I · Web viewDavenport Plant - GHG Monitoring Plan March 2014 Davenport Plant - GHG Monitoring Plan...

GHG MONITORING PLAN

Continental Cement CompanyDavenport Plant

March 6, 2014

1

Davenport Plant - GHG Monitoring PlanMarch 2014

TABLE OF CONTENTS

I. INTRODUCTION....................................................................................................................3

II. THE DESIGNATED REPRESENTATIVE [40 CFR 98.4].................................................3

A. ALTERNATE DESIGNATED REPRESENTATIVE.........................................................3

B. PROCEDURES FOR DELEGATION OF AUTHORITY...................................................4

III. GHG EMISSION SOURCE INFORMATION [40 CFR 98.3(g)(5)(i)(B)].........................4

A. EMISSIONS DATA COLLECTION PROCEDURES........................................................5

B. NON-EMISSIONS DATA COLLECTION PROCEDURES..............................................7

C. RESPONSIBLE POSITIONS FOR DATA COLLECTION...............................................9

D. QUALITY ASSURANCE AND MAINTENANCE PROCEDURES...............................10

IV. RECORD RETENTION.....................................................................................................10

V. REVIEW AND REVISION OF PLAN..............................................................................11

APPENDIX A – Review and Revision Log..............................................................................12APPENDIX B – Table C-1 to Subpart C of 40 CFR Part 98....................................................14APPENDIX C – Notice of Delegation of Authority.................................................................17APPENDIX D – List of Approved Methods for Fuels Analysis...............................................19

2


GHG MONITORING PLANDAVENPORT PLANT

I. INTRODUCTION

A facility that is required to report greenhouse gas (GHG) emissions in accordance with 40 CFR 98 Mandatory Greenhouse Gas Reporting must prepare and maintain a written GHG Monitoring Plan as described in §98.3(g)(5) of the regulations. The elements required by the regulations include the following items:

Identification of positions of responsibility (i.e. job titles) for collection of the GHG emissions data;

Explanation of the processes and methods used to collect the necessary data for the GHG calculations; and

Description of the procedures and methods that are used for quality assurance, maintenance and repair of all continuous monitoring systems, flow meters, and other instrumentation used to provide data for the GHGs reported under this part.

This GHG Monitoring Plan has been developed for CCC’s cement manufacturing plant located in Buffalo, Iowa. The plan identifies the GHG emissions generating sources and the information listed above for these sources. In addition, this document outlines the GHG emissions recordkeeping system and contains a log for tracking revisions to the plan.

II. THE DESIGNATED REPRESENTATIVE [40 CFR 98.4]

The Designated Representative (DR) for the Davenport Plant is the Plant Manager who shall be responsible for certification and submittal of the annual GHG report. The Plant Manager is authorized by CCC to certify and submit GHG related documents on the company’s behalf. The current Designated Representative is identified in the Certificate of Representation on file with the USEPA. A change in the identity of the Designated Representative requires a new submittal of the Certificate of Representation via the e-GGRT electronic system.

A. ALTERNATE DESIGNATED REPRESENTATIVE

In accordance with §98.4(f), an Alternate Designated Representative (ADR), the Environmental Manager for the plant, has been identified in the Certificate of Representation. The Environmental Manager, as the alternate designated representative, may act on behalf of the Plant Manager in his function as Designated Representative. A change in the identity of the Alternate Designated Representative requires a new submittal of the Certificate of Representation via the e-GGRT electronic system.

3


B. PROCEDURES FOR DELEGATION OF AUTHORITY

The Plant Manager or Environmental Manager may delegate their authority for electronic submittal/access to other individuals. A Notice of Delegation must be submitted electronically to USEPA containing the following items:

1. Contact information for the Plant Manager or Environmental Manager.2. Contact information for each delegated individual.3. A list of submissions authorized.4. The name of the facility.5. Signed certification statement.

The Notice of Delegation is performed using the e-GGRT system.

