RECEIVED

CLERK'S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

MAR 2 ? 2006

STATE OF ILLINOIS

IN THE MATTER OF

:

)

Pollution

Control Board

PETITION OF LAFARGE MIDWEST, INC

.

)

FOR BOILER DETERMINATION THROUGH)

2

ADJUSTED STANDARD PROCEEDINGS

)

Case No. AS

6

_-,

Pursuant to 35 111. Adm. Code 720.132 and

)

720.133

)

Petitioner .

)

NOTICE OF FILING

TO :

Illinois Pollution Control Board

Division of Legal Counsel

Attn: Dorothy M. Gunn, Clerk

Illinois Env. Protection Agency

100 West Randolph St., Suite 11-500

1021 North Grand Avenue East

Chicago, IL 60601-3218

P.O. Box 19276

Springfield, IL 62794-9276

PLEASE TAKE NOTICE that on this 28t

h

day of March 2006, a copy of the attached

Petition of Lafarge Midwest, Inc. for Boiler Determination Through Adjusted Standard

Proceedings

was filed with the Office of the Clerk of the Illinois Pollution Control Board, a copy

of which is herewith served on you

.

Respectfully Submitted,

On behalf of the LAFARGE MIDWEST, INC .,

By: Hinshaw & Culbertson LLP

Jo

Atta

~~

-

.

IIts Att .

HINSHAW & CULBERTSON LLP

456 Fulton Street, Suite 298

Peoria, IL 61602-1220

309-674-1025

This document utilized 100% recycled paper products

80212378v1 NEWFILE

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF :

)

PETITION OF LAFARGE MIDWEST, INC. )

FOR BOILER DETERMINATION )

THROUGH ADJUSTED STANDARD )

PROCEEDINGS )

Pursuant to 35 Ill. Adm. Code 720.132 and )

720.133

.

)

AS t-03

RECEIVED

CLERKS OFFICE

MAR 2 ° 2006

STATE OF ILLINOIS

Pollution Control Board

PETITION FOR BOILER DETERMINATION

THROUGH ADJUSTED STANDARD PROCEEDINGS

NOW COMES the Petitioner, LAFARGE MIDWEST, INC., by and through its

attorneys, Hinshaw & Culbertson LLP, and presents to the Illinois Pollution Control Board

(hereafter "Board"), its Petition for Boiler Determination Through Adjusted Standard

Proceedings (hereafter "Petition"), pursuant to 35 Ill. Adm. Code Sections 720.132 and 720 .133

requesting a determination that Raw Mill Dryer #1 and Raw Mill Dryer #2 operated at its Joppa

Portland Cement Manufacturing Plant be considered "boilers" as that term is defined in 35 Ill

.

Adm. Code 720.110 .

The Board's determination that each of the Raw Mill Dryers are "boilers" pursuant to the

criteria set forth in 35 Ill. Adm. Code 720.132 will allow them to be used for the combustion of

off-specification used oil for the purpose of energy recovery, in compliance with 35 Ill . Admin .

Code 739 .161 . The Board regulations at 35 Ill. Adm. Code 720.133 provide that the Board will

make such a boiler determination on a case-by-case basis utilizing the Adjusted Standard

procedures of Subpart D of 35 Ill. Adm. Code Part 104 .

In support of its Petition, the Petitioner states as follows

:

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I .

Description of Petitioner and Joppa Portland Cement Manufacturing Plant

The Joppa Portland Cement Manufacturing Plant ("Joppa Plant") is owned and operated

by Lafarge Midwest, Inc. ("Lafarge"), a subsidiary of Lafarge North America, Inc . Together

with its subsidiaries, Lafarge North America is the largest supplier of cement and a leading

ready-mixed concrete supplier in North America . The Company also is one of the top four

producers of construction aggregate (crushed stone, sand and gravel) and a leading manufacturer

of gypsum drywall . Lafarge North America has over 1,000 operations doing business in almost

every State and throughout all provinces in Canada through its Lafarge Canada, Inc . subsidiary.

Lafarge's products are used in the construction of such diverse projects as roads, offices,

factories, hospitals, department stores, sports stadiums, banks, museums, high-rise apartments,

amusement parks, swimming pools and bridges. In 2004, Lafarge North America shipped 133

million short tons of aggregate, 11 .4 million cubic yards of ready-mixed concrete, 14 .2 million

tons of cement and 2.2 billion square feet of gypsum drywall

.

The Joppa Plant is located in Massac County, Illinois adjacent to the Ohio River in

extreme southern Illinois

.

The closest community is Grand Chain, Illinois and the common

address for the Joppa Plant is 2500 Portland Road, Grand Chain, Illinois . Massac County is a

predominantly rural county, the 7th smallest in Illinois, with a county-wide population of

approximately 15,000 residents (2000 Census). The County seat and largest municipality in

Massac County is Metropolis which has a municipal population of approximately 6,500

residents. According to the Illinois Department of Commerce and Economic Opportunity, the

populations in Metropolis and Massac County have decreased slightly since the 2000 Census .

Other small communities in Massac County include Brockport (population 1,054), Joppa

(population 409) and the small, unincorporated towns of Boaz, New Colombia, Mermet, Round

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Knob, Big Bay and Unionville. In addition to the Joppa Plant, other industry in Massac County

include the Joppa Steam Electric Plant, a 1100 MW coal-fired electric power generating facility

owned and operated by Electric Energy, Inc. An aerial photograph showing the location of the

Joppa Plant and the surrounding area is attached hereto as

Exhibit A. A map depicting the

location of the Joppa Plant and the population density in the surrounding area of Massac County

is attached hereto as Exhibit B .

The Joppa Plant manufactures Portland cement which is the active ingredient of concrete.

Portland cement is a closely controlled chemical combination of calcium, silicon, aluminum, iron

and small amounts of other ingredients to which gypsum is added in the final grinding process to

regulate the setting time of the concrete . Lime and silica comprise about 85% of the mass of

Portland cement. Common among the materials used in its manufacture are limestone or marl

combined with shale, clay, slate or blast furnace slag, silica sand, and iron ore

.

Two different types of cement manufacturing processes, the "dry" and "wet" methods,

can be used to manufacture Portland cement. The Joppa Plant utilizes the dry process and its two

cement kilns are classified as conventional "long dry" kilns . In the dry cement manufacturing

process, raw materials are ground, mixed and fed to the kiln in a dry state . No water is added to

the raw materials prior to processing. In other respects, the wet and dry cement manufacturing

processes are essentially alike .

At the Joppa Plant, limestone rock is the principal raw material used in the process .

Limestone rock is quarried off-site and crushed to a size of about three inches or smaller. It is

then transported by river barge and unloaded at the Joppa Plant site

.

Together with the crushed limestone, other raw materials are added as sources of

calcium, iron, silica and alumina. The raw materials or "raw mix" is dried and ground into a fine

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mix before introduction into the rotary kilns . After introduction into the kiln, the raw material is

heated to almost 3,0000 F in cylindrical steel rotary kilns lined with special refractory fire brick .

Kilns are mounted with the axis inclined slightly from the horizontal . The finely ground raw mix

is fed into the higher end of the kiln. At the lower end are the burners which provide a blast of

heat and flame produced by precisely controlled burning of powdered coal, petroleum coke and

other supplemental fuels .

As the material moves through the kiln, certain elements are driven off in the form of

gases while the remaining ingredients undergo chemical and mineralogical changes to create a

new substance with new physical and chemical characteristics

.

The new substance, called

"clinker", is formed in pieces about the size of marbles. A small amount of gypsum is added to

the clinker and the mixture is ground to a fine powder which is the final product - Portland

cement .

Depending on the proportions of the original raw materials, the duration and intensity of

the kiln processing and the parameters set during final grinding of the clinker, different cements

are produced with distinctly different capabilities and uses

.

Each step in the manufacture of

Portland cement is checked by frequent chemical and physical tests in plant laboratories . The

finished product is also analyzed and tested to ensure that it complies with all product and ASTM

specifications

.

Lafarge's Joppa Plant manufactures several varieties of cement products and successfully

competes in the international marketplace . A critical component of the Plant's ability to compete

in the competitive international cement market is its ability to utilize cost effective, alternative

energy sources. As energy prices reach record highs, Lafarge's commitment to utilize alternative

energy sources is becoming more important to its financial viability . During 2005 Lafarge will

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utilize

approximately

20,000

tons

of tire-derived fuel in its kiln operations, offsetting

approximately the same amount of coal/coke that would have otherwise been burned in 2005

.

As of September 1, 2005 Lafarge has utilized 870,000 gallons of specification used oil that

replaced approximately 3.3 millions cubic meters of natural gas that would have been required

for it Raw Mill operations. This used oil supplemental fuel accounted for 60% of all the fuel

used by the Raw Mills in 2005, to date . Receiving Board approval in these proceedings to utilize

off-specification used oil as supplemental fuel in the Raw Mill Dryers is a significant opportunity

to further control escalating energy costs while converting a potential waste product into a

valuable fuel source

.

The U. S. Environmental Protection Agency ("USEPA") actively promotes and approves

the recycling of used oil for energy recovery and has done so since Congress passed the Used Oil

Recycling Act in 1980. USEPA's administrative regulations implement the legislative intent to

promote the recovery of thermal energy from used and waste oils (See 40 Code of Federal

Regulations Part 279) .

To implement the Illinois Legislature's directive to adopt a waste

management program consistent with the federal program and secure USEPA approval thereof,

the Board has adopted "identical-in-substance" regulations designed to encourage used oil

recycling and burning of used oil for energy recovery

.

Utilization of off-specification used oil fuel in the Raw Mill Dryers at the Joppa Plant is

not expected to change the current air emissions from the facility as compared to the combustion

of on-specification used oil fuel that currently is allowed under the existing Construction Permits

and the federally-enforceable Clean Air Act Permit Program ("CAAPP") Operating Permit

issued for the Joppa Plant. Use of used oil fuel would be subject to approval by the IEPA

through issuance of a new Construction Permit and modification of the Joppa Plant's Title V

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CAAPP Operating Permit. The review and approval processes employed by IEPA's Bureau of

Air, Permits Section officials will provide the opportunity to resolve any questions related to air

emissions from combustion of off-specification used oil as supplemental fuel in the Raw Mill

Dryers .

II .

Petition Content Requirements of 35111 . Adm. Code 104.406

Set forth below is the information specified by 35 Ill . Adm. Code 104.406 to be included

in a Petition for Adjusted Standard. Since 35 Ill. Adm. Code Sections 720.132 and 720.133

mandate the use of the Board's Adjusted Standard procedures (Subpart D of 35 Ill . Adm. Code

Part 104), for determining whether a particular enclosed flame combustion device is a "boiler,"

this Petition addresses the requirements of Subpart D and includes the information specified in

Section 104.406. The information is organized under headings corresponding to the

informational requirements of each subsection of Section 104 .406, in compliance with that

regulation .

a)

A statement describing the standard from which an adjusted standard is sought.

This must include the Illinois Administrative Code citation to the regulation of

general applicability imposing the standard as well as the effective date of that

regulation;

Response :

The Board has promulgated administrative regulations applicable to the

management of used oil which are set forth at 35 Ill . Adm. Code Part 739. Section 739.161(a) of

Subpart G of the Part 739 Standards for the Management of Used Oil

[35 Ill. Adm. Code

739.161(c)], allows the combustion of off-specification used oil as fuel for the purpose of

recovering the thermal energy contained in the used oil. The burning of off-specification used

oil is allowed only in certain devices specified in 35 Ill . Adm. Code Section 739 .161(a),

including "industrial boilers located on the site of a facility engaged in a manufacturing process

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where substances are transformed into new products, including the component parts of products,

by mechanical or chemical processes ."

