May 24, 2017 LAFARGE CANADA INC. BATH CEMENT PLANT EVALUATION OF LOW CARBON FUELS - PROJECT 3, CONSIDERATIONS FOR PERMANENT USE Draft Project Description Version 1.0 DRAFT REPORT d Report Number: 1649607 Distribution: Lafarge Canada Inc. 1 PDF Copy - Golder Associates Ltd. Submitted to: Lafarge Canada Inc. 6501 Bath Road, Hwy. 33 Bath, ON K0H 1G0 DRAFT
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May 24, 2017
LAFARGE CANADA INC. BATH CEMENT PLANT
EVALUATION OF LOW CARBON FUELS - PROJECT 3, CONSIDERATIONS FOR PERMANENT USE
Draft Project Description Version 1.0
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Report Number: 1649607
Distribution:
Lafarge Canada Inc. 1 PDF Copy - Golder Associates Ltd.
Submitted to:
Lafarge Canada Inc. 6501 Bath Road, Hwy. 33 Bath, ON K0H 1G0 DRAFT
EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 i
DOCUMENT VERSION CONTROL
The Project Description Report is a living document; it will be updated periodically throughout the environmental
assessment (EA) process in response to stakeholder comments. Updates will be documented in the following
table to allow stakeholders to track and monitor changes to the Project Description over time.
Version Date Revision
Description Prepared By
Reviewed By
(Facility Contact)
1.0 May 24, 2017 Draft Rachel Lee Gould Blair Walker
DRAFT
EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
2.0 RATIONALE FOR THE PROJECT (ESP STEP 2) ................................................................................................ 2
2.1 Problem and Opportunity Statement ......................................................................................................... 2
2.2 Canada and World-Wide Fuel Substitution ............................................................................................... 3
2.3 Purpose of the Project .............................................................................................................................. 4
3.2.1 Construction ........................................................................................................................................ 9
These materials are classified as by-products of existing recycling programs (i.e., have passed through an existing
recycling program and been rejected), or are not eligible for recycling, and are therefore destined for landfill. None
of these materials are deemed ‘hazardous waste’ under the Ontario Environmental Protection Act, General –
Waste Management Regulation 347.
The materials will be generated from within a service area comprised of the provinces of Ontario and Quebec and
the state of New York, U.S.A. Local materials meeting the three sustainability criteria will be preferentially sourced;
materials from Quebec and New York will be used as necessary to ensure a constant source of fuel to the plant
based on commercial realities. The fuel types selected for Round 5 were so chosen due to their availability in
sufficient quantities to afford a regular supply.
All of these LCF types are expected to perform well as fuels, to reduce emissions, to reduce greenhouse gases
directly and indirectly, and to provide local opportunities for economic development – all the while meeting the
economic criteria necessary to justify capital expenditures.
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3.2 Project Phases
For this Project, Evaluation of Low Carbon Fuels – Project 3, three distinct phases of project development have
been identified: construction, operations, and retirement. A discussion of each phase is provided below.
3.2.1 Construction
As discussed in Section 2.4, Lafarge has received approval (ECA #3610-8Y9NVD) to construct and permanently
operate the LCF fuel management system. This includes the LCF fuel staging/processing system (shredding,
blending, mixing, and grinding the fuel) and fuel delivery system (off-loading, storage, and injection into the kiln).
Consequently, no potential construction-related effects for the fuel platform were assessed for Evaluation of Low
Carbon Fuels – Project 3.
Lafarge proposes to re-grade and re-surface the area identified as LCF 1 on Figure 2 and construct a covered
structure to store processed LCFs. This structure will be temporary in nature, similar to a large hoop tent, installed
directly on the aggregate surface (no flooring), with electricity and water supplied from the cement plant. In addition,
a small, shallow lined collection pond is proposed in LCF 1 to collect surface runoff from the graded aggregate
pad. This infrastructure was assessed as part of the Evaluation of Low Carbon Fuels – Project 1. Consequently,
this proposed infrastructure is not being assessed in Evaluation of Low Carbon Fuels – Project 3.