III. GHG EMISSION SOURCE INFORMATION [40 CFR 98.3(g)(5)(i)(B)]

CCC is subject to the mandatory greenhouse gas annual reporting requirements because it is located in the United States and belongs to the cement production source category listed in 40 CFR 98.2(a)(1). GHG emissions from all source categories present at the facility for which calculations methodologies are provided in the rule must be calculated and reported. The GHG emitting sources present at the facility are subject to the requirements of Subpart H of 40 CFR 98, Subpart H requires reporting of process and combustion CO2, CH4 and N2O emissions from the cement kiln. In addition, Subpart H requires reporting of CO2, CH4 and N2O emissions from all other stationary combustion sources in accordance with Subpart C of 40 CFR 98.

Table 1 provides a listing of emission units at CCC that trigger reporting requirements under Subpart C and H of 40 CFR 98. Each source or group of sources that are aggregated have been assigned a GHG emission source number. The fuel streams associated with the source and the emission calculation methodology are also identified.

4


Table 1: Identification of GHG Emission Sources

GHG Source ID/

Emission Source ID

Unit Description

Max Design Rate or

Rated Heat Input

Capacity

Fuel(s) Combusted

Applicable Subpart

CPGHG1/EU0466-1

PH/PC Cement Kiln and RM Air Heater

145.3 tph clinker356.5

MMBtu/hr

Coal, Coke, Fuel Oil, Natural Gas, Used Oil, TDF, PDF, SWDF, MBM, Comp Fuels, ethanol, DDGS, BDPB

Subpart H

GPGHG2 Building heaters, hot water heaters (I-10, I-11, & others), kiln pilots (All natural gas uses except for the Coal Mill Heater)

<250 MMBtu/hr

Natural Gas Subpart C

GHG3/EU0667-2

Coal Mill Air Heater

0.01 MMcf/hr Natural gas Subpart C

GHG4/EU0020-1

Emergency Generator

335 hp #2 Fuel Oil Subpart C

GHG5/EU0030-1

Diesel Water Pump 196 hp #2 Fuel Oil Subpart C

CPGHG6 Quarry Garage and miscellaneous plant heaters

<250 MMBtu/hr

Propane Subpart C

CPGHG7 ASF Building Heaters

<250 MMBtu/hr

Propane Subpart C

The kiln is equipped with a CO2 continuous emissions monitoring system (CEMS) meeting the criteria outlined in 98.33(b)(4)(iii). GHG emissions from the kiln’s process and combustion operations are determined by operating and maintaining the CEMS to measure CO2 emissions according to the Tier 4 Calculation Methodology specified in Subpart C.

The emissions from the other stationary combustion units at the Davenport facility include a raw mill air heater, a coal mill air heater, space heaters and miscellaneous water heaters all of which combust natural gas. In addition, there are emergency generators and a water pump that use #2 fuel oil and building heaters that use propane. The natural gas burning units have been combined as a common pipe GHG emission source.

A. EMISSIONS DATA COLLECTION PROCEDURES

The CO2 emissions from the kiln are required to be determined using the Tier 4 calculation methodology in accordance with 40 CFR 98.83(c) and 98.33(a)(4). Tier 4 mandates the use of a CO2 CEMS and a continuous stack gas flow meter. If CO2 concentration is monitored on a dry

5


basis, a correction for the stack gas moisture content is required, using either continuously monitored stack gas moisture monitor in accordance with 40 CFR 75.11(b)(2) or the default moisture percentage from 40 CFR 75.11(b)(1). Hourly measurements of moisture-corrected CO2

concentration and stack gas flow rate are first converted to CO2 mass emission rates in metric tons per hour then multiplied by the operating time in that hour to convert it to metric tons. Hourly mass emissions are summed over each calendar quarter and the quarterly totals are summed to determine the annual CO2 emissions.

CH4 and N2O emissions from the kiln fuel combustion are calculated using Equation C-10 in 98.33(c)(4) for units that use Tier 4 calculation methodology:

CH4 or N2O = 0.001 x (HI)A *EF (Eq. C-10)

where:

(HI)A = Cumulative annual heat input derived from reports required under 75.64 or from the best available information (MMBtu).

