FREDRICK J. DINDOFFER FDINDOFFER@BODMANLAWCOM 313-393-7595

BODMAN PLC 6TH FLOOR AT FORD FIELD 1901 ST. ANTOINE STREET DETROIT, MICHIGAN 48226 313-393-7579 FAX 313-259-7777 

# bodman

ATTORNEYS & COUNSELORS 

### September 5, 2012

VIA EMAIL (BLAKLEY.PAMELA@EPA.GOV} VIA FACSIMILE 

### (312-692-2450) VIA ELECTRONICALLY(WWW.REGULATIONS.GOV}


### Ms. Pamela Blakley, Chief United States Environmental Protection Agency Control Strategies Section Air Programs Branch (AR-18) 77 WestJackson Boulevard Chicago, Illinois 60604
Re: EPA Docket ID No. EPA-ROS-OAR-2010-0954 Comments ofSt. Marys Cement Inc. (U.S.) Regarding Notice ofProposed Rulemaking Published at 77 Fed. Reg. 46912-46928, Monday, August 6, 2012 

### Dear Ms. Blakley: I am forwarding to you by fax, email and electronically the comments of St. Marys Cement, Inc. (U.S.) to the above-referenced USEPA NPRM. The original of these comments were transmitted yesterday by overnight delivery to your office. The original that was sent yesterday contains original signatures, and also has color copies, and therefore 

### will be easier for EPA to review and understand. These additional sets of the same comments are being sent by me today, simply to assure that everything is received by EPA by today's deadline. Please let me know ifyou have any questions. Sincerely,

# 7~**~1v~tj~** FredrickJ. Dindoffer

FJD/ttv Attachments

DETROIT TROY ANN ARBOR CHEBOYGAN DALLAS Detroit_12227041

# ST MARYS CEMENT

Via OvernightU.S. Mail September 4, 2012 Ms. PamelaBlakley, Chief Control Strategies Section Air Programs Branch (AR-18) United States Environmental ProtectionAgency 77 WestJackson Boulevard Chicago, IL 60604 Re: EPADocket

### ID No. EPA-ROS-OAR-2010-0954 Phone: 231-237-1342 St. Marys Cement Inc. (U.S.) 16000 Bells Bay Road Charlevoix, Michigan 49720 WWN.stmaryscement.com



### Comments ofSt. Marys Cement Inc. (U.S.) ("SMC"), 

### in oppositionto USEPA's Notice ofProposed Rulemaking, entitled "40 CPRPart 52 --Approval and Promulgation ofAir Quality Implementation Plans; Michigan; Regional Haze State ImplementationPlan; Federal Implementation Plan for Regional Haze; Proposed Rule", which was published at 77 Fed. Reg. 46912-46928, on Monday, August 6, 2012 

### (the "NPRM").St. Marys Cement Inc. (U.S.)- BART- Response to August 2, 2012 email

Dear Ms. Blakley:
I am writing in behalfofSt. Marys Cement Inc. (U.S.) ("SMC") to provide comments ofSMC to the above-captioned U.S. EPA NPRM. Accordingly, enclosed please find the following documents: !. 

### Comments ofSt. Marys Cement Inc. (U.S.) ("SMC"), in opposition to USEPA'sNotice ofProposed Rulemaking, entitled "40 CPRPart 52 --Approval and Promulgation ofAir Quality Implementation Plans; Michigan; Regional Haze State Implementation Plan; Federal Implementation Plan for Regional Haze; Proposed Rule", which was published at 77 Fed. Reg. 46912-46928, on Monday, August 6, 2012 (the "NPRM"); 2. SMC's August 2, 2012 letterto Mr. Douglas Aburano and Mr. Vincent Hellwig (along with attachments and appendixes); and 3. SMC's August 8, 2012letterto Mr. 

### John Surnmerhays, responding to his August 2, 2012 email to Cortney Schmidt. SMC requests that each ofthe above documents be placed in the public record relating to this NPRM, and that EPA consider the matters contained in them. In the end, upon consideration of all of this information, SMC believes that either: (!) 

### EPA should withdraw its decision to disapprove the portions ofthe Michigan State Implementation A VCNA Company VCNA is the North American subsidiary of Votorantim Cimentos, a leading international basic building materials company headquartered in Brazil.

### Plan related to NOx emissions from SMC's Charlevoix Michigan plant and its proposal to set a Federal Implementation Plan NOx emissions limit for that plant; or (2) EPA should accept and adopt the alternative limits proposed by SMC in its enclosed comments.

Ifyouhave any questions about this, please contact me. Sincerely,

# ~~ilJ Cortney Schmidt Environmental Manager 231-237-1342
Cc: DirkCox

### UPS Next 

### Day Air'') 

### UPS Worldwide Express'M

# Document 1

### Comments of St. Marys Cement Inc. (U.S.) regarding: 

## NPRM at 77 Fed. Reg. 46912, August 6, 2012 EPA Docket ID 

### No. EPA-ROS-OAR-2010-0954 Subject: 

### Comments ofSt. Marys Cement Inc. (U.S.) ("SMC"), in opposition to USEPA's Notice of Proposed Rulemaking, entitled "40 CFR Part 52 --Approval and Promulgation ofAir Quality Implementation Plans; Michigan; Regional Haze State Implementation Plan; Federal Implementation Plan for Regional Haze; Proposed Rule", which was published at 77 Fed. Reg. 46912-46928, on Monday, August 6, 2012 (the "NPRM").

Executive Summary This document is submitted as the comments of St. Marys Cement Inc. (U.S.) ("SMC") in opposition to the NPRM published at 77 Fed. Reg. 46912, et seq., August 6, 2012. SMC requests that these comments be placed in the Public Record established for the NPRM. In accordance with these comments, SMC requests that EPA approve the portions of Michigan's State Implementation Plan (SIP) that concern NOx emissions limits from the SMC Charlevoix plant. EPA's disapproval of the portion of Michigan's SIP which set limits for NOx emissions from the SMC Charlevoix, Michigan plant [to satisfy the Best Available Retrofit Technology (BART) requirements set forth in section 169A of the Clean Air Act. 42 USC 7491], and EPA's proposal to promulgate a federal implementation plan (FIP) for those NOx emissions, are arbitrary, capricious, beyond the authority granted by the Clean Air Act and otherwise unlawful. In fact, based on the BART factors, Michigan's SIP determined a proper emissions limit for NOx from the SMC Charlevoix Michigan plant.
In addition, as described below, EPA's proposed BART determination for NOx emissions from SMC's Charlevoix plant is flawed. First, EPA's suggestion that a Selective Non-Catalytic Reduction (SNCR) system will allow SMC to meet EPA's proposed NOx limits is inaccurate and contrary to the overwhelming weight of evidence. The extremely low NOx emissions limits proposed by EPA are not achievable by SMC's Charlevoix plant. The effectiveness of SNCR depends on placing the reagent in the gas stream within a specific temperature range for a sufficient time to complete necessary reactions. The temperatures and residence times at Charlevoix are not sufficient for this to occur. No cement plant with the same age and design as SMC's Charlevoix facility meets the extremely low NOx rates proposed by EPA. The only approach that might 

### allow reducing NOx emissions from the Charlevoix plant to the limits EPA has proposed would be by redesign and installation of major modifications to the entire calciner, including an in-line multistage burner system, coupled with an SNCR system. Even with all of those changes, SMC is not confident that EPA's proposed limits could be achieved. More importantly, EPA's guidance on how to implement the BART requirements makes clear that such a redesign is not appropriate to satisfy BART: "We do not consider BART as a requirement to redesign the source when considering available control alternatives. For example, where the source subject to BART is a coal-fired


### 1

### electric generator, we do not require the BART analysis to consider building a natural gas-fired electric turbine although the turbine may be inherently less polluting on a per unit basis." 40 CFR Part 51, Appendix Y. Second, EPA's estimated costs to achieve its proposed NOx limits are inaccurate. The costs that would be necessary for changes of a redesign ofthe plant, construction, equipment and operating expenses to meet EPA's proposed limits show that EPA's proposed limits are not cost-effective, and again are not consistent with BART (which is a retrofit approach, not a fully new design.) Moreover, this proposal jeopardizes the viability ofthe Charlevoix plant. Ifthese emissions limits are imposed, a major redesign (for a new inline multi staged calciner) would be required for the plant. The attendant capital and operating costs are of a magnitude that would require approval of SMC's parent company in Brazil, and such projects are compared/prioritized against other projects. As a result, it is possible that, in this fragile economy, this proposed rule could lead to suspension or even cessation of operations at Charlevoix. SMC then could supply its markets in Michigan, Wisconsin and Illinois from its Canadian plants, which are operating far below full capacity, just as it did before it acquired the Charlevoix plant. This would have a devastating effect on the northern Michigan economy. Nonetheless, SMC is committed to improving its environmental performance. Therefore, in lieu of EPA's proposal, SMC hereby offers to reduce its NOx emissions, and to reduce its SOx emissions and to limit its production, in amounts that will reduce the plant's impact on the Seney Wildlife Area to a greaterextent than the 0.4 deciviews (dv) that EPA projected would be achieved by its NOx limits. Using this alternative approach, the matter will be resolved amicably and will result in an improved condition for Seney.

Introduction SMC is one of northern Michigan's largest companies. It directly employs approximately 130 individuals, with an annual payroll of about $12 million. The plant provides an annual contribution to the local economy of about $20 million. Local taxes paid are roughly $2 million annually. Of course, the economic impact of the plant extends to a multitude of suppliers, local businesses, local governments, schools and families that rely on SMC's presence. SMC does not abuse its significant economic presence in Charlevoix. SMC has a documented history as a good corporate citizen and a good neighbor. SMC always works constructively with EPA and MDEQ and will continue to do so. As an initial matter, therefore, it is unfortunate that this critical review of EPA's proposed BART emissions limits for SMC's Charlevoix plant must be submitted. This might have been avoided if EPA had communicated directly with SMC to clarify the facts, and if EPA had done so much earlier in the process. Surprising SMC at the last minute with this NPRM puts inordinate and unnecessary pressure on everyone to act quickly, when more deliberate, collaborative action might have avoided any difficulties.

2The following analysis by necessity points out numerous flaws with EPA's NPRM. In fact, the NOx limits stated in MDEQ's SIP for SMC are appropriate, and there is no justification for the NOx limits EPA seeks to impose on SMC's plant. Nonetheless, as noted in closing, SMC is prepared to accept limits that are more stringent than should be required under BART, and that are more stringent than are being required of numerous other cement manufacturers, including its closest competitor.

