900 SW Fifth Avenue. SUlle 2600 

## STGEL
Portland. Oregon 97204 main 503.224 JJ80 fax 503 220 2480

# ~~,~**1A'\\oW.~loel.com** ATTORNEYS AT LAW

THOMASR. WOOD Direct (503) 294-9396 

### October 5, 2011 trwood@stoel.com



### U.S Environmental Protection Agency Region 8 1595 Wynkoop St. Denver, CO 80202-1129 Attention: Vanessa Hinkle, 8P-AR


### Re: Response to Request for Additional Information for Montana City BART Determination
Dear Vanessa:
On September 19,2011, Ash Grove Cement Company ("Ash Grove") received by mail your informationrequest made pursuant to Section 114 ofthe Clean Air Act and requesting information for use in determining Best Available Retrofit Technology ("BART") for the Montana City facility. Specifically, you requested that Ash Grove document that wet scrubbing is not technically feasible and that Ash Grove submit a five factor analysis ofdry scrubbing techniques. This submittal was requested to be submitted by September 30, 2011-9 working days after receipt ofthe 114 request by mail. As I communicated to you, Ash Grove believes that this is anunreasonable amount oftime to allow for response to such a significant request. A complete 5 factor analysis cannot be performed in 9 days. However, Ash Grove committed to do the best it could do within the time frame allowed. This letter constitutes Ash Grove's response to this request.
I. 

### Confidential Business Information

Ash Grove is claiming confidential business information ("CBI") status for the information provided in this 114 response. This information complies with 40 CFR §§ 2.203(b) and 2.301 as well as Montana law. The identified information is eligible for CBI treatment under 40 CFR § 2.208 for the following reasons: (a) this claim ofconfidentiality has not expired by its own terms, been withdrawn, orwaived; (b) Ash Grove does not release information claimed as CBI to non-employees; only limited authorized employees have access to the financial information and production information claimed as CBI; Ash Grove intends to continue to keep internal distribution ofthis material limited and external distribution ofthis material prohibited; (c) the information is not obtainable without Ash Grove's consent; (d) there is no statutory obligation to disclose this information; and (e) disclosure ofthis information would harm Ash Grove's competitive position by making capital investment, cost ofproduction, and operating information, not otherwise available, potentially known to Ash Grove's competitors.

70926750.10012028-00054**/\IJ'>~J** CJlifol-niJ IdJho
rvl inn (' .., 0 l J 0 reg 0 nUl J h \V**~l** h I 11 0 I t) 11U.S Environmental ProtectionAgency Region 8 October 5, 2011 Page 2

The cementbusiness is intensely competitive as manufacturers compete for shares in a limited market. The marketis increasingly threatened by the import ofoverseas products and by new competitors. Consequently, informationrelated to production, operation, performance, cost, pricing, and value, ifdisclosed to competitors canreveal critical dataregarding Ash Grove's ability to compete in the market.
II. Background

Ash Grove's Montana City kiln is a long wet kiln that has been in operation since 1963. Thekiln currently employs an electrostatic precipitator ("ESP") for the control ofparticulate ("PM"), good combustion practices and burnerpipe maintenance/positionfor NOx control and inherent scrubbing and the use oflow sulfur coal as a component ofthe fuel mix for S02 control. As was previously described in Ash Grove's February 28, 2008 letter to Ms. Callie Videtich, a mass balance ofsulfur inputs and emissions indicate that in 2006 the inherent dry scrubbing achieved by the kiln design resulted in 80 percent control ofS02. Although inlet/outlettesting has not been performed, the kiln ESP would be expected to achieve 95 to 99 percent control. The PM emissions from the clinker cooler are controlled by a baghouse. Although inlet/outlettesting has not beenperformed, the clinker coolerbaghouse would be expected to achieve 99 percent control.

III. Response to Questions

Ash Grove has undertaken to respond to EPA's request to the best ofits ability. Ash Grove
reserves all objections to this informationrequest and the obviously inability ofthe company to respond to a request ofthis magnitude in the time provided. In your September 9,2011 letter, youposed two questions. Each ofthose questions is reproduced below in italics and the response follows. 

### RequestNo 

### 1: Supportyourstatementthat wetscrubbing is nottechnically feasible.

In my letter ofJuly 18,2011, I explained that wet scrubbers are no longer a technically feasible control for consideration as BARTtechnology for the Montana City kiln. As explained in further detail below, this conclusion was based on an analysis performed consistent with EPA's guidance inthe July 6, 2005 BART guidelines.

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In a BART analysis data are collectedthrough a five step process to arrive at a selection ofthe bestmethods ofemissions reduction ofNOx, S02, and PM at the BART source. The five steps followed to develop information for making the BART determination are the following:
1. Identify all available retrofit control technologies. 2. Eliminate technically infeasible options. 3. Evaluate control effectiveness ofremaining control technologies. 4. Evaluate impacts and documentthe results. 5. Evaluate visibility impacts.

These steps generate datathat are used to evaluate the costs and benefits ofvarious control technologies and, ultimately, identify the retrofit technology appropriate for installation at the
source. Step 2 ofthe BART analysis involves the evaluation ofall the identified available retrofit control technologies to determine technical feasibility. A control technology is technically feasible ifit has beenpreviously installed and operated successfully at a similartype ofsource or ifthere is technical agreement that the technology can be applied to the source. Two terms, "available" and "applicable," are used to define the technical feasibility ofa control technology. A technology that is being offered commercially by vendors or is in commercial demonstration or licensing is generally deemed an available technology. Technologies that are in development and testing stages are classified as not available. Similarly, unless a technology canbe demonstrated to comply with all applicable requirements, it cannotbe considered available. The fact that a technology mightbe considered available is not a sufficientbasis for concluding that a technology is applicable, and, therefore, technically feasible. A commercially available technology must also be "applicable," i.e., it must have beenpreviously installed and operated at
a similar type ofsource or a source with similar gas stream characteristics. Unless the technology is identified as both available and applicable, the technology is not considered technically feasible and, therefore, is not carried into Step 3 ofthe BART analysis process.
Wet scrubbing is no longer an "available" control technology for wet cementkilns. As part of the February 28,2008 BART submittal, Ash Grove included a proposal from MECS for its Dynawave Scrubbing System. At that time, wet scrubbing was considered technically feasible for a wet kiln such as the one employed at Ash Grove's Montana City plant. The MECS proposal was dated April 27, 2007 and thus predated by several years the imposition ofstringent
new and existing source PM limits for cementkilns. Atthat time, the other primary supplier of wet scrubbing technology to the cement industry was Solios. Since the 2007 proposal was issued, EPA has imposed stringent new PMrequirements. Specifically, the revised NESHAP