No other construction activities have been identified for Evaluation of Low Carbon Fuels – Project 3.
3.2.2 Operations
For Evaluation of Low Carbon Fuels – Project 1, Lafarge is proposing to receive and process up to 135,000 tonnes
of LCF per year. A maximum of 250 tonnes of LCF per day would be used as fuel in the cement plant, with
potentially another 125 tonnes of LCF per day processed on-Site and shipped off-Site to third party users. No
changes to the tonnes of LCF received or processed per year are proposed for Evaluation of Low Carbon Fuels –
Project 3.
Further details on the operations phase of the Project are provided in Sections 3.3 through 3.8.
3.2.3 Retirement
All LCFs stored on Site will be fully used or will be removed from the Site and shipped to other approved fuel users
or to an approved waste management facility for disposal or other uses. Remaining equipment will be dismantled
and removed from the Site. No residual impacts from this Project are expected.
The Bath Plant has quarry reserves representing over 100 years of operation and there is a Quarry Rehabilitation
Plan in place that describes the eventual closure of the quarry operations and cement plant.
3.3 Low Carbon Fuel Transport
Lafarge has received approval (ECA #9606-8Z7S9Z) for a maximum of 1,200 tonnes of LCF to be received at the
Site per day, via fully enclosed trailers, tarped dump trucks, or by railcar. For Evaluation of Low Carbon Fuels –
Project 3, no additional increase in maximum LCF tonnage received at the Site per day is required.
LCF material is typically shipped to the Lafarge Bath Plant on a campaign basis, due to the commercial realities
of material availability. The estimated maximum number of trucks transporting LCFs to and from the Site in a single
day is 21 (15 trucks delivering LCF to the Site, and 6 trucks leaving the Site with processed LCF destined for third
party consumers) or residual wastes (destined for recycling/disposal).
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All haulers delivering LCF will be required to comply with Lafarge’s transportation program. This includes
instructions around using public roadways, remaining within approved traffic routes, refraining from the use of
engine brakes, complying with Site safety & insurance requirements, and to be cognizant of the concerns of the
local community. Although the facility will be open continuously 365 days per year, Lafarge’s experience is that
the vast majority of truck traffic will be Monday to Friday, during daylight hours, due to commercial practicalities.
Where practical, LCF will be shipped to the Lafarge Bath Plant using railway gondola cars. The Site railway spur
can accommodate approximately 10 to 16 gondola cars, dependent on their length. This equates to a maximum
shipment of 600 tonnes of LCF materials that would be unloaded and stockpiled on Site.
3.4 Fuel Staging/Processing System
Lafarge currently holds a permanent ECA (#3610-8Y9NVD) for the operation of the LCF staging/processing
system, for activities including sorting, shredding, blending, screening, magnetic separation, and grinding. A brief
description of the LCF staging/processing system is provided below. Further details of the system can be found in
the Design and Operations Report for the Low Carbon Fuel Initiative (Lafarge 2016), and on the sorting and
shredding operations in Sections 3.4.1 and 3.4.2 below.
Deliveries of LCFs are booked in advance through the Lafarge Site Manager (or designate) or an authorized and
trained third party operator designated by Lafarge. All LCF suppliers are required to submit and have approved a
Fuel Data Sheet, prior to scheduling, for each type of LCF. The Fuel Data Sheet includes a detailed description of
the material types expected in the LCF load and associated testing required.
Characterization of the LCFs includes analyses of combustion properties (e.g., moisture content, ash content,
heating value) and chemical contents (e.g., chlorine, sulphur, nitrogen, hydrogen, oxygen, metals). Further testing
details can be found in the Low Carbon Fuels Demonstration Project Testing Plan (Golder 2016). Lafarge has
internal Quality Assurance and Quality Control standards that must be contractually met in order for the fuels to
be accepted at Site.
