2014 Toxics Reduction Act Substance Accounting Reporting Values for Canada Building Materials Kingston Ready Mix Concrete Plant for PM 10

Transcription

1 March 31, 2015 BCX File: Via E mail: crevans@vcsmc.com Canada Building Materials Co. 55 Industrial Street, 4 th Floor Toronto, Ontario M4G 3W9 Attention: RE: Colin Evans Environment and Lands Manager 2014 Toxics Reduction Act Substance Accounting Reporting Values for Canada Building Materials Kingston Ready Mix Concrete Plant for PM 10 BCX Environmental Consulting (BCX) is pleased to provide this letter for your file regarding the 2014 Toxics Reduction Act (TRA) Substance Accounting reporting requirements for the Canada Building Materials (CBM) ready mix concrete (RMC) plant in Kingston, Ontario for particulate matter 10 µm or less (PM 10 ). TRA requires manufacturing and some mineral processing facilities that are required to report to NPRI to complete substance accounting requirements by June 1 st for the NPRI reportable substances for the same reporting year. TRA substance accounting is not required for substances that do not meet the NPRI reporting thresholds. BCX understands that the CBM Kingston RMC plant is required to report PM 10 to NPRI for the 2014 reporting year. Using information provided by CBM, and the tailored NPRI calculation sheets prepared by BCX, BCX calculated facility and process level substance accounting values. BCX understands that CBM is responsible for submitting the TRA substance accounting report to the Ministry of the Environment and the public posting of the facility level values for PM 10 usage and creation for the 2014 reporting year on the internet. 372 Eagle Street, Newmarket, ON L3Y 1K4 (P) (F)

2 Canada Building Materials March 31, 2015 Colin Evans BCX File: Should you require further information or clarification, please call me at your earliest convenience at (905) ext. 112 or by at Sincerely, BCX ENVIRONMENTAL CONSULTING. Per: Christina Wright, M.Env.Sc., EP Environmental Compliance Specialist Attachments: NPRI and TRA Substance Accounting Calculation Spreadsheets Limitations: 1. This assessment is based on CBM s internal assessment of their employee hours for the Kingston RMC plant (i.e. more than 20,000). 2. This assessment is based on the 2014 data provided by CBM and BCX s previous work for the Kingston site. 2

3 National Pollutant Release Inventory and Toxics Reduction Act Calculation Sheets Reporting Year: 2014 Prepared for: Canadian Building Materials Ready Mix Concrete Division Kingston Plant Facility Address: 2363 Unity Road Kingston, Ontario K7L 5C6 Prepared by: BCX Environmental Consulting 372 Eagle Street Newmarket, Ontario BCX Project No.: Date: 1 Jun 15

4 NPRI and TRA Substance Accounting Input Data Natural Gas Usage (sitewide) 151,024 m 3 No. 2 Fuel Oil Usage (sitewide) 2,163 L Average Wind Speed in Area 4.49 m/s Quantity of Fine Aggregate Used 42,797 tonne Fine Aggregate Moisture Content 4.8 % Quantity of Coarse Aggregate Used 24,357 tonne Coarse Aggregate Moisture Content 4.8 % Quantity of Cement Used 11,209 tonne Quantity of Slag Used 2,348 tonne Quantity of Fly Ash Used 0 tonne Wind Erosion PM10 Emissions from ECHO 2.20E 04 tonne/yr Wind Erosion PM2.5 Emissions from ECHO 3.00E 05 tonne/yr 1 of 1