Detailed Comments and Analysis

A. EPA's NPRM seeks to act beyond the authority allowed by the Clean Air Act. EPA's disapproval of the portion of Michigan's SIP related to BART requirements for SMC's Charlevoix plant NOx limits, and the proposal to substitute EPA's own limits in their place, is impermissible under the Clean Air Act. This is made clear, for example, by three recent U.S. Courts ofAppeals decisions: (1) EME Homer City Generation, LP v. EPA, No. 11-1302 (D.C. Cir. August 21, 2012), in which the U.S. Court ofAppeals forthe D.C. Circuit vacated the EPA's Transport Rule; (2) Luminant Generation Co. 

### v. EPA, 675 F.3d 917 (5th Cir. 2012), in which the 5'h Circuit rejected EPA's disapproval of a portion of the Texas SIP that provided for PCP (pollution control projects) standard permits; and (3) Texas 

### v. EPA,
--- F.3d ----, No. 10-60614, 2012 WL 3264558 (5th Cir. Aug. 13, 2012) in which the 51h Circuit again overruled EPA's attempt to disapprove a portion of the Texas SIP, which in this case provided for a Flexible Permit Program which allowed minor NSR sources to make modifications to facilities without additional regulatory review provided that the emissions increase would not exceed an aggregate limit specified in the permit. A common thread runs through these cases. The courts held that the Clean Air Act embodies a combination of separate federal and state authorities. "So long as the national standards are met, the State may select whatever mix ofcontrol devices it desires." Texas v. EPA, At *2, quoting Union Elec. Co. v. EPA, 427 U.S. 246, 266 (1976). Similarly the same court stated: "Accordingly, the EPA ensures that a state's SIP is adequately compliant with the CAA, but has no authority to condition approval of a SIP based simply on the preference ofthe EPA for a particular control measure." Id. At *11. Similarly, by analogy to EME Homer, in this matter, Michigan is the entity in the first instance tasked by the Clean Air Act with (a) determining if a source is BART eligible, and if so (b) determining BART emissions limits for that source. In fact, the EPA recognizes in its NPRM that "the regional haze rule does not mandate specific milestones or rates of progress" and "Class I states have significant discretion in establishing reasonable progress goals." See 77 Fed. Reg. at 46914. Nonetheless, EPA disapproved Michigan's BART determination for the SMC Charlevoix plant, and proposes to substitute its own NOx


### 3

### emissions limit based on its determination that the SNCR technology represents BART. See 77 Fed. Reg. at 46921. EPA has overstepped the Clean Air Act's division of authority by disregarding Michigan's BART findings and substituting its own. As the EME Homer 

### court stated, "[t]he States have the primary responsibility for determining how to meet [the national air quality standards] and regulating sources within their borders." EME Homer 

### at 6. The court went on to hold that the "statutory federalism bar prohibits EPA from using the SIP process to force States to adopt specific control measures." Id. at 42. Importantly, in the NPRM, EPA found that Michigan's SIP "includes a reasonable set of measures that provide its appropriate share of reductions toward achieving reasonable progress goals." See 77 Fed. Reg. at 46919. In other words, the emissions limits proposed by Michigan for SMC and others allow the State to meet its EPA-approved reasonable progress goals for improving visibility. Accordingly, as in EME Homer, 

### EPA cannot then go beyond the statutory text and require emissions limits for SMC which would go beyond allowing the State to meet those progress goals. The EME Homer

### court stated that EPA has "'no authority to question the wisdom of a State's choices of emissions limitations,' so long as the State's SIP submission would result in 'compliance with the national standards for ambient air."' EME Homer

### at 42-43 (quoting Train v. NRDC, 

### 421 U.S. 60, 79 (1975)). These BART requirements are included within the overall limiting provision that EPA is to require "such emission limits, schedules of compliance and other measures as may be necessary to make reasonable progress toward meeting the national goal specified in subsection (a) ofthis section." 42 USC 7491(b)(2) (emphasis added). For these reasons alone, EPA should withdraw its NPRM. and approve the portions ofthe Michigan SIP at issue.



### B. Even if EPA was permitted to second-guess Michigan's SIP, the NPRM's analysis of BART for SMC was faulty. EPA's analysis of BART for SMC's Charlevoix facility in the NPRM, and in the May 24 Letter it references, is incorrect. First, Michigan's SIP limit of 6.5 pounds of NOx per ton of cement clinker produced (6.5 lbs/ton) is appropriate for the Charlevoix facility. In contrast, EPA incorrectly evaluates the technical issues to arrive at an inappropriate suggested emissions limit of 2.3 lbs/ton. Second, EPA's analysis fails to consider other criteria that are required for setting BART limits. As stated by the BART regulations, there are six criteria that the state must consider in establishing a BART limit: "***The emission limitation must be established, on a case-by-case basis, taking into consideration [1] the technology available, [2] the costs of compliance, [3] the energy and non-air quality environmental impacts ofcompliance, [4] any pollution control equipment in use or in existence at the source, [5] the remaining useful life ofthe source, and [6] the degree of improvement in visibility which may reasonably be anticipated to result from the use ofsuch technology." 40 CFR 51.301.



### 4[1] The overwhelming evidence shows that Michigan's SIP limits were appropriate and that EPA did not properly evaluate the capabilities oftechnology available for NOx control at Charlevoix
.
a. Charlevoix already has incorporated many modern elements of ki ln design and operation that improve NOx control in its aging system, beyond that employed by many of its competitors. At its inception, the Charlevoix plant employed a long wet ki ln process technology [similar to the type employed even now at SMC's chief nearby competitor, Lafarge, in Alpena M ichigan] which accord ing to the EPA would have had NOx emissions in the range of 10 lbs/ton clinker. However, in the late 1970s the Charlevoix plant [unlike some of its competitors) began to upgrade its technology. At that point, the Charlevoix plant was converted into a preheater/pre-calciner process, employing afirst generation, flash calciner with a shortened kiln system. This first generation system was at the cutting edge oftechnology for its t ime. However, as technology has continued to advance, the Charlevoix system is not as efficient and effective as today's newly designed systems. Below is a pictorial model of the Charlevoix kiln in let, riser, bypass take-off, orifice, tertiary air in let, swirl, round drop, fl ash fu rnace (aka flash calciner), and the lowest stage (4th Stage) cyclone.

### Char**e\To i,~**  

# Riser Design

4'.**Sta~e** Cyclone
)Nirl Chamber O r ifice F..ound D ro p-o ut
- Ki ln In let. LoNer Riser ..._ ___ Flash Furnace

Kil n G a s Bypass T ake-Off

Upon the acquisition of the Charlevoix facility in 2005, SMC purchased and installed a state of the art fabric fi lter baghouse for the main stack particulate em ission control, at a cost exceeding $12 mi ll ion. SMC furthered its environmental stewardship, by agreeing with EPA to spend $6.3 mi llion to implement



### 5a supplemental environmental project (SEP) 1for installation of an Indirect Fire system (IDF) in 2006 which includes low NOx burners. Indeed, SMC exceeded that commitment and spent $8.5 million on the project. This IDF generally is regarded as Best Available Control Technology (BACT). In total, SMC spent in excess of $20 million on these controls. Meanwhile, many of SMC's competitors have not upgraded their emissions controls to the same degree. Subsequent to SMC's purchase of the Charlevoix plant, there have been continued emissions improvements from best practices learned via the Votorantim Cement Production Systems (VCPS) which have led to better maintenance routines, operations routines and procedures, leading to sustainable environmental improvement in the overall condition of the facility. By utilizing the VCPS system, SMC has been able to certify the facility under ISO 9001, 14001 and 18001, and has been the recipient of multiple environmental stewardship awards from industrial associations.
b. The normal variability of NOx formation in cement kilns, justifies the 6.5 lbs/ton NOx emission limit contained in Michigan's SIP. According to a PCA report on Cement Kiln Operation "There is also a significant variability of NOx emissions from a cement kiln due to,"

.... "the characteristics of the raw materials, the fuels used, how and where the fuels are introduced into the kiln, the way in which the kiln is operated (e.g., percentage of excess air, retention times), and the specifications for the final product. Beyond this, however, it is important to note that raw materials differ from site-to-site and may change from day-to-day at the 

### same site."
From the same PCA report on Cement Kiln Operation "The figure below illustrates the variability of NOx emissions from cement kilns showing a range from basically zero to more than 1400 ppm. Other welldocumented studies have shown similar results, with NOx emissions ranging from less than 2 pounds/ton clinker to nearly 14 pounds per ton clinker."

1 This project was undertaken in cmmection with the settlement ofan enforcement action, United States v. CEMEX Inc. and St. Marys CementInc. (U.S.), taken onbehalfofthe U.S. Environmental Protection Agency and the Michigan DepartmentofEnvironmental Quality under the Clean Air Act and the MichiganNatural Resources and Environmental Protection Act.


### 6

# EPA Report on ='JOx \·ariability 1n Cetnent 1\

# Ianufacturing 

# :.J

.. I 

# I

.... . .:,
...

.**~** 

### i 6 

# I

..**~.** 

### : ::
... i 

# .. ,.. .**~** ; ; :

### •. :



### ,_._ 

# . ... :-**~**

SMC's Charlevoix facility has the same variability. Set out below is a graph showing the normal distribution ofthe Charlevoix plant's specific NOx emissions perton ofclinker produced from 2006 to 2008. The average ofthis data is 4.56 lbs/ton, but there is a significant standard deviation of0.64 lbs/ton lead ing up to a 99.7% confidence number of 6.47 lbs/ ton. Accordingly, any discussion of NOx control at Charlevoix must recogn ize that the current permit limit of 6

.5 lbs/ton is appropriate. Moreover, that limit is attainable by SMC's Charlevoix plant only because it has put in place more modern technology than its competitors, such as Lafarge's Alpena plant. When considering BART requirements to reduce haze concerns at Seney, SMC already has made significant progress
. Therefore, MEDQ was correct in keeping that value as the emissions limitfor SMC's Charlevoix plant, and then expecting competitors to advance their controls to catch up with SMC's performance. EPA was incorrect when it failed to give credit to the progress that SMC's Charlevoix plant already had made in NOx control, compared to others in the cement indus try.
EPA will expect compliance with its emission limit every day, notjust 110n average" over several years. Therefore, EPA also was incorrect when it derived its proposed NOx emission limit of2.3 lbs/ton forthe Charlevoix plant by applying a presumed 50% reduction against the plant's 4.561bs/ton average, which was achieved over several years. That should be obvious because an 11average" value means that halfof the actual performance isgreater than that average. Therefore, when setting an em issions limit, any



### 7proposed reduction should not be applied to an average performance over several years, but instead must take into consideration the normal standard deviation from that average. This is the same rationale thatwas recently used by the EPA in its agreement with Holcim's Montana Plant. Consequently, in this instance, ifthere was to be any reduction, it must be applied against the 6.5 lbs/ton value which represents the 99.7% confidence value ofSMC's actual performance.



## :::?006
- 2008 NOx Actual Data

I_ 

# I I ' I 

# r = ==

=·· 

### [ ; : : :

## ·. I ;: : :·. 

## 1"

:::·. I , ; :: ·. 