3.4.1 Sorting Operations
Lafarge has learned through the Low Carbon Fuel Demonstration Project that it cannot rely solely on third party
suppliers to provide LCF materials for the plant in a suitable form. To facilitate a continuous flow of materials and
manage supply fluctuations, Lafarge must be prepared to accept unprocessed (whole) LCF materials (as approved
under their permits) directly from waste generators as well.
Materials that come directly from waste generators would require further processing, to prepare the fuel for
shredding. The fuels would require sorting to segregate the desired LCFs from unsuitable materials (such as bricks
or metal). This sorting process would provide the Quality Control that Lafarge requires: namely that the materials
destined for the shredding and fuel delivery systems are of high quality for cement production and meet the Lafarge
approval requirements. All rejected materials would be shipped off-Site to the municipal landfill, recycling depot,
or licensed disposal facility (dependent on the type of reject material), or reused for another purpose. Lafarge
proposes to sort the LCFs brought to the Site in the area identified as LCF 1 on Figure 2. Most sorting activities
would take place inside a covered structure to protect the fuels from the elements (e.g., rain/snow).
In addition to the sorting process described above, a screening process for small metals (e.g., nails) takes place
during the fuel off-loading system (see Section 3.5.1 for more information).
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EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
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3.4.2 Shredding Operations
Prior to use as fuel through the primary fuel combustion system, the LCFs must be finely shredded into a consistent
size suitable for injection with the pulverized coal and petroleum coke currently used in the cement kiln. Under the
Site’s permanent ECA (#3610-8Y9NVD), shredding operations may be conducted by Lafarge or a third party –
either on-Site or off-Site – with shredded fuel product either used at Site in the cement manufacturing process or
shipped off-Site to other regional fuel users.
LCFs, either processed or partially processed (shredded), or unprocessed (whole), will be supplied from a variety
of suppliers, or directly from waste generators, as determined by market availability. Lafarge has learned through
the Low Carbon Fuel Demonstration Project that access to LCFs is improved if they can provide the shredding
services. This allows the plant to have a more consistent supply of LCFs, and to exercise better quality control
over the materials. Consequently, Lafarge proposes to shred LCFs at the Site, in the area identified as LCF 1 on
Figure 2. This area is ideal for the shredding activities as it allows for unprocessed LCF materials to be brought to
the Site by railcar (a rail spur that can accommodate from 10 to 16 gondola type rail cars, dependent on their
length, is adjacent to LCF 1) or truck. LCF 1 is approximately 2.1 hectares in size.
The equipment at LCF 1 to be used for the shredding operations has not yet been purchased. It is expected that
mobile equipment (such as a hydraulic excavator or ‘grappler’) would be used to transfer the raw materials arriving
on the railway cars to either a temporary storage pile or directly to the shredding equipment. A typical shredding
machine, for an operation of this magnitude, would be a portable machine with a cutting adjustment to allow the
raw materials to be processed into two sizes. Generally, the raw materials would be shredded in a two-step
process, from coarse (larger particle size) to fine (smaller size), to ensure a consistent quality fuel. Other mobile
equipment, such as a front end loader or trailer, would be used to transfer the processed fuels into temporary
storage piles or directly to the fuel delivery system. LCFs would be shredded in batches, dependent on material
availability and cement plant requirements, with shredding activities taking place on and off over the cement plant
operating hours (24 hours a day, 7 days a week) as required.
Shredding machines generally come equipped with water sprays and light gauge metal enclosures and hoods
over the conveyors to minimize the production of dust and keep any dust in close proximity to the shredders.
In addition, to control the dispersion of dust and fine particles, Lafarge would limit the operations of the shredding
equipment during high winds. These measures are anticipated to control dust generated from the shredding
operations. The Site housekeeping program would also be amended to include the shredding operations, so that
the area is kept in an orderly and clean manner.