EF = Fuel specific emission factor from Table C-2 (kg CH4 or N2O per MMBtu) in Subpart C- General Stationary Fuel Combustions Sources

1. Emissions Data Acquisition

The CEMS data acquisition system (DAS) collects and records the information from the continuous CO2, stack gas flow rate and stack gas moisture monitors. Hourly average CO2

concentration, flow rate and moisture content values are used to calculate the hourly CO2 mass emission rate using equations C-6 and C-7 of 40 CFR 98.33(a)(4). The hourly CO2 mass emission rates are multiplied by the operating times and summed for each calendar quarter and the quarterly CO2 emissions are summed for the calendar year to yield annual CO2 emissions in metric tonnes.

The cumulative annual heat inputs (HI)A, as required to calculate CH4 and N2O emissions, are determined based on fuel analysis for the higher heating value (HHV) of each fuel stream. The HHV of each solid fuel stream is determined by obtaining a sample for each lot and conducting analysis for heat content in accordance with ASTM methods using a bomb calorimeter. Natural gas HHV information is provided by the supplier at least twice per year.

2. Missing Data Procedures

In accordance with 40 CFR 98.35, for missing records of CO2 concentration, stack gas flow rate, percent moisture, and fuel usage, a substitute data value must be used in place of the missing parameter. The CEMS data acquisition system (DAS) will replace invalid hourly CO2

concentration data and flow rate data in accordance with the missing data substitution procedures in 40 CFR Part 75. If HHV analysis of a fuel stream is not available as required, the substitute value for missing fuel HHV data will be the arithmetic average of the valid recorded value of the parameter immediately preceding and immediately following the missing data timeframe. If no valid recorded data is available, the substitute value will be the first valid value obtained after the

6


missing data period. In the event of missing stack gas moisture data, the best available estimate of the stack gas moisture will be determined and substituted into the calculations.

CCC will document and retain records of the procedures used to determine all substitute data values for fuel usage and production amounts.

B. NON-EMISSIONS DATA COLLECTION PROCEDURES

1. Clinker Production Data

The process control system continuously monitors the kiln system feed rate as determined by the impact flow meter. The feed rate is converted to a clinker production rate using the plant’s predetermined conversion factor. The Plant Information Reporting (PIR) system compiles the continuous process control system information into daily, monthly and annual totals. Periodic adjustments to the PIR system are done in accordance with the CCC Standard Method for Physical Counts of Finished Goods.

Missing Data: Whenever a quality-assured value for monthly clinker production is not available, a substitute value will be determined using accounting information or the maximum theoretical production for the missing time period.

2. Operating Hours

Operating hours of the kiln is recorded and maintained in the DAS. Operating hours of the other stationary combustion units recorded and maintained in the operating record log.

3. Cement Production Data

Monthly cement production is required to be reported in the annual report. The process control system continuously monitors the feed rate to the finish mill as determined by the weigh scales. For the finish mill system, the feed rate is equivalent to the finished cement production rate. The PIR system compiles the continuous process control system information into daily, monthly and annual totals. Periodic adjustments to the PIR system are done in accordance with the CCC Standard Method for Physical Counts of Finished Goods.

Missing Data: Whenever a quality-assured value for monthly cement production is not available, a substitute value will be determined using accounting information or the maximum theoretical production for the missing time period.

4. Fuels Combusted

Coal/Coke: The process control system continuously monitors the fuel feed rate as determined by the weigh feeders. The PIR system compiles the continuous process control system information into daily, monthly and annual totals. Periodic adjustments to the PIR system are done in accordance with the CCC Standard Method for Physical Counts of Finished Goods. If data for carbon content is not provided by the vendor in periodic reports, at least an annual grab sample of the storage pile will be analyzed.

Diesel Fuel: The volume of the loads delivered divided by the operating time of the alternate fuel system for the kiln determines the kiln burn rate. Receipts plus beginning inventory minus

7


ending inventory gives us our burn rate for PIR less any amount utilized by the emergency engines onsite. Usage is recorded monthly.