70926750.1 0012028-00054U.S Environmental Protection Agency Region l October 5, 2011 Page 4

PM limit for existing kilns is 

### 0.04lb/tonclinker and the limit for newkilns is 0.01 lb/ton clinker. The revised NSPS limit for new, modified or reconstructed kilns is also 0.01 lb/ton clinker. Since these standards were issued, Solios withdrew from the market, now beingunwilling to guarantee that their wet scrubbing technology will meet the cementNSPS and NESHAP PM limits. Similarly, MECS will not guarantee that its Dynawave technology will meetthe NSPS and new source NESHAP limits. The total capital cost ofinstalling a wet scrubber (based on a 2010 MECS proposal) is slightly more than $30 million (see attached cost-effectiveness analysis for costing details). Ash Grove could not be re:llistically expectedto install a $30 million control system on a 50 year old kiln without upgrading the kiln to maximize its output. Such a capital outlay would notbejustifiedunder any circumstances, but certainly not where the kiln is operating at its current levels. IfEPA requires installation ofa $30 million wet scrubber, the result will eitherbeplant closure orreconstruction ofthe kiln. Reconstruction ofthe kiln would necessarily triggerNSPS and the 0.01 lb/ton clinkerPM standard whichthe wet scrubber manufacturers will not guarantee that a wet scrubber canmeet. Because a wet scrubber is not available, as that tenn is used in the BART gllidelines, the technology cannot be considered technically feasible.
Wet scrubbing is also not an applicable technology for a wetkiln such as Ash Grove's Montana Citykiln. The Montana City kiln is a long wet kiln. Althoughthere are 5 kilns in the U.S. that
are using wet scrubbers to control S02 emissions, none ofthese kilns are wetkilns. Each ofthe 5 kilns is a preheater/precalcinerkiln. There is no basis for assuming that the technology employed on a preheater/precalcinerkiln will be transferrable overto a long wetkiln without extensive experimentation and pilot studies to detennine how the equipment mustbe modified to meetthe PM standards. Therefore, wet scrubbing is not applicable, as that tenn is used in the BART guidelines, and so cannotbe consideredtechnically feasible.
Ash Grove perfonned an independent analysis ofthe limited data available onthose few kilns where wet scrubbers have been installed in orderto verify the PM compliance issue. As noted above, the 5 kilns inthe U.S. using wet scrubbers to control S02 emissions are all preheater/preca1cinerkilns while the Montana City kiln is a long wetkiln. The significantly different exhaust gas characteristics between a preheater/precalcinerkiln and a long wet kiln are, in part, responsible for the technology not being directly transferrable. For example, the air flow Through a wet kiln is roughly twice that ofa dry kiln on a dscf/ton feed basis. However, even if those differences are disregarded, the evidence indicates that a wet scrubber will increase filterable particulate matter emissions to a**pOl:~!** that the plant will be unable to consistently meet the existing source NESHAP PM emission limit of0.04 lbs/ton ofclinker, let alone the new source emission PM limit (NSPS and NESHAP) of0.01 lbs/ton ofclinker. This conclusion is

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based onthe data Ash Grove collected and assessed ofPM emissiontests for four ofthe five kilns to determine the expected PM emissions from a wet scrubber on a cementkiln.

As EPA has previouslyrecognized, in order to accurately predict long term performance, it is necessary to take into account the variability tllat occurs test-to-test as well as run-to-run. EPA has long understood that it must employ statistical methodologies to address the need to account for variability in developing emission limits that accurately represent the ability ofa source to perform over an extended period oftime. For example, EPA stated in the preamble to the Hazardous Waste Combustor ("HWC")NESHAP that "sources which are lowest emitting in single emissiontests may not be the lowest emitters overtime due to their test-to-test variability." 72 Fed. Reg. 54875,54878 (Sept. 27, 2007). Later in the HWC NESHAP, EPA discussed the issue ofvariability for controls otherthan fabric filters ("FF"):

Sources equipped with control devices other than FFs are likely to emit more overtime than they do in individual test conditions, even after adjusting testresults to account for run-to-run variability. (Put another way, these sources' performance in individual test conditions
are likely notrepresentative ofwhat they will emitover time.) This is because test-to-test variability, that is, long-term variability, has not been taken into account. Since these other control devices are known to be more variable and less efficient than FFs, TSD Vol. III pp. 16-3 to 4 and 11, failure to considerlong-term variability (i.e., looking exclusively at results ofsingle performance tests) results in these sources' performance not being fully characterized. Long-term variability exists due to, among otherthings, variation over time in control device performance and varying ash feed rates. EPA confirmed in a series ofanalyses ofHWCs that this test-to-test variability for non-FF equipped devices both exists and is appreciable. Idat 54878-79.

This same issue ofvariability and the need to account for it was discussed extensively in the PC NESHAP. In that context, EPA stated that it sought to define the NESHAP limits based onthe
use ofavailable data such that ifthey wereto randomly select a future test from any ofthe sources, they would be 99 percent confident that the future value would fall below the established limit. 75 Fed. Reg. 54969, 54975 (Sept. 9,2010). Although Ash Grove does not necessarily agree that EPA's approach is a fair method to use to set enforceable limits monitored using CEMs, Ash Grove applied a similar methodology to

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### U.S Environmental ProtectionAgency Region 8 October 5,2011 Page 6

evaluate howthe wet scrubbercontrolled kilns would perfonn. First, in order to nonnalize results and employ the available data, it was necessary to detennine what grain loading wouldbe necessary in order to achieve the existing source PM standard of0.04 lbs/ton ofclinker. This
was detennined by taking the actual flow rate and production levels during several source tests perfonned at the Montana City kiln. This gives the infonnation necessary to convert the lbs/ton clinker limit to a gr/dscf

### limit.


### Table 1: Montana City Kiln

Date ofTest Run Flow Rate (dscfm) Production Rate (TPH) dscfhon clinker MACTLimitpounds per ton ofclinker MACT Limit