### [ ; : :: ·. 

# I::::: ·

c. Although better performing than other old plants, unique Charlevoix design features increase NOx formation compared to the most modern kiln designs.
The Charlevoix plant has several unique features that complicate the daily operation ofthe facility. One of these features is the way the plant was modified in late 1970s. As stated above, the plant was originally a long wet kiln measuring over 600 feet in length. However, in 1979, t he kiln was shortened to just above the bull gear, resulting in a length of 355 feet, while maintaining the same Kiln diameter of 18.5 feet in the burning zone. These measurements thus lead to a length to diameter ratio (L/D) at Charlevoix of 19.1 to 1. This is extremely long when compared to the new kiln systems currently being designed and built

. The current standard for the L/D ratio of a new kiln is 13:1. What this means is that the Charlevoix plant essentially has 100 extra feet of length in its kiln shell. This extra shell is a heat sink, which affects the chemical reactions, the thermal energy consumption, the retention time in the Kiln and th e temperature profile of the remaining system. This heat sink and other design inefficiencies


### 8requires an increase in the fuel consumption on the plant's Main Burner, which raises the typical thermal energy consumption of**~sao** kCal/kg Clinker and ultimately the NOx value, to the Charlevoix heat consumption of**~930kcals/ton** of clinker. This additional fuel required to produce a ton of clinker results in more products of combustion, which is why the NOx values in Charlevoix are higher than would be typical in a shorter, more modern kiln system with a 13:1 L/D ratio. 

### The manner to which the plant was modified in 1979, namely the length afkiln versus diameter and the extremely short gas retention time within the calciner vessel, are reasons whythe Charlevoixplant cannot be expected to haveNOx emissions thatonly the mostmodern kiln designs achieve.
Another such complication of the facility is the inherent sulfur content in the raw materials. To manage the sulfur volatilization in the Kiln system and subsequently the build-up in the riser round drop-out and swirl chamber areas the plant has to operate the Kiln in an oxidizing atmosphere. The oxidizing atmosphere allows a portion of the sulfur to combine with and exit the system within the clinker, limiting the likelihood that the sulfur will condense to form calcium sulfate. Calcium sulfate will condense and adhere to the riser round drop-out and swirl chamber creating restrictions and operational difficulties. The trade-off penalty for having to operate the system in an oxidizing atmosphere is the increased fuel consumption and eventually increased NOx generation. As shown in the EPA provided table below, the oxygen content and temperature profile significantly affects the NOx formation.

9

# ::.JOx Formation based on Oxygen Content

Summarizing these operational difficulties points, increased amounts ofoxygen in the combustion zoneanda longer retention timeatelevatedtemperatures leadtogreateramounts ofNOxformation. SMC's Charlevoixfacility is affectedbyall ofthese conditions. Theplanthas to operate in an oxidizing atmosphere due to the inherent sulfur content in the raw materials, and theplant has a longer kiln shellthan wouldbedesigned today, because ofthe mannerin which itwas modifiedin 1979.

d. EPA's conclusion that SNCR will allow a 50% reduction in NOx emissions from the Charlevoix plant is incorrect because the plant's design is incompatible with effective SNCR use. EPA's analysis incorrectly assumes that one can count on achieving a 50% reduction in NOx from any cement kiln system, by merely strapping an SNCR system onto it. That is not true. SNCR can achieve significant improvements in NOx emissions when it is applied to some older kiln systems: (i) ifthey have design features compatible with SNCR effectiveness; and 

### (ii) if they have not yet incorporated the upgraded technology already employed by SMC at Charlevoix. As examples, EPA recently set BART NOx limits for several such older plants. For the Lafarge plant in Alpena, EPA set a BART NOx limit of 4.89 lbs/ton on a 12-month rolling average. Similarly, BART NOx limits were set for the Holcim and Ash Grove


### 10plants in Montana, at 6.5 lbs/ton and 8.0 lbs/ton, respectively. Each ofthese had older systems that had not been upgraded to the same degree as the Charlevoix plant. By adding an SNCR system, it may be possible to reduce their NOx emissions to the degree set by EPA

. SMC already outperforms those numbers with the improvements it already has put in place. Those competitors are merely catching up with SMC.
When SNCR is coupled with a current modern kiln design, the results often can be very low NOx emissions. For example, at Suwannee Florida, SMC is part ofajoint venture in which that plant achieves NOx emissions of 2.3 lbs/ton. That result is achieved through a combination of design factors that limit the extent of NOx formation at the outset (e.g., proper kiln length to diameter dimensions and increased calciner retention time), coupled wit h SNCR control added to a system designed to be compatible with SNCR. These circumstances are not true at the Charlevoix plant.

(i) Actual test results demonstrate that SNCR will have only limited success in NOx control at Charlevoix.
Also upon the acquisition of the Charlevoix facility in 2005, even though it was not required, SMC hired DeNox Technology (an east coast engineering firm with experience in implementing SNCR in European cement plants) to assist SMC in the examination and implementation of an SNCR system. During the trial, DeNox experimented with multiple port locations, multiple nozzle configurations, multiple reagent flows rates, and evaluated different operating temperatu re profiles to implement t he most effec t ive location and operation ofan SNCR system.



## SNCR Trial Locations Ga

sb.it or lo ' · est Cyclone J;.11er Duct af ter T.:..Ouct

J;.iser Du ct prie>r to 'f-::llll"ijJI>- - T ADuc t 1 2 and 4 Nozzlc$1

11Both SMC and DeNox had hoped and expected to achieve NOx reductions of about 40
- 60%, when injecting a normalized stoichiometric ratio (NSR) of 1.0

. Despite their best efforts, SMC and DeNox were only able to achieve

### shortterm actualNOx reduction efficiencies. Below are the summarized results of the DeNox trials based location and reagent inject rate.



# DeN

# ox Trials 

# c:ha.rle\T oi x: T\II**s** 

### :: 38 I S8\ I) 609**~** {) .:.

### ,, 

# -
. 

# ,, 

# 1

s:: s 

# o**~** 

### 21

. .:.**}~** 

# s-· .

# - 39

.6\
) I O:,

### .3 I '1
- 

## "' 36 

### a;.; - 125 9 :;6.1**;,~** 

### 282 J

### 72**23 9:~**  

### 639 

# s .:.o 7}:

In no case did the SNCR achieve t he NOx reduction that was expected, regardless ofeither the NSR used or the injection location. In one test run, the reduction was 36.8%, with an NSR of greater than 1. However, that was coupled with a significant amount of ammonia slip, based on the theoretical calculations from the NOx present. The time frames for this trial were short, roughly several10 minute runs to consolidate the average, and thus SMC is not confident t hat these reductions are sustainable. As noted in the graph, when using an NSR of 1.07, there was a negative theoretical NOx reduction hig hlighting t he Ammonia Slip. In fact in only one situation (15.8% reduction) was the NSR value equal to or less than the SNCR efficiency, in all other cases where the NSR value exceeds the SNCR efficiency the conditions are right for ammonia slip, and indeed that was observed during the trials. The picture below documents the ammonia slip that actually occurred at the Charlevoix F acility.


### 12

# Arnr nonia Slip during DeNox Trial

The DeNox report, attached as Appendix A, also states: "Overall, SNCR performance was lower than expected. Typically, NOx reduction at a NSR of 1.0 is40- 60%; Charlevoix demonstrated 25
-30%." Then the DeNox report included the following statement in its recommendations: "The 20% overall reduction can be achieved at a reagent NSR of approximately 

### 0.7". In other words, SNCR will have limited effectiveness at Charlevoix under even the best circumstances. DeNox's owner noted (just as EPA stated) that he had seen SNCR effectively solve NOx issues in multiple cement plants. However, he commented to SMC that he was amazed that SNCR is not as efficient in SMC's system, and he believed it must be because of Charlevoix's calciner design. 

### The Charlevoix Plant at best can achieve a potential, but unsustainable, 20% overall NOx reduction with the use ofSNCR, and even at this low rate ofNOx reduction theplant will expect to experience ammoniaslip.
As previously mentioned, accord ing to the EP A "Relatively high concentrations of NH3 sli p can react with 502 and su lfur trioxide (S03) in the flue gas and form ammonium sulfates and bisu lfates, which, in turn, can cause plugging of the air preheater passages." The plant has had to adapt the operation of the facility to manage the inherent su lfur content in the raw materials. 

### Given thisfact, andwhathas been experienced at Charlevoix, there is a high propensity to have ammonia slip while utilizing SNCR, and dealing with build-upshouldbeexpected .

13EPA's NPRM discounted SMC's actual test results at Charlevoix which demonstrated that it could not achieve a high degree of NOx control by use of SNCR. However, instead of attempting to understand why SNCR is not effective at Charlevoix, EPA simply disputed these actual test results and without support concluded that a 50% NOx reduction would be achieved by use of SNCR in the current Charlevoix kiln system. What EPA failed to understand is that SMC is not a recalcitrant company that is attempting to avoid SNCR. Indeed, SMC was one of the first companies to use SNCR in North America. SMC would be pleased if SNCR would work effectively at Charlevoix. However, the fact is that it does not.

(ii) Well known factors, inherent in Charlevoix's design, prevent effective use ofSNCR. Unfortunately, inherent design limitations of the Charlevoix kiln system prevent SNCR from being an effective control. The low NOx control efficiency of SNCR at Charlevoix is dictated by the temperature profile, retention time, geometry, and minor elements in the gases. The following is a representation of the typical temperature profile and retention time forthe Charlevoix facility.


# Typical Tin1e 

# an d Ter nperature Profile

.:.:: =**-~ :**  ;' • - , . . (**"' ~**  ti! :! "' : : .... - - !

..... :**~** 5-! ::" : :**~** !:: " : :

Charlevoix does not have temperatures necessary to support SNCR Reactions. According to an EPA report "Nitrogen Oxides Emission Control Optionsfor Coal-Fir ed Electric Utility Boilers" , corroborated by a separate reportfrom the PCA, entitled "Summary ofControl T echniquesforNitrogen Oxide"



### 14**~** EPA: SNCR is a post combustion technology in which a reagent is injected into the furnace above the combustion zone, where it reacts with NOx to reduce itto N2 and water. In general, SNCR reactions are effective in the range of 1800-2100 °F. (892 C
- 1148 

### C)
PCA: Relatively high temperatures within a limited range are required for the SNCR reactions to proceed productively

.The appropriate temperature range, or temperature window, for SNCR is approximately 1,600aF to 2,000aF
The following graph shows the typical SNCR efficiency curves for both Urea and Ammonia reagents, based on temperature. Also imposed on the graphs is the typical temperature range ofoperation forthe Charlevoix facility.