Used Oil: Flow meters measure instantaneous usage. This is confirmed with level indicators. Monthly adjustments for PIR are based on receipts plus beginning inventory minus ending inventory to determine true monthly usage.

Natural Gas: The process control system continuously monitors the fuel feed rate as determined by the revenue meter. The PIR system compiles the continuous process control system information into daily, monthly and annual totals. Higher heating values determined by approved ASTM Methods are provided semi-annually by the supplier.

Propane: Volumetric measurements are taken from the revenue meter associated with the delivery vehicle and are used to determine monthly usage rate.

Missing Data: A substitute value will be determined from the arithmetic average of the data immediately preceding and following the missed data point. If the “after” values are not available, the “before value” or the best available estimate based on all available process data may be used. As an alternative, accounting information may be used for the missing period to determine a substitute value r by sampling and analysis as appropriate.

5. Biomass Combusted

As of the date of this plan, the only biomass combusted at the Davenport plant is glycerin and corn/bean seeds in the kiln system. However, the plant is permitted to utilize various other forms of biomass. Quantities of the biomass combusted are documented based on shipping manifests and applicable measuring devices (e.g., glycerin).

8


C. RESPONSIBLE POSITIONS FOR DATA COLLECTION

Table 2: List of Job Positions Responsible for Data Collection

DataResponsible Party (Title) Description of Responsibilities

Collection Frequency

Monthly CO2 emissions CEMS DAS

1. Sum hourly CO2 mass emissions from the CEMS on a monthly basis2. Sum monthly totals to determine annual CO2 emissions

Monthly

Annual Heat Input from Solid Fuels Quality Manager Determine cumulative annual heat input from

combustion of fuel Annually

Annual Heat Input from Natural Gas Quality Manager Determine cumulative annual heat input from

combustion of fuel Annually

Solid Fuels UsageProduction

Manager and Plant Controller

Record usage of solid fuels combusted in kilns Annually

Solid Fuels Usage Quality Assurance

Maintenance Manager Calibrate weigh scale accuracy. Annually

Natural Gas UsageProduction


Record usage of natural gas combusted in kilns and stationary combustion units from monthly bills

Annually

Natural GasQuality Assurance Supplier Calibrate flow meter Annually

Clinker ProductionProduction


Record kiln feed usage ratesPhysical inventory and inventory adjustment procedures

Annually

Clinker Production Quality Assurance

Maintenance Manager Calibrate kiln feed weigh scale accuracy. Annually

Cement ProductionProduction


Record cement production Annually

Cement Production Quality Assurance

Maintenance Manager Calibrate weigh scale accuracies. Annually

Operating Hours Production Manager Record operating hours for each kiln. Annually

Calibration Drift Assessments CEMS DAS

Record results of all calibration drift assessments for the CO2 monitor and the flow rate monitor

Daily

Cylinder Gas Audits Environmental Manager Record results of all cylinder gas audits Quarterly

(3 of 4)

RATA Environmental Manager

Record results of RATAs on the CO2 monitor systems Annual

Missing Data Periods and Substitution Records

Environmental Manager

Record any instances of missing data and data substituted As occurring

9


D. QUALITY ASSURANCE AND MAINTENANCE PROCEDURES

The CO2 and flow rate monitors must be certified to use the Tier 4 methodology. Per 98.34(c)(1), The calibration drift test and relative accuracy test audit (RATA) procedures of Performance Specification 3 in appendix B to part 60 of this chapter (for the CO2 concentration monitor) and Performance Specification 6 in appendix B to part 60 of this chapter (for the continuous emission rate monitoring system as outlined in Appendix A to 40 CFR Part 60.

Per 98.34(c)(3), the on-going quality assurance procedures in appendix F to 40 CFR Part 60 are followed, including:

daily calibration drift assessments for the CO2 and flow monitors, cylinder gas audits of the CO2 concentration monitor in three of the four quarters

of each year (except for non-operating quarters), and annual RATAs of the CO2 concentration monitor and the continuous emission rate

monitoring system. The continuous emission rate monitoring system RATA need only be done at one operating level representing normal processing conditions.