- Grains per ton ofclinker Grains per dscfto meet theMACT Limit during this stack test 91712010 56649 38.8 87601.5 0.04 280 0.00320 9/7/2010 61164 38.9 94340.4 0.04 280 0.00297 91712010 64547 39.0 99303.1 0.04 280 0.00282 9/8/2010 58938 38.8 91141.2 0.04 280 0.00307 9/8/2010 60382 38.9 93134.2 0.04 280 0.00301 9/8/2010 56870 38.9 87717.2 0.04 280 0.00319 10/7/2009 57471 39.3 87742.0 0.04 280 0.00319 101712009 58772 39.3 89728.2 0.04 280 0.00312 10/7/2009 57682 39.3 88064.1 0.04 280 0.00318 Average 0.00308 STDev 0.00013 95% Percentile (low) 0.00287 95% Percentile (high) 0.00330 Minimum 0.00281



### In evaluating the results ofthis conversion, Ash Grove applied a 90 percent confidence interval by adding 1.65 standard deviations ("STDev")**~o** 

### the average ofthe data set. Because a 90 percent confidence interval means that there is a 90 percent likelihood that a value will not lie above orbelow the data set, this means that ifEPA sets a limit equal to the 90 percent confidence interval, they would predict that 5 percent offuture test values would fall outside ofeach end of the range. As this test is not as rigorous as the one defined by EPA in the PC NESHAP, ifthe 90

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percent confidence interval generates a value equal to or greater thanthe regulatory limit, the kiln in questions would not be deemed compliant.

Ash Grove found one stacktest for the Holcim kiln located in Florence, Colorado. This preheater/precalcinerkiln employs a wet scrubberto control S02 emissions and there is a baghouse upstream ofthe wet scrubber. The PM emission rate from this single test was 0.0020 gr/dscf. While this might suggest that a wet scrubbercontrolled kiln could comply with the range ofgrain loading limits necessary to achieve compliance with the existing source standard atMontana City, more comprehensive testing at otherkilns with wet scrubbers paints a very different picture.

Ash Grove found two stacktests for the TXI kiln located in Midlothian, Texas. This preheater/ precalcinerkiln employs a wet scrubberto control S02 emissions and has a baghouse upstream ofthe wet scrubber. The results ofeach ofthe runs for these two stacktests are presented in Table 2.


### Table 2: TXI: Midlothian, TX

Date Test Runs #/hr gr/dscf bws 02 T stack (F) 9/26/2006 8:30 to 9:37 12.15 0.0027 0.180 12.4 286 9/26/2006 13:38 to 14:47 10.3 0.0023 0.187 11.6 283 9/29/2006 8:07to9:13 7.67 0.0017 0.183 11.6 280 9/28/2006 6:35 to 7:51 16.45 0.0040 0.181 11.4 272 9/28/2006 10:20 to 11 :28 8.54 0.0020 0.185 11.8 278 9/28/2006 14:02 to 15:08 18.8 0.0046 0.186 10.4 272 Average 12.31833 0.0029 STDev 0.0012 95% Percentile 0.0048
These data from the TXI Midlothiankiln showthatthe 95th percentile grain loadingbased on these six testruns wouldbe 0.0048 gr/dscf. This is well above the upperbound 95thpercentile that wouldbe required to be in compliance with the existing source PM standard at Ash Grove's Montana City kiln. Similarly, the 95thpercentile value required to meetthe existing source PM standard at Ash Grove's MontanaCity kiln is 0.0033 gr/dscf. The 95thpercentile value for TXI's Midlothian kiln is significantly higherthan that ofthe 95th percentile value at the Montana City kiln and the average value for the TXI kiln is only slightly lower that the average Montana City compliantvalue. This indicates thatwith a scrubber downstream ofabaghouse, Ash Grove's Montana City kiln wouldbe expectedto violate the existing source PM standard a

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### U.S Environmental Protection Agency Region 8 October 5,2011 Page 8

significant amount ofthe time. This is not consistent with EPA's stated target ofbeing 99 percent confident that future values would fall belowthe established limit.

Datafrom nine stacktests for the Hokim Kiln 1located in Midlothian, Texas further bear out this trend. Hokim Kiln 1is a preheater/precalciner kiln that employs a wet scrubber to control S02 emissions with anupstream baghouse to control particulate. The results ofthose stacktests
are presented in Table 3.


### Table 3: Holcim Kiln No.1; Midlothian,TX

Test Date #/hr gr/dscf bws 02 T stack (F) 10/9-10/2000 13.21 0.0056 0.188 12.4 137 10/11-13/2000 16.15 0.0074 0.196 13.2 139 6/24-25/2002 8.64 0.0034 0.192 12.2 138 6/25-26/2002 15.90 0.0062 0.184 11.7 139

1113/2004 5.53 0.0020 0.180 14.2 135 1114/2004 17.00 0.0062 0.192 12.6 138 3/14/2007 3.91 0.0015 0.172 13.2 133 3/15/2007 11.82 0.0057 0.206 11.1 141 8/25/2008 11.10 0.0042 0.218 12.5 146 Average 11.47 0.0047 STDev 0.0020 95th Percentile 0.008


### As can be seen from this set ofsource tests, the average grain loading at Holcim's Kiln No.1 is well in excess ofthe upper bound 95thpercentile value ofgrain loadings that would demonstrate compliance with the existing source PM standard at Ash Grove's Montana City. As with the TXI kiln data, the Hokim KilnNo.1 data indicate that using a wet scrubber downstream from a baghouse wouldresult in Ash Grove's Montana City kiln exceeding the existing source PM standard considerably more than 50 percent 01 

### the time.

This is again demonstrated when examining the data from Hokim KilnNo.2 in Midlothian, TX. Ash Grove obtained sixteen stacktests for the Holcim Kiln 2, thus providing a very robust data set. As with the other kilns examined, this preheater/precalcinerkiln employs a wet scrubber to control S02 emissions with a baghouse upstream ofthe scrubber. The results ofthe stack tests from Hokim Kiln No.2 are shown in Table 4.

