GENERAL49680

• Permit No: M1977208
• IBM Index Class Name: General Documents
• Doc Date: 6/16/2003
• Doc Name: Human Health Evaluation of Cement Kiln Emissions
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

2.0 Data Summaries and Comparisons
2.1 Permit requirements
2.1.1 Particulate Matter (PM)
Particulate emissions (PM) were measured using two different methods (M29 sampling train
and M26A sampling train). Both of these EPA-approved methods are equivalent approaches
to the measurement of PM and are frequently used together as a quality control check. As
shown in Table 2, both methods were internally consistent within each test (+/- 10%) and
demonstrated similar results for both FF and TDF tests. PM increased by 11% by the M29
train and decreased by 5% by the M26A train when TDF was used compared to FF. If the
results of the two methods are averaged together, the PM concentrations measured during the
source emissions tests represent approximately 27%-28%of the annual permit requirement for
the plant for PM if extrapolated on an annual basis for FF and TDF respectively.
2.1.2 Criteria Pollutants
The effect of TDF on the emission rates of criteria pollutants was mixed (Table 2). Nitrogen
oxides (NOx) and sulfur oxides (SOx) decreased substantially, while Total Hydrocarbons
(THC) and Carbon Monoxide (CO) increased. However, all of these pollutants were measured
at concentrations consistent with satisfactory compliance with the annual permit limits for the
facility (personal communication from Steve Mossbergz).
2.1.3 VOC
VOC emission rates were higher for TDF (0.9 Ib/hr) than for FF (0.2 Ib/hr) but the rates were
extremely low for both tests (Table 2). If these emission rates are extrapolated on an annual
basis, the VOC emissions for the FF test would total 0.8 tons/yr, while TDF VOC emissions
would total 3.6 tons/yr. These emissions represent 0.6% and 2.6% of the permitted VOC levels
for FF and TDF respectively. A more detailed comparison of VOC emission rates for the FF
and TDF tests is provided in Table 5.
2.1.4 HCI
HCI emission rates were similar and very low for both the FF and the TDF test(Table 2). There
are no direct emission rate limits for HCI specified in the permit.
2.1.5 Lead
Lead emission rates from the FF and TDF tests were low in both cases, although TDF did
show an increase (Table 2). Both of these emission rates generate annual emissions for lead
that are 1/1000`h (FF) to 1/600`h (TDF) of the current permit limits.
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