### S:-JCR 

## ReagentEfficiency Cun·es 

## based on -:-emperature\\·ith Charle\·oix Oper2.ting Ranges 1 00 90**2~** 7':. t>O 

## s c 40 30 20 10 0 12CO

- U rea JC· OArnro inia SNi rll nlet T

errpe ratu re Peak Efficiency 1900



### The typical temperature profilefor the Charlevoix operation is shown above, and illustrates that nowhere in the Kiln riser, orflash calciner regions ofthe system does the plant reach the optimum temperatureprofile to

### supportan effective SNCR reaction.
The residence time at Charlevoix is not adequate for use of SNCR. Again according to an EPA report 

### "Nitrogen Oxides Emission Control Optionsfor Coal-Fired Electric Utility Boiler s", wh ich is corroborated by a separate report from the PCA entitled 

### "SummaryofControl TechniquesforNitrogen Oxid e"



### 15**~** EPA: Inadequate flue gas temperature and/or reaction time for SNCR kinetics and mixing of the reagent with flue gas can contribute to an increase in NH3 slip. PCA: Reaction times are finite so reductions are more effective with ample residence time at the optimal temperature. Effective NOx reduction requires a minimum residence time of about a half a second. As seen in the figure below.
Below is a representation of a /{Lab trial" or "best case scenario" showing the effects of residence time on the SCNR reactions. Also imposed on this curve is the typical temperature range for the Charlevoix facility. Given the actual geometry and normal production rates there is only a 0.11 second retention time between the reagent injection point and the time the system reaches the low end of efficiency point for the SNCR reaction. There was no curve found in the literature that depicts the expected efficiency of the SNCR reaction at the extremely short 0.11 seconds of retention time present in the Charlevoix operation. However, it can be easily inferred that the reaction efficiency would be significantly lower than the percentage shown for the 0.2 second residence time curve below.


# SNCR Efficienc\· based on Residence Time (Lab Trial)

50

20



### The design ofthe riser, swirl chamber, andflash calciner at the Charlevoix facility does not have enough retention time tosupportan effective SNCR reaction.



### 16Ammonia Slip is a likely result of use of SNCR at Charlevoix. Once more, according to an EPA report entitled 

### "Nitrogen Oxides Emission Control Options for Coal-Fired Electric Utility Boilers", which is corroborated by a separate report from the PCA entitled 

### "Summary ofControl Techniquesfor Nitrogen Oxide"**~** EPA: In general, NH3 may reduce NOX, oxidize to form NOx, or remain unreacted and pass through the stack. This unreacted portion is referred to as "NH3 slip."
PCA: The effectiveness of 5NCR depends on many factors. To provide effective removal, the reagent (and products of decomposition) and NOx must be well-mixed, and within the optimal temperature window for an ample amount of time. At temperatures below the optimal temperature window, reaction rates are low, resulting in low NOx reduction and unreacted reagent (leading to unwanted ammonia emissions referred to as ammonia slip).**~** EPA: Relatively high concentrations of NH3 slip can react with 502 and sulfur trioxide (503) in the flue gas and form ammonium sulfates and bisulfates, which, in turn, can cause plugging of the air preheater passages. Indeed, the 5NCR tests conducted at Charlevoix by DeNox, discussed above, showed ammonia slip was occurring.

The size of Charlevoix reduces its ability to control NOx using SNCR. From the EPA report on 

### "Nitrogen Oxides Emission Control Optionsfor Coal-Fired Electric Utility Boilers"**~** EPA: "5NCR effectiveness may depend on the size of the boiler. At larger boiler sizes, the capability to uniformly distribute a chemical reagent, urea or NH3, throughout the furnace volume may diminish, which, therefore, may negatively impact NOx removal efficiency."

... "Data also show that whereas smaller boilers may be able to achieve >60% NOx reduction, larger boilers may be capable ofachieving reductions of**only~** 30%."
A study conducted and presented for the IEEE found a similar tendency when dealing with Cement Kilns ofvarious capacities and design vintages.

"A correlation between plant size and reduction efficiency was noted during the testing conducted. This correlated with previous findings that larger plants had lower efficiencies than smaller sized plants."

... "Intuitively it seems to make sense that large gas flows with larger cross sectional areas would result in less mixing and direct contact between the NH3 and NO. However testing conducted at several of the plants shows that the addition of more injector


### 17nozzles in the same location traversing the dueling did not increase efficiency. Under the first assumption the increase in injection locations with the same flow should have overcome the presumed lack of mixing and increased efficiency noted."

The following figure shows the best results achieved from five plants and the three plants with smallest capacity have much higher efficiencies than the two larger capacity facilities.



# SNCR Test Results based on Capacity



# .·-·=""" '-·-·- o ....... ,,.,....., 

# ........_-·---·1 J

The EPA and the IEEE papers mirror what SMC already knows: size matters. 

### When it comes to NOx removal efficiencies, larger operations are not as efficient as smaller system and thus the Charlevoix plantshouldnotbe expected to haveNOx reduction efficiencies ofthesmallerplants.

[2] EPA did not correctly determine the costs ofadditional controls to meet its proposed limits.

a. EPA's proposed NOx emissions limit is not cost-effective.
In addition to the limited NOx control effectiveness of SNCR in the current Charlevoix system, demonstrated during the DeNox testing, the reagent application also hampered the operating system by 

### 18creating a buildup situation. This material buildup led to significant downtime and exposed SMC's operating staffto potentially unsafe and dangerous tasks associated with clearing the system. Both SMC and the EPA recognize that there are potential solutions that would both improve NOx control and address the buildup problem, but given the amount of research SMC has completed at the Charlevoix facility, the most effective solution is an extensive modification to the flash calciner including geometry changes to the process ductwork. These modifications would bring the calcining portion of the plant up to the state of the art, but they do not entirely address the operating limitations at the plant. The extent ofthe necessary modification is shown in the figure below. For sake of clarity, this is not a minor matter. As shown in the figure, this modification would add 120 feet in elevation and would involve a new capital cost of$18 million.



# Calciner Modification ' RetentionTime

' Staged Combustion t,JOx l't:d: cttore 1n:o the

' Capital Cost

i 2C!'**Ve:r"~ICCI** f'-·1GdiflCJ.ttcr cf Preh::c:ter.-Fia:-f-. Caicii-:E:r

To illustrate the impact of this on costs, Table 1 shows the costs associated with employing SNCR with a redesigned inline multi staged calciner. In this demonstration, SMC includes an estimated $18 million dollar direct cost for modification to the flashcalciner, plus the cost of injecting 360 gallons of reagent per hour. SMC expects that these physical modifications and increased reagent use have the potential to result in a 40% annual NOx reduction. In this scenario, as a result of the calciner improvements, which are prerequisite to achieving more reaction time, SMC removed any cost associated with buildup and downtime losses. However, the improvements in operating efficiency of the SNCR system, still do notjustify the cost of NOx removal under a BART analysis. As shown in Table 1, by using the EPA's cost effectiveness model SMC determined that the cost would be greater than $6,700 per ton of NOx



### 19removed. Moreover, this is not BART. As noted earlier, EPA's guidance on how to implement the BART requirements makes clear that such a redesign is not intended to satisfy BART: "We do not consider BART as a requirement to redesign the source when considering available control alternatives. For example, where the source subject to BART is a coal-fired electric generator, we do not require the BART analysis to consider building a natural gas-fired electric turbine although the turbine may be inherently less polluting on a per unit basis." 40 CFR Part 51, Appendix Y.
Table 2 shows the costs associated with EPA's recommendation, but with necessary clarifications, to correct several of EPA's assumptions including a $0.68 million' potential solution 

## I modifications of a $1.4 million SNCR system, to mitigate the operating problems encountered. Note, over the last five years SMC has tried many approaches to find a solution, including the installation and operation of air cannons to maintain the cleanliness of the ductwork, and further attempts using different rates of reagent, and different nozzle designs, but none of the these alternatives have been able to solve the plugging problems. Note, this shows that the cost ofwould be $6,249 per ton of NOx removed.
Within the NPRM and in the referenced May 241etter the EPA lists several erroneous assumptions as to the efficiency and operation of a generic SNCR system, without considering the engineering design details that would be necessary for successful implementation at Charlevoix. One such assumption is that it will only be necessary to heat urea for 4000 hours during the colder months. SMC did not have to assume such a number because the plant consultant used actual local meteorological data. SMC's consulting engineering on this question determined that urea will crystallize into a salt at a temperature of approximately 48 degrees F. Utilizing local meteorological data it was determined that heat input would be required 6,570 hours per years to prevent the urea from crystallizing into salt, and thus becoming non-effective.
Another incorrect EPA assumption concerns SMC's business and long range plans for the SMC plant in Charlevoix. EPA assumed SMC was on a 15 year equipment life schedule. SMC maintains that the EPA air pollution cost control manual allows for a 

### 10 year equipment life schedule and that this would more closely match SMC's short and long term plans.
EPA also incorrectly assumes that the cost of urea (before dilution) is $450 per ton. According to SMC's urea provider that would be the cost of Urea where it is imported in the Gulf of Mexico. That is not the price, as delivered, in northern Michigan. SMC's quoted cost for 45% Urea solution delivered to Charlevoix is $1.74 per gallon (See Appendix B).
The EPA also assumes that operating an SNCR system at Charlevoix would result in a 50% reduction in NOx emissions. This assumption is based on a best case scenario from a facility which operated an entirely different process. But upon review of the EPA's own literature, industrial reports and site specific data a potential sustainable NOx reduction of 10% to 20% is likely for a kiln of Charlevoix's size and design. The attached OeNox report, derived from the Charlevoix Plant, again states "Overall, SNCR

2 No explanation or data was provided to support this assumed cost. 20

### performance was lower than expected. The DeNox report stated that: "The 20% overall reduction can be achieved at a reagent NSR of approximately 0.7". In other words, SNCR will have limited effectiveness at Charlevoix under even the best circumstances.

b. The economic impact of EPA's proposed NOx limit would be devastating to northern Michigan.
As noted at the outset of these comments, SMC is one of northern Michigan's largest companies. It directly employs approximately 130 individuals, with an annual payroll of about $12 million. The plant provides an annual contribution to the local economy of about $20 million. Local taxes paid are roughly $2 million annually. Of course, the economic impact of the plant extends to a multitude of suppliers, local businesses, local governments, schools and families that rely on SMC's presence. For the last several years we have been in a fragile economy. In particular, the cement industry has been hard hit by reduced construction activity. Just as is true in many other industries, there has been consolidation in the cement manufacturing sector ofthe economy. Production has been shifted to more efficient operations. In line with that, for example, SMC was forced to shift production from its Dixon Illinois facility to Charlevoix, because Charlevoix could provide all of the production volume that was needed in a way that still allowed the company to make a return on its investment.
As demonstrated above, it is not possible for the existing Charlevoix plant system to achieve EPA's proposed 2.3 lbs/ton NOx limit. Moreover, this proposal jeopardizes the viability of the Charlevoix plant. These emissions limits would require new capital expenditures of $18 million for a major redesign and construction of a new inline multi staged calciner, plus a new SNCR system, and the attendant increased annual operating costs. Capital and operating costs of this magnitude would require approval of SMC's parent company in Brazil, and such projects are compared/prioritized against other projects. Even with all ofthese major design changes, SMC is not confident that EPA's proposed 2.3 lbs/ton limit could be achieved. As a result, it is possible that, in this fragile economy, this proposed rule could lead to suspension or even cessation of operations at Charlevoix. SMC then could supply its markets in Michigan, Wisconsin and Illinois from its Canadian plants, which are operating far below full capacity, just as it did before it acquired the Charlevoix plant. The result of that will be a loss of the jobs, payroll, taxes and other economic contributions that SMC currently adds to the northern Michigan economy. This would have a devastating effect on the northern Michigan economy.