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# u.s Environmental Protection Agency Region 8 October 5, 2011 Page 9

Table 4: Holcim Kiln 

### No.2; Midlothian, TX

TestDate #/hr gr/dscf bws 02 T stack (F) 12/4-5/2000 11.75 0.0046 0.189 12.9 141 1/3-4/2001 15.85 0.0069 0.182 12.9 145 6/24-25/2002 3.75 0.0014 0.207 13.0 142 6/25-27/2002 5.97 0.0021 0.207 12.7 142

8/26/2003 15.30 0.0057 0.195 10.3 139 11/4/2004 1.06 0.0016 0.188 13.3 137 11/3/2004 9.20 0.0035 0.175 13.5 135 2/28 -3/02/2007 6.36 0.0022 0.168 12.2 134 2/28 -3/01/2007 8.09 0.0031 0.174 11.6 136 8/28/2008 18.30 0.0062 0.195 12.8 146 7/30/2009 16.00 0.0056 0.189 13.0 138.7 7/30-31/2009 8.60 0.0031 0.208 12.3 141.4

7/21/2010 4.80 0.0017 0.178 13.0 144.5 7/20/2010 9.00 0.0033 0.184 12.8 137.2 11/9/2010 1.14 0.0004 0.164 13.2 135 11/9-11/2010 2.75 0.0011 0.169 12.6 135

Average 8.62 0.0033 STDev 0.0020 95th Percentile 0.0066 Again, as with all ofthe tests exceptthe single test onthe Florence kiln, these data clearly show that a kiln with a wet scrubber, even one with a baghouse upstream ofthat scrubber, cannot reliably meetthe existing source NESHAP PM limit. The average value for all ofthese tests is 0.0033 gr/dscf--exactly equal to the upperbound 95thpercentile for the range ofgrain loadings predicted to meet the existing source PM standard at the Montana City kiln. Thus, these data indicate that were the Montana City kiln to employ a wet scrubber, it would be expectedto exceed the existing source PM standard approximately halfofthe time.

No stacktests were found for the Lehigh Davenport kiln.

These stacktest results provide a compelling basis for concluding that ifthe Montana City cement kiln employs a wet scrubber, it cannotreliably meet the existing source NESHAP PM limit. The data summarized above demonstrate that a kiln with a wet scrubber would at best meetthe PM standard only about halfofthe time. However, the NESHAP requires that kilns demonstrate continuous compliance utilizing a PM CEM. Given the available data, one cannot conclude that compliance with the existing source PM limit can be consistently demonstrated when a PM CEM is employed. This explains why one leading manufacturer ofwet scrubbers for the cement industry is no longer selling wet scrubbers for cement kilns and the other primary

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manufacturer will no longerprovide written guarantees thatthe equipment will meet the standard. In light ofthe test data and the lack ofconfidence ofthe manufacturers that their wet scrubbing equipment can meet the existing source PM standard (let alone the standardthat would apply ifAsh Grove were to reconstruct its kiln) there is no basis on which to conclude that wet scrubbing is currently technically feasible. EPA cannot consider a control technology to be technically feasible ifthose controls are unlikely to be capable ofoperation without causing the Montana Cityplant to exceedthe existing source PC NESHAP PM standard.

In addition to the technical feasibility issues associated with the inability ofthe Montana City kiln to comply with the PC NESHAP and NSPS PM standards, wet scrubbing is also technically infeasible due to the lack ofavailable waterto operate the scrubber. Since the 2007 BART analysis was prepared, the State ofMontanahas decreased the waterright held by Ash Grove's Montana City plantto matchhistorical use. As a result, a considerable amount ofthe water for which the plantpreviously held a waterright, has now been withdrawn bythe State. The Montana City plant is in an areathat only receives 11.9 inches ofwaterperyear. In such an area, water is an extremely valuable commodity. Because ofthe overappropriation ofwater rights, the State has become increasingly active in trimming existing waterrights to match historic use. This is what occurred to Ash Grove. A wet scrubber is anticipated to consume approximately 38 gallons/minute ofwater, a total ofapproximately 19 million gallons/yr**(~61** acre-ft/year). EPA cannot require Ash Grove to install and operate such a technology in an arid part ofthe country where there is no certaintythat Ash Grove would even be able to obtain a 61 acre-ft/year waterright. Furthermore, even ifAsh Grove were able to obtain a waterright to such a large quantity ofwater, there is no guarantee that the company would be able to rely on that waterright. In a dryer year than normal, 8 more senior waterrights holder could require that Ash Grove cease its use thus resulting in the closure ofthe plant. The large amount ofwater required to operate a wet scrubberin the arid location ofthe Montana City plant poses one more reason why a wet scrubber is not technically feasible.

Forthe reasons stated above, Ash Grove has concludedthat wet scrubbing is not a technically feasible technology for the wet kiln atthe Montana Cityplant. We also note thatbased on Ash Grove's latest information regarding the cost ofwet scrubbing, the costperton ofS02 controlled is nearly $11,000 perton. We have included with this response the mostrecent costeffectiveness calculations prepared by Trinity Consultants. Atthis cost, wet scrubbing is unquestionably not cost-effective and so cannot be considered BARTfor S02.

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### RequestNo 

### 2: Submita 

### 5factor analysis of dry

### scrubbingtechniques

You had also requested thatAsh Grove conduct a 5 factor analysis ofdry scrubbing technologies for S02 control. Although you did not define what you meantby "dry scrubbing technologies," Ash Grove conservatively optedto include both Dry Adsorbant Addition ("DAA") as well as Semi-Wet Scrubbing.
The BARTrule states that a BART determination should address the following five statutory factors:

1. Existing controls 2. Cost ofcontrols 3. Energy and non-air quality environmental impacts 4. Remaining useful life ofthe source 5. Degree ofvisibility improvement as a result ofcontrols Further, the BARTrule indicates that the five basic steps in a BART analysis can be summarized
as follows:

I. Identify all available retrofit control technologies; 2. Eliminate technically infeasible control technologies; 3. Evaluatethe control effectiveness ofremaining control technologies; 4. Evaluate impacts and document the results; 5. Evaluate visibility impacts
Ash Grove has prepared this analysis specific to DAA and semi-wet scrubbing, while otherwise remaining consistent with the methodology outlined above.

I. Identify All Available Retrofit Control Technologies
As at EPA's request, this analysis is limited to DAA and semi-wet scrubbing, this particular step ofthe analysis is pre-determined.

2. Eliminate Technically Infeasible Control**~~chnologies** Ash Grove believes that neither DAA nor semi-wet scrubbing is technically feasible. DAA is in the earliest stages ofdevelopment and while various companies have begun experiments in its application to cement kilns, it is not a proven technology at this time.