Maintenance procedures for the CEMS are documented in the maintenance manual and standard operating procedures of the plant.

Quality assurance requirements for measuring fuel feed rates when estimating the cumulative annual heat input for equation C-10 are not specified in Subpart C. However, procedures used to ensure the accuracy of fuel usage estimates for determining emissions from stationary combustion sources must be documented in accordance with 98.3(g)(5)(i)(C). Solid fuel usage is based on weigh belt measurements. Calibration of the weigh belt is conducted annually using an internal standard operating procedure. The weigh belt has a relative accuracy of 5 % or better. The electrical department will also check the calibration annually. Natural gas usage is determined using monthly supplier bills which are based on the flow meter maintained by the supplier. The flow meter measures natural gas entering the facility. Records of inventory are retained for liquid fuels to determine usage.

IV. RECORD RETENTION

The following records are required to be retained for three years.

A list of all GHG emission generating units or activities, The data used to calculate GHG emissions for each unit or activity, GHG emission calculations, Analytical results for all parameters used to calculate GHG emissions, Facility operating data or process information used to calculate GHG

emissions, Annual GHG emission reports, Missing data information including duration, corrective actions, cause and

preventative measures taken, A written GHG Monitoring Plan, The results of QA/QC tests of measurement instrumentation, The maintenance records for all measurement instrumentation,

10


The “company records” utilized and an explanation of how they are used,

These records must be available in an easily accessible format for inspection and review.

V. REVIEW AND REVISION OF PLAN

As specified by 40 CFR 98.3(g)(5)(iii), the GHG Monitoring plan must be revised as needed to reflect changes in production processes, monitoring instrumentation, and quality assurance procedures; or to improve procedures for the maintenance and repair of monitoring systems to reduce the frequency of monitoring equipment downtime.

The GHG Monitoring Plan will be reviewed at least annually. A review is required when there is a change in production processes, monitoring instrumentation, quality assurance procedures or any other changes that affect the determination of GHG emissions. The GHG Monitoring Plan will be revised to reflect the changes identified during a review. Review and revisions will be documented in the log located in Appendix A of this document.

11


APPENDIX A – Review and Revision Log

12


Date Description of Review/Revision Pages RevisedPerson Making

RevisionsMay 2011 Review, no revisions made N/A Bonita Berry

March 2014 Revision to update for CEMS All Schreiber, Yonley

December 2018 Changed from Lafarge to CCC All Bonita Goode

13


APPENDIX B – Table C-1 to Subpart C of 40 CFR Part 98

14


15


16


APPENDIX C – Notice of Delegation of Authority

17


For The Designated Representative or Alternate Delegating AuthorityName:

Address:

Email address:

Phone No.:

Fax No.:

For The Agent Delegated AuthorityName:

Address:

Email address: Delegated Electronic Submissions:

Phone No.: 1.

Fax No.: 2.

“I agree that any electronic submissions to the Administrator that is by an agent identified in this notice of delegation and of the type listed, and for the facility designated, for such agent in this notice of delegation and that is made when I am a designated representative or alternate designated representative, as applicable, and before this notice of delegation is superseded by another notice of delegation under §98.4(m)(3) shall be deemed to be an electronic submission certified, signed and submitted by me. Until this notice of delegation is superseded by a later signed notice of delegation under §98.4(m)(3), I agree to maintain an e-mail account and to notify the Administrator immediately of any change in my e-mail address unless all delegation of authority by me under §98.4(m) is terminated.”

________________________________________________________Designated Representative or Alternate Designated Representative

_________________________________Date of Delegation

18


APPENDIX D – List of Approved Methods for Fuels Analysis

19


§98.34(a)(6)(i) ASTM D4809–06 Standard Test Method for Heat of Combustion of Liquid Hydrocarbon Fuels by Bomb Calorimeter (Precision Method) (incorporated by reference, see § 98.7).