5 NPRI & TRA Substance Accounting Non Combustion Calculations Particulate Matter 10µm or Less Process # Activity Annual Creation Destruction M Moisture U Wind Emissions Destroyed Content (1) Speed (2) Material Control Control Air Releases Created Emissions Usage Efficiency Efficiency (%) (m/s) (%) (%) 1 Delivery truck(s) to stockpile (sand) (3) % 1.78E 02 0% 0.00E E 02 1 Delivery truck(s) to stockpile (coarse aggregate) (3) % 1.01E 02 0% 0.00E E 02 2 Front end loader/truck transfer to grizzly (drive over hopper) (sand) (3) % 1.78E 02 0% 0.00E E 02 2 Front end loader/truck transfer to grizzly (drive over hopper) (coarse aggregate) (3) % 1.01E 02 0% 0.00E E 02 2 Transfer of material from Conveyor #1 to Conveyor #2 (sand) (4) (5) % 9.84E 04 75% 7.38E E 04 2 Transfer of material from Conveyor #1 to Conveyor #2 (coarse aggregate) (4) (5) % 5.60E 04 75% 4.20E E 04 2 Transfer from Conveyor #2 to aggregate compartments (sand) (3) % 1.78E 02 0% 0.00E E 02 2 Transfer from Conveyor #2 to aggregate compartments (coarse aggregate) (3) % 1.01E 02 0% 0.00E E 02 1 Delivery of cement material to silo from tanker truck (6) (8) % 2.69E 03 0% 0.00E E 03 1 Delivery of slag to silo from tanker truck (6) (8) % 5.64E 04 0% 0.00E E 04 1 Delivery of fly ash to silo from tanker truck (7) (8) % 0.00E+00 0% 0.00E E+00 2 Material transfer from silos to cement weigh scale (cementitious material) (8) (9) % 7.46E 06 0% 0.00E E 06 2 Material transfer to ready mix truck at the loading point (sand/coarse aggregate/cementitious materials) (10) % 2.10E+00 0% 0.00E E+00 1 Wind erosion from aggregate material storage (sand and coarse aggregate) (11) (12) 0% 1.47E 03 85% 1.25E E 04 (1) (2) (3) (4) (5) A 75% control efficiency is assumed for three sides and a top enclosure at the transfer point. (6) Emission factor for cement tanker unloading for PM10 is 0.24 kg/tonne (U.S. EPA, AP 42, Section "Concrete Batching," January 2012). (7) Emission factor for cement supplement tanker unloading for PM10 is 0.65 kg/tonne (U.S. EPA, AP 42, Section "Concrete Batching," January 2012). (8) A control efficiency of 99.9% is assumed for a well maintained pulse jet type baghouse (CBM, 2012). (9) (10) (11) Since coarse aggregate and sand are received washed a moisture content of 4.8%, moisture upper limit for drop equation, has therefore been assumed to maintain the data quality rating of A (U.S. EPA, AP 42, Section "Aggregate Handling and Storage Piles," November 2006). Average wind speed for surrounding area used. Emission factor equation: k(0.0016)(u/2.2) 1.3 /(M/2) 1.4 kg/t, where k=0.35 for PM10 (particles less than 10 microns), M is the moisture % of materials, U(m/s) is wind speed at the material drop point (U.S. EPA, AP 42, Section "Aggregate Handling and Storage Piles," November 2006). Emission factor: 2.3x10 5 kg/t (controlled conveyor transfer), U.S. EPA, AP 42, Section , "Crushed Stone Processing and Pulverized Mineral Processing," August 2004, Table since the sand and coarse aggregate are received washed to remove fines. Emission factor: 5.5x10 4 kg/t (uncontrolled conveyor transfer for PM10), U.S. EPA, AP 42, Section , "Crushed Stone Processing and Pulverized Mineral Processing," August 2004, Table since the cementitious materials are dry. Emission factor for uncontrolled truck loading for PM10 is kg/tonne, (U.S. EPA, AP 42, Section "Concrete Batching," January 2012). PM10 air releases value for stockpile wind erosion taken from ECHO calculator version (CBM, 2012). Created value for PM10 back calculated using water spray control efficiency. (12) A 85% control efficiency is assumed for a water spray on the storage piles (CBM, 2012).