[3] the energy and non-air quality environmental impacts of compliance



### 21

### Another concern SMC has about potential discussions to increase the molar ratio of reagent as indicated in the EPA letter is the significant ammonia slip that might occur. The photograph shown above, taken during the DeNox trials, highlights a significant detached plume that SMC believes to be directly from the reagent addition. [4] any pollution control equipment in use or in existence at the source As previously discussed, SMC has purchased and installed a state of the art fabric filter baghouse and has installed an Indirect Fire system (IDF) which includes low NOx burners.

[5] the remaining useful life ofthe source The EPA has incorrectly assumed SMC's business and long range plans for the plant in Charlevoix. SMC continues to maintain that the EPA air pollution cost control manual allows for 

### 10 year equipment life schedules which more closely match SMC's short and long term plans.



### [6] the degree of improvement invisibility which may reasonably be anticipated to result from the use of such technology

a. Seney Impacts
EPA's analysis considered the Charlevoix plant's potential effect on visibility at the Seney Wildlife Area, applying the maximum NOx potential to emit of 6.5 lbs/ton and the maximum potential S02 potential to emit, operating 24 hours per day, 365 days per year. The result, using the CALPUFF model, was a maximum impact on Seney of 5.26 dv in 2002, or an average maximum impact of 3.8 dv for 2002- 2004. EPA then estimated that if the NOx emissions were reduced by use of SNCR, there would be an improvement of 0.4 dv at Seney, which EPA documented to be reasonable and appropriate. As outlined below, SMC proposes an alternative approach, under which it would: (1) 

### reduce its permitted NOx emissions rate; (2) reduce its permitted S02 emissions rate; and (3) limit its total annual production of clinker. The SMC proposal will reduce the impact on Seney by more than the 0.4 dv EPA previously approved.

Conclusion and Proposed Alternative

In conclusion, as shown above, EPA's proposed NOx limit for SMC's Charlevoix plant stated in the NPRM is notjustified. EPA is not empowered to substitute its judgment for that of the state of Michigan as to

22the appropriate BART limit. Also, SMC demonstrated that Michigan was fully justified in adopting the 6.5 lbs/ton BART NOx emission rate, because SMC had already incorporated significant design changes that improved its NOx performance compared with other cement plants of the same vintage. In addition, SMC has shown that EPA's proposed 2.3 lbs/ton rate is not technically attainable without redesigning the entire plant process, and therefore is not cost effective. Moreover, imposition of that limit would be devastating to the northern Michigan economy. Nonetheless, SMC is prepared to improve its effects on visibility at Seney, by additional control of its NOx and S02 emissions. As stated in the opening paragraph, SMC is a good corporate citizen and neighbor. Therefore, SMC proposes to reduce its permitted emissions limits to meet a 30-day rolling average limit for NOx of 4.85 lbs/ton, which is better than the rate that will be met by its competitor, Lafarge, in Alpena Michigan [which is only required to meet a NOx limit of 4.89 lbs/ton on a 12-month rolling average. See, 77 Fed. Reg. at 46920. Both the higher value and the longer averaging time make Lafarge's limit much easier to achieve.] This 4.85 lbs/ton limit represents a 25% reduction in potential NOx emissions. To achieve this reduction consistently SMC will have to operate additional control measures to reduce NOx emissions. Also SMC proposes that it meet a 30-day rolling average limit for S02 of 7.5 lbs/ton, with an annual cap of 3,700 tons per year. This value represents a 16% reduction in potential S02 emissions. Finally, SMC will agree to implement a cap on its clinker production of 1.6 million tons per year, which is a 9.4% reduction from its current maximum of 1.766 million tons per year.

To evaluate the effect of these steps, SMC conducted the CALPUFF model using those inputs. The results are shown in Table 3, along with the CALPUFF results from the current permit limits operated at full potential. The results show an improvement of greater than 1.6 dv at Seney, which is significantly better than the 0.4 dv improvement EPA projected would be achieved with its proposed NOx limit. SMC's proposed limitations result in an improvement of the dv at Seney by 43% and also decrease the days of impact by 47%.

23

# Table 3 CALPUFF Model Results
Impacts at Seney with Current Impacts at Seney with Proposed permitted emissions limits (6.5 emissions limits (4.85 NOx; 7.5 NOx; 13.9 S02); and full production 802); production limit of 1.6 million of 1.766 million tons/vear of Clinker tons/vear of Clinker

Modeled 981h No. of Days Modeled 981h No. of Days Meteorological Data Inputs Percentile Exceeding 0.5 Percentile Exceeding 0.5 Deciview Value Deciview Deciview Value Deciview 2002 5.26 30 2.82 16 2003 3.64 39 2.29 27 2004 2.48 62 1.39 26
2002- 2004 Combined 5.26 131 2.82 69
Average 3.79 44 2.16 23

Net reduction from SMC control measures 43.0% 47.3%

SMC will need time to implement steps to achieve these limitations, and so it proposes that they imposed over the next four years. For all ofthe foregoing reasons, SMC requests; (i) that EPA withdraw its disapproval of the portions of the Michigan SIP that relate to NOx emissions from the SMC Charlevoix plant; (ii) that EPA's proposed NOx limit for the Charlevoix plant be rejected; and (iii) that SMC's proposed alternative limits be adopted. The result will be better for the environment and for all parties involved. Respectfully submitted,

Cortney Schmidt Environmental Manager 231-237-1342

24St Marys Cement

CAPITAL COSTS

l)jrocl CoRo

Pnrchaoed Equipment Co•to[l)

ln;trum.:tlt•tinn Freight Sv.<1.em to addr<S> buildu Purchued Equipment C..Jt, PEC (B) DirectIDrtall•tion Coot.

Foundation.< & rupporL'**Handlin~** & croction Electri<:.al Piping lnmJlotion Paintin Dkred IDotallation C..oto
Site \'reparation, o.< required Buildin[!..>. a.< required Totall:liredCooto, l:IC
IDdired Com En],!ineering

Pcrfotmnnco le.<l Conlin encios TotallDdired: Corn,JC
Total Capital Investmmt DC+IC ANNUAL COSTS

DireotAnnbal Coots, DC

Operator Supervisor OperatingMaterlob

Reagent (Urea) 1.74**~lgol.** 360 gol/hr, 8000 hr/yr, 60 lb/lbmole., 45 wl% Urea Table 1

10% ofoonlm] devioc cm;l (A) 5% ofc<mtrol de\'ioo oo<l {A)
21%

12% ofpurch"ed equip cos\ (B) 4\)% nfpurcho.<ed equip oosl (B) 1% nfpurcha.<ed equip co.<\ (B) 30% ofpurchased eguip cost (B) 1% ofpurcha<e<l equip C<>.<l (B) 1% of urchnsed e ui co<! (B) 85%
Site Specific Site Specific

10% ofpurchased equip roSl (B) 10% ofpurchased equip <:OS! (B) 10% ofpurcho

.. d equip C<>.<l (B) I% ofpurcho.=l equip oo'l (B) 1% of purcho•ed equip eo" (B) )% of urch

.. od ui oosl (B) 35%**~25.38** 112 hr per shift, 8000 hrlyr 15% ofoperator

$177'1 112hrpershifl,8760hrlyr Materials 100% ofmnintcnonco lnbor Eloctrioity 0.0723 $/I:W-hr, 100 kW, 6570 hrlyr (for**heolin~** urea solution in cooler ••••on) Clean out comcntic build up on sides ofdueling- 0 eventsly<Bf, l dny per event, $401\on cornent los\ revenue, 4840 lpd lost cement production, $193,600 per dny lost revenue Total**Di~ct** Annual Cooto, DC IndirectAnnual Cosio Overhead Administrntive Charges Property lax [Not allowed in**Michi~an)** ln.<:Urancc Capitol Recover;> 14.24% for a 10 year equipment life and a 7% inleru<l rote TotallDdlre<:t Annnal Coot., lC
Total Annual Costs- DC+ IC Pollutant Rmloved (ftono/yr) 

# I Cost per ton ofN**0:~:** removed 60% of tot•I hbor :md material rosts !% of Total Copilallnvc<tmenl 0% ofTotal Copitnllnvcstmenl 1% ofTotol Capitollnve<lmen\ 14% 1.37\.(,30 137,163 68,582 18.000.000 19,577,375

2.349.285 7,830,950

195,774 5,873,212

195,7'14 195,774 16,&40,768

36,21S,l43

1,957,737 1.957,737 1,957,737 195,774 195,774 587,321 6,852,081 43,070,224

12,690 1.904 5,011,200

3,025,n4 861,404 0 430,702 6,133,200 Ul,451,29il 15,542,097
2.2n $6,767 Co<! is from !heEnviron Report rontained in Append1x f_ MOG,O()O o[\his i• retrr>-!il capital to winterize tho 'J''lem lo prevOill •olutoon fr=ing. EPA AirPollution Control Cost Manuol EPA Air Pollution Control C"'l Manual E<limoted ooSl for now inline ealdner

EPA Air Pollution Con\rol Cost Manual EPA Air PollutiOTl Conlrol Cost Manual EPA Air Polluti<>n Control Co<l Manual EPA Air Pollution Control Cost Manu"] EPA Air Polloiion Control Cost Manual EPA Air Pollution Cconlrol Cm1 Manual

EPA Air Pollution Contml Co'1 Manual EPA Air Pollution Cnnlml C"<i Monuul EPA Air Pnllution Ccm\.-ol Co<i Manual EPA Air Pollution Control Co'l Mnnual EPA Air Pollution Control Co<! Manual EPA Air Pollu1ion Conlr<>l C<>m Manunl

EPA Air Pollution Control Cost Manunl

EPA Air PolluliOJl COJltrol Co.;t Manual

This isba""<' on past history ofcleon-oul while using • SNCR for the ozone 'J'Siem.