The Board has promulgated regulations set forth at 35 Ill . Adm. Code Sections 720.132

and 720.133 establishing the criteria and procedures for making a determination that certain

enclosed devices using controlled flame combustion are "boilers" that may be utilized for the

burning of off-specification used oil, even though such devices do not otherwise meet the

definition of "boiler" contained in 35 Ill. Adm. Code 720.110. Section 720.132 establishes the

criteria to be considered by the Board in making such "case-by-case" determinations and Section

720.133 mandates use of the Adjusted Standard procedures of Subpart D of 35 Ill . Adm. Code

104 to determine whether a particular enclosed flame combustion device is a "boiler" that may

be used to bum off-specification used oil .

Through this adjusted standard proceeding, Petitioner seeks a determination that its Raw

Mill Dryer #1 and Raw Mill Dryer #2 may be considered boilers, even though the dryers may not

otherwise meet the definition of "boiler" at 35 Ill . Adm. Code 721.110 .

Such a case-by-case

boiler determination may be made by the Board upon Petitioner's demonstration of compliance

with the criteria set forth at 35 Ill. Adm. Code 720.132. When the Board makes such a positive

determination, the combustion device is considered a "boiler by designation" as that term is

defined at 35 Ill. Adm. Code 721 .110 (included within definition of the term "boiler") . The

applicable Board regulations, specifically 35 Ill . Adm. Code 720.132 and 720.133 were both

promulgated with an effective date of July 17, 2003

(27 III.

Reg.

12713, effective July 17, 2003)

.

b)

A statement that indicates whether the regulation of general applicability was

promulgated to implement, in whole or in part, the requirements of the CWA (33

USC 1251 et seq.), Safe Drinking Water Act (42 USC 300(f) et seq.),

Comprehensive Environmental Response, Compensation and Liability Act (42

USC 9601 et seq.), CAA (42 USC 7401 et seq.), or the State programs concerning

RCRA, UIC, or NPDES [415 ILCS 5/28.1] ;

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Response :

The

regulations applicable

to

case-by-case boiler

determinations,

specifically 35 Ill. Adm. Code Sections 720.132 and 720.133, were promulgated to implement,

in whole or in part, the requirements of the Illinois program for the management of solid and

hazardous waste, the Illinois analog to the federal regulatory program under the Solid Waste

Disposal Act, as amended by the Resource Conservation and Recovery Act, 42 U .S.C. §6901, et

sue .

(hereafter "RCRA".)

c)

The level of justification as well as other information or requirements necessary

for an adjusted standard as specified by the regulation of general applicability or

a statement that the regulation of general applicability does not specify a level of

justification or other requirements [415 ILCS 5/28.11 (See Section 104 .426) ;

Response :

The Board's regulations at 35 Ill. Adm. Code 720.132 and 720.133

establish the criteria and procedures for obtaining a case-by-case boiler determination by the

Board. Section 720.132 establishes the criteria to be considered by the Board for making a case-

by-case determination that certain enclosed devices using controlled flame combustion are

"boilers" that may be utilized for burning off-specification used oil for energy recovery, even

though such devices do not otherwise meet the definition of a "boiler" set forth at 35 Ill. Adm .

Code §720.110. Section 720.133 mandates use of the Adjusted Standard procedures of Subpart

D of 35 Ill. Adm. Code 104 to determine whether a particular enclosed flame combustion device

is a "boiler" that may be used to bum off-specification used oil

.

(Note

:

Sections 720 .132 and 720.133 are virtually identical to the federal RCRA

regulations at 40 CFR 260.32 and 260.33 which establish the criteria and "variance" procedures

for "case-by-case" determinations that specific combustion devices can be considered "boilers

.")

The criteria to be considered by the Board and the procedures to be followed in making a

case-by-case determination that certain enclosed devices using controlled flame combustion are

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"boilers" are provided by Sections 720 .132 and 720.133. Those regulations are set forth in full

below :

Section 720.132

Boiler Determinations

In accordance with the standards and criteria in Section 720 .110 (definition of

"boiler"), and the procedures in 720.133, the Board will determine on a case-by-

case basis that certain enclosed devices using controlled flame combustion are

boilers, even though they do not otherwise meet the definition of boiler contained

in Section 720.110, after considering the following criteria :

a)

The extent to which the unit has provisions for recovering and exporting

thermal energy in the form of Steam, heated fluids or heated gasses ;

b)

The extent to which the combustion chamber and energy recovery

equipment are of integral design ;

c)

The efficiency of energy recovery, calculated in terms of the recovered

energy compared with the thermal value of the fuel ;

d)

The extent to which exported energy is utilized ;

e)

The extent to which the device is in common and customary use as a

"boiler" functioning primarily to produce steam, heated fluids or heated

gases; and

0

Other relevant factors

.

(Source: Amended at 27111. Reg. § 12713, effective July 17, 2003 .)

Section 720.133

Procedures for Determinations

The Board will use the procedures of Subpart D of 35 Ill. Adm. Code 104 for

determining whether a material is a solid waste

or for determining whether a

particular enclosed flame combustion device is a boiler

.

(Emphasis added .)

(Source: Amended at 27 Ill. Reg. § 12713, effective July 17, 2003 .)

d)

A description of the nature of the petitioner's activity that is the subject of the

proposed adjusted standard. The description must include the location of, and

area affected by, the petitioner's activity. This description must also include the

number of persons employed by the petitioner's facility at issue, age of that

facility, relevant pollution control equipment already in use, and the qualitative

and quantitative description of the nature of emissions, discharges or releases

currently generated by the petitioner's activity ;

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Response :

The principal product produced by Lafarge at the Joppa Plant is Portland

cement. The cement manufacturing process consists of the following activities : (1) raw material

receiving, (2) raw material storage; (3) raw material reclaim; (4) raw material grinding and

drying; (5) raw mix storage and kiln feed; (6) pyroprocessing in the rotary kilns; (7) clinker

storage and reclaim; (8) clinker grinding; and (9) cement storage and load-out

.

Raw Material Receiving - Raw materials are received at the Joppa Plant primarily by

barge traveling the Ohio River, but are also received by truck, and potentially by rail . Typical

raw materials include limestone, sand, clay, gypsum, bottom ash, fly ash, iron oxide, mill scale,

iron slag, shale, alumina, spent industrial catalysts, foundry sand, coal tailings and fuels such as

coal and petroleum coke .

Raw Material Storage - Raw materials are unloaded, screened and immediately

conveyed to outside storage piles, covered storage piles, concrete storage bins and enclosed steel

storage tanks. In general, the larger shipments are stored either in the outside storage areas or

covered storage piles where the materials can be gradually reclaimed for use in the cement

manufacturing process

.

Raw Material Reclaim - Raw materials are reclaimed from storage piles and storage

structures by several methods. Materials from covered storage piles or outside storage piles are

transferred via under-pile reclaim system, or front end-loader and truck to one of several reclaim

hoppers that feed various conveyors. Lafarge also operates portable belts to transfer materials

from the plant-site storage locations to the existing conveyor systems. Materials from inside

storage can feed directly to conveyors via vibratory feeders located under the covered storage

hall. Materials stored in bins and tanks are fed directly to the conveyor system .

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Raw Material Grinding and Drying

- Raw materials are fed to the Raw Mill System by

conveyors. The raw materials used at the Joppa Plant are typically coarse and wet before being

fed into the Raw Mill Systems. The Raw Mill System is a continuous process . In the first stage

of the Raw Mill System, raw materials are added to the "raw mix" in the separator body of the

grinding process. The raw mix is then dried by direct contact with the hot dry gas produced by

the Raw Mill Dryers

.

After the drying process, the raw mix is fed into one of two 3,000

horsepower Nordberg ball mills where it is ground to a fine consistency. After grinding, the raw

mix is retuned to the separators where the fine material is removed for later introduction to the

kiln while the coarser material is mixed with new raw material and sent back through the drying

and grinding processes, i.e. dried by direct contact with the hot dry gas produced by the Raw

Mill Dryers and returned to the ball mills for further grinding

.

The raw materials in the Raw Mill Systems are recycled through the Raw Mills via air

conveyance, air separators, screw conveyors and belt conveyors . As the materials are dried in

the Raw Mill Dryers and ground to the desired particle size, they are removed in the air

separators. The resulting mixture, often referred to as "kiln feed" is pneumatically conveyed to

four storage silos located near the feed end of the cement kilns .

The typical feed to the Raw Mills consists of approximately 90% limestone with the

balance composed of sand, clay, mill scale, bottom ash, fly ash and other materials. In general,

all raw material used in the cement manufacturing process is added at this point . The exception

is the addition of gypsum that occurs when the clinker is ground into the finished Portland

cement product.

Raw Feed Storage and Transfer to Kilns - The ground and dried raw materials

produced by the Raw Mill System is pneumatically conveyed to four large storage and blending

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silos located near the feed end of the kilns . Raw "kiln feed" is then transferred to smaller surge

or "feed" tanks before transfer to the kilns

.

In addition, a hopper and conveyor system at the

feed end of the kilns allows reclaim of outside materials (typically clinker) at the feed end of the

kilns .

Pyroprocessing in the Kilns- Both kilns at the Joppa Plant are long dry kilns . Each kiln

is essentially a slightly inclined rotating cylinder with the raw feed introduced into the uphill end

of each kiln while fuel and air is introduced into the downhill end . As the kiln rotates, the raw

feed and combustion air flow counter-current

.

In the #1 Kiln, the raw feed is introduced directly into the kiln via a bucket elevator . The

#2 Kiln is equipped with a one-stage preheater where the raw feed is introduced into a series of

cyclones .

In the cyclones, the material flows counter-current with the kiln exhaust, thus

recovering heat from the #2 Kiln exhaust gases to preheat the raw feed before introduction into

the kiln, itself.

Once in the kilns, the raw materials undergo complex chemical and physical changes to

produce the "clinker" which is ground into finished Portland cement. The ratio of raw feed to

clinker is approximately 1 .5 to 1. The loss of material during pyroprocessing in the kilns results

from additional moisture being driven off as well

as chemical reactions yielding gaseous

products. As the clinker leaves the kilns, it resembles road gravel in size and consistency, with

most material having a diameter of 0 .5 to one inch.

After exiting the kilns, the clinker is fed directly to the clinker coolers, where it is air-

cooled. In the clinker cooler, the clinker travels across grates as air is blown upward through the

product. The cooled clinker is transferred via belt conveyors from the clinker coolers to storage

to await grinding .

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Clinker Storage and Reclaim - Clinker from the clinker coolers is transferred via

conveyors either to covered storage piles, covered storage bins or directly to the steel feed tanks

associated with the Finish Mill Systems .

From the covered storage piles, clinker can be

transferred as needed to outside storage piles for long-term storage . From the outside storage

piles, clinker can be trucked to outside crusher/reclaim systems. From covered storage piles,

reclaimed clinker is transferred via conveyors to the concrete bins that feed the #1 Finish Mill

system or the steel tanks that feed the #2 Finish Mill system

.

Clinker Grinding in Finish Mills- The clinker and small amounts of gypsum (95

:5

typical ratio) are introduced into the Finish Mills for grinding to a precise, extremely fine particle

size .

Similar to the Raw Mill System, the Finish Mill System moves the material via air

conveyance, air separators, screw conveyors and belt conveyors . As the clinker and gypsum

mixture is ground to the desired particle size, they are removed in the air separators

.

The

resulting product, finished Portland cement, is pneumatically conveyed to the storage silos

.

Cement Storage and Loadout - Finished Portland cement is conveyed pneumatically

from the Finish Mill systems to several storage silos . From each storage silo, the cement can be

further transferred either to other storage silos, to trucks or to river barges . All conveyance of

the finished product is via pneumatic conveyors .

Through this Adjusted Standard proceeding, Lafarge seeks Board approval to utilize off-

specification used oil fuel as supplemental fuel in the two Raw Mill Dryers

.