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Semi-wet scrubbing is similarly unproven. Semi-wet scrubbing is notbeing operated on any cementkiln in the country. Ash Grove has proposed semi-wet control to EPA Headquarters in relationto its Midlothian, TXplant, but as an Innovative Control Technologyproject where Ash Grove would seekto implement a pilotproject for the technology. That site was chosen because its S02 emissions are several fold higher than those from the MontanaCity plant. As discussed above, a control technology is technically feasible only ifit has beenpreviously installed and operated successfully at a similartype ofsource orifthere is technical agreement that the technology canbe applied to the source. In addition, thetechnology must be both "available" and "applicable." Technologies that are in development and testing stages are not considered available. A commerciallyavailable technology must also be "applicable," i.e., it must have been previously installed and operated at a similartype ofsource or a source with similargas stream characteristics. Unless the technology is identified as both available and applicable, the technology is not considered technically feasible and, therefore, is notcarried into Step 3 ofthe BART analysis process. Because semi-wet scrubbing is not being operated on any cementkiln inthe country, let alone a wet cementkiln, it is not consideredtechnically feasible. Again, as was clearly stated inthe BARTrule preamble, "[EPAdoes] not expect a source ownerto conduct extended trials to learnhowto apply a technology on a totally new and dissimilar source type. Consequently, you would not consider technologies inthe pilot scale testing stages of development as "available" for purposes ofBARTreview." 70 Fed. Reg. at 39165. As semiwet scrubbing is in the pilot scale testing stages ofdevelopment, it must be eliminated from consideration in Step 2. Althoughboth DAA and semi-wet scrubbing are properly eliminated in Step 2, we have nonetheless carriedboth technologies through into the subsequent steps. ForDAA, this is because Ash Grove is proposing to install DAA as an innovative control technology on its MontanaCity kiln. For semi-wet scrubbing, Ash Grove has carried the technology through the subsequent stages so as to document all ofthe additional reasons why, even ifit were technically feasible, semi-wet scrubbing would not constitute BART.

3. Evaluate The Control Effectiveness OfRemaining Control Technologies

Because ofthe technical infeasibility issues associated with both DAA and semi-wet scrubbing, it is extremely difficult to estimate the control effectiveness. ForDAA, there is no record which
can be used to estimate a specific system removal efficiency ("SRE"). Giventhe lack of information, Ash Grove is conservatively estimatingthat it will achieve an SRE of20percent of the existing baseline. 1 Ash Grove has also conservatively estimated that semi-wet scrubbing

I Ash Grove wishes to note that the existing baseline S02 emissionrate has changed since the 2007 BART submittal. As described in the 2007 document, an S02 CEMhad been operating (continued

...)

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will achieve an SRE of90 percent. While the SRE for semi-wet scrubbing may be extremely optimistic, Ash Grove does not believe that it changes the outcome ofthis analysis.

4. Evaluate Impacts And DocumentThe Results Step four for the BART analysis procedure is the impact analysis. The BART determination guidelines list the four factors to be considered in the impact analysis:

• Cost ofcompliance
• Energy impacts • Non-air quality environmental impacts; and
• The remaining useful life ofthe source
AGC has conducted an impact analysis for both ofthe two control options notwithstanding the fact that neither is considered technically feasible.
Cost ofCompliance
Ash Grove's construction consultant derived the cost ofa semi-wet scrubbing system based on a vendor quote that was not site-specific. Based on this cost, Trinity Consultants performed an economic analysis to determine the annualized cost for semi-wet scrubbing using the standardized OAQPS format. Ash Grove divided the annualized cost ofsemi-wet scrubbing by the annual tons ofS02 reduced to determine the costeffectiveness for semi-wet scrubbing. The "annual tons reduced" were determinedby subtracting the estimated controlled annual emissions

(

... continued) only a shorttime as ofthe preparation date ofthat submittal. As a result, very little was known about the variability ofthe S02 emissionrate or how to control that emissionrate through process changes. Since that time the plant management has employed the CEMto adjust kiln operation in a manner that the S02 emissionrate has decreased considerably. Specifically, in the original BART submittal Ash Grove estimated that the annual S02 emission rate was 981 tons/yr derived by multiplying the average emission rate during 2006 (254 lb/hr) by the annual operating hours (7,740 hours). Based on the average emissionrate during 2010, Ash Grove now estimates the hourly S02 emission rate as 612 tons/yr. Ash Grove believes that this revised emission rate, which assumes an average emissionrate of 147 lb/hr and 95 percent availability (8,322 hours),
more accurately characterizes the baseline emissionrate for the plant as it has been operated during the past several years.

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from the baseline annual emissionrate of612 tons/yr (see above). The estimated controlled annual emissions were calculated by applying the 90 percent control efficiency to the baseline annual emissions rate. The attached cost-effectiveness spreadsheet provides the cost effectiveness analysis related to semi-wet scrubbing. As can be seen from the analysis, the cost ofcontrol is not considered cost-effective. OtherBART determinations have considered costs in
excess of$4,000 perton ofpollutant controlled to be excessively expensive. Here, Ash Grove has documented that the cost would be $4,052/per ton. This is not considered cost-effective.
As Ash Grove is proposing to employ DAA as BART, it did not prepare a cost-effectiveness analysis for the technology. Energy Impacts
A semi-wet scrubberrequires an additional fan ofconsiderable horsepower to move the flue gas through the scrubber. Therefore, this element ofthe analysis also weighs against requiring a semi-wet scrubber as BART.

Non-Air Quality Environmental Impacts

The key non-air quality environmental impacts associated with semi-wet scrubbing, as opposed to DAA, is the consumption ofwater. DAA relies on the inherent moisture in the exhaust gas to operate. By contrast, semi-wet scrubbing requires 3.5 gallons/minute ornearly 2 million gallons ofwaterper year. As noted above, the Montana City plant is located in an extremely arid location and its water right wasjust severely reduced by the State ofMontanato match historic
use. This means that newwater use would require ash Grove to obtain additional waterrights in
an area where all surface water is fully appropriated and groundwater is limited and subjectto beingturned offduring dry periods ifa senior waterright is affected. EPA has a long record of notrequiring water intensive control technologies in arid regions due to the severe environmental impacts. In this case, semi-wet scrubbing should not be required as BART due to its consumption ofsignificant quantities ofwater that may simply not be available. Remaining Useful Life ofSource

Ash Grove does not believe that the remaining useful life ofthe source is a relevant factor to the analysis.