EPA Air Pollution Control Co" Manunl EPA Air Pollution Control Cost Manual EPA Air PolluliOTl Control Cost Manual EPA Air Pollution Control Cost Manunl

5141.5 fj 5 #Nox per Ton clinker nnnunliaed. with permit efforcod plnnl maxSt Marys Cement

CAPITAL COSTS

Dltct!CooU

l'llrclra.oed Equipment Co<to(l)

SNCR ln&trumcnt•tion Freight System to •ddres,; huildu l'llrcbued Equipmc)l.t Cmt, PEC (Jl.)**m~ct** lnlllallatlon Colto

Foundations&. suppnris Hondling &. ere.ctinn Elearieol Piping ln•ulmion Direct Inolallation Com
Site Prcporation, os required Build**in~<.** os required Total Direct Cod•, DC {Ddlrect CooU Engineering Construction ond field ""P""""' Contractor fee_< Star1-up Pt:rfonnonce te_<! Cm1tin oncie• Tot.ollodirect Cooto, lC Total Capital Investment- DC+ IC ANNUAL COSTS

DirectAlu>nal CooU, DC

OperodiDgLabor

Open!or Supervisor OperatingMaterial•

Reagcul (llnoo) L74**~/gal,** ISO**~allhr,** 8000 hrlyr, 60 lbnbmole, 45 wt% Urea MaioleDnce

Lo»m Table 2

10% of<=Jtroldovie<ocost(A) 5% ofoonlrol de\'icc cost {A) 50% 21%

12% ofpurcha•od equip coS! (B) 40% ofpurcha.ed equip ca&t (B) 1% ofpurch>-<cd "'!"iP co.t (B) JO% ofporcha•ed equip ros\ (B) I% of purchased equip oost (B) 1% of urchosed e ui co•t (B) 85%
Site Spec:ifoc Site Specific

10% ofpurchosed equip co<! (B) ]0% ofpumh.,ed equip ooSl (B) 10% ofpuroh"ed equip cost (B) 1% ofpurchased equip**ct;~,<\** (B) I% of**purclm.<~Cd** '4Uip cost (B) 3% of urchased e ui cost {B) 35%

$25 38 1/2 hr per shift. 8000 hrlyr

]5% ofoperator

Sl7_77 lhrper•hifi.8760hrlyr Materials 100% ofmointonance lob!r Electricity 0.0732 $/kW-hr, 100 kW, 6570 hrlyr {for healing urea solution in cooler"""""") Clean out cemcntic build np on sides ofdueling- 2 cvo::ntsly<Oar, I day per event, $40!\on cemcnllo.<t revenue, 4&40 tpd lo•t cement pwductim1, $193,600 per day )ostr<OVenue Tot.ol Direct Allnual Costa, DC b:

..

Urect Armual eo.u
Administrative Charges Prt>p<:rty lox (Nm oilowed in Michigan) Insurance Copital Recovery 14.24% for a 10 veor equipment life ond a 7% inl=<t rnte Total Indirect Aluoual Colto, IC TotalAnnual Co5ts- DC+IC
PolbrtontRemoved {loDolp) ]costper ton ofNO:o: removed 60% of tolallahor and motcriol oo•t• 2% of Total Capilol!nve•lment 0% ofTotal Capitallnvestmenl 1% ofTotal Copitallnveslrnent 14% 1,371,63[1 137,163 68,582 6S5,815 l,l63,19D

271,583 905,276 22,632 678.957 22.632 21,632 1,923,711

4,186,!101

226,319 226.319 226,319 22,632 22,6l2 67,&96**7~2,llli** 4,979,017

12,690 1.904 2,505.600

17.512 17,511 47.501

387,200 2,989,9:1!1

1,533.131

99,580 0 49)90 709,012 2,391,513 5,381 433
$6,249 Co;t ;,from**th~**Environ Repor1 e<mtoincd in Appcndi:.: F_ $400,1100 ofthi< i• retro·fil cnpitolto wintorizc: the "l'•t= \o prevent •elution freezing EPA Air Pollution Control Co&t Manual EPA Air Pollution Control Cru;t Monual EPA Engineer As.umption by**Re~ion** V

EPA Air Pollutitm Control Co.<t Manual EPA Air Pollution C"nlrol Co<! Manual EPA AirPollution Control Co<! MBnuol EPA Air Po\lutioo Control Cos\ Manual EPA Air Pollution Control Co>1 Manual EPA Air Pollution Control Co<t Manual

EPA Air Pollution Cnn\fol Co;t Manual EPA Air Pollutioo Control Cos! Monunl EPA Air Pollution Control Cost Manual EPA AirPollution Control Co.<! Manual EPA Air Pollution Control Co;t Manuol EPA Air Pollution Control Com Monuol

EPA AirPollution Control Co•! Manual

EPA Air Pollution Conkrol Co<! Manual

Thi• i.< b"ed on past history ofc\eon-ou! while using • SNCR for the ozone ey•tem

EPA Air Pollution Control Cost Manual EPA Air Pollution Control Cost Mnnual EPA Air Pollution Control Co•l Manuol EPA Air Pollution Control Cost Mnnuol

5741.5 6.5 II N"" per Ton clinker annualized with permit effnrced plont max

# Appendix A

# NOx RemovalMeasurements with a Urea Based SNCRSystem at the St. Mary's Cement CharlevoixFacility



# Draft Report

Prepared By: 

# De-NOX Technologies, LLC 22 Partridge Lane East Hampstead, NH 03 826

MAY2005

# INTRODUCTION StMary's Cement Company operates a 4450 TPD (clinker) cement manufacturing facility in Charlevoix, Michigan. The Company retained De-NOx Technologies to evaluate the effectiveness ofan SNCR system for reducing NOx emissions. The test apparatus consisted ofa 5000 gallontank trailerto receive and store 40 wt% 

### urea, 4 DNT dual fluid reagent atomizing injectors, a portable pump skid, compressed air control system, reagent distribution assembly, and various hoses in lieu ofpermanent piping. The pump skid contained flow meters to measure reagent flow and the main stack CEM system was used to monitor performance. SNCRrequires injection ofeither ammonia or urea into the furnace gas atjustthe right temperature to react withNOx to form N2. Ifurea is used, the high temperatures in the combuster breaks down each mol ofurea into two mols ofammonia and one mol ofCO. Properreagent atomization is also critical to assure complete dispersion and mixing with the NO molecule. The reaction requires a temperature of 1600-2000 degF, in the presence ofoxygen. Residence time and mixing are critical factors for obvious reasons and the presence ofCO will lower the optimumtemperature window.

The predominantreaction is described as follows:

UREA+NITROGEN OXIDE NITROGEN+ CARBON DIOXIDE+ WATER

# TEST SCOPE AND METHODOLOGY
The objectives ofthe test were threefold: 1. Optimize injection location and settings. 2. Generate stoichiometric performance curves, and 3. Generate some continuous run data
Figure I has sectional side views ofthe kiln outlet, calciner, and Stage 4 Cyclone. Gasses exitingthe kiln at 1700 degF flow up through a riser duct where I) approximately 10% the gas is removed (bypassed) from the system, 2) Tertiary Air at 1500 degF is added (from the clinker cooler), and directedtangentially into the bottom ofthe calciner. In the calciner, more fuel (coal) is added before flowing into the lowest off our cyclone pre-heaters. This drawing also identifies the four locations at which injection was tested. Location 1 was after bypass and before Tertiary Air. Location 2 was after TertiaryAir but before coal addition. Location 3 was inthe crossover duct betweenthe calciner vessel and the Stage 4 cyclone. Location 4 was in the outlet ofthe Stage 4 cyclone.

# TEST RESULTS
The summarized datais presented inTable 1 and Figure 2. In general, the data was taken in ten minute increments- usually 10 minute baseline, 10 minute at Inj # 1, 10 min at lnj 2, then backto a baseline. In 

### general,a step change in reagent injectiontook 2-3 minutes to be fully developed at the CEM. Location 3 was dismissed immediately since NOxreduction was near zero. Ofthe other three, there was no clear winner. Overall, SNCRperformance was lower than expected. Typically, NOx reduction at a NSR of 1.0 is 40- 60%; Charlevoix demonstrated 25-30%. Figure 3 illustrates the Charlevoix test results for the three positive test locations and compares them to a European cementplant and typical small electric power boiler plants. Ofparticular interest is that the location ofinjection did not appearto significantly affect the result, eventhoughthey reportedly represent significantly different 02 and CO conditions. As well, several datapoints were conducted at Location # 1 with 2 injectors and with 4 injectors- and contrary to common logic and historical fact- the runs with 2 injectors had statistically better results. Limited gas conditions data is available at the actual points ofinjection- inparticular CO and 02. A couple explanations for the relatively poorresults is high CO and/orpoor gas mixing. It 

### is fairly well known that CO enhances the kinetics ofthe SNCRreaction (shifts the optimumtemperature windowto a lower range). Since the levels ofCO inthe injection zone may be very high, the most likely explanation for the poorresults could be that much ofthe ammonia could be converted to NO (whichis then reducedto N2 by reaction with a secondNH3 molecule). The SNCRreactiondoes notperform well in zones ofincomplete (or active) combustion/oxidation. DNT's experience with a similar coal fired process suggests that reagentutilization in active combustion zones will be low (or zero) -butmoving injection downstream after removal ofcombustion conditions can be very effective.

# RECOMMENDATIONS
The following is recommended:

• Ofthe four locations tested, the area after introduction ofTertiary Air seems to be themost promising from a chemical perspective. It

### has adequate 02 and residence time prior to introduction ofcoal in the calciner. • The specific location ofthe injectors inthe "After Tertiary Air" zone should be changed to improve dispersion- See previous memo. • The 20% overall reduction can be achieved at a reagent NSR ofapproximately 0.7 • Annual reagent consumption should be approximately 3 GPM (of40% urea solution) at full load. Thepermanent system should be designed with adequate margin above that. • Consider testing and/or relocating the injection zone to the outlet duct ofthe Stage 4 Cyclone ifthe Vortex Finder is re-installed.

# AppendixBAppendixBFrom:C!ausenrStevenTa:SchmidtCortneyCc:Subject:GP4924[45%UreaSolution)Cortney,TheFOBBeaverCreekpriceforGP4924145%UreaSolution)is$0.1759lb.The4J.%ureasolutionweightpergallonis9.5lbspergallon.ThepricepergallonFOBBeaverCreekis$1.671.Thanks,•Ste#c0.(jk.zu,.GPChemicals,LLC:WoodAdhesivesMobile-541.261.5496NOTE:ThedeliverypriceofthismaterialfromBeaverCreek,MltoCharlevoix,Mlvariedfrom"'$.08to$.10pergallon.

# Document2

# ST MARYS CEMEN T

ViaU.S. Mail August 2, 2012 Mr. Douglas Aburano AttainmentPlanning and Maintenance Section United States Environmental ProtectionAgency 77 WestJacksonBoulevard Chicago, IL 60604-3590 Mr. 