A substantial

amount of energy is needed to dry the raw mix to the very low moisture content that must be

achieved before the raw materials can be introduced into the kilns

.

Currently, Lafarge is

authorized to use natural gas and on-specification used oils as fuels in the two Raw Mill Dryers

.

Construction Permit No. 03080024 issued by the IEPA Bureau of Air on January 14, 2004,

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authorizes the use of on-specification used oil fuel for the two Raw Mill Dryers. A copy of

Construction Permit No

.

03080024

is attached hereto as Exhibit C. Allowable emissions under

the Construction Permit authorizing the combustion of on-specification used oil in the Raw Mill

Dryers are set forth below

:

Lafarge's proposal to utilize off-specification used oil fuel in the Raw Mill Dryers

provides significant environmental benefits by recycling used oils that are continuously

generated from motor vehicles, refineries and manufacturing operations using machining/cutting

oils, heat transfer fluids, hydraulic fluids and general lubricants . Burning used oil is an accepted

and proven means of energy recovery in Illinois and throughout the United States . Recycling

off-specification used oil by recovering the thermal energy through combustion in industrial

boilers converts a potential waste stream into a valuable fuel source. Utilizing off-specification

used oil fuel would permit Lafarge to better manage its fuel costs to stay competitive in the

international marketplace. It would provide additional security for operations at the Joppa Plant

and reduce exposure to the volatility of price and supply of natural gas, a non-renewable source

of energy

.

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Air Contaminant

Emissions (lbs/hour)

Emissions (tons/year)

NOx

10.9

16.60

CO

2.5

4.15

S02

77.1

39.00

PM

0.01

0.10

VOM

0.4

0.50

---

Economic Value of the Joppa Plant to Massac County and State

-The Joppa Plant

was developed at its current location in 1960 with the construction of Kiln #1 and all of the

associated storage structures, process and pollution control equipment and ancillary facilities

needed to manufacture Portland cement

.

The plant has been improved and expanded on

numerous occasions with the addition of Kiln #2 in approximately 1975

.

As of January 1, 2005 Lafarge employed 124 full-time employees at the Joppa Plant; 43

salaried plant employees and 81 other employees .

The annual payroll for 2004 was

approximately $7,737,000

.

Annual tax payments made to the State of Illinois and Massac

County are approximately $153,000. Through its payroll and tax payments, Lafarge supports the

depressed economy in Massac County .

Reported Emissions .

The federal Clean Air Act and the Illinois Environmental

Protection Act require reporting of air pollutant emissions by regulated sources and tracking of

reported emissions data by the State of Illinois . To implement the requirements of State and

Federal law, the State of Illinois has implemented an Annual Emissions Reporting requirement

which applies to all sources required to have an operating permit in accordance with 35 Ill . Adm .

Code 201 .302. The requirements applicable to the Annual Emissions Reporting program are

codified in 35 Ill . Adm. Code Section 254

.

In accordance with applicable regulations, Petitioner submits an Annual Emissions

Report to the Illinois Environmental Protection Agency to report on actual emissions from all

emissions units and activities at the Joppa Portland Cement Plant. The most recent Annual

Emissions Report was due on or before May 1, 2005

.

Set forth below is a summary of the emissions reported by Petitioner in its most recent

Annual Emissions Report which was submitted to the Agency on March 15, 2005

.

The

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Summary Sheets from Petitioner's Annual Emissions Report are attached to the Petition as

Exhibit D .

Other Discharges. Operation of the Joppa Portland Cement Plant also results in

generation of process wastewater and sanitary wastewater and the discharge of storm water

runoff from the site. Petitioner discharges process wastewater, sanitary wastewater and storm

water runoff under NPDES Permit No . IL0004081 . This NPDES Permit was issued on May 26,

2000 with and effective period of five years. An application for renewal of the NPDES Permit

was timely submitted to the Illinois Environmental Protection Agency and such submittal

continues the effective period of the permit until action by the agency .

In addition, the Petitioner was issued a Permit to Construct a new sanitary wastewater

treatment facility on April 19, 2005, designated Permit Number 2005-EN-3317

.

The new

sanitary wastewater treatment facility came on-line during November 2005

.

The following table identifies the discharge points, wastewaters and effluent limitations

established by NPDES Permit No . IL0004081

:

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2004 REPORTED EMISSIONS FOR ENTIRE FACILITY

Pollutant

2004 Emissions (tons/year)

CO

448

Lead

0.14

NH3

1 .4

NO.

3,310

PM

256

PM10

183

PM2.5

30

S02

745

VOM

163

---

Attached as Exhibit E is NPDES Permit No. IL0004081 and Permit to Construct No

.

2005-EN-3317 for the new sanitary wastewater treatment facility

.

e)

A description of the efforts that would be necessary if the petitioner was to

comply with the regulation of general applicability. All compliance alternatives,

with the corresponding costs for each alternative, must be discussed.

The

discussion of costs must include the overall capital costs as well as the annualized

capital and operating costs ;

Response :

Through

this

Adjusted

Standard

proceeding,

Petitioner

seeks

a

determination by the Board that the Raw Mill Dryers operated at its Joppa Plant may be

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Outfall

Number

Description

Limitations

001

Non-contact cooling water, cooling tower blow

Flow, pH and temperature

down and storm water runoff. These wastewaters

are treated in a settling pond prior to discharge to

the Ohio River

.

002

Treated sanitary wastewater. At a cost in excess of

Flow, pH, biological oxygen

$300,000, new sanitary wastewater treatment plant

was constructed and brought on line in November

2005. Treatment consists of BOD removal through

a sand bed media, disinfection using chlorine and

de-chlorination prior to discharge of the treated

effluent .

demand

("BOD"),

total

suspended solids ("TSS"),

fecal coliform, ammonia and

residual chlorine

003, 004

Storm water runoff from storage piles

.

Flow, pH and TSS

& 005

006, 007

Storm water runoff associated with industrial

Subject to facility Storm Water

& 008

activity

.

Pollution

Prevention

Plan

requirements,

including

containment systems, erosion

control measures and waste

and housekeeping controls

.

---

considered "boilers" for purposes of using off-specification used oil as supplemental fuel. The

two Raw Mill Dryers function as direct-fired process heaters to reduce the moisture content of

the raw materials to allow grinding of the "raw feed" to the proper particle size and reduction of

the moisture content of the raw feed before introduction into the kilns for pyroprocessing. The

finished Portland cement is the main component of concrete used as an architectural building

material and in numerous construction and building applications

.

Lafarge believes that its Raw Mill Dryers meet the definition of "boiler" in 35 Ill. Adm .

Code §720.110 and consequently, would be authorized under the existing regulations to utilize

off-specification used oil as supplemental fuel. However, Petitioner has consulted with IEPA

officials regarding previous proposals to utilize off-specification used oil as supplemental fuels

.

Through those discussions, Lafarge has been advised that it must utilize the Adjusted Standard

administrative process before the Pollution Control Board to receive a "case-by-case" boiler

determination that would permit use of off-specification used oil as supplemental fuel for the

Raw Mill Dryers .

Lafarge would not risk an enforcement action by proceeding to utilize off-specification

used oil as a fuel in the Raw Mill Dryers without assurances that such actions were done in full

compliance with all applicable standards. According to IEPA's interpretation of Section

720.110, Lafarge is prohibited from burning off-specification used oil for energy recovery in its

Raw Mill Dryers unless and until it receives from the Pollution Control Board a determination

that each of the Raw Mill Dryers satisfy the criteria to be classified a "boiler by designation

."

Other than Board approval, there are no compliance alternatives, no capital improvements and no

operational changes that would allow Petitioner to "comply with the regulation of general

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applicability" which would prohibit combustion of off-specification used oil until a case-by-case

determination is made by the Board that the Raw Mill Dryers are "boilers by designation ."

Costs of Specification Used Oil vs . Off-Specification Used Oil. Petitioner is proposing

to supplement the current fuels used in the Raw Mill Dryers, specifically natural gas and on-

specification used oil, with off-specification used oil as a cost saving measure. Off-specification

used oil, due to its lower cost, will further reduce Lafarge's fuel costs and overall operating costs

to produce finished Portland cement at the Joppa Plant

.

Lafarge is proposing to use approximately 1,500,000 gallons of used oil fuel per year in

the Raw Mill Dryers. In the Southern Illinois markets, specification used oil currently is priced

at an average of $0.91 per gallon while off-specification used oil is averaging around $0 .81 per

gallon. Based on projected usage of 1,500,000 gallons per year and current market pricing, this

translates to an annual cost of $1,369,000 for on-specification used oil and $1,281,000 for off-

specification used oil. The additional cost savings of $88,000 annually gained by using off-

specification used oil as supplemental fuel is a significant amount and this annual cost saving is

expected to increase as the market costs for natural gas and on-specification used oil fuel

continue to escalate

.

As the costs of natural gas and on-specification used oil fuel increase, the economic

benefits associated with using off-specification used oil as a supplemental fuel also increase

.

According to the Energy Information Administration of the U.S. Department of Energy, natural

gas prices in the United States have more than doubled in the past three years, primarily because

development of new gas supplies has not kept pace with increasing demand. (see Annual Energy

Outlook 2005 - Market Trends: Natural Gas Demand and Supply). Natural gas is increasingly

popular for use in homes, businesses, industrial facilities and electric power-generation because

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it is efficient, clean and reliable. Over the last several years, increased demand was spurred by

the electric power industry, which is opting for cleaner, gas-fired power plants rather than

conventional coal-fired power generation

.

Power plants were consuming 24 percent more

natural gas in July 2005 than in July 2004, according to the federal Energy Information

Administration

.

In addition to a lag in the development of new natural gas production supplies,

catastrophic weather has further widened the gap between supply and demand

.

In 2005,

hurricanes Katrina and Rita devastated more than 250 oil and natural gas platforms in the United

States and Mexico. Almost nine percent of the Gulf Coast's annual production of natural gas was

lost between August 26th and October 19th, according to the U .S. Minerals Management

Service

.

Historically, the factors that led to rising oil prices, such as political instability or war in

major production areas such as the Middle East, did not affect U .S. natural gas prices, because

more than 90 percent of the natural gas used in this country was produced domestically

.

However, many large industrial facilities can switch between natural gas and oil with modest

capital expenditures for fuel oil storage and distribution facilities . In the past, in times of rising

natural gas prices, these industrial facilities would switch to lower-priced fuel oil and diesel, thus

relieving demand and upward price pressure on the natural gas market . Today, however, with oil

prices spiking at prices of upwards of $60 or $70 per barrel, many industrial facilities cannot

afford to switch to virgin fuel oil, distillate or diesel fuels and are utilizing large quantities of

alternative fuels, including recycled used oil .

The rising prices for natural gas and refined

petroleum products has further increased the demand for used oil fuels, and thus, the market

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prices

for both on-specification

and

off-specification used

oil

are

expected

to

continue

increasing

.

t)

A narrative description of the proposed adjusted standard as well as proposed

language for a Board order that would impose the standard. Efforts necessary to

achieve this proposed standard and the corresponding costs must also be

presented;

Response :

Pursuant to the criteria set forth at 35 Ill . Adm. Code §720.132, the Board

may grant the requested Adjusted Standard through a determination that each Raw Mill Dryer is

a boiler, even though it may not otherwise meet the definition of the term "boiler" set forth at 35

Ill. Adm. Code §720.110. Once the Board determines that each of Petitioner's Raw Mill Dryers

meet the criteria set forth at 35 Ill . Adm. Code §720.132, both units will meet the regulatory

definition of the term "boiler" at 35 Ill . Adm. Code 720.110, which states in relevant part

:

Boiler by designation. The unit is one that the Board has determined, on a case-

by-case basis, to be a boiler, after considering the standards in Section 720 .132.

