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facility and expects this to remain constant going forward.The facility also has additional 12-month rolling <br /> fuel use limits for pipeline quality natural gas and propane of not more than 381,373 one million British <br /> Thermal Units. The cement kiln itself is subject to a multitude of control technologies and monitoring <br /> required under maximum achievable control technology LLL(the maximum achievable control technology <br /> for Portland cement manufacturing). For the purposes of this analysis, the agencies assume that the 53 <br /> percent primaryfuel stock supplied bythe King II Mine is an appropriate surrogate for permitted emissions <br /> at the Pueblo facility. The King II Mine coal feeds the kiln, and it is reasonable to delineate the total site <br /> emissions required to support the kiln operations as attributable to the coal itself because no other <br /> sources of coal are sent to Pueblo at this time and that is not expected to change in the future. The <br /> differences in the fuel compositions used at the Pueblo facility would provide for varying emissions <br /> profiles. The available literature suggests that on average TDF can provide for lower particulate matter <br /> emissions on an energy density basis. None of the other criteria pollutants were shown to have a <br /> statistically significant difference for TDF firing vs.traditional fuels(including coal).The agencies note that <br /> some of the literature suggests that CO2 emissions from TDF would be reduced by 8 to 20 percent <br /> compared to traditional fuels. However,for this analysis the range of potential reductions(from tire types <br /> and computational methods) and equipment and firing practices associated with using TDF in the <br /> literature is highly variable and thus too speculative to support any further delineation of emissions at the <br /> Pueblo facility(TDF 2017). Where the literature suggests a pollutant would be solely attributable to coal, <br /> that value will be disclosed (e.g., Hg). <br /> Table 2.2-14 Pueblo Facility King II Emissions (tpy) <br /> Source PM10 PIVI2.5 CO NOx VOC S02 CO2e1 Hg <br /> (lb/yr) <br /> Facility 221 217 588 604 52 505 735,230 25 <br /> 1CO2e emissions are based on 2017 EPA FLIGHT reported emissions <br /> The GCC Rio Grande Tijeras Plant (Table 2.2-15) has similar operations to that of the Pueblo facility and is <br /> covered under NM Title V permit#532.The permit and underlying construction permits provide for all the <br /> same source requirements (controls and monitoring) as the Pueblo facility and is publicly available from <br /> the Albuquerque Environmental Health Department for review. <br /> Table 2.2-15 Tijeras Facility King II Emissions (tpy) <br /> Source PM10 PIVI2.5 CO NOx VOC S02 CO2e1 Hg <br /> (lb/yr) <br /> Facility 135 66 790 772 79 21 306,846 10 <br /> 1CO2e emissions are based on 2017 EPA FLIGHT reported emissions <br /> Unlike the Pueblo facility, the Tijeras kiln is fired entirely on coal (a minor amount of natural gas is used <br /> for startup) and the kilns themselves do not appear to have a fuel throughput limits, but rather <br /> performance-based clinker production limits (33.7 tons/hour). Similarly, the permit does not contain <br /> explicit limits for GHG and mercury emissions but does provide for mercury monitoring requirements and <br /> performance-based standards. Facility GHG emissions were obtained from the USEPA's Facility Level GHG <br /> Tool (FLIGHT)for 2016.The data and methodology (subpart C, equation C-2a)that GCC utilized to report <br /> Dunn Ranch Area LBA and Mining Plan Modification 22 <br /> Technical Resources Report <br />