### Vincent Hellwig, Chief Air 

### Quality Control Division Michigan Department ofEnvironmental Quality P.O. Box 30260 Lansing, MI 48909 DearMessrs. Aburano and Hellwig, Phone : 231
-237-1342 St. Marys Cement Inc. (U

.S

.} 16000 Bells Bay Road Charlevoix, Michigan 49720
www
.stmarysc ement.com



### St. Marys Cement Inc. (U.S.) ("SMC") is hereby responding to the enclosed May 24, 2012 letter Mr. Aburano transmitted to Mr Hellwig (the May 24 Letter) and also to follow up on comments made during our July 19, 2012 meeting at the EPA Region 5 office in Chicago. SMC only received a complete copy ofthe Ma y 24 Letter on June 29, and therefore SMC has had only a month to evaluate these complex matters. Accordingly, SMC reserves the right to supplement or correct this response and proposal in 

### the event SMC becomes aware of additional pertinent information orifitlater discovers errorsthatmust be corrected.
Executive Summary
As described below, EPA's proposed BART determination for NOx emissions from SMC's Charlevoix plant is flawed. Nonetheless, SMC is committed to improving its environmental performance. Therefore, in lieu ofEPA's proposa l, SMC hereby offers to reduce its emissions in an amount thatwill reduce the plant's impact on the Seney Wildlife Area to a greater degree than the 0.4 deciviews (dv) that was projected by EPA's analysis. Usingthis alternative approach, the matter will be resolved amicably and will result in an improved condition for Seney. Accordingly, SMC would appreciate your earliestresponse to this approach.

A VCNA Company VCNA is the North Am erican subsidiary of Votorantim Ci mentos, a leading international basic building materials company headquartered in Brazil.

T"'\.,, ..... ;, l "'l i ")O A n ")

### Introduction
As an initial matter, itis unfortunate thatthis critical review ofEPA's proposed BART emissions limits for SMC's Charlevoix, Michigan plant must be submitted. This might have been avoided if, instead of assuming many key points, EPA had communicated directly with SMC to clarify the facts, and ifEPA had done so much earlier in the process rather than waiting until the last minute. SMC has a documented history as a good corporate citizen and a good neighbor. SMC always works constructively with EPA and MDEQ and will continue to do so. However, surprising us at the last minute puts inordinate and unnecessary pressure on everyone to act quickly, when more deliberate, collaborative action might have avoided any difficulties.
EPA's analysis ofBART for SMC's Charlevoix facility in the May 24 Letter is incorrect. First, EPA's discussion incorrectly evaluates the technical issues to arrive at an inappropriate suggested emissions limit of2.3 pounds ofNOxperton ofClinkerproduced (2.3 lbs/ton) for the Charlevoix facility. Second, EPA's analysis fails to consider other criteriathat are required for setting BART limits. As statedby the BART regulations, there are six criteriathat mustbe considered in establishing a BART limit:
"***The emission limitation must be established, on a case-by-case basis, taking into consideration [1] the technology available, [2] the costs ofcompliance, [3] the energy and nonair quality environmental impacts ofcompliance, [4] any pollution control equipment in use or in existence at the source, [5] the remaining useful life ofthe source, and [6] the degree of improvement invisibility which may reasonably be anticipated to result from the use ofsuch technology." 40 CPR 51.301. Analysis [I] EPAdid not properly evaluate the technology available forNOx control at Charlevoix At it is inception, the Charlevoix plant employed a long wet kiln process technology which according to the EPA would have had NOx emissions in the range of 10 lbs/ton clinker. Then in the late 1970s the Charlevoix plant was converted into a preheater/pre-calciner process, employing a first generation, flash calciner with a shortened kiln system. This first generation system was at the cutting edge oftechnology for its time. However, as technology has continued to advance, the Charlevoix system is not as efficient and effective as today's newly designed systems. These new advances were based on lessons learned, and improved upon, from plants like Charlevoix. This has made it possible for the newly installed preheater/pre-calciner lines to

### achieve specific NOx emiSSIOn rates m the low 2.0 lbs/ton of clinker range, instead of approximately 7.5 lbs/tonproduced at Charlevoixprior to SMC's purchase ofthe facility. Subsequent to SMC's purchase of the Charlevoix plant, there have been continued emissions improvements from best practices learned via the Votorantim Cement Production Systems (VCPS) which have led to better maintenance routines, operations routines and procedures, leading to sustainable environmental improvement in the overall condition of the facility. By utilizing the VCPS system, SMC has been able to certifY the facility under ISO 9001, 14001 and 18001, and has been the recipient ofmultiple environmental stewardship awards from industrial· associations. Upon the acquisition ofthe Charlevoix facility in 2005, SMC purchased and installed a state of the art fabric filter baghouse for the main stack particulate emission control, at a cost exceeding $12 million. SMC furthered its environmental stewardship, by agreeing with EPA to spend $6.3 million to implement a supplemental environmental project (SEP) 1 

### for installation ofan Indirect Fire system (IDF) in 2006 which includes low NOx burners. Indeed, SMC exceeded that commitment and spent $8.5 million on the project. This IDF generally is regarded as Best Available Control Technology (BACT). In total, SMC spent in excess of $20 million on these controls. Also upon the acquisition ofthe Charlevoix facility in 2005, even though it was not required, SMC hired DeNox Technology (an east coast engineering firm with experience in implementing SNCR in European cement plants) to assist SMC in the examination and implementation of an SNCR system. During the trial, DeNox experimented with multiple port locations, multiple nozzle configurations, multiple reagent flow rates, and evaluated different operating temperature profiles to implement the most effective location and operation ofan SNCR system. Both SMC and DeNox had hoped and expected to achieve NOx reductions of about 40

- 60%, when injecting a normalized stoichiometric ratio (NSR) of 1.0. Despite their best efforts, SMC and DeNox were only able to achieve 

### short term reduction efficiencies of 25

- 30%. The DeNox report, attached as Appendix A states: "Overall, SNCR performance was lower than expected. Typically, NOx reduction at a NSR of 1.0 is 40

- 60%; Charlevoix demonstrated 25-30%." Then the DeNox report included the following statement in its recommendations: "The 20% overall reduction can be achieved at a reagent NSR of approximately 0.7". In other words, SNCR will have limited effectiveness at Charlevoix under eventhe best circumstances. DeNox's owner noted (just as EPA stated) thathe had seen SNCR effectively solveNOx issues in multiple

1 This project was undertaken in connection with the settlement ofan enforcement action, United States v. Cemex, Inc. and St. Marvs Cement Inc. (U.S.), taken onbehalfofthe U.S. Environmental Protection Agency and the Michigan Department ofEnvironmental Quality under the Clean Air Act and the Michigan Natural Resources and 

### Environmental Protection Act.

### cement plants. However, he commented to SMC: "it amazes me why it is not as efficient in your system, and it must be because ofyour calciner design." So, over the years, SMC has reduced its NOx emissions by 40%, through the use ofthese best practices and the installation of the BACT technology discussed above. The result, as demonstrated in the period of 2006 to 2008, has been a statistical 30 day rolling average NOx emissions of4.56 lbs/ton.

[2] EPAdid not correctly determine the costs ofadditional controls to meet its proposed limits. In addition to the limited molar effectiveness of SNCR at Charlevoix, the reagent application hampered the operating system by creating a buildup situation. This material buildup led to significant downtime and exposed SMC's operating staff to potentially unsafe and dangerous tasks associated with clearing the system. Both SMC and the EPA recognize that there are potential solutions to this problem, but given the amount ofresearch SMC has completed at the Charlevoix facility, the most effective solution is an extensive modification to the flash calciner including geometry changes to the process ductwork. These modifications would bring the calcining portion of the plant up to the state of the art, but they do not entirely address the operating limitations at the plant. To illustrate this, Table 1 shows the costs associated with employing SNCR with a redesigned inline multi staged calciner. In this demonstration, SMC includes an estimated $18 million dollar direct cost for modification to the flash calciner, plus the cost ofinjecting 360 gallons ofreagent per hour. SMC expects that these physical modifications and increased reagent use have the potential to result in a 40% armual NOx reduction. In this scenario, as a result ofthe calciner improvements, SMC removed any cost associated with buildup and downtime losses. However, the improvements in operating efficiency ofthe SNCR system still do notjustifY the cost ofNOx removal. As shown in Table I, by using the EPA's cost effectiveness model SMC determined that the cost would be greater than $6,700 per ton ofNOxremoved. Table 2 shows the costs associated with EPA's recommendation, but with necessary clarifications, to correct several of EPA's assumptions including a $0.68 million2 

### potential solution I 

### modifications of a $1.4 million SNCR system, to mitigate the operating problems encountered. Note, over the last five years SMC has tried many approaches to find a solution, including the installation and operation of air cannons to maintain the cleanliness of the ductwork, and further attempts using different rates ofreagent, and different nozzle designs, but none ofthe these alternatives have been able to solve the plugging problems.

2 

### No explanation or data was provided to support this assumed cost.St Marys Cement

CAPITAL COSTS

Direct Collfo

Pon:hued Equipment Cooto(l)

In<trumenta!iun Freight Sv:<tem to addres' huildu Pnrchaoed Eqlliproent Coot, l'EC (B)
DiredIDrtallatinn Com

Foundation< & rupports Hondilng & erection Electrical Piping
Paintin Direct lnotallatlon Codo
Site Prcp:rrati<m, as required**Buildm~s.** as required
Total Direct Cooto, DC
IDdired C.nto**En~inecring** CoMtruction and field exj>ellses Start-up Performance test Conlin encies TotaliDdl..ecl Coot., IC Total C•pital lnyestment DC+JC ANNUAL COSTS

DirectAnnnal Com, DC

Operath•gLab<or

Operator Supervisor Opentlng Material•

Reagent (Urea) 1.74 $/gal, 360 gallhr, 8000 hr/yr, 60 lhllhmolc, 45 1\1% Ure•
Lah<>r Materials Table 1

IG% ofcomroi device com (A) 5% ofrontrol device""'! (A)
21%

12% ofpurchasedequipeos!{B) 40% nfpurchase<l equip rost (B) 1% ofpurchased equip cost (B) 30% ofpurchased equip oos! (B) 1% ofpurchased equip cmt (B) I% of urchased e ui cost (B) 85%
Site Spcdfic S!le Specific

10% ofpurcha'"d equip cost (B) 10",4, ofpurchased equ1p oost (B) 10% ofpurcha.cd equip cost (B) 1% ofpurch.sed equip COS! (B) I% ofpurchased equip rost (B) 3% Gf urchosede ui cost (B) 35%