A covered structure, approximately 20 m wide by 40 m long, will be installed in LCF 1 to store processed fuels prior
to use in the plant and protect them from the elements (e.g.; rain and wind). On occasion, shredded materials
could be stored outdoors, under temporary cover such as tarps, for short periods of time to facilitate material
handling and storage activities. A lined collection sump will also be installed to capture surface water runoff from
the area for sedimentation control and use as dust control. It is anticipated that for most of the year the lined sump
would be dry. However, in the rare event that excess water exists, overflow from the pond would be directed to
the main quarry sump and managed with the quarry’s surface water management system.
To control surface runoff laden with dust and fine particles at LCF 1 area, activities would be limited during intense
rain events and snow would be removed from working areas prior to commencement of shredding operations.
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EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 12
3.5 Fuel Delivery System
Lafarge currently holds a permanent ECA (#3610-8Y9NVD) for the operation of the LCF delivery system. For the
Pilot Project (ECAs #2950-AK2RFX and #9606-8Z7S9Z), a maximum of 75 tonnes of LCF may be subjected to
thermal treatment per day. For Evaluation of Low Carbon Fuels – Project 1 and Evaluation of Low Carbon Fuels
– Project 2, a maximum of 250 tonnes per day is proposed for the listed LCFs on a permanent basis; this
represents approximately 30% of the annual fuel usage and matches the stated goal of the Cement 2020 initiative.
No changes to the maximum tonnes of LCFs subjected to thermal treatment per day are proposed for Evaluation
of Low Carbon Fuels – Project 3. Currently, fuel types used for the cement manufacturing process (i.e., coal,
petroleum coke, virgin biomass) are listed in the existing ECAs without limit, other than practical fuel demand
requirements.
A brief description of the LCF delivery system is provided below. A schematic of the delivery system is illustrated
on Figure 4. Further details of the system can be found in the Design and Operations Report (Lafarge 2016).
The System has three distinct phases or sub-systems, as follows:
Fuel Off-Loading System;
Fuel Storage System; and
Fuel Injection System.
3.5.1 Fuel Off-Loading System
The Fuel Off-Loading System transfers prepared LCF into the Fuel Storage System for subsequent controlled
injection into the kiln burner by the Fuel Injection System. The Fuel Off-Loading System is located east of the
cement storage dome.
Fuel is typically transported to the Fuel Off-Loading System in self-unloading tractor trailer trucks (e.g., walking
floor). The trucks back up to a stationary bunker where the prepared LCF is unloaded into a receiving hopper. The
fuel is subsequently transferred via a conveyor to the screening station. The presence of nails and other metal
components can result in damage to conveyance systems and, if in high enough amounts, can create a risk of
product contamination. Magnetic separation is a common material processing step and the number of magnetic
separation stages and the type of system will vary depending on the likelihood of metal contamination in the fuel
source material and the nature of the contamination. The screening station, in a series of steps, removes oversized
LCF materials and detects and removes small metal materials. These residual wastes (e.g., tramp metal, off-spec
material, and materials arising from maintenance activities on equipment) will be removed from the LCF off-loading
system and collected in bins for transport to a recycling/disposal facility.
After screening, the prepared LCF is transported via conveyor to a 3-way diverter valve in the Fuel Holding System.
LCF material is separated into one of two bulk storage bins, depending on the type of fuel, or it can bypass the
Fuel Storage System and go directly to the Fuel Injection System.
3.5.2 Fuel Storage System
The Fuel Storage System acts as the buffer between the Fuel Off-Loading System and the Fuel Injection System
and, where both bulk storage bins and/or the bypass are in use, affords the opportunity to blend different types of
LCFs. Typically, the Fuel Storage System controls the unloading of material from the truck trailers.
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May 24, 2017 Report No. 1649607 13
The Fuel Storage System is comprised of two bulk storage bins to hold the off-loaded prepared LCFs. These bins
can store up to an estimated 150 tonnes each. Two discharge conveyors transport the fuel from each bin to the
Fuel Injection System. These conveyors operate independently, allowing different ratios or blends of fuel to be
transported. The blends of fuels will differ, dependent on the fuel availability at the time.