6 NPRI & TRA Substance Accounting Non Combustion Calculations Particulate Matter 2.5µm or Less Process # Activity Annual Creation Destruction M Moisture U Wind Emissions Destroyed Content (1) Speed (2) Material Control Control Air Releases Created Emissions Usage Efficiency Efficiency (%) (m/s) (%) (%) 1 Delivery truck(s) to stockpile (sand) (3) % 2.69E 03 0% 0.00E E 03 1 Delivery truck(s) to stockpile (coarse aggregate) (3) % 1.53E 03 0% 0.00E E 03 2 Front end loader/truck transfer to grizzly (drive over hopper) (sand) (3) % 2.69E 03 0% 0.00E E 03 2 Front end loader/truck transfer to grizzly (drive over hopper) (coarse aggregate) (3) % 1.53E 03 0% 0.00E E 03 2 Transfer of material from Conveyor #1 to Conveyor #2 (sand) (4) (5) % 2.78E 04 75% 2.09E E 05 2 Transfer of material from Conveyor #1 to Conveyor #2 (coarse aggregate) (4) (5) % 1.58E 04 75% 1.19E E 05 2 Transfer from Conveyor #2 to aggregate compartments (sand) (3) % 2.69E 03 0% 0.00E E 03 2 Transfer from Conveyor #2 to aggregate compartments (coarse aggregate) (3) % 1.53E 03 0% 0.00E E 03 1 Delivery of cement material to silo from tanker truck (6) (8) (9) (10) % 3.43E 04 0% 0.00E E 04 1 Delivery of slag to silo from tanker truck (6) (8) (9) (10) % 7.18E 05 0% 0.00E E 05 1 Delivery of fly ash to silo from tanker truck (7) (8) (9) (10) % 0.00E+00 0% 0.00E E+00 2 Material transfer from silos to cement weigh scale (cementitious material) (10) (11) (12) % 2.11E 06 0% 0.00E E 06 2 Material transfer to ready mix truck at the loading point (sand/coarse aggregate/cementitious materials) (8) (13) % 2.68E 01 0% 0.00E E 01 1 Wind erosion from aggregate material storage (sand and coarse aggregate) (14) (15) 0% 2.00E 04 85% 1.70E E 05 (1) (2) (3) (4) (5) A 75% control efficiency is assumed for three sides and a top enclosure at the transfer point. (6) Emission factor for cement tanker unloading for PM10 is 0.24 kg/tonne (U.S. EPA, AP 42, Section "Concrete Batching," January 2012). (7) (8) (9) (10) (11) (12) Since coarse aggregate and sand are received washed a moisture content of 4.8%, moisture upper limit for drop equation, has therefore been assumed to maintain the data quality rating of A (U.S. EPA, AP 42, Section "Aggregate Handling and Storage Piles," November 2006). Average wind speed for surrounding area used. Emission factor equation: k(0.0016)(u/2.2) 1.3 /(M/2) 1.4 kg/t, where k=0.053 for PM2.5 (particles less than 2.5 microns), M is the moisture % of materials, U(m/s) is wind speed at the material drop point (U.S. EPA, AP 42, Section "Aggregate Handling and Storage Piles," November 2006). Emission factor: 6.5x10 6 kg/t (controlled conveyor transfer for PM2.5), U.S. EPA, AP 42, Section , "Crushed Stone Processing and Pulverized Mineral Processing," August 2004, Table since the sand and coarse aggregate are received washed to remove fines. Emission factor for cement supplement tanker unloading for PM10 is 0.65 kg/tonne (U.S. EPA, AP 42, Section "Concrete Batching," January 2012). PM2.5 emission factors for uncontrolled truck loading and uncontrolled cement silo filling are not available. The ratio of the average uncontrolled truck loading emission factors for PM10 and PM2.5 (12.74%) from the U.S. EPA, "Emission Factor Documentation for AP 42 Section Concrete Batching," June 2006, Table 17.3) was applied to the PM10 emission factor for uncontrolled truck loading in U.S. EPA, AP 42, Section 11.12, "Concrete Batching," January 2012) to estimate the PM2.5 emission factor for truck loading since it was assumed that the ratio between the size fractions would remain the same. Since both the truck loading and silo filling emission factors are based on transferring only cementitious material it was assumed that the fraction of PM2.5 from silo filling would be the same as the fraction of PM2.5 from truck loading. A control efficiency of 99.9% is assumed for a well maintained pulse jet type baghouse (CBM, 2012). Emission factor: 5.5x10 4 kg/t (uncontrolled conveyor transfer for PM10), U.S. EPA, AP 42, Section , "Crushed Stone Processing and Pulverized Mineral Processing," August 2004, Table since the cementitious materials are dry. A PM2.5 emission factor for uncontrolled conveyor transfer is not available. The ratio between the PM10 and PM2.5 controlled conveyor transfer emission factors (28.26%) was applied to the PM10 uncontrolled conveyor transfer emission factor to estimate the PM2.5 emission factor since it was assumed that the ratio between the size fractions would remain the same. (13) (14) Emission factor for uncontrolled truck loading for PM10 is kg/tonne, (U.S. EPA, AP 42, Section "Concrete Batching," January 2012). PM2.5 air releases value for stockpile wind erosion taken from ECHO calculator version (CBM, 2012). Created value for PM2.5 back calculated using water spray control efficiency. (15) A 85% control efficiency is assumed for a water spray on the storage piles (CBM, 2012).

