BridgeGap Engineering Blog » PCA

Possible Relief for Cement Sector?

Lehigh Ben — Thu, 18 Aug 2011 16:22:53 +0000

Is relief is on the horizon for the cement industry? Recently, two representatives introduced a bill titled “Cement Sector Regulatory Relief Act of 2011.” If passed, this legislation will require the Environmental Protection Agency (EPA) to re-propose three rules aimed at the portland cement industry. These rules were targeting the solid waste incineration initiatives started by many companies.

The president and CEO of the Portland Cement Association (PCA) Brian McCarthy said, “The bill introduced…by Reps. Sullivan and Ross will allow the industry to continue its dialogue with the EPA with the goal of crafting rational and feasible emission standards. We are not shying away from environmental regulations. We take our environmental stewardship seriously and have a long history of investing in continuous improvements that preserve U.S. manufacturing capacity and the economy.” If current regulations remain in place, approximately a fifth of domestic plants could be forced to close and cost the industry $3.4 billion over three years.

PCA Urges Reform of Environmental Laws

Lehigh Ben — Tue, 10 May 2011 21:57:41 +0000

Aris Papadopoulos recently testified before the Congressional Subcommittee on Energy and Power. Papadopoulos, CEO of Titan America and Chair of the Portland Cement Association (PCA), urged Congress to address harmful regulations before they could seriously wreck the economic recovery of the country.

Papadopoulos’s testimony was presented during a hearing to assess the impact of recent EPA regulations on several industrial sectors. His testimony focused on the negative impact that these regulations would place on the economy when demand for cement returns. His evidence was research conducted recently by the Massachusetts Institute of Technology (M.I.T.). M.I.T. has found that the cement industry can take a leading role in reducing greenhouse emissions along with overcoming other environmental challenges. He also warned that if regulations remained unchanged, the cement industry would follow the way of big oil, creating a dependence on foreign imports.

In closing, Papadopoulos remarked, “Congress must craft legislation that mitigates the impacts of harmful regulations. It must replace them with policies that promote job growth, investment certainty, and responsible environmental stewardship. This will revive private sector confidence, create good jobs for Americans and restore economic prosperity.”

EPA in “listening mode” regarding Mercury Emissions

admin — Fri, 19 Jun 2009 14:44:52 +0000

The EPA has formally proposed new regulations to limit the mercury emissions from cement kilns to 43 pounds per million tons of production. They arrived at this figure by examining the top 1/8 of kilns in the US (Recall during our earlier post on Keith Barnett’s presentation that MACT Standards, by law, may be no less stringent than the average emissions from the “best 12 percent” or ‘cleanest’ plants already in operation where data is available).

The PCA is pointing out that mercury emissions have more to do with the raw materials available than the overall operation. In a press release they argue the regulations are unfair and overly burdensome. A PCA spokesman estimates that cement imports could rocket to 43% of demand if the regulation is put in place as currently written.

A spokesman for the EPA says they are in “listening mode” at this time and will consider suggestions from the cement industry.

The Dallas News reported from the EPS public hearing, one of three to be held around the country this week on the subject. As might be expected, the members of the public who attended were not sympathetic to the concerns of the industry.

Edgar Stahl, said he was unsympathetic with industry concerns over the rule’s cost. “Put them out of business until they can make clean cement,” Stahl declared.

The EPA’s proposal to require reductions in mercury and other pollutants from cement kilns is called Proposed Amendments to National Air Toxics Emissions Standards for Portland Cement Manufacturing. You can read the proposal and related documents at www.epa.gov/ttn/atw/pcem/pcempg.html.

As recommended by Richard Pleus, Ph.D. Toxicology, who spoke at the recent IEEE Technical Conference on the subject of Mercury Emissions, “We all want to protect human health and the environment, but in order to do so”:

1. Educate yourself (science needs reliable data – not public opinion – to make good business decisions)

2. Get the science right – “all things are poison and nothering is without poison, only the dose permits something not to be poisonous”.

one nanogram is equal to one drop of detergent in enough water to fill a string of railroad cars ten miles long.
one part per billion is 1 second in 32 years.