3.5.3 Fuel Injection System
From the Fuel Holding System, LCFs are transported via conveyor to the second screening station. Oversized
materials, or LCFs that have clumped together, are separated and directed to the grinder (or shredder) for further
processing. All materials are then transported via a long conveyor up to the burner floor in the mill building into the
kiln metering bin.
Using a series of conveyors, the fuel is transported to the air lock. The air lock is a rotary valve that keeps air from
entering the LCF conveying system. The kiln feed blower moves the fuel from the air lock to the injection point and
ultimately into the kiln. The flow rate of traditional and low carbon fuels is controlled to achieve a uniform delivery
and to ensure that minimum temperatures in the kiln are maintained. The average temperature in the combustion
zone is 1,450 degrees Celsius (the flame is significantly hotter); the residence time at temperatures in excess of
1,000 degrees Celsius is over 10 seconds. These temperatures are well in excess of the temperatures necessary
to ensure efficient combustion of the fuels used in the process.
3.6 Low Carbon Fuel Efficiency
The Site will generate on average 17-19 gigajoules of thermal energy output from every tonne of LCF used. In a
full production year of 7,400 hours of operation, this equates to approximately 400 Terajoules of energy from LCF
for every 10% co-fire (substitution of traditional fuel with LCF) increase.
3.7 Low Carbon Fuel Storage
ECA #9606-8Z7S9Z allows for a maximum of 19,970 tonnes of LCF to be stored at the Site at any one time. This
includes unprocessed (whole) LCFs, partially and fully processed LCFs, and residual waste. Storage of LCF is
critical to the operation of the plant to facilitate a continuous flow of materials and manage seasonal supply
fluctuations (for example, asphalt shingles would only be available in the summer during the roofing season). No
changes to the maximum storage volume of LCFs at the Site at any one time are proposed for Evaluation of Low
Carbon Fuels – Project 3. Storage areas associated with the LCF are illustrated on Figure 2 and are described in
Table 3-1. Further information regarding LCF storage capacity at the site is provided in the Design and Operations
Report (Lafarge 2016). DRAFT
EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 14
Table 3-1: Low Carbon Fuel Storage Areas
LCF Area Number
Description Type of Storage
LCF 1
2.1 hectare area situated west of the existing Bath Plant Solid Fuel Storage Area and abutting a section of the on-Site railway spur
LCF staging and processing operations will take place here. Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present. Temporary working stockpiles of unprocessed LCFs will be stored uncovered on the ground; stockpiles of partially and fully processed LCFs will be stored under a covered structure. On occasion, processed LCFs could be stored outdoors, under temporary cover such as tarps, for short periods of time to facilitate material handling and storage activities.
LCF 2 Repurposed former “Bunker C” building located near rail spur to west of cement storage silos
Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present.
LCF 3
Fuel Delivery system, located east of cement storage dome and south of kiln burner system, at grade and at the kiln burner elevation
Trailers, or storage with walking floor bins, of processed LCFs.
LCF 4 “LSI” building and storage hall Temporary working stockpiles of partially and fully processed LCFs. This storage is inside a building.
LCF 5 10 hectare area located east of the storage hall
Short term storage of self-unloading trailers and dump trucks of unprocessed, partially, and fully processed LCFs will be present.
FF 1 Existing stockpile area for marine shipments of fossil fuels, gypsum, and slag
Unprocessed, partially, and fully processed high density LCFs may be stockpiled here temporarily, in addition to fossil fuels. Non-hydrophobic fuels, or otherwise unsuitable for outdoor storage, will be covered.
3.8 Relevant Bath Operations Activities
The Bath cement plant has been in operation for over 40 years, and has continually sought to improve the
efficiency of its operations and promote an environmentally sustainable business. The use of LCFs at the Bath
plant has been under consideration for many years, with the benefits/impacts to the plant’s sustainability approach