|Gossman Consulting, Inc.|
A Review of Potential Solutions to Control Dioxin (PCDD/PCDF) Emissions from Cement Kilns
Presented at the April 2003 A&WMA Hazardous Waste Combustors Specialty Conference
Gossman Consulting, Inc.
45W962 Plank Rd.
Hampshire, IL 60140
kilns first focused on the need to
emissions as part of the BIF regulations over a decade ago. More
recently the Hazardous Waste Combustor
(HWC) MACT and Portland Cement (PC) MACT regulations have imposed
and testing requirements on all cement plants in the United States. Numerous
plants both in the U.S. and around
the world have faced the “surprise” of needing to
measurements that were higher than expected – sometimes
Potential control strategies
based on actual experiences are reviewed in this paper.
QUALITY CONTROL FIRST
looking at control strategies the first
must be addressed when the “surprise” of higher
than expected (or
emission measurements occur is to….check the data!
There have been numerous
circumstances where a poorly designed
test, an inexperienced stack test crew and/or calculation errors have
in erroneously high dioxin emission results1.
GCI continues to see errors
in about 30% of
the reports we review.
These types of
errors can materially impact results and the net impact on corporate
credibility and community relations can be enormous.
including a thorough QA/QC program and
careful selection of stack test crews and analytical laboratories are
Despite rather clear Clean Air Act language to the contrary and EPA’s contention that temperature control alone is sufficient to control PCDD/PCDF emissions, changes in raw materials have remedied dioxin emission problems at some facilities. Over a decade ago it was clear that naturally occurring dioxins and organic precursors found in some limestone, shale and clay were the cause of elevated dioxin emissions from some cement plants2. Finding alternatives to these raw materials became an important strategy for BIF regulated cement kilns. More recently some alternate sources of raw materials have been found to contain organic precursors or dioxins themselves and have resulted in elevated dioxin emissions from cement plants. Table 1 provides examples.
Potentially Problematic Alternative Raw Materials
PCBs that decomposed into dioxins
Organic precursors or dioxins
Secondary aluminum smelting dross
Dioxins or organic precursors
control at the inlet of the APCD is
advocated by EPA to control dioxin emissions from cement kilns. In
many cases it can work.
There is an inverse
between dioxin emissions and APCD inlet temperatures3.
critical point on the curve is
frequently kiln specific, most likely because of gas residence times
temperature measurement location issues.
older kilns improvements in design and
chain sections can lower kiln exit temperature and have the added
improving energy efficiency.
temperature control techniques include water spray systems and air
The down side with many of
the temperature lowering techniques is that additional draft fan
A novel, proprietary
technique for wet kilns developed by Continental Cement Company, LLC
ALTERNATE CONTROL OPTIONS
are a number of alternate control options
be considered, however these may be expensive or problematic to
Gore manufactures a Remedia
The Gore bags for baghouses
actually destroy dioxins as the exhaust gasses are simultaneously
This system has been tested
on cement plants and shown to reduce 90% or more any dioxins present4. This
is a relatively expensive option but
may, nonetheless, be worth exploring if there are no other suitable
alternative raw materials that make up a
small fraction of the kiln feed, yet contain dioxin precursors or even
themselves, feeding the raw materials to the feed shelf in a
preheater/precalciner kiln allow the organics to be destroyed and still
functional use of the alternate raw material.
This however may limit the
volume of the raw material that can
utilized since these materials will not be ground and uniformly
into the raw feed.
In preheater/precalciner kilns with inline raw mills the development of recycling loads of volatile metals is well known4. This same phenomenon with organic precursors can lead to dioxin emissions an order of magnitude greater when a raw mill is off versus operational. Careful design of operating conditions for stack testing and ongoing operations, as well as potential modification for how CKD is recycled back into the system, should minimize this phenomenon.
the understanding of dioxin emissions
strategies for cement kilns has advanced considerably in the last ten
The EPA approach, temperature
control, is not the only methodology available and cannot be counted on
provide operationally acceptable and economically feasible results in
circumstance, yet even in this area innovation potential still exists. An
important part of any ongoing dioxin
emission control strategy is effective testing of alternative raw
Gone are the days of
bringing in a truck full to “just try out”.
That does not mean that a new
stack test is required for every
alternative raw material – despite what a regulator might say. An
effective alternative raw material
testing program, included as part of a facility’s Operations
plan, can eliminate or significantly curtail the need for new stack
each change in raw materials.
1. Gossman, D. Quality Control Review of Mercury and PCDD/PCDF Emissions Data From Cement Kilns Used for MACT Evaluations. A&WMA Conference. Nashville, TN. June, 1996
2. Constans, D. Sources of PCDDs/PCDFs in Cement Kiln Emissions. A&WMA Conference. Nashville, TN. June, 1996.
3. W.L. Gore & Associates, Inc. 101 Lewisville Road – 21921, P.O. Box 1100 Elkton, MD 21922
Influencing Emission Levels
PCDD/PCDFs from Cement Kilns. A&WMA
Kansas City, MO. March,