70926750.1 0012028·00054U.S Environmental ProtectionAgency Region 8 October 5, 2011 Page 15

5. Evaluate Visibility Impacts
The final step ofthe analysis is to evaluate the visibility impacts associated withthe different control alternatives. In performing this assessment, it is importantto note that S02 is not a controlling pollutant in Ash Grove's visibility ,malysis. The predominant driver ofvisibility impacts at Class I areas from the Montana City kiln are the NOx emissions. S02 emissions contribute an almost insignificant amount to visibility impacts from the Montana Cityplant. As Table 

### 5below shows, this means that the imposition ofany S02 control at the plant results in minimal visibility improvement. The incremental improvement in visibility attributable to requiring semi-wet scrubbing as BART is a mere 

### 5percent improvement ora 0.16 dv improvement in visibility. Based onthe annualized cost ofthe semi-wet scrubbers, this results in
a cost ofwell over $13 million dollars per deciview ofimprovement. This cost is clearly not justified and semi-wet scrubbing should not be required as BART.

TABLES

Maximum 8th High

(t.dv) Change From Baseline

(dv) Percent Improvement Existing 2.699



### -­ -­

DAA 2.666 -0.033 1% Semi-Wet Scrubber 2.539 -0.16 6%

A more detailed summary table ofthe modeling results is included as an attachment to this letter.

6. Select BART for S02

Based onthe analysis above, there is a strong argument that semi-wet scrubbing is not a technically feasible control technology. However, even ifthat concern is ignored, the environmental impacts, cost impacts and lack ofany material improvement in visibility associated with semi-wet scrubbing all combine to demonstrate that it would be arbitrary and capricious to considerthis technology to constitute BART. Although similar arguments against DAA being a technically feasible control technology exist, Ash Grove is willing to take onthis technology as a innovative control and commit to operate the technology such that S02 emissions are limited to I47lb/hr (30 day rolling average). As with semi-wet scrubbing, this control technology will notresult in significant visibility improvement. However, the development ofDAAtechnology for wet kilns may prove useful at otherplants across the country and so there is separate merit in installing the technology.

70926750. J0012028-00054

### U.S Environmental Protection Agency Region 8 October 5,2011 Page 16

IV. PM BART Although EPA did not request additional informationregarding BARTfor PM, Ash Grove wanted to update the agency as to its currentplans for PM control. As noted above, Ash Grove currently operates anESP for controlling PM from the kiln. Estimated annual PM emissions have averaged approximately 100 tons/yr with the ESP in operation. However, Ash Grove is moving forward with installing a baghouse on the kiln exhaust which it anticipates will decrease kiln PM emissions from approximately 37 lb/hr used in the modeling to approximately 5 lb/hr,
an estimated reduction in actual PM emissions ofover 85 percent. While NOx, not PM, is not the primary driver ofvisibility impacts, we wished to make EPA aware ofthis increase in emissions control that the company is investing in.

V. StatementofCertification

Included as an attachment to this letteris a Statement ofCertification from Dick Johnson, the plant manager ofAsh Grove's Montana plant, certifyingthe accuracy ofthe statements and materials comprising this submittal. However, Ash Grove is unable to certify that the submittal is complete given the unreasonably short time frame allowed for the response.
Please let me know ifyou have any questions after reviewing this submittal.

cc: Dick Johnson JeffBriggs Fran Streitman Curtis Lesslie Bob Vantuyl Kasi Dubbs Attachments: 1. Wet scrubber cost-effectiveness analysis 2. Semi-wet scrubber cost-effectiveness analysis 3. Revised modeling summary 4. Certification statement

70926750.1 0012028-00054AGC Montana City SO, Control Cost Effectiveness Analysis Wet Scrubber Direct Costs NoCc:Ii Purchased E ui ment Costs MECS 11)1IIIW8\"(: SCl'\lbbo;lrQuolc; 2010 $9.000 k S

..**rut>~r.** S**1.~(lO** k**Rea~ell1** rrr-:r &. tiller $24U k hIll",. t>uddlll{l_ S!lOO ShJJ!lc J"p'_I', $600 k Wei SCI\lllller Ul\Il SlZ.I4II.0(JO HnUelll hllOdhnll.l**111~lrum,,"llllion** mel Sales Tax (3°,. aCEe)**S,'(,.L~O(l** () 03 A Freillhl So'oorEe $(,07.(J{)(1 OOs A SuhtotaJ. I'ufchllsed LqulpmCmCOs\ (PEe) SI3.JJI.lU(l fl

l'D"'.=,,.'-"'"'Slll"'"!!lllli"'"''-'C-'''os'"'\S'--­ -----1006 H. from CONTROL COST MANUAl
Fou"daliOll ((,°0or PEe) S7KIl.f>72 EPA**45~** 'H·OZ-()()] (eeM] Suppons (60 0 ofPIT)**PKh_f>7~** O()(,13 fmm CCM HlIfldlitl!lllOd ErcCllOIl (40°'. or ['Ee)**S:'.~44A80** ()**~o** H. frolll CCM Elco.;mcal(IO'oofPECj $131.112 001 B,rromCCM Pipll1p.(30.oofI'FC} SJ.'I,n

..'f,1l (1.30 B. rlOm CeM**~lsulB.1I011** for Dllc",,'orl (1% of PEl') S13 1.112 0.t}1 fl. from CCM P .c ,,,,"","',"'.l!''''o .•**'''O!.!r1'EEC''-------,SC-"hCC'O__,''~L''''''-'w--,.,~'''--,sta~Il'--,''-** ••-;Ce CC ",--',**-~S'C''''I~:~~~'C;.,,~~'--,** ---j(l.lll H. [.om CCM

Tolll DirKI lOllI SZ4.ZSS.720**-'.In'''d''';r''''~,,t-'C'''os,,ts'-- ;-:bl:::.--,''~c:,:::il1P.:-------------------,S,.;,;:;,,,:;;,m"''',----\MECSlJovt18** **B.\'eScl\Jl>hcl()uole20111** CooslruclJOll and Field Expense (10°'0 ofl'EC) S1.3 tl.120 0 to fl, CCM Contractor h::es (IOO'oofI'ECj S1..'I11.120 !l III fl. CCM Sl.lI.n-up (10 "0 ofPEC) S131,112 (I,or Jl.CCM I'erfomulncc res' (IO--oofI'EC) SI,ll.J 12 001 B. CCM ",C","'''''''''-''**~""""'''-' "'20"'%'-"O"'f1CE'E"'CL------COT..,"'-,.'~'"-,di..,'K-'.."C..,"'-,**  __**~~;",:~,;,~~",:;,:,,~,-,** ---jAGe. EnllllloemHI. bUmble

