Lehigh Cement Company, LLC
Alternative Fuels Proposal
Community Information Meeting ▪ The Queensbury Hotel ▪ February 27, 2019

trust earned daily

 Introducing Our Team

From Glens Falls:
David Dreyer, Plant Manager
John Stephenson, Production Manager
Jana Frederick, Environmental Manager
John Aylward & Maggie Donohoe, Process Engineers
Tim Kilpeck, Safety Professional
From Our Corporate Team:
Tim Matz, Senior Director, Environmental Affairs
Adam Swercheck, Environmental Director
Victor Hays, Alternative Fuels Manager – North Region

Slide 2

 I Lehigh Cement Company, LLC Glens Falls Plant

 

Slide3 LGhigh Hanson


Our Glens Falls Plant: 125 Years of Tradition
 Longest continuously operating gray cement plant in the United States.
 “Glens Falls Portland Cement Company” incorporated in 1893.
 Celebrated 125 years of operation in 2018
 One of only two cement manufacturing plants remaining in NY
 Part of the Heidelberg Cement Group
 More than 90 employees working in Glens Falls
 800 acres in Warren and Saratoga counties
 Manufacture (4) cements – T1, T2, T3, Masonry
 The “IRON CLAD” brand associated with the
Glens Falls Plant since early 20th Century.

Slide 4

4

 Our Glens Falls Plant: Small But Nimble

 Capacity to produce about 560,000 metric tons of cement annually
 Transfer +100,000 tons/year to a sister facility in Cementon, NY (Catskill)
 500,000 tons of cement = 60,000 homes or a two-lane highway from
Glens Falls to the Canadian Border
 Plant is small in today’s world, but employees are highly responsive to
customers’ needs and we’re fortunate to mine some of the finest
limestone in the world.

“Our high-quality stone and outstanding employees are what sustains us”

Slide 5
5

 Our Quarry: Some of the Finest Limestone in the World


Located in Moreau, mined since 1920



Approximately 335 acres



1906: First privately built bridge over the Hudson



CaCO3 Richer as Depth Increases

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Slide 6
6

CaO (Calcium Oxide)
concentration and therefore
hardness increases as the
quarry depth increases.

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Slide7 Lehigh Hanson


 

 

 

 

 

 

 

 

 

 

 

 

 

 

Understanding Our Cement Kiln


204 ft. long x 14.5 ft. inside diameter, sloped at 0.375”/ft



May be fired using coal and/or natural gas



Fuels must have enough BTUs to achieve 3500°F (1/3 surface temperature of sun)



Max rotation is 150 RPH; approx. 45 minutes feed to discharge end

Slide 8
8

 Environmental Advantages of a Cement Kiln
 3500 deg. F flame is much higher than most industrial burners (e.g.
waste-to-energy incinerators). Combined with extended residence time
in kiln, this results in total destruction of fuel products. No residual ash
is generated.
 Alkaline conditions inside the kiln, due to high-calcium raw mix, absorb
acidic combustion products.
 Clinker absorbs physically and chemically into its structure.
 Kiln acts as large thermal sink.

Cement kilns are ideally equipped for renewable and engineered fuels.
Slide 9
9

 Advanced Controls Minimize Air Emissions


The following control devices reduce
emissions:
 Electrostatic precipitator controls
Particulate Matter emissions
 Selective Non-Catalytic Reduction
system for NOx control
 Hydrated Lime for SO2 control
 Activated Carbon used to control
Mercury Emissions
 Temperature controls reduce
formation of Dioxins/Furans
 Baghouse on cooler vent controls
Particulate Emissions
 41 Dust Collectors located
throughout the facility remove PM

Slide 10

 Current Air Emission Standards
Lehigh’s air emissions are strictly regulated by the federal and state
governments based on what they have determined to be protective of
human health and the environment.
In 2015 …
1.

USEPA enacted stringent new air emission standards for Portland
Cement industry nationwide, lowering allowable emission limits and
expanding the number of regulated constituents.


Limits established for Mercury and Total Hydrocarbons



Limits lowered for Particulate Matter — a surrogate for heavy
metals other than mercury

2.

Lehigh invested more than $6 million in enhanced emission controls at
its Glens Falls plant to ensure compliance with new standards and
achieve EPA’s designated Maximum Achievable Control Technology
(MACT).

3.

New standards reflected in Lehigh’s current air emissions permit.

Slide 11

 Current Air Emission Standards
In July 2018 …

Slide 12

1.

USEPA completed a re-evaluation of the MACT standards for
the industry, including public health risks, as required every
eight years.

2.

Re-evaluation consisted of extensive air dispersion modeling
and health risk assessments based on data from all Portland
cement plants in the country.

3.

USEPA concluded that “…the standards provide an ample
margin of safety to protect public health, and that it is not
necessary to set a more stringent standard to prevent an
adverse environmental effect.”

 Continuous Monitoring for Emissions
 Lehigh has continuous monitoring for the following emissions:
 Mercury
 THC or total hydrocarbons
 Dioxins/Furans
 Particulate Matter
 NOx
 Opacity
 CO2
 Data is measured five times per minute and averaged every minute.

 Daily, weekly, monthly, quarterly and/or annual quality assurance activities
required to ensure accuracy of monitors, with results submitted to
regulatory agencies
 Preventative maintenance is performed on scheduled basis.
 Alarm notifications and alerts in Main Control Room should any problem
with analyzer occur.
Slide 13

 Stack Testing
 A third-party environmental monitoring firm performs the
following stack testing:
 Annual performance test of Particulate Matter
 Annual performance test for SO2
 Dioxin/Furan performance test every 30 months
 Annual Relative Accuracy Test Audit (RATA) for THC, Mercury, Nox and
CO2
 NYSDEC Oversees & Reviews Results
 NYSDEC approves testing protocol.
 NYSDEC is on-site to witness the testing.
 Stack testing results that have been verified for quality assurance are
submitted to regulatory agencies within 60 days.