7 NPRI & TRA Substance Accounting Combustion Calculations Particulate Matter 10µm or Less and 2.5µm or Less Process # 2 Source Natural gas fired steam boiler & comfort heating units Annual Fuel Consumption (1) (2) Created Emission Factors Emissions Air Releases Value Units PM10 PM2.5 Units PM10 PM2.5 PM10 PM ,024.0 m lb/10 6 scf 4.61.E E E E 04 2 No. 2 Fuel oil fired comfort heating furnace 2,163.0 L lb/10 3 gal 1.04.E E E E 04 Emissions = Emission Factor (lb/10 6 scf) x Fuel Consumption (m 3 /yr) x ( scf/m 3 ) / 10 6 x (kg/2.2lb) x (tonne/1000kg) Emissions = Emission Factor (lb/10 3 gal) x Fuel Consumption (m 3 /yr) x (0.12) / 10 3 ) x (tonne/1000kg) (1) (2) (3) Emission factor taken from U.S. EPA, AP 42, Section 1.4 "Natural Gas Combustion," July 1998, Table for filterable particulate. To convert from m 3 to scf multiply by scf/m 3. Filterable particulate emission factors taken from U.S. EPA, AP 42, Section 1.3 "Fuel Oil Combustion," September 1998, Table for residential furnace. To be conservative it was assumed that all particulate matter was PM2.5. (4) To convert from lb/10 3 gal to kg/10 3 L multiply by 0.12.

8 NPRI SWIM Summary Contaminant Name NPRI Reporting Threshold Total Air Releases Reportable to NPRI? (Y/N) Stack Air Releases Storage & Handling Air Releases Fugitive Air Releases Particulate Matter 10µm or Less Yes Particulate Matter 2.5µm or Less No Basis of Estimate E2 E2 E2 E2 Published Emission Factors

9 TRA Substance Accounting SWIM Summary Contaminant Name CAS# Usage Creation Air Releases Contained in Product Reason for Reason for Reason for % of % of % of % of Unit Significant Unit Significant Unit Significant Unit Change Change Change Change Change Change Change Particulate Matter 10µm N/A 0 0 tonne N/A N/A tonne 2.6% No significant change tonne 2.6% No significant change Reason for Significant Change N/A N/A tonne N/A N/A

10 TRA Substance Accounting Process Flow Diagram Stage 1 Ready Mix Concrete Batching Process 1 Delivery & Storage Process 2 Ready Mix Concrete Production & Shipping A1A C1A A2A C2A A2E C2E D2E A2G C2G Sand Delivery Drive Over Hopper Transfer from Conveyor #1 to Conveyor #2 Transfer from Conveyor #2 to Aggregate Compartments A1B C1B A2B C2B A2F C2F D2F A2H C2H A2J C2J Stone Delivery Drive Over Hopper Transfer from Conveyor #1 to Conveyor #2 Transfer from Conveyor #2 to Aggregate Compartments Truck Loading A1C C1C A2C C2C Cementitious Material Delivery to Silos (controlled with BHs) Cement Scale (controlled with a BH) A1D C1D D1D A2D C2D A2I C2I Wind Erosion from Sand & Stone Stockpiles Natural Gas Combustion (Boiler & Comfort Heating) No. 2 Fuel Oil Combustion (Comfort Heating) Legend A Onsite release of toxic substance to air Path of toxic substance C Creation of toxic substance Path of material flow D Destruction of toxic substance BH Baghouse