3. Understand whether the problem is local or global (volcanic eruptions in the South Pacific cause mercury deposition along the Northern Pacific coast of the US)

4. Communicate, communicate, communicate.

The EPA will take written comments until Sept. 4; then it will consider the comments and issue a final rule by March 31. To comment on the proposal, refer to EPA docket number EPA-HQ-OAG-2002-0051 and use one of the following methods.

Online: Go to www.regulations.gov and follow the instructions for submitting comments.

E-mail: Send a message to a-and-r-docket@epa.gov.

Mail: EPA Docket Center (6102T)

Docket ID No. EPA-HQ-OAR-2002-0051

1200 Pennsylvania Ave. N.W.

Washington, D.C. 20460

How Important is Time in the 21st Century & How Do You Manage It?

experts@bridgegap — Sun, 07 Jun 2009 02:30:39 +0000

How will Business in the 21st Century Look? Sure it depends on your industry… but the value of time… how can you measure it?

Check out this link - Sony played this mind-blowing video at their Executive conference this year

Mind-Blowing Video… time in the 21st century

In the 21st Century where knowledge is relatively cheap, time is nearly priceless and experience can be difficult to find… how do you most effectively structure any business? It seems to the experts at BridgeGap Engineering that relationships you can trust for timely responses and results are of key importance. The value of time will continue to increase as change happens faster.

Economic Recovery?

admin — Sat, 06 Jun 2009 06:53:10 +0000

Notwithstanding the excellent speech by Ed Sullivan at the IEEE Conference we reported on, the Washington Post today reports that job losses slowed dramatically in May, and were far smaller than analysts predictions, fueling hopes that economic recovery is near. While the hoped for bottom in housing has yet to be seen, more promising signs seem to be reported every week. Is all this just the result of deficit spending driven stimulus or is the turnaround real?

IEEE Conference Environmental Workshop

experts@bridgegap — Sat, 06 Jun 2009 00:39:30 +0000

Here is a list of the speakers for the concurrent Environmental Workshop and our notes on what they had to say during their presentation and during the subsequent Q&A Session for conference participants:

1. AB -32: CO2 Climate Change and the Cement Industry by Michael Stevens of National Cement:
• All 6 cement companies and 11 cement plants in California are working together to (1) establish a GHG Emissions Cap for 2020 and to (2) establish mandatory reporting rules.
• California’s intent is to be pre-emptive and thereby autonomous.
• Their concerns: (1) the relatively few low-cost abatement technologies that are available and (2) the severe risk of “Emissions Leakage”.
i. “Leakage” means cement imports from other states or parts of the globe who have higher GHG footprints than California able to import cement into California.
ii. It is not protectionism! The Environment is a Global Issue!
iii. The intent is to avoid another OPEC (Oil Producing Export Countries) Effect where a US-based industry moves overseas.
iv. California desires WTO compliance.
v. California would like to establish “sister plants” in provinces in China.
• Their proposal: A Hybrid concept which combines cap-and-trade with performance standards (credits)
i. Where the PCA decides what the “performance standards” are, such as:
1. The use of SCM’s (Supplementary Cementitious Materials).
2. The “re-carbonization” effect of concrete.
ii. Proposed baseline: 1995.
• Cement industry represents 2% of California’s total CO2 emissions.
2. NESHAP Update by Keith Barnett of the EPA (Office of Air Quality Planning and Standards):
• NESHAP: National Emission Standards for Hazardous Air Pollutants
• The initial standards were written in 1999 (Reconsideration versus Remanded)
• MACT Standards, by law, may be no less stringent than the average emissions from the “best 12 percent” or ‘cleanest’ plants already in operation where data is available.
• In the 2007 Brick Decision, the court found “fundamental failure” by the EPA to set floors (or minimum stringency requirements) at the emission levels actually achieved by the best-performing sources. As a result, the EPA cannot ignore non-technology factors that set HAP limits.
• The March 2007 D.C. Circuit also rejected the EPA’s attempt to ensure that the Brick MACT provided enough leeway to accommodate the operational variability among similar sources (EPA must estimate variability, e.g. wet kilns versus dry kilns).
• Higher emitters are at risk to closure.
• During the establishment of THC Floors by the EPA, only 14 kilns had CEM’s that measure THC so the top 12 percent is only 2 kilns! Based on the fact that THC is so variable based on raw materials found locally, it is easily concluded that there is insufficient data available to set emissions standards.
• Establishment of PM Floors and HCl Floors – Method 321 and Method 5, respectively.
• The proposed rules consider the following pollutants:
i. PM
ii. HCl
iii. THC
iv. Hg
v. HCl
vi. SO2
• Some of the emission-reduction equipment being evaluated includes:
i. broken bag detectors
ii. wet scrubbers
iii. activated carbon injection systems
iv. regenerative thermal oxidizers.
• By 2013, the proposed equipment additions are projected to reduce mercury emissions by 81%-93%, THC emissions by 75%, and Particulate emissions by 90 to 96%.
• The mercury ruling, alone, will affect 93 cement plants and 163 cement kilns in the U.S. The EPA estimates that the capital cost of the program will be about $1.14 billion. However, this is based on 2005 numbers. Today, there are 112 cement manufacturing plants in the U.S. as several new plants have come online in the last four years. The estimated emission control cost for a new 1.2 million-ton-per-year cement line is $17.6 million.
• RTO’s have negative impacts such as increasing CO2 emissions.
• During the Q&A Session, Mr. Barnett seemed to ‘flip-flop’ during the following exchange:
i. In response to concerns about certain plants being unable to survive, Mr. Barnett said, “using the available control technologies, it is possible to meet the limits”.
ii. In response to the EPA’s identification of RTO’s as an “Available Control Technology” when there are only 2 such installations in the US, Mr. Barnett said, “we don’t mandate the use of certain technologies (RTO’s), we only mandate what the emissions limit is”.
• Wet scrubber waste can be used as “gypsum” in the finish mill.
• Activated carbon waste can be recycle and “reactivated”.