An industrial boiler located on the site of a facility engaged in a manufacturing process is

authorized under Subpart G of 35 Ill. Adm. Code Part 739 to utilize off-specification used oil for

energy recovery. Upon determination by the Board that Petitioner's Raw Mill Dryers should be

classified as a "boiler," these units will be allowed to burn off-specification used oil for energy

recovery because they will be considered a "boiler by designation" and are "located on the site of

a facility engaged in a manufacturing process where substances are transformed into new

products ."

Adequacy of Current Air Pollution Control Equipment .

Emissions from the Raw

Mill System are controlled by modem, high-efficiency fabric filter baghouse particulate control

systems to minimize the release of particulate matter and other air contaminants in the exhaust

gases .

The combined capture and removal efficiency of these baghouse systems typically

achieve greater than 99 .9% overall control efficiency

.

As identified in the CAAPP Title V

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Operating Permit issued for the Joppa Plant, the exhaust from Raw Mill #1 is controlled by the

North DCs #1 and #2, South DCs #1 and #2 and the Auxiliary DC . The exhaust from Raw Mill

#2 is controlled by the Utility DC #2 and Air Separator DC #1

.

The dried "kiln feed" captured in the control equipment is a valuable material that is

returned to the production process . In addition to controlling particulate emissions, maximizing

capture of the dried raw materials entrained in the exhaust gases from the Raw Mills increases

plant productivity and profitability that is critical to the overall financial health and long-term

viability of the Joppa Plant. Consequently, there exists a strong economic incentive to operate

the fabric filter baghouses at maximum removal efficiency

.

Petitioner has estimated the potential particulate emissions from utilizing up to 1,500,000

gallons of off-specification used oil

as a supplemental fuel in the Raw Mills. Based on those

calculations, total particulate matter ("PM") emissions and emissions of PM10 resulting from the

combustion of off-specification used oil supplemental fuel will be orders of magnitude lower

than the emissions allowed by the CAAPP Title V Operating Permit. In addition, emissions

from the combustion of off-specification used oil fuel will be in compliance with Construction

Permit No. 03080024 issued by the IEPA Bureau of Air on January 14, 2004, authorizing the use

of on-specification used oil fuel for the two Raw Mill Dryers

.

Because predicted emissions from the combustion of off-specification used oil are

predicted to be well below the allowable limits of the CAAPP Title V Operating Permits and the

2004 Construction Permit, Petitioner believes that no modifications to the existing fabric filter

baghouse control equipment will be required to further control emissions when combusting off-

specification used oil fuel . Additionally, Petitioner believes that no additional pollution control

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equipment will be required to control emissions from the combustion of off-specification used

oil as supplemental fuel in the Raw Mill Dryers

.

Utilization of off-specification used oil fuel in the Raw Mill Dryers will need to be

reviewed and approved by the Illinois Environmental Protection Agency air permitting officials,

with issuance of a Construction Permit and modifications to the existing CAAPP Title V

Operating Permit .

Under the provisions of 35 Ill. Adm. Code Section 201, the use of off-

specification used oil as a supplemental fuel in the Raw Mill Dryers is likely to be considered a

change in the method of operation which would trigger construction and operating permit

requirements . All questions about the air pollutant emissions associated with combustion of used

oil fuel would be addressed and fully answered through the air permitting review process

conducted by IEPA .

Proposed language for a Board Order that would approve the requested Adjusted

Standard relief :

1

.

Procedural History

2 .

Background

3 .

Agency Recommendation

4.

Response to Recommendation

5 .

Discussion

Legal Framework

Availability ofRelief Under Section 720.132

Section 720.132 Factors

Other Relevant Factors

6.

Conclusion

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The Board finds that Lafarge Midwest, Inc. has established under Section 720.132 of the

Board regulations (35 Ill. Adm. Code 720.132), that each of the Raw Mill Dryers at the Joppa

Plant satisfies the criteria set forth in Section 720.132 to be considered a "boiler . " Accordingly,

the Board finds and determines that the Raw Mill Dryers are "boilers" within the meaning of 35

III Adm. Code 720.110.

The Board's determination that the Raw Mill Dryers are "boilers" will allow the units to

be used for the combustion of off-specification used oil for energy recovery, in compliance with

Section 739.161 of the Board's regulations (35 711. Adm. Code 739.161). The Board emphasizes

that use of off-specification used oil as fuel for the Raw Mill Dryers must comply with all other

applicable Illinois and federal environmental standards and requirements, including the terms

and conditions of "CAAPP Operating Permit and Title I Permit No . 95090110" issued for

operation of the Joppa Portland Cement Manufacturing Plant and associated air pollution

control equipment and any subsequent modifications thereto .

This opinion constitutes the Board's findings offact and conclusions of law .

ORDER

1 .

The Board finds that the Raw Mill Dryers operated by Lafarge Midwest, Inc . at its Joppa

Portland Cement Manufacturing Plant meet the criteria set forth in 35 Ill . Adm. Code

§720.132 to be considered a "boiler . "

The Board accordingly grants Lafarge Midwest,

Inc. an Adjusted Standard under 35 Ill. Adm. Code 720.132 and determines that the Raw

Mill Dryers are "boilers by designation" under 35 Ill. Adm. Code §720.110.

2 .

The Adjusted Standard will allow the Raw Mill Dryers to combust off-specification used

oil for energy recovery under 35 Ill. Adm. Code 739.161, subject to compliance with all

other applicable Illinois and federal environmental standards and requirements

.

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IT IS SO ORDERED .

g)

The quantitative and qualitative description of the impact of the petitioner's

activity on the environment if the petitioner were to comply with the regulation

of general applicability as compared to the quantitative and qualitative impact

on the environment if the petitioner were to comply only with the proposed

adjusted standard.

To the extent applicable, cross-media impacts must be

discussed. Also, the petitioner must compare the qualitative and quantitative

nature of emissions, discharges or releases that would be expected from

compliance with the regulation of general applicability as opposed to that which

would be expected from compliance with the proposed adjusted standard;

Response :

Lafarge believes that the Raw Mill Dryers at its Joppa Plant meet the

regulatory definition of a "boiler" in 35 Ill. Adm. Code 720.110 and therefore are allowed to

combust off-specification used oil fuels . However, IEPA officials have advised that obtaining a

"boiler by designation" determination from the Pollution Control Board is necessary to comply

with the applicable regulations. As a result, Lafarge is not able to secure the full benefits of used

oil recycling and recover the significant amount of thermal energy contained in the off-

specification used oil available as dryer fuels

.

Lafarge will continue to combust substantial quantities of natural gas and on-

specification used oil in its Raw Mill Dryers and be subject to the economic uncertainties

associated with the volatility of oil and natural gas supplies and costs . As the costs of natural gas

and petroleum increase and the availability of these non-renewable resources decreases, the

economic success and viability of the Portland cement production operations at the Joppa Plant

are threatened

.

The Joppa Plant itself utilizes a number of other byproducts and materials from other

industries as the raw materials in cement manufacturing processes. For example, Lafarge utilizes

petroleum coke, a byproduct of the refining process, and waste tires as fuel for the kilns. In

addition to byproduct fuels, Lafarge utilizes spent foundry sand, fly ash, bottom ash, iron slag

and mill scale as raw materials in the raw feed. If not utilized by Lafarge as alternative raw

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materials in the cement manufacturing process, most of these industrial byproducts would be

landfilled or otherwise disposed of as waste

.

If the Board grants Lafarge's Adjusted Standard request, it would purchase off-

specification used oil fuel from regulated used oil marketers at a cost per Btu of thermal energy

that is significantly less than the escalating cost of natural gas and petroleum. The used oil fuels

would be subject to strict specifications to ensure high Btu value, allow complete combustion

and produce negligible change in the combustion exhaust gas composition .

The only consequence associated with the Board's approval to approve Lafarge's request

to utilize off-specification used oil fuels in its Raw Mill Dryers would be a possible change in the

air emissions from the Raw Mill Dryers. As noted above, the Raw Mill Dryers are permitted to

combust natural gas and on-specification used oil as the primary dryer fuels

.

The Title V

CAAPP Operating Permit establishes emissions limitations for particulate matter ("PM/PM1o"),

sulfur dioxide ("SO2"), carbon monoxide ("CO"), volatile organic material ("VOM"),

and

nitrogen oxides ("NO.") . Compliance with the permitted emissions limits is achieved by full and

complete combustion of the fuel and operation of air separators, and cyclone equipment designed

to remove particulate matter from the mill exhaust gases

.

Lafarge has investigated how combustion of off-specification used oil fuel would affect

air emissions from the Raw Mill Dryers and whether it would maintain compliance with the

existing emission limitations of the Title V CAAPP Operating Permit and the 2004 Construction

Permit authorizing combustion of on-specification used oil fuel in the Raw Mill Dryers . Based

on representative off-specification used oil fuels that would be supplied by reputable, authorized

used oil marketers, Lafarge estimates that emissions from the Raw Mill Dryers would not exceed

the existing permit limits. Utilization of off-specification used oil fuel in the Raw Mill Dryers

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must be reviewed and approved by the IEPA's Bureau of Air permitting officials, with issuance

of a Construction Permit and modifications to the existing Title V CAAPP Operating Permit . As

a result, any questions associated with combustion of off-specification used oil fuel would be

addressed and fully resolved through the air permitting review process

.

Attached hereto as

Exhibit F is the Clean Air Act Permit Program ("CAAPP") Title V Operating Permit and Title I

Permit No. 95090119 issued November 14, 2002 for Petitioner's Joppa Plant

.

Quantitative and Qualitative Impacts of Using Supplemental Used Oil Fuels

.

In

preceding sections of this Petition, Lafarge has described the results of its investigations of air

emissions associated with the combustion of off-specification used oil fuel as a supplemental

fuel in the Raw Mill Dryers compared to the permitted fuels natural gas and on-specification

used oil fuel. All emissions associated with combustion of off-specification used oil fuel would

be less than the allowable emissions under the current CAAPP Title V Operating Permit and

2004 Construction Permit

.

Utilization of off-specification used oil fuel in the Raw Mill Dryers will need to be

reviewed and approved by the IEPA air permitting officials, with issuance of a Construction

Permit and modifications to the existing Operating Permit. The permitting process would ensure

that all emissions associated with combustion of off-specification used oil fuel would be in full

compliance with all applicable regulatory requirements and environmental standards

.

On a qualitative basis, Lafarge's proposal to utilize off-specification used oil fuel in the

Raw Mill Dryers provides significant environmental benefits by recycling and reclaiming the

thermal energy from used oils that are generated from motor vehicles, refineries and numerous

industrial processes. Recycling used oil for reuse or energy recovery provides environmental

and economic benefits . According to the USEPA's Office of Solid Waste, re-refining used oil

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80212418v1 NEWFILE

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for reuse as a lubricant takes approximately one-third the energy of refining crude oil to lubricant

quality. It takes 42 gallons of crude oil, but only one gallon of used oil, to produce two and a

half quarts of new, high-quality lubricating oil . In addition, as a fuel source one gallon of used

oil processed for fuel contains about 140,000 British Thermal Units (BTUs) of energy

.

Substituting off-specification used oil for natural gas helps to conserve this non-

renewable resource. As noted in preceding sections of this Petition, the demand for natural gas

has far outpaced current supplies and as a result, natural gas prices in the United States have

more than doubled in the past three years . Substituting on-specification and off-specification

used oil fuel in place of natural gas provides an environmental benefit by conserving a valuable

natural resource .