11 TRA Substance Accounting Particulate Matter 10µm or Less Stage: 1 Ready Mix Concrete Batching Processes: 1 Delivery and Storage 2 Ready Mix Concrete Production & Shipping Code Description Quantity (tonne) A1A Air Release Process 1 (Sand Delivery) 1.779E 02 A1B Air Release Process 1 (Stone Delivery) 1.012E 02 A1C Air Release Process 1 (Cementitious Material Delivery) 3.254E 03 A1D Air Release Process 1 (Wind Erosion from Sand & Stone Stockpiles) 2.200E 04 A2A Air Release Process 2 (Sand Drop Into Drive Over Hopper) 1.779E 02 A2B Air Release Process 2 (Stone Drop Into Drive Over Hopper) 1.012E 02 A2C Air Release Process 2 (Transfer to Cement Scale) 7.456E 06 A2D Air Release Process 2 (Natural Gas Combustion) 4.606E 04 A2E Air Release Process 2 (Transfer of Sand from Conveyor #1 to Conveyor #2) 2.461E 04 A2F Air Release Process 2 (Transfer of Stone from Conveyor #1 to Conveyor #2) 1.401E 04 A2G Air Release Process 2 (Transfer of Sand from Conveyor #2 to Aggregate Compartments) 1.779E 02 A2H Air Release Process 2 (Transfer of Stone from Conveyor #2 to Aggreagate Compartments) 1.012E 02 A2I Air Release Process 2 (No. 2 Fuel Oil Combustion) 1.038E 04 A2J Air Release Process 2 (Truck Loadout) 2.101E+00 C1A Creation Process 1 (Sand Delivery) 1.779E 02 C1B Creation Process 1 (Stone Delivery) 1.012E 02 C1C Creation Process 1 (Cementitious Material Delivery) 3.254E 03 C1D Creation Process 1 (Wind Erosion from Sand & Stone Stockpiles) 1.467E 03 C2A Creation Process 2 (Sand Drop Into Drive Over Hopper) 1.779E 02 C2B Creation Process 2 (Stone Drop Into Drive Over Hopper) 1.012E 02 C2C Creation Process 2 (Transfer to Cement Scale) 7.456E 06 C2D Creation Process 2 (Natural Gas Combustion) 4.606E 04 C2E Creation Process 2 (Transfer of Sand from Conveyor #1 to Conveyor #2) 9.843E 04 C2F Creation Process 2 (Transfer of Stone from Conveyor #1 to Conveyor #2) 5.602E 04 C2G Creation Process 2 (Transfer of Sand from Conveyor #2 to Aggregate Compartments) 1.779E 02 C2H Creation Process 2 (Transfer of Stone from Conveyor #2 to Aggregate Compartments) 1.012E 02 C2I Creation Process 2 (No. 2 Fuel Oil Combustion) 1.038E 04 C2J Creation Process 2 (Truck Loadout) 2.101E+00 Page 1 of 4

12 TRA Substance Accounting Particulate Matter 10µm or Less D1D Destruction Process 1 (Wind Erosion from Sand & Stone Stockpiles) 1.247E 03 D2E D2F Destruction Process 2 (Transfer of Sand from Conveyor #1 to Conveyor #2) Destruction Process 2 (Transfer of Stone from Conveyor #1 to Conveyor #2) 7.382E E 04 Note: PM10 is not used and TRA does not require a contained in product value for this substance. Usage/Quantity Entering the Process + Creation = Air Release + Destruction + Disposal + Transfer + Contained in Product/Quantity Exiting the Process Page 2 of 4

13 TRA Substance Accounting Particulate Matter 10µm or Less Mass Balance Assessment Description Quantity (tonne) Process 1 Usage/Quantity Entering the Process Creation C1A + C1B + C1C + C1D Air Releases A1A + A1B + A1C + A1D Destruction D1D Disposal Transfer Quantity Exiting the Process / Contained in Product Unaccounted Material (Difference between INPUTS and OUTPUTS) 0 Process 2 Usage/Quantity Entering the Process Creation C2A + C2B + C2C + C2D + C2E + C2F + C2G + C2H C2I + C2J Air Releases A2A + A2B + A2C + A2D + A2E + A2F + A2G A2H + A2I + A2J Destruction D2E + D2F Disposal Transfer Quantity Exiting the Process / Contained in Product Unaccounted Material (Difference between INPUTS and OUTPUTS) 0 Process Mass Balance Rationale Process 1: Process 2: Approximately equal. No rationale is required. Approximately equal. No rationale is required. Page 3 of 4