Slide 14

 Emissions Data – Internal & External Reviews

 Emissions data is reviewed for compliance daily at morning
Production Meeting.
 Plant level data is submitted to Corporate leaders semi-monthly.
 Data reports are submitted to NYSDEC and EPA Region 2 on
required schedules.

Slide 15

 Emissions Control Performance — December 2018

ppmvd @ 7% O2

Glens Falls - Kiln
THC Performance (30-day RA)
25
Actual
15

Limit

5

Glens Falls - Kiln
Mercury Performance (30-day RA)
Ounces/Ton

0.0011

Actual

0.0006

Limit
0.0001

lb/ton clinker

Glens Falls - Kiln
NOx Performance (30-day RA)
3
2.5
2
1.5
1

Slide 16

Actual
Limit

 Why Alternative Fuels?
• Lehigh’s parent companies view alternative fuels as an essential
component in reducing fossil fuel use and our carbon footprint, and has
established a goal of reaching 30% alternative fuel use globally by
2030.
• Lehigh is currently using engineered fuels similar to that proposed for
Glens Falls at four plants in the U.S. and Canada — in some instances
in greater volumes and with higher plastic content.
• Air emissions at these plants are below applicable emission limits.

HeidelbergCement has established “Sustainability Commitments 2030”
Slide 17
17

 Why Alternative Fuels at Glens Falls?
• Reduces fossil fuel consumption, contributing to parent’s company’s
Sustainability 2030 goal.
• Reduces fuel costs, which account for 25% of total operating costs
in Glens Falls.
• Added benefit: Keeps a non-recyclable material out of landfills
All while keeping air emissions well below currently allowable limits.

Our employees are working hard to keep us competitive in a global market.
Alternative fuels will reduce fuel cost, which help to keep us sustainable.
Slide 18
18

 What is Our Alternative Fuel?
A 60/40% mix of plastic trimmings and cardboard fiber
from recycled paper mills:
 Corrugated cardboard boxes from homes and businesses arrive at
recycled paper mills in flattened, compacted bales.
 Bales go into a pulper where water breaks the cardboard back down into
fibers that will be recycled into new cardboard.
 A chain-like rope is run through the pulper to remove the baling wire and
any plastic-based labels, tapes, wrappings that were on the boxes.
 The materials and some fiber wrap around the rope, forming what is
called “raggertail.”
 The rope is pulled from the pulper and the raggertail is sent to Lehigh’s
supplier, Frontier Fibers, where it is processed through screen
shredders, magnets, and an eddy current to remove both ferrous and
non-ferrous metals, before being shipped to Lehigh as a engineered
fuel. Without a market, this material would be landfilled.
Slide 19

 How Will Lehigh Use The Fuel?
 Material will arrive by truck in a compacted form (no baling or wrapping)
and be fed directly from the truck into a feed hopper and then into a
pipeline, at a controlled rate, into the kiln.
 Lehigh proposes to use raggertail as a maximum of 15% of our fuel mix.
 It will always be combined with coal and/or natural gas, which will make
up 85% of our fuel mix.
 Each delivery will be sampled for a variety of
constituents as required by DEC.

Slide 20

 Preparing For Our Permit Application
2016:
 Lehigh obtained a Beneficial Use Determination for raggertail from
NYSDEC, allowing for emissions testing to determine if material could
be used as fuel source while keeping emissions below currently
allowable levels.
2017:
 Lehigh purchased and installed alternative fuel handling system to
conduct air emissions testing.
 Lehigh retained third-party environmental testing firm to conduct air
emissions tests using alternative fuel.
 Testing protocols were approved in advance by NYSDEC, and NYSDEC
was on-site to observe all testing.
 Testing was conducted using blend of alternative fuel and coal to
demonstrate compliance with existing limits and conclude no changes
needed.
Slide 21

 Emissions Testing Results
 Lehigh tested for those constituents included in its New York State
air permit.
All of Lehigh’s regulated air emissions were well below
the plant’s current permitted levels.
 Lehigh also tested for materials regulated under Part 212 of NYS
law (e.g., metals) that “have the potential to be emitted” from our
processes.
All materials detected were below state emissions
guidelines. Those same constituents were also detected
during testing without raggertail — again, all within
state guidelines.

Slide 22

 Air Emissions Comparison
Dioxins / Furans ng/dscm @7% O2
0.4

0.35

0.3

0.25

0.2

0.15

0.1

0.05

0
Raggertail

Slide 23

Emission Standard

 Air Emissions Comparison
Particulate Matter lbs/ton clinker
0.08

0.07

0.06

0.05

0.04

0.03

0.02

0.01

0
Raggertail

Slide 24

Emission Standard

 Air Emissions Comparison

THC ppm @ 7% 02
30

25

20

15

10

5

0
Raggertail

Slide 25

Emission Standard

 Air Emissions Comparison

Mercury lbs/MMtons clinker
60

50

40

30

20

10

0
Raggertail

Slide 26

Emission Standard

 Draft Permit Issued
 Lehigh submitted the test results and its permit modification
application to NYSDEC.
 Application does not ask for any increase in our currently allowable
air emission limits.
 NYSDEC concluded use of raggertail “will not cause ambient
impacts above State guideline concentrations,” and issued our draft
permit.
 Public Comment Period runs through March 15, 2019

Slide 27

 I Thank you for your time!

 

Slide 28 Lehlgh Hanson