Indirectly, the Board's approval of the relief requested by Lafarge would support the

additional environmental benefits associated with the industrial byproduct recycling operations at

the Joppa Plant. As noted earlier, Lafarge's production of Portland cement at the Joppa Plant

utilizes a number of industrial byproducts to produce the finished product, byproducts that

otherwise would be landfilled as solid wastes . Controlling the operating costs of the Joppa Plant

by approving use of lower cost off-specification used oil supplemental fuel would provide more

stability to Lafarge's production operations and maintain the environmental benefits of recycling

various industrial byproducts into Portland cement products . It would reduce Lafarge's exposure

to the volatility of price and supply of natural gas, a non-renewable source of energy .

Sources of Used Oil Supplies and Basic Quality Control Management Standards

.

Included in Exhibit G is a description of the nature and source of the used oil that is likely to be

available for use as supplemental fuel for the slag dryer . In addition, Exhibit G summarizes the

key procedures that would be instituted to control the quality of off-specification used oil to be

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80212418v1 NEWFILE

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used as fuel for the slag dryer. This summary document, entitled

"Potential Supply Sources and

Basic Principles of Management of Off-Specification Used Oil Fuel for the Joppa Raw Mill

Dryers,"

was prepared for Lafarge by Systech Environmental Corporation, a wholly owned

subsidiary of Lafarge. It is anticipated that Systech Environmental Corporation will serve as

Lafarge's principal contractor for identifying and qualifying used oil suppliers and making

arrangements for delivery of off-specification used oil fuels to the Joppa Plant by pre-qualified

suppliers

.

h)

A statement which explains how the petitioner seeks to justify, pursuant to the

applicable level of justification, the proposed adjusted standard

;

Response :

Section 720.132 of the Board's regulations (35 Ill. Adm. Code §720.132),

establishes the criteria to be considered by the Board in making a "case-by-case" determination

that certain enclosed devices using controlled flame combustion are boilers, even though they do

not otherwise meet the definition boiler contained in Section 720 .110. The criteria for "case-by-

case" boiler determination track closely the regulatory definition of "boiler" set forth at 35 Ill .

Admin. Code 720.110. Consequently, when evaluating whether a particular combustion source,

such as the Raw Mill Dryers at the Joppa Plant, should be classified as a boiler, the regulatory

definition of "boiler" provides the determinative physical characteristics .

Set forth below is the regulatory definition of a "boiler" set forth at 35 Ill . Admin. Code

720.110

:

"Boiler" means an enclosed device using controlled flame combustion and

having the following characteristics

:

Boiler physical characteristics .

The unit must have physical provisions for recovering and

exporting thermal energy in the form of steam, heated fluids, or

heated gases; and the unit's combustion chamber and primary

energy recovery sections must be of integral design

.

To be of

integral design, the combustion chamber and the primary energy

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recovery sections *such as waterwalls and superheaters) must be

physically formed into one manufactured or assembled unit

.

A

unit in which the combustion chamber and the primary energy

recovery sections are joined only by ducts or connections carrying

flue gas is not integrally designed; however, secondary energy

recovery equipment (such as economizers or air preheaters) need

not be physically formed into the same unit as the combustion

chamber and the primary energy recovery section. The following

units are not precluded from being boilers solely because they are

not of integral design: process heaters (units that transfer energy

directly to a process stream) and fluidized bed combustion units ;

and

While in operation, the unit must maintain a thermal energy

recovery efficiency of at least 60 percent, calculated in terms of the

recovered energy compared with the thermal value of the fuel; and

The unit must export and utilize at least 75 percent of the

recovered energy, calculated on an annual basis

.

In this

calculation, no credit may be given for recovered heat used

internally in the same unit .

(Examples of internal use are the

preheating of fuel or combustion air, and the driving of induced or

forced draft fans or feedwater pumps) ; or

Boiler by designation .

The unit is one that the Board has

determined, on a case-by-case basis, to be a boiler, after

considering the standards in Section 720 .132 .

The 35 III . Admin. Code 720.132(a) Criteria .

Set forth below is a demonstration that

Petitioner's Raw Mill Dryers satisfy each of the criteria specified at 35 Ill. Admin. Code

720.132(a) to be considered a boiler

.

Section 720.132(a)

The extent to which the unit has provisions for recovering

and exporting thermal energy in the form of steam, heated

fluids

or heated

gases:

The Raw Mill Dryers are constructed with burners designed to recover the maximum

amount of thermal energy in the fuel being burned in order to heat the raw material mix and

drive off moisture. Each Raw Mill Dryer functions as a direct-fired process heater in which the

"raw feed" and additional air are brought into contact with the hot combustion gases

.

The

thermal energy released by the combustion of the fuel is transferred to the raw mix and "raw

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feed" materials. Heating the raw materials vaporizes a portion of the moisture that is in the pores

of the material . The heat is then exported in the form of heated and dried "raw feed" materials,

hot gases and water vapor. The "raw feed," hot gases and water vapor are discharged from the

dryer through cyclone and air separators, where the heated and dried raw materials are removed

from the exhaust gas stream. Based on the raw material size, coarser raw materials are fed to the

raw mills to further reduce particle size, while the finer hot, dried "raw feed" is conveyed

directly to the four storage silos located near the feed ends of the two kilns

.

The Raw Mill Dryers are fully enclosed with an outer shell of steel

.

The burning

chamber is lined with a high temperature resistant refractory material and the transport shaft is

lined with ceramic tile. This design is conducive to recovering as much energy

as possible from

the fuel. (A schematic drawing of the Raw Mill System is included as Exhibit H.)

Section 720.132(b). The extent to which the combustion chamber and energy

recovery equipment are of

integral design ;

The Raw Mill System is designed such that operation of the Raw Mill is dependant upon

operation of the Raw Mill Dryer and the dryer cannot operate if the Raw Mill is not operating

.

The entire system was installed as one operating unit and the function of the Raw Mill Dryers is

to directly heat the raw materials and provide the centrifugal force (air velocity) to the separators .

The Raw Mill Dryers are not operated as an independent revenue source .

The combustion chamber and energy recovery sections of each Raw Mill Dryer are

integral in design and assembly to function as a single unit . In addition, the regulatory definition

of a "boiler" set forth in the Board's regulations at 35 Ill . Adm. Code 720.110 includes an

express exemption from the "integral design" element for process heaters such as the Raw Mill

Dryers. The regulation states :

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"The following units are not precluded from being boilers solely because

they are not of integral design : process heaters (units that transfer energy

directly to a process stream) and fuidized bed combustion units

. "

Because the Raw Mill Dryers are direct-fired process heaters where the thermal energy of

the combusted fuel is transferred directly to the raw materials being processed, the element of

"integral design" is not a sole determinative criterion in this proceeding

.

Section 720.132(c)

The efficiency ofenergy recovery, calculated in terms of

the recovered energy compared with the thermal value ofthe fuel;

For purposes of calculating the efficiency of energy recovery, a detailed analysis of the

Raw Mill Dryers is necessary. The Raw Mills Dryers can be depicted in the following process

flow diagram :

Qin = Heat into

DRYER

t

Wcycle

"Qin" = heat into the system

"Qout" = Energy out of the system

"Wcycle"=net amount of energy transfer by heat and work .

Qout = Heat out of

Systems undergoing the drying process as described above deliver a network transfer of

energy to the surroundings. This is called a "power cycle" .

Thermal efficiency is

calculated in engineering thermodynamic reference materials as the following

:

q = Wcycle/Qin eq#1

An alternative form based on the balance of the system described above can be

:

q = (Qin-Qout)/Qin eq#2

Equation #2 translates into

: Efficiency = Energy Absorbed (Qin-Qout) divided by Qin

(Heat into system)

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The efficiency method described above is based on the principles of the First and Second

Laws of Thermodynamics, hence a method uniformly used worldwide for the design, operation

and evaluation of heat systems. (See

Fundamentals of Engineering Thermodynamics,

Michael J

.

Moran, Third Edition,

1996,

pages

60-61

;

Chemical and Process Thermodynamics,

B.G. Kyle,

Second Edition,

1992,

page

63

A heat balance has been calculated for the Raw Mill Drying System to provide the input

variables for the thermal efficiency calculations . All values and parameters used in the heat

balance calculations are set forth in the following Tables :

•

Table I. Heat Balance Calculations : Total Heat In-Raw Mill 1

•

Table

2

.

Heat Balance Calculations : Total Heat Out-Raw Mill 1

•

Table

3

.

Heat Balance Calculations : Total Heat In-Raw Mill 2

•

Table 4. Heat Balance Calculations

: Total Heat Out-Raw Mill 2

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Table 1. Heat Balance Calculations: Total Heat In RM 1

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Line

Feed

Definition

As Measured (kg/hr)

Moisture Calculation

As

measured

(dry

basis)

Feed

Kg/

Kg mix

T(C)

CP

(kcallkgC)

Heat (Kcal/Kg Mix)

1

North CF

North Combustion Fan

10,100

10,029

10,029

0.0875

35

0.2450

0.7504

2

South CF

South Combustion Fan

13,756

13.659

13,659

0.1192

35

0.2450

1 .0220

3

North FAD

North Fresh Air Damper

19.034

11 .657

11 .657

0.1017

39

0.2459

0.9755

4

South FAD

South Fresh Air Damper

11,740

18,900

18,900

0.1649

39

0.2459

1.5816

5

Raw Mix

Raw Material

120,000

114,600

114,600

1 .0000

60

0.2150

12.9000

6

Raw Mix H2O

Raw Material Water

5.400

5,400

0.0471

60

0.4594

1.2988

7

North CF-H20

North Combustion Fan Air Water

71

71

0.0006

35

0.4570

0.0099

8

South CF_H2O

South Combustion Fan Air Water

97

97

0.0008

35

0.4570

0.0135

9

North FAD H2O

North Fresh Air Damper Air Water

83

83

0.0007

39

0.4587

0.0129

10

South FAD H2O

South Fresh Air Damper Air Water

134

134

0.0012

39

0.4587

0.0209

11

North Fuel Gas H2O

North Fuel Gas Water

4

4

0.0000

80

0.4759

0.0012

12

North Fuel Oil H2O

North Fuel Oil Water

2

2

0.0000

80

0.4759

0.0007

13

South Fuel Gas H2O

South Fuel Gas Water

5

5

0.0000

80

0.4759

0.0017

14

South Fuel Oil H2O

South Fuel Oil Water

2

2

0.0000

80

0.4759

0.0005

15

North Gas Latent Heat

36

32

32

0.0003

80

0.2500

0.0057

16

North Oil Latent Heat

248

246

246

0.0022

80

0.4492

0.0773

17

South Gas Latent Heat

50.4

45

45

0.0004

80

0.2500

0.0079

18

South Oil Latent Heat

205

204

204

0.0018

80

0.4492

0.0638

19

False Air

5,463

5,463

5,463

0.0477

39

0.2459

0.4572

20

North Fuel Combustion Heat Gas

40

(m3/hr)

35.4300

2.9531

21

North Fuel Combustion Heat Oil

248

44.0330

22.7918

22

South Fuel Combustion Heat Gas

56

(m'lhr)

35.4300

4.1344

23

South Fuel Combustion Heat Oil

205

44.0330

8.8280

24

Total Heat In

---

Table 2. Heat Balance Calculations: Total Heat Out RM I

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35

1 .0793

10.7174

2.1057

18.4900

0.2373

22

639

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25

False Air in Stack Gas

5,463

Estimate 10%

5,463

5,463

0.0477

88

0.2573

26

Stack Gas

60,048

54,244

54,244

0.4733

88

0.2573

27

Stack Gas-

1-120

Stack Gas Water

5,803

5,803

0.0506

88

0.4725

28

Raw Mix

Raw Material

115,288

114.600

114,600

1.0000

86

0.2150

29

Raw Mix-1-12

0

Raw Material Water

688

688

0.0060

86

0.4599

31

Heat of vaporization

4,712

0.0411

539

32

Heat Out

33

Other heat escaping the system (radiation, joints, filings, etc .)

