October 30, 2009 

## Subject: Meeting between with Polysius Corporation (DRAFT) Location: 180 Interstate North Parkway, Atlanta, Georgia 30339 Date: October 28, 2009 Participants: See attached list This meeting was held to discuss common areas of interest to the cement industry, the U.S. EPA, State regulatory agencies, and Polysius. I. Polysius presented background information on the company and on current projects they have as they relate to the cement industr y and pollution control. The following is a summary of the key areas and points presented by Polysius.

• Current environmental trends present th e following challenges and opportunities: o Global warming o Preventing emissions of NOx and VOC o CO2 minimization

• In response to these challenges/opportunities , Polysius has projects in the following areas: o Use of SNCR/SCR o Refitting existing plants o Blending cements o Use of new binding agents o CO2 capture and sequestration (CCS) Polysius provided an overview of their current work in the areas of controlling/reducing NOx, THC, and mercury. NOx Control

• Trends in government regulation of NOx are toward increasingly st ringent standards.

• TA-Luft, Germany’s environmental agency reduced the NOx limit down to 500 mg/Nm3 (1.95-2.0 lb/st) by the year 2002, with an eventual goal in 2013 of 1.5 lb/st. Multistage Combustion (MSC)

• Able to reduce emissions from 1500 down to 800 mg/Nm3

• Prepol MSC – utilizes two burning/reducing zones

• MSC: o Reduce NOx by up to 30% o Fuel dependent o Decrease in process stability (due to su lfur and alkali) with aggressive MSC o Limit is about 800 mg/Nm3 (3.2 lb/st)

• Fuel dependency of MSC o Need at least 32% volatiles in fuel to get good NOx removal o Bituminous coal, mostly east of the Missi ssippi River has vola tiles in the range of32-35%. o Coals west of the Mississippi (e.g., lignite coal) typically ha ve 35-40% volatiles and offer the potential for improved MSC performanceOctober 30, 2009

o Alternative fuels may offer improved MSC performance in the range of 200-250 mg/Nm3. o In Germany, alternative fuels are allo wed with the applicable regulations determined by the amount of alternative fuel burned. Below 25% alternative fuel, cement regualton apply; 25-65%, combinati on of cement and waste incinerator regulations apply; above 65%, wast e incineration regulations apply. MSC and SNCR

• Can reduce NOx down to 500 mg/Nm3 (1.95-2.0 lb/st)

• Performance affected by: o Each kiln is different (at same molar ratio (NMR), kilns perform differently o Concurrence of reduction and combustion o Secondary emissions of NH3 and CO (a bove NMR of 1, potential for NH3 slip; detached plume possible) SCR

• Able to reduce NOx down to 200 mg/Nm3

• Catalyst types: o Honeycomb – need channe l size of at least 1.5mm o Plate – need surface area of at least 300 m2/m3

• Elex and Polysius - joint ve nture on SCR/catalyst controls

• Interested in performing fu ll scale demonstration of SCR with industry and/or government sponsorship to investigate pe rformance in reducing NOx and VOC and oxidizing mercury

• 2 plants in Germany to start using SCR in Spring 2010; 2 more SCR controlled plants being built in Australia.

• Monselice, Italy SCR experience o 2400 tpd PH kiln o NOx in inlet 3.6-4.0 lb/st o 90% or better control with SCR o Each catalyst has its own dust blowing sy stem; not always effective w/ some plugging o Catalyst taken off line ever y few months for cleaning o Catalyst running for 5000-7000 hrs o Goal is take catalyst dow n once/yr for cleaning THC Control

• Based on lab tests on samples of limestone fr om US cement companies, THC emissions were predicted: o Average was 20 ppm o 95% were 50 ppm or less o Less than 1% were 7 ppm or less

• 2009 tests from Europe yi elded similar results

• VOC would be a preferred surrogate for organic HAP because it does not include methane, which can be as much as 50-60% of THC RTO

• Due to the low organics content of their exha ust gases, TXI Midlothian RTO is fired with natural gas in order to be regenerativeOctober 30, 2009

• Heat exchanger replacement occurs ev ery 5 years at a cost of $2.75 million

• CO2 emissions from RTO are 80,000 tpy ACI

• Works well on higher hydrocarbons –90% removal on C4; 70% removal on C3; 30% removal on C1

• Performance of ACI on THC is problema tic when the methane portion is high SCR

• 35-50% removal Mercury

• Polvitech – fixed bed active coke technology – installed on European incinerator in 1991 o Activated coke used instead of coal; ac tivated coke has much greater surface area than coal allowing smaller filter bed than possible with coal; sufficient activated coke not available in the U.S. o Designed for removal of dioxin/furan and sulfur o Plant burned biosolids/sewage sludge containing mercury o Use for mercury removal would re quire different bed thickness. o Original design burned spent coke with other fuel o Design for mercury control could dispos e of ESP dust in order to bleed off mercury to reduce mercury emissions o Coke bed did not control methane

• ACI o Option 1 – Desorption of CKD. Heat C KD with natural gas to volatilize and concentrate mercury in small exhaust gas stream; remove mercury with fixed bed coke bed; pilot trials were conducted in 1992 o Option 2 – Add second baghouse to colle ct carbon and landfill or recycle o With both options, concerned with the fi nal disposition of the waste mercury and associated future liabilities if mercury leaches out or otherwise enters into the environment o At recent limited test of ACI at cement plant, did not remove mercury. May have been due to high temperature. Must be concerned about acid dew point if lowering temperature to improve effici ency because of stack corrosion unless stack designed for acid gas condensation

• SCR o At waste incinerator plant in Germany, SCR completely absorbed and oxidized elemental mercury with desorption after the SCR

• Wet Scrubber o Removal of HCl may increase chlorine content of scrubber sludge beyond the 0.1%, which would make the sludge unsuitable for use as gypsum o Looking for solutions that do not involve use of water because of potential detrimental effects on gypsum, issues of wa ter scarcity, and final sludge disposal issues. II. Al Linero, Florida Department of Environmental Protection, gave a presentation outlining the issues associated with sources of mercury and possible control options, theOctober 30, 2009 distribution of mercury in raw materials, and the use of fly ash from power plants from the Florida perspective. Hi s presentation is available at: http://www.dep.state.fl.us/Air/per mitting/construction/cement/Cement.ppt III. Keith Barnett, U.S. EPA provided an overview of:

• Possible EPA plans for the regulation of CO2 from cement manufacturing

• Affects of CAA section 129 rules on cement kilns that burn solid waste