(ii) ASTM D240–02 (Reapproved 2007) Standard Test Method for Heat of Combustion of Liquid Hydrocarbon Fuels by Bomb Calorimeter (incorporated by reference, see § 98.7).

(iii) ASTM D1826–94 (Reapproved 2003) Standard Test Method for Calorific (Heating) Value of Gases in Natural Gas Range by Continuous Recording Calorimeter (incorporated by reference, see § 98.7).

(iv) ASTM D3588–98 (Reapproved 2003) Standard Practice for Calculating Heat Value, Compressibility Factor, and Relative Density of Gaseous Fuels (incorporated by reference, see § 98.7).

(v) ASTM D4891–89 (Reapproved 2006) Standard Test Method for Heating Value of Gases in Natural Gas Range by Stoichiometric Combustion (incorporated by reference, see § 98.7).

(vi) GPA Standard 2172–09 Calculation of Gross Heating Value, Relative Density, Compressibility and Theoretical Hydrocarbon Liquid.

§98.34(b)(4)

(i) AGA Report No. 3, Orifice Metering of Natural Gas and Other Related Hydrocarbon Fluids, Part 1: General Equations and Uncertainty Guidelines (1990) and Part 2: Specification and Installation Requirements (2000) (incorporated by reference, see § 98.7). (ii) AGA Transmission Measurement Committee Report No. 7, Measurement of Gas by Turbine Meters (2006) (incorporated by reference, see § 98.7).

(iii) ASME MFC–3M–2004 Measurement of Fluid Flow in Pipes Using Orifice, Nozzle, and Venturi (incorporated by reference, see § 98.7).

(iv) ASME MFC–4M–1986 (Reaffirmed 1997), Measurement of Gas Flow by Turbine Meters (incorporated by reference, see § 98.7).

(v) ASME MFC–5M–1985 (Reaffirmed 1994), Measurement of Liquid Flow in Closed Conduits Using Transit-Time Ultrasonic Flowmeters (incorporated by reference, see § 98.7).

(vi) ASME MFC–6M–1998 Measurement of Fluid Flow in Pipes Using Vortex Flowmeters (incorporated by reference, see § 98.7).

20


(vii) ASME MFC–7M–1987 (Reaffirmed 1992), Measurement of Gas Flow by Means of Critical Flow Venturi Nozzles incorporated by reference, see § 98.7).

(viii) ASME MFC–9M–1988 (Reaffirmed 2001), Measurement of Liquid Flow in Closed Conduits by Weighing Method (incorporated by reference, see § 98.7).§98.34(b)(5)(i) ASTM D1945–03 Standard Test Method for Analysis of Natural Gas by Gas Chromatography (ii) ASTM D1946–90 (Reapproved 2006) Standard Practice for Analysis of Reformed Gas by Gas Chromatography.

(iii) ASTM D2502–04 (Reapproved 2002) Standard Test Method for Estimation of Molecular Weight (Relative Molecular Mass) of Petroleum Oils from Viscosity Measurements.

(iv) ASTM D2503–92 (Reapproved 2007) Standard Test Method for Relative Molecular Mass (Relative Molecular Weight) of Hydrocarbons by Thermoelectric Measurement of Vapor Pressure.

(v) ASTM D3238–95 (Reapproved 2005) Standard Test Method for Calculation of Carbon Distribution and Structural Group Analysis of Petroleum Oils by the n-d-M Method. (vi) ASTM D5291–02 (Reapproved 2007) Standard Test Methods for Instrumental Determination of Carbon, Hydrogen, and Nitrogen in Petroleum Products and Lubricants.

(vii) ASTM D5373–08 Standard Test Methods for Instrumental Determination of Carbon, Hydrogen, and Nitrogen in Laboratory Samples of Coal.

21

Date post:	11-Mar-2020
Category:	Documents
Upload:	others
View:	0 times
Download:	0 times

I · Web viewDavenport Plant - GHG Monitoring Plan March 2014 Davenport Plant - GHG Monitoring Plan...

Documents