3. Mercury Speciation, Evolution and Ultimate Fate in Cement Manufacturing by Connie Senior:
• Mercury emissions can range from less than 1 to more than 1000 micrograms per cubic meter. These are enormous swings! Mercury is difficult to measure in a cement kiln. Stack emissions are 5 to 20 times lower when raw mill is on line.
• There are various measurement methods depending upon the need to distinguish between Hg0, Hg1, Hg2. Distinction between Hg types is important only if you are installing a scrubber because the scrubbers are effective for reducing Oxygenated Hg.
• All measuring methods in flue gas are extractive therefore difficult (for example, the environment is dusty and sampling HgCl2 is very sticky):
i. Impinger methods
ii. Sorbent traps
iii. CEM’s (sampling challenges – variation is great so probably need CEM’s).
• Process affecting Hg in a Cement Kiln:
i. Hg condenses on dust in the FF and onto the feed to a mill.
ii. Typically, 80% can be “scrubbed” by a vertical raw mill.
iii. 50 to 90% can be “scrubbed” across a FF.
iv. If recycling dust, there is no collection. Spikes will occur when CKD is recycled.
• Hg behavior is very complex.
• Temperature control: lowering the temperature of exhaust gas will capture mercury.
• Halogen content can drive change from elemental to oxidized (HgCl2).
• Slip stream dust removal during raw mill running is not an effective control strategy.
• Slip stream to finish mill will reduce Hg emissions during the raw mill down condition, but system removal efficiencies are low so this method may not be effective if significant levels of mercury need to be removed. You need to undertake a complete mass balance of Hg in your system.
• Traditional Mercury Controls:
i. Waste main filter dust (low removal rates)
ii. Wet scrubber (low removal rates and expensive to install & operate)
iii. Activated Carbon Injection
• New Methods for Mercury Controls:
i. Roaster (higher removal rates at lower operating costs due to small system at high concentration rates).
1. Requires heat source (bypass gas, cooler vent, or HGG) to boiling point.
2. Hot EP dust to blending silo.
3. Gas phase Hg then cooled and condenses on Remaining dust. An adsorbent (sorbent) is optional. This Hg-rich dust is then added to finish cement.

