reactive gas in the form of O3
• Primary component in smog
• Not to be confuse with good ozone
• Powerful respiratory irritant

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St. Louis Ozone

• In 1995, five counties near St. Louis were
  designated as ozone nonattainment areas
• Nonattainment areas are those which do not meet
  one or more on the National Ambient Air Quality
  Standards for criteria pollutants designated by
  the Clean Air Act, or that do not attain the
  federal air quality standard for one or more
  pollutants as determined by the EPA.

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St. Louis Ozone (Cont.)

• During summer of 2002, St. Louis met federal
  standards for ozone.
• In May the following year, they asked for and
  were granted a status of ozone attainment area.
• With increases in emissions of ozone forming
  pollutants such as NOx, there is worry that St.
  Louis could be reclassified as a ozone
  nonattainment area again.

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St. Louis Ozone (cont.)

• Reasons for concern
• NOx and pollutants formed from it can be
  transported over long distances
• Prevailing winds blow southwest to northeast

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Sources

• Roanoke Cement MSDS or CKD
• EPA Air Toxics Website http//www.epa.gov/ttn/atw/
  hlthef/mercury.html
• Oklahoma State University Environmental Health
  and Safety http//www.pp.okstate.edu/ehs/training/
  mercury.htm
• WI DNR Oxides of Nitrogen http//www.dnr.state.w
  i.us/org/aw/air/HEALTH/oxides.htm
• ASTDR Nitrogen Oxides Sulfur Dioxide
  www.envirotools.org/factsheets/contaminants/nitrog
  enoxides.shtml
• Pollution Prevention and Abatement Handbook
  Sulfur Oxides
• MO DNR Ozone http//www.dnr.state.mo.us/oac/faq-
  answers.htm
• MO DNR Air Pollution Control Program
  http//www.dnr.mo.gov/env/pnmr04_01.htm