34

Total Heat Out

35

% Recovery

---

Table 3. Heat Balance Calculations : Total Heat In RM 2

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36

Heat (Kcal/Kg Mix)

3.6417

5.1823

12.9000

1.2988

0.0481

0.0680

0.0111

0.0007

0.0525

0.0831

0.8853

27.4001

24.5184

2.1468

21.3993

2.2245

18.4900

0.2373

22.1639

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Line

1

2

3

4

5

6

7

8

9

10

11

12

13

14

Feed

CF

FAD

Raw Mix

Raw Mix H2O

CF H 2O

FAD-HO

Fuel Gas H2O

Fuel Oil H2O

Gas Latent Heat

Oil Latent Heat

False Air

Fuel Combustion Heat Gas

Fuel Combustion Heat Oil

As

measured

(dry

Definition

As Measured (kg/hr)

Moisture Calculation

basis)

Feed

Combustion Fan

36,388

36,132

36,132

Fresh Air Damper

51,444

51,417

51,417

Raw Material

97,000

92,635

92.635

Raw Material Water

4,365

4,365

Combustion Fan Air Water

256

256

Fresh Air Damper Air Water

362

362

Fuel Gas Water

27

27

Fuel Oil Water

2

2

270

243

243

216

214

214

8,783

8,783

8,783

300

(m3/hr)

216

Kg/

Kg mix

0.3900

0.5551

1.0000

0.0471

0.0028

0.0039

0.0003

0.0000

0.0026

0.0023

0.0948

T(C)

38

38

60

60

38

38

80

80

80

80

38

CP (kcaLkgC)

0.2457

0.2457

0.2150

0.4594

0.4582

0.4582

0.4759

0.4759

0.2500

0.4492

0.2457

35.4300

44.0330

Total Heat In

Table 4. Heat Balance Calculations : Total Heat Out RM 2

15

False Air in Stack Gas

8,783

Estimate 10%

8,783

8,783

0.0948

88

0.2573

16

Stack Gas

92,505

87,549

87,549

0.9451

88

0.2573

17

Stack Gas-1-120

Stack Gas Water

4,956

4,956

0.0535

88

0.4725

18

Raw Mix

Raw Material

93,191

92,635

92,635

1 .0000

86

0.2150

19

Raw Mix H2O

Raw Material Water

556

556

0.0060

86

0.4599

20

Heat of vaporization

3,809

0.0411

539

21

Heat Out

22

Other heat escaping the system (radiation, joints, filings, etc .)

23

Total Heat Out

24

% Recovery

---

The following parameters were used to calculate the heat balance for the Raw Mill Drying System

:

Inlet Parameters RMI (Table 1)

Heat input from north combustion fan (CF) _ (Dry North combustion Fan Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *

Temperature ofAir stream (°C) * Specific Heat capacity ofAir @ stream T

Heat input from south combustion fan (CF) = (Dry South combustion Fan Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour))

Temperature ofAir stream (°C) * Specific Heat capacity ofAir @ stream T

Heat input from north Fresh Air Damper (FAD) = (Dry Fresh Air Damper Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *

Temp erasure ofAir stream (°C) * Specific Heat capacity ofAir @ stream T

Heat input from south Fresh Air Damper (FAD) - (Dry Fresh Air Damper Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour))

Temperature ofAir stream (°C) * Specific Heat capacity ofAir @ stream T

Heat input from Raw Material stream - (Dry Raw material Feed Rate (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature Raw

material Feed before dryer ('C)

* Specific Heat capacity of Raw material @ stream T ** The raw material feed rate was used as the reference

material (Kcal /Kg raw material)

Heat input from water in raw material - (Water mass flow in raw material (kg/hour) * /Dry Raw material Feed Rate (Kg/hour)) * Temperature

water in raw material (°C) * Specific Heat capacity of water @ stream T

Heat input from water in north combustion fan air stream = (Water mass flow in combustion fan air stream from relative humidity (kg/hour) /

Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in combustion fan air stream (°C) * Specific Heat capacity of water @ stream

T

Heat input from water in south combustion fan air stream -(Water mass flow in combustion fan air stream from relative humidity (kg/hour) /

Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in combustion fan air stream ('C) * Specific Heat capacity of water @ stream

T

Heat input from water in north fresh air damper air stream = (Water mass flow in fresh air damper air stream from relative humidity (kg/hour)

* /Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in fresh air damper air stream (°C) * Specific Heat capacity of water @

stream T

Heat input from water in south fresh air damper air stream - (Water mass flow in fresh air damper air stream from relative humidity (kg/hour)

* /Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in fresh air damper air stream ("C) * Specific Heat capacity of water @

stream T

Heat inputfrom water in north furnace Natural Gas stream -(Water mass fow in north furnace gas from moisture provided by gas company

(kg/hour) * /DrV Raw material Feed Rate (Kg/hour)) * Temperature of water in gas stream (°C) * Specific Heat capacity of water @ stream T

Heat input from water in north furnace oil stream - (Water mass fow in north furnace oil from moisture provided by oil company (kg/hour)

•/

Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in oil stream (*C) * Specific Heat capacity ofwater Astream T

Heat inputfrom water in south furnace Natural Gas stream - (Water mass fow in south furnace gas from moisture provided by gas company

(kg/hour) */DryRaw material Feed Rate (Kg/hour)) *Temperature of water in gas stream (°C) *Specific Heat capacity of water @ stream

T

Heat input from water in south furnace oil stream -(Water mass flow in south furnace oil from moisture provided by oil company (kg/hour) * /

Dry Raw material Feed Rate (Kg/hour)) *Temperature of water in oil stream(°C) *Specific Heat capacity of water @ stream T

Heat input from latent heat of north furnace natural gas - (Dry north furnace natural gas fow rate (kg/hour) /Dry Raw material Feed Rate

(Kg/hour)) * Temperature of natural gas stream (°C) * Specific Heat capacity of natural gas @ stream T

Heat inputfrom latent heat of north furnace oil - (Dry north furnace oil flow rate (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *

Temperature of oil stream (°C) * Specific Heat capacity of oil @ stream T

Heat input from latent heat of south furnace natural gas - (Dry south furnace natural gas fow rate (kg/hour) /Dry Raw material Feed Rate

(Kg/hour)) * Temperature of natural gas stream('C) * Specific Heat capacity of natural gas @ stream T

Heat input from latent heat of south furnace oil - (Dry south furnace oil flow rate (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *

Temperature of oil stream (*C) * Specific Heat capacity of oil @ stream T

Heat input from false air = (Dry false air Airfow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature ofAir stream (°C) *

Specific Heat capacity ofAir @ stream T

False air is the air as a result of in-leakage in the system . It is estimated to be about 10% of the

stack's airflow rate

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Heat input from north furnace natural gas stream =north furnace natural gas f ow rate from gas meter (ft^3/hour) * Gas fuel value from gas

company (BTU/(t^3) *conversion, factor toKcal /Dry Raw material Feed Rate (Kg/hour)

Heat input from north furnace natural oil stream = north furnace oil flow rate (kg/hour) * oil fuel value from oil company (BTU/kg) *

conversion factor to Kcal /DryRaw material Feed Rate (Kg/hour)

Heat input from south furnace natural gas stream =south furnace natural gas flow rate from gas meter (ft A3/hour) * Gas fuel value from gas

company (BTU/ft^3) *conversion factor to Kcal /Dry RawmaterialFeed Rate (Kg/hour)

Heat input from south furnace natural oil stream= south furnace oil flow rate (kg/hour) * oil fuel value from oil company (BTU/kg) *

conversion factor to Kcal /Dry Raw material Feed Rate (Kg/hour)

Total heat in -SUMLines (1 to 23)

Outlet Parameters RM I (Table 2)

Heat output from false air= (Dry false air Airfow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature ofAir stream (°C) *

Specific Heat capacity of Air @stream T ***False air is the air as a result of in-leakage in the system. It is estimated to be about 10% of the

stack'sairflow rate

Heat output from stack stream -(Dry stack stream Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *Temperature of Air stream

(°C) * Specific Heat capacity ofAir @ stream T

Heat output from water in stack air stream - (Water mass flow in stack air stream from relative humidity (kg/hour) */Dry Raw material Feed

Rate (Kg/hour)) * Temperature of water in stack air stream (°C) * Specific Heat capacity of water @ stream T

Heat output from Raw material stream = (Raw material mass flow rate after dryer (kg/hour) /Dry Raw material Feed Rate (Kg/hour))

Temperature Raw material after dryer (°C) * Specific Heat capacity of Raw material @ stream T

Heat output from water in raw material stream after dryer-(Water mass fow in raw material steam (kg/hour) /Dry Raw material Feed Rate

(Kg/hour)) * Temperature water in raw material (°C) * Specific Heat capacity of water aAstream T

Heat output from heat loss thru the system walls= Total heat out (SUM lines 14 to 18 and line 20) *0 .025

Heat output released from the vaporization of water - Water mass flow, rate (kg/hr) /Dry Raw material Feed Rate (Kg/hour) * heat of

vaporization of water

Heat out - (SUM Lines (25 to 31)) /0.975 (stack factor)

Other heat escaping the system =Line24

•

Line 32 ** This heat includes the radiation heat loss

Total heat Out -SUMLines (32 to 33)

%Recovery, -(Line 34 -Sum Lines (25 to 27) -Line 33)/(Sum Lines (20 to 23) *100%

Inlet Parameters RM2 (Table 3)

Heat input from combustion fan (CF) _ (Dry combustion Fan Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature of

Air stream (°C) * Specific Heat capacity ofAir @ stream T

Heat input from Fresh Air Damper (FAD) _ (Dry Fresh Air Damper Airfow (kg/hour) /Dry Raw material Feed Rate (Kg/hour))

Temperature ofAir stream (°C) * Specific Heat capacity ofAir @ stream T

Heat input from Raw Material stream = (Dry Raw material Feed Rate (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *Temperature Raw

material Feed before dryer (°C) * Specific Heat capacity of Raw material @ stream T ** The raw material feed rate was used as the reference

material (Kcal /Kg raw material)

Heat input from water in raw material = (Water mass fow in raw material (kg/hour) */Dry Raw material Feed Rate (Kg/hour)) * Temperature

water in raw material (°C) * Specific Heat capacity of water @ stream T

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Heat input from water in combustion fan air stream -(Water mass flow in combustion jan air stream from relative humidity (kg/hour) */Dry

Raw material Feed Rate (Kg/hour)) * Temperature of water in combustion fan air stream (C) * Specific Heat capacity of water @ stream T

Heat input from water in fresh air damper air stream = (Water mass fow, in fresh air damper air stream from relative humidity (kg/hour) * /

Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in fresh air damper air stream

("C) * Specific Heat capacity of water @ stream

T

Heat input from water in furnace Natural Gas stream = (Water mass flow in furnace gas from moisture provided by gas company (kg/hour) */

Dry Raw material Feed Rate (Kg/hour)) * Temperature of water in gas stream (°C) * Specific Heat capacity of water @ stream

T

Heat input from water in furnace oil stream = (Water mass fow in furnace oil from moisture provided by oil company (kg/hour) * /Dry Raw

material Feed Rate (Kg/hour)) * Temperature of water in oil stream (°C) * Specific Heat cap aciy of water (7a, stream T

Heat input from latent heat

of

furnace natural gas =(Dry furnace natural gas fow rate (kg/hour) /Dry Raw material Feed Rate (Kg/hour))

Temperature of natural gas stream("C)*Specific Heat capacity of natural gas @stream T

Heat input from latent heat

of

furnace oil= (Dry furnace oil flow rate (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature of oil

stream (°C) * Specific Heat capacity of oil @ stream T

Heat inputfrom false air = (Dry false air Airfow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature ofAir stream CC) *