4. SNCR & SCR: Their Implication for NOx Reduction in the Cement Industry by Bob Schreiber:
• NOx is 90% NO, 10% NO2.
• SNCR is proven technology:
i. 40% reduction = 400 tons out of 1000 tpy.
ii. Ammonia used as reagent for SNCR.
iii. NSR – normalized stoichiomentric ratio = 1.0 which means assume that it all mixes (no slip).
iv. Reagent cost $669,000 per year.
v. Cost effectiveness in 2008 is about $1,400/ton.
vi. Typically SNCR Systems are able to reduce 30-60% NOx depending upon temperature and turbulence.
vii. Recently being tried in long kilns where the desired temperature range (1850 F) is about 1/3 the way down the kiln.
• There are no successful applications of SCR for NOx reduction in the cement industry:
i. Need to keep the catalyst clean (cleaning system required).
ii. Any amount of SO3 will generate salts which will plug the catalyst.
iii. There is also pressure drop across the catalyst.
iv. SCR requires less reagent than SNCR. However, you need to regenerate the catalyst every 3 years (significant cost).
v. Cannot apply SCR to long wet or long dry because can’t get it at the temperature required … requires gas re-heat on the clean side.
vi. SCR catalyst is poisoned by SO2 (due to higher SO2 to SO3 conversion).
vii. Because of the expense of the catalyst, pilot testing must be performed 18 months in advance.

5. Toxicology of Hexavalent Chromium and Mercury by Rick Pleus:
• Fugitive emissions may be contributing to Hexavalent chrome because heating causes the conversion from Chrome 3 to Chrome 6.
• Trivalent Chromium is needed by the human body.
• Heavalent Chromium (unlike Mercury) is a carcinogen.
• Sources of Mercury:
i. Organic mercury compounds – e.g. fungicides in fish in the form of methyl-mercury.
ii. Inorganic mercury (mercuric) compounds – e.g. medicines and colored paints
iii. Elemental (metallic) mercury – found in thermometers.
• Is the problem global or local? Should there be fish advisories?
i. First, you need to determine the most sensitive endpoints (e.g. babies, elderly, pregnant, and children).
ii. The largest fish have the highest concentration of mercury because Methyl Mercury goes through the food chain.
iii. There are typically higher concentrations of Hg inside the household compared to outside ambient air.
iv. Pregnant women should have fish advisory.
v. Mercury does leave the human body over time.
• Everything is toxic … it all just depends upon the dose!
• The media is often doing a dis-service.
• One nanogram of Cr6 = 1 part per trillion. To put this into perspective, one part per billion is equivalent to just 1 second in 32 years so 1 part per trillion is equivalent to 1/10th of a second in 32 years.
• Don’t pull the fire alarm if there’s no alarm!
• Risk = Outrage + Hazard by Peter Sandman, 2007. Therefore focus on the hazard – not on the outrage!

State of the US Cement Industry Address by Ed Sullivan

experts@bridgegap — Wed, 03 Jun 2009 17:09:45 +0000

The 2009 Conference Program opened with a powerful speech made by Ed Sullivan, Chief Economist for the Portland Cement Association.

(Sullivan, by the way, recently testified to Congress on the stimulus package and has received high praise for the accuracy of his predictions).

1. Short Term Forecast: The Bad News: ‘Green shoots’ of recovery? … What green shoots?

We have not bottomed out and we will remain dramatically depressed because an economy cannot truly recover until people are employed: The number of job losses from Novemember 2008 through April 2009 are staggering (550,000 to 700,000 per month) and just because the job losses have slowed does not mean that we are recovering. Since 2007, there have been 2.7 million job losses.
The impacts of the housing crisis will continue to be felt for many months and the private sector for construction will not recover before end of 2010.
There is no near-term relief until people start to go back to work and, once this happens, the point of “full recovery” is 2 years off .
The recovery will be based on US Economic Policy.
Historically, this will be known as THE GREAT RECESSION.
Considering imports and plant closures, the decline is 45 million metric tons of cement in 2010.
This is due to MARKET IMBALANCES. The US Cement Industry has embarked on its most aggressive period of expansion in history (25 million tons of new capacity). The recession began in 2007 and the US Cement Industry did not feel it because import reductions absorbed the imbalances. At the same time, changes in regulations for Supplementary Cementitious Materials added another 2 million tons of “new capacity”.
Plant closures (16).
Plant utiliztion rates will decline: 80% projected.
Stimulus Package will provide some relief, but hardship facing the industry will not be avoided.
Further plant closures may materialize.