14 TRA Substance Accounting Particulate Matter 10µm or Less Quantification Method and Best Available Method Rationale Process 1: Delivery & Storage Quantity Codes All Published Emission Factors Quantification Method Best Available Method Rationale This is the best source of data available and is consistent (where appropriate) with ECA calculation methodology Process 2: Ready Mix Concrete Batching Quantity Codes All Published Emission Factors Quantification Method Best Available Method Rationale This is the best source of data available and is consistent (where appropriate) with ECA calculation methodology Mass Balance Facility Wide Facility Usage/Quantity Entering the Process Creation C1A + C1B + C1C + C1D + C2A + C2B + C2C + C2D + C2E + C2F + C2G + C2H C2I + C2J Air Releases A1A + A1B + A1C + A1D + A2A + A2B + A2C + A2D + A2E + A2F + A2G A2H + A2I + A2J Destruction D2E + D2F Disposal Transfer Quantity Exiting the Process / Contained in Product Unaccounted Material (Difference between INPUTS and OUTPUTS) 0 Page 4 of 4

15 TRA Substance Accounting Description of Ready Mix Concrete Batching Stage The operation of ready mix concrete batching is considered one stage for the purpose of TRA substance accounting. The stage is divided into two processes: delivery & storage, and ready mix concrete production. The descriptions of the two processes are provided below. Process 1 Delivery & Storage Aggregate materials (sand and stone) are delivered to the facility by truck and deposited onto stockpiles. Cementitious material is delivered by tanker truck and stored in silos. Emissions from each silo are controlled by a baghouse. Process 2 Ready Mix Concrete Production As needed, aggregate materials are transferred from the stockpiles by a front end loader into the drive over hopper (grizzly). Aggregate material from the drive over hopper is transferred to Conveyor #1 underground. Aggregate material from Conveyor #1 is then transferred to Conveyor #2 aboveground. Conveyor #2 transfers aggregate material into the aggregate compartments and then to the aggregate weigh scale inside the plant. The appropriate mass of material is loaded onto Conveyor #3 inside the plant and transferred directly into the ready mix truck through a collection hopper at the loading point. Cementitious materials from the storage silos are fed to the cement weigh scale. Emissions from the cement weigh scale are controlled by a separate baghouse. The appropriate mass of cementitious materials from the cement weigh scale are fed directly into the ready mix truck through a collecting hopper at the loading point. Water containing small quantities of admixtures is also added directly into the ready mix truck. A natural gas fired boiler is used, as required, to raise the temperature of the water before use. Natural gasfired comfort heating units are used, as required, at the plant. No. 2 fuel oil fired comfort heating furnace is used as required in the garage. Page 1 of 1

16 TRA Substance Accounting Process Description Particulate Matter 10µm or Less Process 1 Delivery & Storage Particulate matter is created and released to atmosphere when aggregate material is delivered (C1A and C1B, A1A and A1B), when cementitious material is delivered to silos (C1C, A1C) and from wind erosion of aggregate stockpiles (C1D, A2D). The majority of the created wind erosion particulate is destroyed by a water spray on the aggregate stockpiles (D1D). Process 2 Ready Mix Concrete Production Particulate matter is created and released to atmosphere when aggregate material is dropped into the drive over hoppers (C2A and C2B, A2A and A2B), when cementitious material is transferred to the cement scale (C2C, A2C), from natural gas combustion (C2D, A2D), transfer of aggregate material to conveyors (C2E, C2F, C2G and C2H; A2E, A2F, A2G and A2H), from No. 2 fuel oil combustion (C2I, A2I) and truck loadout (C2J, A2J). A portion of the particulate created during the transfer of aggregate material to Conveyor #1 is destroyed by enclosure at the transfer point (D2E and D2F). Page 1 of 1