Air Quality Committee Meeting
Tuesday, February 8, 2000
Attendees
Doug Ryan, Audrey-Lyn Stockton, Chuck Lightburn, Steve Harem, Lucinda Smith, Ray.
The meeting began at 7:00 p.m. with a discussion of wood combustion and Holnam's air emissions permit. The Colorado Department of Public Health and Environment (CDPHE) is currently in the process of writing a Title V Operating Permit for Holnam. The permit writing process is very involved, as the permit will regulate all of the cement plant's potential air emissions and related plant processes. Holnam submitted their original Title V permit application on February 23, 1996, and CDPHE's Air Pollution Control Division (APCD) is still working on the draft permit (which is currently over 100 pages long). Before the permit is finalized, the draft will be submitted for public comment. The APCD expects to have the draft ready for public comment in about six weeks.
Audrey-Lyn Stockton noted a concern related to the 'Alternative Operating Scenarios' included in the draft permit which includes a list of alternate fuels and raw materials that Holnam would be allowed to use in the cement-making process. The list contains such items as oil-contaminated soil (which would be used as a source of silica). Chuck Lightburn noted that the list is being revised and some materials have already been removed from the list. Committee members raised some questions regarding permit conditions for switching to alternate fuels or raw materials. For example, would additional stack testing or other emissions monitoring be required? Unfortunately, Holnam's environmental manager was not in attendance to provide specific answers.
Steve Harem presented an idea as to how the Air Quality Committee could evaluate the impact of burning wood products at Holnam. He first listed the pollutants that could potentially be emitted from the combustion of wood products. The list was assembled from EPA emission factor information for various wood burning processes such as those found at oriented strand board (OSB) manufacturing plants. Steve then suggested that each pollutant of concern could be evaluated by asking what the emission rate would be, could emissions be controlled, and how could stack emissions be monitored.
Committee members generally agreed that a test burn and stack testing would be necessary in order to determine the actual emissions. The EPA has emissions data from several types of wood burning processes, but none of these processes are exactly like Holnam's cement calciner or kiln. Chuck suggested that Holnam would be willing to do a 'worst case' test burn using ground wood from the landfill.
Based on AP42 emission factors for wood products, the following possible emissions were identified:
Pollutant(s)
2002 MACT std?
Current CEM?
Likely increased emissions from burning wood?
SO2, Nox, CO, CO2
yes
Yes
Insignificant
PM (is a surrogate for HAPs metals such as lead)
yes
Opacity
Yes
Hydrocarbons
no
Intermittent
?
VOC's
no
No
Yes
SVOC's (semi vol org cmpds)
no
Yes
Dioxins (from Chlorine)
Yes
Yes
Furans (from Chlorine)
Yes
Yes
Formaldehyde
No
Naphthalene
No
Phenol
No
MDI
No
Chlorine
no
PF resin
No
The issue of emissions monitoring was briefly discussed. Holnam's LaPorte plant already has continuous emissions monitors (CEMs) for SO2, NOX, CO, CO2, and Opacity. Technology does not exist for continuously monitoring some of the other pollutants of concern. It is likely that Holnam's Title V permit would require some sort of periodic stack testing to measure these pollutants, but specific requirements are not available. Doug Ryan noted that EPA often regulates hazardous air pollutants (HAPs) by requiring continuous monitoring of some surrogate. For example, it might be determined that lead emissions are one percent of total particulate matter (PM) emissions. In this case, EPA would use PM as a surrogate, limiting lead emissions by adjusting the limit on total particulate emissions. The relationship between lead and PM emission rates could be initially determined and then periodically checked by conducting stack tests.
It was suggested that Holnam should do a more global evaluation of air quality impacts by considering the emissions from all the sources that would be involved in a wood burning project. In addition to the combustion process, this would include wood grinding, trucking, and related fuel handling processes. The committee briefly discussed these other sources of air emissions. In particular, particulate (fugitive dust) emissions are a concern for any wood grinding or wood chip storage operation.
Issues related to the fuel source were also discussed. Air emissions would likely be directly related to the composition of the wood fuel. Would treated wood products such as telephone poles or railroad ties be a problem? Chuck indicated that Holnam did not want to burn any creosote-treated wood. Therefore, the landfill would have to keep such materials out of the fuel. Engineered wood products such as OSB or plywood might be a problem due to the glues they contain. A test burn and stack test would be required to determine whether such materials would be acceptable.
Committee members agreed that another meeting would not be necessary until after Holnam's draft Title V Permit was available and ready for public comment. The meeting was adjourned at 9:00 p.m.
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