Tolal lotpitallnvefihnenl (Tn)
Direct Annual Costs Hour> per Year 950 '0 Annual Run Time 11.322

Oneratlll Labor 0l'elalOr (0 5 hris/lin. 3 shlns:dav. 365 d.-yr. S25,hr) SU'lCl'\'lsor 15°'0 oj o>crator SubtOlal 0l>cralllltll.<l(lor Sl\.MIll 520B SIS.Nt CCM

Labor (D,' hrlshlti. 3**~hlft~'dlIy,** 365 d:vr, :ii25'hr) Maleflill 1000 /. of**m<linlenlln~** ll1t>or SuhlOtal. Mawtmane<.: S13,688 S13 Mil S27.:n5 CCM

lJtlhtles f]octrlcl1

PUl1ll' (kWj -l6J 51 MECS**[)vnawa~e** Scrtlbl:>er Quote 2007. 510 hp (l1l0 kW) wsl

.. 't1l U.'illge. scaled up accordlnp. to () 6 power n>le fron> 75,000 -;cfln {I 15,057 aclln)'o 160,OOD adn> ,if;. 350 dCll Fnue O(a

... l1o,," rate

Cil-il (S:kW-hrl**~uh\(lllli.** l:k,,;ln<,;ll,**-----;s~~~';"~~"'~~+;** ---1 NorthWestern Enerll:\' smaJllndu.i1l\', Helena, M'I •**Lllm~SI~le** Slufl".'

Am'Xlol R,;qu"c:J**(llI11~',)** 3.2% MECS**I~Tlllwavc** ScruhberQuole 2007. 650 Ih hr hmcsl'Ilc USllllc scaled up acu,rdintllO 0.6 J'l',,"er mlc from 75,000 ,;erm (115.057 act'm) 10 160.000 ac:Jln If I' 350dCllFl1ucllasl!owrate Ch,,(S'lu'l) Sublolal, 11m..:**---;C~C7~~-l7'·:"76** ---1 (S15 from Table 3 1-2 ofNLA· evaluation)

MECS [)ynllwllve Scrtlhher Quote 2007, J I lllIl'lmn wakr uSiltle ';Caled up accordintllO0 6 [lOWer rule ironl 75,000 'iC11ll (115.057 aclm) 10 IMl.OOO OcCllI ti ]50 Amounl kcqu"':d (tlf'>l'l) 1711 dell F lluejl.as no,," rale CllSl (SdOOO**~lIllns) ~ublOIIiI.** **wa,cf---;cS:",~:4"'5;C'~** Helena Water

- S2 60 !>cr 7411ll,allons'**~Iud** e**DI~l'>O!'al** MECS Dyllawavc Scruhl:>er QuOle 2007.1.350 lbll>' sludlle p.encralJOIl, scaled up accordmp. hl 0 (, JXl"'cr rule irom 7S,O()O >;cfrn (11S,057 act'm) 10 160,000 act'm Amounl Geueraled (tpy) 6,84(, fa' 350 dell F tluejl.asllowrale D1sprnal Fe.: (Siton) SubtolO(I. Sludge**-----;S"'.1:"';~"'~~K",;**---1 1,eWll Wld Clark CounlV Landfill d

Sublotal. Uhhlles $716,162

TOlal DirKt '\nnu.1 Costa 5759,278
IndirectAnnual Costs Overhead (60G,0 ofsum ofoperaullg. ,u[ll:l".·I.or, maintenance lal>or & llla'enals) S300,271 [)oesnullndlJdee!eclrlcll'\ AdrnlUistraliv.: (2% TCI) S600,448 O,02TCI Property Tax (1°'0 TCl) S300.224 () 01 TCI lusurwlcc(lo'oTClj S300.224 001 TCI Ca }]jal**Rec:o~el"\'** 15 vear life 7 S3 296 3U1 Totallndir('(;tAnnual CO$t s.a,797,468
Conclusion

rolll Annu

..liu·d CUJit 55.556,746

l'ollutant t:mission Rale Prior to Scrubht'r (lOnl' SO/yr) 612 111I.,ed un 20](1 aH:rlltle ':1ll15Sllrl**nu~** of 14711->'-1->1 S02 (with**I'roccs.~** ...",,,ols Irnplemeillcd). ';5"" ul'lnne

Pollutant Remo\'i·d (tons SOl/lr) C".I Pt'rT"n "rl'oIlUlanl !Wn",,,flI lIIa••i"'i 900 '0 removal. A.>slJlIles**9~"··"** conlrol C<julprn"'l1 upume

TOlal ,\nllullli"l"II COlli**IlO'£i~·;..** ... lmp

....vt'n'.1I1 5 I lkch'iew 1m rOH'mt"nl SS,556.746 1,u60 $34729,663
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hltp. !Iwww Cl hckna.mI.U**!ildep"nlllo:tll.'!"lIdnlllll~lralL ~'C->oCr\'IC""""**  filllU1CC,ul1**ht)'-eUSlomcr-ser~Il:Cs.'-eU** slonler,mquLrIe;,.- water-rales.hlml d http 'Iw

...."" co lew,s-clllrk.ml.usldcl'0rtmalls.'pubhc_worhi.•olid_wastc.htmlAGC Montana City S02 Control Cost Effectiveness Analysis Semi-Wet Scrubber Notes Direct Costs Purchased EflU!nment Costs Sohos Enhanced Semi-v.et Serubber QUOIC 2010 (2010 Quote) Scrubber Unit $),690,000 2010 Quote Instrumentation S7JO.OOO 00) A Sales Tax (3% ofEC) SI32,600 2010 Quote FrelPht $300000 Subtotal, Purchased Equipment Cosl (PEC)**S4JI~2,600** B

Direct Installation Cosls Ci\'11 Structural (inel. mal'l) Foundation Supports Handling and Erection ElecLrieal Piping Insulation for Ductwork Paintin Subtotal, Dmxt Installation COSI $1,020,000 Inel Inel $1,690,000

$620,000 Incl Incl Incl $),330,000 2010 Quote

2010 Quote 20lO Quote

Total Dirert Cosl $8,182,600
Indirect Costs Ellglnccnng Construction and Field Expense