Specific Heat capacity ofAir @ stream T *** False air is the air as a result of in-leakage in the system . It is estimated to be about 10% of the

stack's airflow , rate

Heat input from furnace natural gas stream =furnace natural gas flow rate from gas meter (R^3/hour) * Gas fuel value from gas company

(BTU/ft^3) * conversion factor to Kcal /Dry Raw material Feed Rate (Kg/hour)

Heat input from furnace natural oil stream =furnace oil fow rate (kg/hour) * ail fuel value from oil company (BTU/kg) * conversion factor to

Kcal /Dry Raw material Feed Rate (Kg/hour)

Total heat in -SUMLines (I to 13)

Outlet Parameters RM 2 (Table 4)

Heat output from false air - (Dry false air Airflow, (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature ofAir stream (°C) *

Specific Heat capacity of Air @ stream T *"* False air is the air as a result of in-leakage in the system

. It is estimated to be about 10% of the

stack's airflow rate

Heat output from stack stream - (Dry stack stream Airflow (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) * Temperature of Air stream

(°C) * Specific Heat capacity ofAir @ stream T

Heat output from water in stack air stream -(Water mass fow in stack air stream from relative humidity (kg/hour) */Dry Raw material Feed

Rate (Kg/hour)) * Temperature of water in stack air stream (°C) * Specific Heat capacity of water @ stream T

Heat output from Raw material stream - (Raw material mast flow rate after dryer (kg/hour) /Dry Raw material Feed Rate (Kg/hour)) *

Temperature Raw material after dryer (°C) * Specific Heat capacity

of

Raw material @ stream T

Heat output from water in raw material stream after dryer - (Water massflow in raw material steam (kg/hour) /Dry Raw material Feed Rate

(Kg/hour)) * Temperature water in raw material (°C) * Specific Heat capacity of water @ stream T

Hem output from heat loss thru the system walls-Total heat out (SUM lines 14 to 18 and line 20) * 0.025

Heat output released from the vaporization of water - Water mass fow rate (kg/hr) /Dry Raw material Feed Rate (Kg/hour) * heat of

vaporization of water

Heat out = (SUM Lines (15 to 20)) / 0.9 75 (stack factor)

Other heat escaping the system-Line 14- Line 21 ** This heat includes the radiation heat loss

Total heat Out

SUM Lines (21 to 22)

Recovery = (Line 23-Sum Lines (15 to 17)- Line 22)/(Sum Lines (12 to 13) * 100%

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Other Definitions

•

"CP" = Specific Heat Capacity. At a given temperature, this is the heat input expected

from each of the components named above

.

•

"As measure sample." On actual conditions, without moisture adjustments

•

"Moisture calculation." In the case of the air, the relative humidity and temperature is

used along with a Psychometric chart to determine the Kg of water/Kg or air ratios

.

•

"As measured (Dry basis)." Stream of water or material with the moisture removed

•

"Kg/Kg Raw Mix." When performing heat balances it is important to select a reference

variable. In this case, we selected the raw mix feed as a reference variable

.

•

"T

.

:

This is the actual temperature of the material or gas stream

.

•

"Heat." The heat consumption can be obtained by multiplying the Kg/Kg Raw Mix times

the temperature times the CP of the individual values

.

Assumptions Used in Heat Balance

Calculations .

One of the primary tasks in

designing combustion equipment or engineering a complex mineral drying process is the

development of a heat balance .

Development of a heat balance is essentially a detailed

accounting of the distribution of heat input, heat output and system losses . The heat balance

accounting relies on actual test data, mathematical derivations and generally accepted

engineering assumptions. Bejan, A ., "Advance Engineering Thermodynamics," John Wiley &

Sons, 1988. Two of those assumptions used by Petitioner in preparation of the heat balance

calculations for the Raw Mill Dryers were the amount of "false air" input to the system and the

amount of heat loss due to "shell radiation." These two assumptions are utilized in deriving heat

balance calculations, designing drying equipment and improving the efficiency of the cement

manufacturing process. Bhatty, J.I., Miller, F.M. and Kosmota, S.H ., "Innovations in Portland

Cement Manufacturing," Portland Cement Association, 2004

.

For Lafarge cement manufacturing and mineral processing facilities and generally within

the cement industry, an accepted assumption for average "false air" in newer combustion

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equipment and mineral drying systems is a 10 percent value

.

This value takes into account

devices such as expansion joints, inspection doors/ports, normal equipment wear and any other

in-leakage inherent with the system. An accepted assumption for average heat losses due to

"shell radiation" in newer combustion equipment and mineral drying systems is a 2 .5 percent

value. This assumption addresses the radiant heat lost to the surrounding structures of the dryer

or combustion device .

Thermal Energy Recovery Efficiency Calculation

.

The definition of the term "boiler"

at 35 Ill. Admin. Code 720.110 specifies a standard for thermal energy recovery efficiency for a

boiler. The relevant portion of the definition (which is identical to the federal definition) states

:

"While in operation, the unit must maintain a thermal energy recovery efficiency of at least 60

percent, calculated in terms of the recovered energy compared with the thermal value of the fuel"

Calculations to demonstrate compliance with the 60% thermal energy recovery efficiency

standard of Section 721 .110 were performed as described below

:

•

Thermal value of the fuel from lines 24 and 14 in Tables 1 and 4 Raw

Mills 1 and 2 are 67.9089 and 76 .0901 respectively.

•

Recovered Energy = Energy used by the system . This value is calculated

as follows

:

o

The total value of energy used is calculated by subtracting the total

heat out less 1 .5% to account for energy used in the preheating

process of the Raw Mill Dryer

.

o

In order to calculate the recovered energy (energy absorbed) from

the system, to the total heat value calculated above, we will

subtract all heats that leave the system (False air in stack gas, stack

gas, stack gas H2O, and radiation)

0

The values obtained from the step above are 56.1986 and 68.3712

Kcal/Kg raw mix for Raw Mill Dryers 1 and 2 respectively .

•

Finding the thermal energy recovery as per 40 CFR 260 . 1 0(l)(iii): The last

step is to divide the recovered energy (energy absorbed) by the thermal

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value of the fuel producing energy recovery efficiencies of 86 .84% and

82.05% for Raw Mill Dryers 1 and 2 respectively.

As demonstrated by the foregoing calculations (and supported by the heat balance

calculations), the Raw Mill Drying System achieves a thermal energy recovery efficiency

of 86.84% and 82.05% for Raw Mill Dryers 1 and 2, respectively. The thermal energy

recovery efficiency clearly exceeds the Section 720.110 criterion of a minimum of 60%

recovery.

Section 720.132(d)

The extent to which exported energy is utilized;

The definition of the term "boiler" at 35 Ill . Admin. Code 720 .110 specifies a

standard for utilization of the recovered thermal energy for a boiler . The relevant portion

of the definition (which is identical to the federal definition) states : "The unit must

export and utilize at least 75 percent of the recovered energy, calculated on an annual

basis. In this calculation, no credit may be given for recovered heat used internally in the

same unit. (Examples of internal use are the preheating of fuel or combustion air, and the

driving of induced or forced draft fans or feedwater pumps.)"

Internal use of the recovered heat only occurs during preheating every time the

system is started. The preheating hours account for 1 .5% of the total operating hours in a

year. With the loss of 1 .5 percent of the fuel heat input due to preheating the dryer, the

annual energy recovery is estimated to be 82 .40% for Raw Mill Dryer #1 and 79.85% for

Raw Mill Dryer #2. The utilization of the recovered thermal energy clearly exceeds the

Section 720.110 criterion of a minimum of 75% utilization

.

Section 720.132(e)

The extent to which the device is in common and customary use

as a "boiler"functioning primarily to produce steam, heated fluids or heated gases

.

Direct-fired dryers and process heaters are widely used in the production of

cement and other non-metallic mineral products. Cement kilns and the associated

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process heaters and dryers used in the production of Portland cement utilize a tremendous

amount of fuel to prepare and dry the raw materials used in the dry cement manufacturing

process and to produce the extreme temperatures and long residence times needed to

calcine limestone rock, shale, sand and other minerals to produce clinker and ultimately

Portland cement. It is a matter of common knowledge that cement kilns utilize a variety

of fuel types including coal, petroleum coke, specification and off-specification used oil,

used vehicle tires and even hazardous wastes in a safe and environmentally sound manner

under express authorization and approvals from state and federal environmental

regulatory agencies

.

Lafarge operates a large Portland cement manufacturing plant located near

Alpena, Michigan. The Alpena Plant is Lafarge's largest cement-producing facility and

reputed to be the largest cement manufacturing facility in North America . The plant

consists of five cement kilns that produce approximately 2.7 million tons of cement

annually .

Lafarge is committed to sustainable development and the Alpena Plant has served

as a showcase for several environmentally beneficial recycling projects . For example, the

Alpena Plant is one of the few North American cement plants to use waste heat from the

cement kilns to generate steam which drives turbines that produce electricity to power the

plant's internal electrical system. Another recycling opportunity implemented by Lafarge

at the Alpena Plant was the utilization of off-specification used oil as fuel in the Raw Mill

Dryers .

The State of Michigan administers a used oil regulatory program that is virtually

identical to the federal and Illinois used oil management programs

.

Consequently,

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Lafarge consulted with the Michigan Department of Environmental Quality

("DEQ") to

secure approval to combust off-specification used oil fuel in the Alpena Raw Mill Dryers

.

Under the DEQ-administered used oil/RCRA regulations, specifically Michigan DEQ

rules R299.9814 and 299 .9101, Lafarge was required to demonstrate that the Alpena Raw

Mill Dryers satisfied the physical boiler criteria established by USEPA (and adopted by

both Illinois and Michigan), to demonstrate that combustion of off-specification used oil

fuel in the dryers constituted a legitimate use for energy recovery .

The Michigan DEQ reviewed the design, combustion efficiency and energy

recovery attributes of the Alpena Raw Mill Dryers and determined that the Raw Mill

Dryers satisfied the physical criteria established by USEPA (and adopted by Michigan

and Illinois), in the regulatory definition of "boiler ."

Because the DEQ officials

determined that the physical criteria were met, Lafarge was given approval to proceed

with the combustion of off-specification used oil fuel in the Raw Mill Dryers .

The

Michigan DEQ approved the use of off-specification used oil fuel by a detailed analysis

of the dryer information provided by Lafarge, and did not require Lafarge to seek a

variance or Adjusted Standard through the "boiler by designation" process . A copy of

the Michigan DEQ's April 2, 2004 determination is attached hereto as

Exhibit I .

The Raw Mill Dryers utilized at Lafarge's Joppa Plant are virtually identical to

the Alpena Raw Mill Dryers that were given approval by the Michigan DEQ to combust

off-specification used oil

.

With respect to the physical criteria established in the

definition of "boiler," specifically integral design, combustion efficiency and energy

recovery, the Raw Mill Dryers at Joppa and Alpena are virtually identical . The Michigan

DEQ's determination that the Alpena Raw Mill Dryers meet the boiler physical

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characteristics and therefore are authorized to combust off-specification used oil fuel is

an excellent example that such combustion sources are

"in common and customary use

as a "boiler" functioning primarily to produce steam, heated fluids or heated gases

."

Moreover, it demonstrates that the Board's approval to grant the adjusted standard relief

requested in this proceeding would be consistent with the findings of other environmental

regulatory authorities

.

Section 720.132()

Other relevant factors .

The federal used oil/RCRA regulations at 40 CFR 260 .33 specify the procedures

for making a case-by-case determination that a particular combustion device, such as the

Raw Mill Dryers at Lafarge's Joppa Plant, should be considered a "boiler" for purposes

of utilizing off-specification used oil fuels. The federal regulations define the term

"boiler" (40 CFR 260.10), allow the combustion of off-specification used oil in boilers

(40 CFR 279.61), and specify the criteria to determine which combustion devices can be

considered equivalent to a boiler and allowed to combust off-specification used oil (40

CFR 260 .32.) As noted above, the Pollution Control Board has completed "identical-in-

substance" rulemakings to adopt these federal RCRA regulations as the Illinois

regulations applicable to the combustion of off-specification used oil in boilers and

similar combustion devices

.