2. Medium Term Forecast: The Good News: ‘ROBUST RECOVERY’

In 2011 and 2012, 3 million new jobs will be added!
Cycles are temporary. Recssions are caused by market imbalances!
The economy will come back and it is going to come back with a flury!
You can expect to pay higher taxes because the government is funding the recovery with debt.
There will be higher interest rates, higher taxes, and potentially higher inflation.
The American consumer may show significantly different spending patterns (e.g. savings versus debt) which adds the potential of slower longer term economic growth.
Moreover, the past cyclical peaks will not “fully recover” until 2015.
We will be rewarded for our short-term pain: The Highway Bill will be HUGE and it will be designed for the long-term (using concrete) rather than the short-term (tar & chip)!
Pent-up demand will be released.
There will be sustained double digit gains in 2011 and 2012, but we don’t reach the past cyclincal peak until 2015.

3. Long Term Forecast: The Great News: Demographics will ‘Drive’ the Demand for Cement

65 million new people will “drive” the US economy from 2007 to 2030.
You can take US Cencus Projections to the bank: There will be 50 million additional licensed drivers in the US .
Just to maintain the roads, there has to be a 25% increase in spending on roads.
For “Green” reasons, the Government will enact measures to avoid highway congestion and fuel loss.
Highways Systems will be expanded. The Obama Administration recognizes this as a problem.
At the same time, we will have SYCHRONIZED WORLD GROWTH: characterized by emerging middle class in developing economies.
Oil Prices will increase again.
New Cocker Installations: liquid asphalt: margins grow. Concrete has a big advantage: There will be 5.5. million tons of additional demand per year just based on increase market share for concrete over asphalt.
Add the impact of ICF Home Construction (resulting from Lifetime CO2 savings by using concrete instead of wood).
Non-residential construction will increase:
i. Clean energy = hydro, wind, nuclear … lots of cement!!!
ii. Successful clean energy … 28 licenses submitted for new nuclear power: the demand for cement will be greater than anyone realizes.
iii. Climate change are not in anyone’s estimates (based only on economics and demographics).
iv. Outlooks is extremely bullish for cement even when the increased use of Supplemental Cementitious Materials are factored in.
v. Cement production, if not increased, will create a 67 MTPA SUPPLY GAP.
vi. ECONOMICALLY, POLITICALLY DEMOGRAPHICALLY, OUR COUNTRY IS GOING TO GROW.
The LONG TERM 67 MTPA SHORTAGE cannot be bridged by new imports because:
1. Port congestion will become a huge issue.
2. The issue will be freight rates which run parallel to oil prices.
Mercury emissions may cause 14 plants to be shut down (-20 MTPA).
THE SUPPLY GAP WILL WIDEN: 67 MTPA becomes 87 MTPA
Climate change initiatives will force the closure of any remaining wet kilns further growing the gap!!
Domestically, it is projected that 40 new cement plants will need to be constructed given the supply gap, the high oil prices, and the changes in construction practices driven by climate change.

Conference Attendance

experts@bridgegap — Sun, 31 May 2009 16:45:16 +0000

Conference Organizers are pretty satisfied with the level of attendance (600 people are reportedly registered) in consideration of the weakened economy. Even more satisfying is that 80 of the 600 are cement producers. California Portland and TXI are key contributors to attendance. Ash Grove has only one registrant, but reportedly will be back in 2010 to support the conference in a big way as long as economic conditions do not worsen. Lehigh-Hanson has one registrant. Titan America has one registrant. Holcim has zero registrants. Holcim is currently in “start-up” mode for the world’s largest cement plant (12,000 tpd) which is the 2011host plant. The sites for future year’s are as follows:

2010 – Colorado Springs – GCC – Pueblo – March 27-31, 2010
2011 – St. Louis – Holcim – Ste. Genevieve – May 22-26, 2011
2012 – San Antonio – Cemex – Balcones – May 13-17, 2012
2013 – Orlando – American Cement
2014 – Calgary/Banff – Lafarge – Exshaw

Welcome to BridgeGap Engineering

experts@bridgegap — Sat, 30 May 2009 17:33:55 +0000

BridgeGap Engineering – Where your Cement, Minerals or Aggregate challenge is our opportunity to provide solutions.

We hope you can take some time to surf the site and get an idea what BridgeGap Engineering is about. This site and blog are going ‘live’ at the end of May 2009. It may take a bit to perfect, but enjoy the changes as time goes by.

Thanks for investing the time – make a call or send and e-mail. We’d love to make contact more directly.