Contractor Fees (10% ofPEC) SIar1-llP (I % ofPEC) Perfomlance Test (1% ofPEC) Conlinllcnclcs Total Indirect Cost $400,000 S660,OOO
S48\260 S4R,526 S48,526 $1.820.000**S3,~62,Jll** 2010 Quote 2010 Quole f,pm CONTROL COST MANUAL· EPN4l2/B·Ol· 001 (CCM), Seclion 5.1, Chapter I, Table I 3 (,CM.**~tlon** :'i. I. Chapter I, Table 1.3 CCM. Sccllon 5 I. Chaptcr I, Table I 3 2010 QuOIC

Tnhll Ca'lihlllnvcsimeni (TCI) SII,644,912
Direct Annual Costs Hours per '{car 95% Annual Run Time &,)22**~t'"** Labor Operator (0.5 hr/shin, 3 shins/day, 365 d Suocrvisor (15% ofoneralor) lyr, S25/hr)
Subtotal, Operating Labor $13,6&& $205) $15,741 estImate CeM

Maintenance Labor (0.5 hr/shIO. shIfts/day. 365 dlyT. Matenal (I OD% ofmaintenance labor $25/hr)

Subtotal, Maintcnance $1 ),6&8**$136~UI** S27,J75 estlmale CeM

Utilities Electncllv

Demand (kW) 75 16 Estimated based on 2011 Turbosome syslem for a lime kJin wllh 69.000cfm nue gas al 300deg F - 377,600 kw-hr. scallXi up aCCQrding to 0.6 powcr rulc to 160,000 cfm

Cost (SIkW-hr) Subtotal, Ek:ctrlclt) $00671**$~I,96&** NorthWestern Energy: small mdustry, Helena. MT a

Hvdrated LIme

Amounl ReqUIred (tonly.-) Cost (S/ton) Subtolal, Lime 1,096 $14500 $15&,910 Based on 2010 average cmission rate of 147 lblhr S02 (wllh process CQntrols implemcnted), CaOH/S02 ratiO of 1.5. 96.8% puril) $/ton deli\'ered (Quote from Graymonl)

Subtotal, U\llibes $200,&7&

Water Amount RCqUlfcd (gpm) Cost (S/1000 gallons) Subtotal. Waler 3 S 13476 S6.075 AGe

- Engmccnng Estlmatc Helena Water

- S2.60 per 74M gallons

Total Dircct Annual CO.'its S250,068
Indirect Annual Costs O\·erhead (60% ofsum ofopcrotmg. supervisor, mamtenanec labor & matenals) $124,&60 Admlnls(rauve (2'111 TCI) S232.K9R 002Tel. CCM, Sec 5 I. Ch I.T,ble I 4**Prope~** Tax (1%TCI) Sllfl,449 0,01 TeL CCM, Sec:'i I,Ch I. Table 1.4 Insurance (1%TCI) SI16,44\;> OOITCI,CCM,Sec51,Ch I,T.ble 14 CaVltal Recoverv (]5 ear hfe. 7 oereenl mterest) $1.27R.549 CCM, Sec I, Ch 2, EQn 2.8a Total lodirect Aonual Cost SI,I<69,205

Total Anouali7.ed**Co~t** S2,119.273

Based on 2010 average emiSSIOn ratc of 1471blhr S02 Pollutant Emissioo Rate Pdor 10 SHubbcr (tons SO}/yr) 612 (with process CQntrols implemented), 95% uptime

Pollutant Removed (tonsSOl/yr) 523 90% removal. Assumes 95%CQnlrol equipment uptime Cost P"rTon ofPolI.fanl Remo\'ed

TOial AnDualized Cost S2.119.273**Deci~iel't** Improvement 0.160 S I Dech'icw 1m lrOl'emeol 513,245,457
, htt :/1 de rtrn n / p WWWCI helena.rnt,us/ pa e IS admJnlstrallHl servlCCS finance/utility customer senIces/customer mqUlnes/waler ralCS hlmlMethod 8 Mode 5 post processing. Percent Changefrom Change from Baseline 3yr98th Baseline Based Based on Natural Maximum 8th

_ Percentile on Maximum Maximum Background Ranked Ranked Ranked High Ddv (22nd High) 8th-High Ddv 8th-High Ddv

Method Ddv Class I Area: Gates ofthe Mountain

BaselinelProcess 2001 Ddv 2002 Ddv 2003 Ddv Ddv

4.196 4.638 4.234 3.777 4.527 4.194 3.698 4.037 4.072 3.217 3.291 3.458 Annual Average 2.699 2.699 N/A N/A Control 3.118 3.169 3.300 2.869 2.872 2.897 2.769 2.724 2.768 2.461 2.597 2.699 Total # days over 0.50 ddv 98 82 71 total across 3yrs 251

Total # days over 1.0 ddv 56 43 42 total across 3yrs 141 4.170 4.581 4.174 3.748 4.486 4.150 3.629 3.984 3.987 3.174 3.231 3.412 20% Reduction. OAA Annual Average 2.666 2.666 -0.033 -1% 3.094 3.112 3.240 2.850 2.825 2.878 2.706 2.69 2.681 2.420 2.571 2.666 Total # days over 0.50 ddv 98 82 69 total across 3yrs 249

Total # days over 1.0 ddv 55 42 41 total across 3yrs 138 4.078 4.376 3.994 3.646 4.343 3.962 3.388 3.794 3.682 90% Reduction. Semi- 3.020 3.015 3.250 Annual Average 2.539 2.487 -0.16 -6% Wet or Wet Scrubber 3.013 2.912 3.038 2.781 2.657 2.813 2.486 2.575 2.551 2.277 2.487 2.539 Total # days over 0.50 ddv 97 81 66 total across 3yrs 244

Total # days over 1.0 ddv 52 37 39 total across 3yrs 128

CONCLUSION: Since Nitrates is a largest percentage ofthe deciview a large reduction in sulfates does not yield a large reduction in deciviews. See individual yeartabs for species % ofdeciview for top 22 ddv.StatementofCertification

Icertifyunder penalty oflawthat Ihavepersonally examined and am familiar with the

infonnation submittedin this document and all attachments and that, based on myinquiry of

those individuals immediately responsible for obtaininginfonnation, I believe that the

infonnation is true, accurate, and complete. I am aware that there are significant penalties

for submitting false infonnation , including the possibilityoffine or imprisonment.

Signature:

# Title:~\ et",

# t ctk.

# ~l~-l v

Date: 

# 1D-)

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# J