In promulgating the referenced RCRA regulations, USEPA has provided

explanations of the regulations and discussed application of the rules to specific fact

patterns. Those explanations and interpretations are set forth in the preamble discussions

that accompany the rulemakings published in the Federal Register

.

In its legislative

capacity, the Board has relied on USEPA preamble discussions to support its own

rulemaking efforts and at times, has actually adopted USEPA guidance as mandatory and

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not advisory. (See the Board's recent rulemaking in R03-18 and its determination in that

rulemaking that USEPA's RCRA guidance for delisting hazardous wastes was mandatory

and not solely advisory .) Consequently, the justifications set forth by USEPA to explain

and interpret the criteria for making "case-by-case" boiler determinations can and should

be relied upon by the Board in reviewing Lafarge's request for a case-by-case boiler

determination in this proceeding .

As provided by 35 Ill. Admin. Code 101 .630,

Petitioner requests the Board take offical notice of USEPA rulemakings and guidance on

utilizing used oil fuels .

In its November 29, 1985 rulemaking for the used oil management standards (50

Federal Register

49164), USEPA explained why it was allowing combustion of off-

specification used oil in industrial boilers but not in "

.

. .nonindustrial boilers (e.g., located

in apartment and office buildings, schools, hospitals .)" USEPA focused on the risks of

burning off-specification used oil in such "nonindustrial" combustion sources due to

proximity to highly populated areas . Due to the greater number of "nonindustrial" boilers

and the location of such sources in populated areas, these combustion sources would

potentially expose many more individuals to emissions from burning off-specification

used oil fuels

.

Combustion of off-specification of used oil in industrial and utility boilers was

believed by USEPA as presenting much lower risks because such boilers are not located

in close proximity to populated areas and because

" .

..large boilers or industrial furnaces

may be operated by trained operators and equipped with combustion controls

sophisticated enough to maintain peak combustion efficiency when burning fuels the unit

is not designed to burn.

Further, many industrial furnaces and some boilers are

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equipped with particulate control equipment that may adequately control emissions from

metal-bearing waste fuels. "

As evidenced by USEPA's preamble discussion, the agency considered four basic

criteria in permitting combustion of off-specification used oil in industrial but not

"nonindustrial" combustion sources: (1) location away from populated areas; (2)

operation by trained operators; (3) maintaining good combustion efficiency to destroy

organics; and (4) pollution control equipment to control particulate matter emissions . In

addition, USEPA has defined certain physical characteristics of boilers to distinguish

boilers used to reclaim thermal energy from used oil or waste from other devices

designed primarily to incinerate or dispose of wastes without legitimate thermal recovery

.

In the final RCRA rulemaking for the definition of the term "boiler," USEPA

explained "The integral design test is supplemented by quantified criteria for continuous

and long-term energy recovery. These supplementary tests are designed to ensure that

units that are physically designed as boilers are not actually being used to destroy

hazardous waste." (50 Fed. Reg. 614.)

The use of off-specification used oil fuel in the Raw Mill Dryers at the Joppa

Plant will satisfy all of the criteria relied upon by USEPA to allow combustion of off-

specification used oil in industrial boilers . As set forth above, the design, combustion

efficiency and energy recovery attributes of the Raw Mill Dryers satisfy the physical

criteria established by USEPA for boilers

.

In addition, the Joppa Raw Mill Dryers satisfy the non-physical criteria identified

by USEPA as justifying combustion in industrial boilers versus non-industrial boilers

.

First, the Joppa Plant is located in the sparsely populated, rural Massac County and its

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location is remote from any significant residential development

.

(See Exhibit B

Population Density Map.) The Joppa Plant and the Raw Mill Dryers, in particular, are

operated by trained personnel. The Raw Mill Dryers are equipped with of state-of-the-

art, efficient combustors and operating controls to maximize complete combustion of the

fuels. Good combustion controls are designed into the system to maximize the extraction

of all Btu value from the fuels combusted . Since fuel costs are critical to the overall

profitability of the Joppa Plant, maximizing fuel efficiency is always a top priority, even

if Lafarge is allowed to use lower cost off-specification used oil fuels

.

Finally, the Raw Mill Dryers are equipped with high-efficiency fabric filter

baghouses, cyclones and air separators designed to capture the heated, dried raw

materials and minimize the release of PM and other air contaminants in the exhaust

gases. Maximizing capture of the heated, dried "raw feed" is another component of plant

productivity and profitability that is critical to the overall financial health and long-term

viability of the facility

.

i)

A statement with supporting reasons that the Board may grant the proposed

adjusted standard consistent with federal law . The petitioner must also inform

the Board of all procedural requirements applicable to the Board's decision on

the petitioner that are imposed by federal law and not required by this Subpart

.

Relevant regulatory and statutory authorities must be cited ;

Response :

The Board may grant the case-by-case boiler determination in this

adjusted standard proceeding in full compliance with federal law. Section 7.2 and 22.4(a) of the

Illinois Environmental Protection Act [415 ILCS 5/7.2 and 22.4(a)] require the Pollution Control

Board to adopt regulations that are "identical in substance" to the hazardous waste regulations

adopted by the USEPA. The USEPA hazardous waste regulations implement Subtitle C of the

federal Resource Conservation and Recovery Act of 1976 [RCRA Subtitle C, 42 U .S.C. 6921, et

seq.]

.

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The federal RCRA regulations contain identical provisions for making a determination

that a particular combustion device, such as the Raw Mill Dryers operated at Lafarge's Joppa

Plant, should be considered a "boiler" for purposes of utilizing off-specification used oil fuels

.

That federal regulation is set forth at 40 CFR 260 .32 "Variance to be classified as a boiler ."

Although the Illinois regulatory program uses the term "adjusted standard" rather than

"variance" to describe the agency "case-by-case" boiler determination, the standards, criteria and

procedures are identical

.

In short, the Illinois hazardous waste management regulations are "identical in substance"

to the federal RCRA regulations with respect to making case-by-case boiler determinations for

certain combustion devices

.

Both Illinois and federal regulations provide a mechanism to

determine

" .

..on a case-by-case basis that certain enclosed devices using controlled flame

combustion are boilers, even though they do not otherwise meet the definition of boiler

contained in Section 260.10." The federal regulation is set forth at 40 CFR 260.32 and the

"identical in substance" Illinois regulation is set forth at 35 IAC 720.132. Approval by the Board

of Lafarge's Petition would be consistent with federal law and the implementing RCRA

regulations

.

j) A statement requesting or waiving a hearing on the petition (pursuant to Section

104.422(a)(4) of this Part a hearing will be held on all petitions for adjusted

standards filed pursuant to 35 Ill .Adm. Code 212.126 (CAA)) ;

Response

:

Petitioner waives its right to a hearing on the Petition

.

k)

The petition must cite to supporting documents or legal authorities whenever

they are used as a basis for the petitioner's proof . Relevant portions of the

documents and legal authorities other than Board's decisions, State regulations,

statutes and reported cases must be appended to the petition ;

Response :

Relevant portions of all documents or other information sources that have

been used to support this Petition are attached .

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1)

Any additional information which may be required in the regulation of general

applicability .

Response :

The regulation of general applicability does not specify any additional

information requirements that must be addressed in this Petition . However, Lafarge requests that

the Board consider the determinations made by other regulatory authorities to allow the

combustion of off-specification used oil in controlled flame combustion devices such as Raw

Mill Dryers used in the dry Portland cement manufacturing process. As noted previously, the

Michigan DEQ has determined that the Raw Mill Dryers at Lafarge's Alpena cement plant meet

the physical characteristics of a "boiler" that are specified in the used oil/RCRA regulations and

approved Lafarge's request to utilize off-specification used oil as fuel in those process dryers

.

(See Exhibit J.) The Raw Mill Dryers in use at Lafarge's Joppa Plant are virtually identical to

the Alpena Raw Mill Dryers authorized by the Michigan DEQ to utilize off-specification used oil

fuel. The technical and regulatory analysis conducted by Michigan DEQ officials should be

considered by the Board in evaluating Lafarge's request to utilize off-specification used oil fuel

in the Raw Mill Dryers at its Joppa Plant.

WHEREFORE, Petitioner requests a determination from the Illinois Pollution Control

Board that each of the Raw Mill Dryers operated at the Joppa Portland Cement Manufacturing

Plant satisfy the criteria set forth in Section 720 .132; that each of the Raw Mill Dryers are

"Boilers by designation" within the meaning of 35 Ill. Adm. Code 720.110; and may utilize off-

specification used oil for energy recovery, in compliance with Section 739 .161 of the Board's

regulations (35 Ill. Adm. Code 739 .161) .

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Jon S. Faletto

Hinshaw & Culbertson LLP

456 Fulton St., Suite 298

Peoria, IL 61602

(309) 674-1025

(309) 674-9328 Fax

jfaletto@hinshawlaw.com

Respectfully submitted,

LAFARGE MIDWEST, INC., Petitioner

By :

7

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zg

-_-

letto

ttorney for Petitioner

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LIST OF EXHIBITS

Exhibit A :

Aerial Photograph of Joppa Plant

(Source: Terraserver.com Aerial Photography Service)

Exhibit B :

Map Depicting Joppa Plant and Population Density in Massac County

(Source: USEPA Enviromapper Database)

ExhibitC :

Construction Permit No. 03080024 issued January 14, 2004, authorizing

combustion of on-specification used oil fuel in the two Raw Mill Dryers

.

Exhibit D

:

Annual Emissions Report for 2004 Calendar Year Reporting Period

Exhibit E :

NPDES Permit No. IL0004081 and Permit to Construct No. 2005-EN-3317 for

the new sanitary wastewater treatment facility .

Exhibit F :

Clean Air Act Permit Program ("CAAPP") Title V Operating Permit and Title I

Permit No. 95090119 issued November 14, 2002

ExhibitG :

Potential Supply Sources and Basic Principles for Management of Off-

Specification Used Oil Fuel for the Joppa Raw Mill Dryers

Exhibit H :

Schematic Drawing of Raw Mill System

Exhibit I :

Michigan DEQ Correspondence (April 2, 2004)

- Approval for Off-Specification

Used Oil Fuel in Alpena Raw Mills

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF

:

)

PETITION OF LAFARGE MIDWEST, INC. )

FOR BOILER DETERMINATION THROUGH)

ADJUSTED STANDARD PROCEEDINGS )

Pursuant to 35 Ill. Adm. Code 720.132 and )

720.133

)

Petitioner.

)

Case No. AS

CERTIFICATE OF SERVICE

I, the undersigned, certify that I have served the attached

Petition ofLafarge Midwest,

Inc. for Boiler Determination Through Adjusted Standard Proceedings

upon the person or

agency to whom it is directed, by placing it in an envelope addressed to

:

Illinois Pollution Control Board

Division of Legal Counsel

Attn: Dorothy M. Gunn, Clerk

Illinois Environmental Protection Agency

100 West Randolph Street

1021 North Grand Avenue East

James R. Thompson Center, Suite 11-500

P.O. Box 19276

Chicago, IL 60601-3218

Springfield, IL 62794-9276

and mailing it via UPS Ground Mail from Peoria, Illinois, on this 28t

h

day of March, 2006, with

sufficient postage affixed thereto

.

Respectfully Submitted,

On behalf of the LAFARGE MIDWEST, INC .,

By: Hinshaw & Culbertson LLP

HINSHAW & CULBERTSON LLP

456 Fulton Street, Suite 298

Peoria, IL 61602-1220

309-674-1025

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80212375v1 NEWFILE