$25.38 112 hr per shift. soon hrlyr

15% ofoperator

$17.77 l/2hrpershift,8760hrlyr

100% ofmaintenancelahor Electricity 0 0723 $/kW-ht, 100 kW, 6570 hr/yr (for heating urea solution in cooler season) Cleen out eementicbuild up on sides ofducting- 0 events/year, I day per event, $40/ton cement lost revenue, 4840 tpd lo:<t cement production, $193,600 per day lost revenue. Total Direct Annual Cooto, DC
IDdlrect Annual Corn Overhead Mministrative Charges Property tax (Not allowed in Michigan) Capita\ Reoov<n 14.24% for' 10 vcar equipment lifo and a 7% intcre'! rote 'fot.oliDdlnct Annual Cooto, IC Total Annual Costs DC+lC
PollutllDt Removed (tono/yr) I cost per ton ofN0 1 removed 60% oftotal labor and material cost' 2% ofTotal Capllallnvestment 0% ofTotnl Cap1tal Investment \% ofTotnl Capitol Investment 14% 1.371.630 137,163 68,582 18,000,000 19,577,375

2,349,285 7.830.950

195,774 5.873,212

195,774 195,774 111,640,7118

36,218,143

1,957,737 1,957,737 1,957,737 195,774 \95,774 sg7,321 6,1152,0111 43,070,224

12,690 1,904 5,011.200

8,756 8.756 47.501

5,090,!107

3,025,984

861,404 0 430,702 6,133,200 10,451,290 15,542,097
2.297 $6,767 Co:<! is from lhe Environ Report contained in Appendix F $400,000 ofthis IS retro-fit capitol to winterize the >')'S!om to prc\'en! solution freezing EPA Air Polhnion Control Co'! Manual EPA Air Pclluti<>n Control Cost Manual Esttmmed ow;t for new inline ealciner

EPA Air Pollution Control Cost Manual EPA Air Pollution Control Cost Manual EPA Air Pollution Control Cost Manual EPA Air Pollution Coo!ml Cost Manunl EPA Air Pollution Control Co>! Manual EPA Air Pollution Control Co,1 Manual

EPA Au Pollution Control Cost Manual EPA Air Pnl\U!ion Control Co.<! Manual EPA Air Ptlllutitm C<mlrol Co.<! Manual EPA Air Pollution Control CoR! Manual EPA Air Pollution Control Cost Manual EPA Air Pollution Control Com M•nunl

EPA Air Pollution Control Cost Manual

EPA Air Pollution Control Cost Manual

TI1is is based on past hi"tory of dean-out vAiile using a SNCRfor tho ozone eystem

EPA Air Pollution Control Co:<\ Manuol EPA Air Pollution Control Cost MamlOl EPA Air Pollution Control Cost Manual EPA Air Pollution Control Cost M:muol

5741.5 6_5**#No~** per Ton clinker annualized witb permit clforccd plant maxSt Marys Cement

CAPITAL COSTS

Direct Coot.

Purehaoed Equipment Costo(t)

SNCR ln<lrumentOlion Freight Svslem to address huildu Purchued Equipment O>Jt, PEC (B)
Direct Inotallatlon Coob

Foundations & supports**Handlin~** & erection Electrical Piping ln.<ulation
Direct InotoJiatlon Codo
Site Prcp3l·atwn, us required Buildings,""required
Total Direct Coot., DC
Indirect Cuoto Engineering

St•n-up PerformanOce test Conlin encoes Total Indlncl Com, IC
TotoJ Capital**Inv~tm""t** DC+IC ANNUAL COSTS

DlnctA=nal Cn.to, DC

Operating L•hor

Operator Supervisor Operating M•terialo

Reagent (Urea) 1.74 $/gol, 180 gallhr, 8000 hr/yr. 60 lbllbmole, 45 wt% Uren Maintenance

L.1hor Mat<:rials Table 2

10% nfoontrol device coot (A) 5% ofcontrol de,•ioe co" (A) 50% 21%

12% ofpurchased eqllip cost (B) 40% ofpurchased equip eo'\ (B) 1% ofpumhosod equip cost (8) 30% ofpurchn>ed equip "'"1 (B) I%**ofpurcl~ased** equip com (B) 1% of urchosed e ui coot (B) 85%
Site Specific Site Specific

10% ufpumha£cd equip coot (B) JO% ofpurchased equip coot (B) 10% ofpurchased eqlllp cost (B) 1% ofpurchased equip crr.ot (B) 1% ofpurcha,;ed equip co•t (B) 3% of urcba"'d e ui**"'~'t** (B) 35%

$25.38 l/2 hr per shift. 8000 hr/yr

15% of operator

$]7.77 I hrpershift,8760hrlyr

IOO"Ii> ofmainteni!Ilot labmElectricity 0.0732 $/kW-br, 100 kW, 6570 hrlyr (fm- heating urea solutwn in cooler "'"on) Clean out cementic build up on sides ofducting- 2 events/year, I day per event, $40/trm ct:mrnl lo;t revenue, 4840 tprllost otment production. $193,600 per day lost r<OVenue. TntoJ**Dlr~t** Annnal Coot., DC
Indirect A=nal Cools Overhtlld Adminiotrative Charges Property tax (Not allowed in Michig•n) lmruranre Capital Recovery 14.24% for a 10- vcar equipment life and a 7% inlc'fcst rotc TotoJ IndirectAnnuoJ Coot1, IC Total Annual**Co~Q;** DC+ IC
PnllutantRemoved (tnuolyr) I costper ton of**NO~:** removed 60% oftotallahor and material costs 2% ofTmnl Capitol Investment 0% ofTotal Cnpitallnvestment 1% ofTotnl Copitallnvestment 14% U7L6JO 137,163 68,582 685.815 1,263,19U

271,583 905,276 22.632 678,957 22,632 22,632 1,923,711

4,1Bii,901

226.319 226)19 226,319 22.632 22,632 67,&96 791,ll6 4,979,017

12.690 1,904 2,505,600

17,512 J/,512 47,501

387,200 1,989,919

].533,131

99,580 0 49.790 709,012 1,391,513 5,381,433 

## '"' $6,249 Cm;t is from the Environ Report contomed 1n Apprndix F $40{],000 ofthis i> rctro-fot capita] to winterize the >y>\enl to prevent solution fr0<:2ing EPA Air Pollution Control Co.<t Mnnual EPA Air Pollution Control Cost Manual EPA Engineer As,.,mption by Region V

EPA Air Pollution Control Co•t M•nual EPA Air Pollution Control Co'1 Manual EPA Air Pollution Control Cost Manual EPA Air Pollution Control Co.<t Monunl EPA Air Pollution Control Cost M•nuol EPA Air Pollution Control Co.<l Manual

EPA Air Pollution Control Cost Manual EPAAir Pollution Control Cn.<t MamlOI EPA Air Pollution Control Co,\ Manual EPA Air Pollution Control Cost Manual EPA Air Pollution Contml Cost Manual EPA Air Pollutit>n Control Cost Mnnua]

EPA Air Pollution Control Cost Manual

EPA Air Pollutioo Control Cost Manual

This is based on past history ofclean-out whik**usin~'** SNCRfor the ozone system

EPA Air Pollution Control Cos\ Manual EPA Air Pollution Control Cost Manu"! EPA AirPollution Control Cos! Manual EPA A1r Pollution Control Cost Manuol

5741.5 6.5 # Nox per Ton clinker annualized with permit efforced plant max

### Withinthe May 24letterthe EPA lists several assumptions as to the efficiency and operation ofa generic SNCR system, without considering the engineering design details that would be necessary for successful implementation at Charlevoix. One such assumption is that it will only be necessary to heat urea for 4000 hours during the colder months. SMC did not have to assume such a number because the plant consultant used actual local meteorological data. SMC's consulting engineering on this question determined that urea will crystallize into a salt at a temperature of approximately 48 degrees F. Utilizing local meteorological data it was determined that heat input would be required 6,570 hours per years to prevent the urea from crystallizing into salt, and thus becoming non-effective. Another incorrect EPA assumption concerns SMC's business and long range plans for the SMC plant in Charlevoix. EPA assumed SMC was on a 15 year equipment life schedule. SMC maintains that the EPA air pollution cost control manual allows for a 10 year equipment life schedule and thatthis would more closely match SMC's short and long term plans. EPA also incorrectly assumes that the cost ofurea (before dilution) is $450 per ton. According to SMC's urea provider that would be the cost of Urea where it is imported in the Gulf of Mexico. That is not the price in northern Michigan. SMC's quoted cost for 45% Urea solution delivered to Charlevoix is $1.74 per gallon (See Appendix B). The EPA also assumes that operating an SNCR system at Charlevoix would result in a 50% reduction in NOx emissions. This assumption is based on a best case scenario from a facility which operated an entirely different process. The attached DeNox report, derived from the Charlevoix Plant, again states "Overall, SNCR performance was lower than expected. The DeNox report stated that: "The 20% overall reduction can be achieved at a reagent NSR of approximately 0.T'. In other words, SNCR will have limited effectiveness at Charlevoix under even the best circumstances. [3] the energy and non-air quality environmental impacts ofcompliance Another concern SMC has about potential discussions to increase the molar ratio ofreagent as indicated in the EPA letter is the significant ammonia slip that might occur. Appendix C provides a photograph taken during the DeNox trials and highlights a significant detached plume that SMC believes to be directly from the reagent addition.

[4] any pollutioncontrol equipment in use or in existence at the source, As previously discussed, SMC has purchased and installed a state ofthe art 

### fabric filter baghouse and has installed an Indirect Fire system (IDF) which includes lowNOx burners.

### [5] the remaining useful life ofthe source The EPA has incorrectly assumed SMC's business and long range plans for the plant in Charlevoix. SMC continues to maintain that the EPA air pollution cost control manual allows for 10 year equipment life schedules which more closely match SMC's short and long term plans.

[6] the degree ofimprovement in visibility which may reasonably be anticipated to result from the use ofsuchtechnology EPA's analysis considered the potential effect on visibility at the Seney Wildlife Area, applying the maximum NOx potential to emit of 6.5 lbs/ton and the maximum S02 potential to emit, operating 24 hours per day, 365 days per year. The result, using the CALPUFF model, was a maximum impact on Seney of 5.26 dv in 2002, or an average maximum impact of 3.8 dv for 2002

- 2004. EPA then estimated that ifthe NOx emissions were reduced by use of SNCR, there would be an improvement of0.4 dv at Seney, which EPA documented to be reasonable and appropriate. As outlined below, SMC proposes an alternative approach, by (1) reducing its permittedNOx emissions rate; (2) byreducing its permitted S02 emissions rate; and (3) limiting its total production of clinker. This will reduce the impact on Seney by more than the 0.4 dv EPA approved.

Conclusion and Proposed Alternative
In conclusion, SMC fully justified the 6.5 lbs/ton BART NOx emission rate adopted by the MDEQ. In addition, SMC has shown that EPA's proposed 2.3 lb/ton rate is not technically attainable without redesigning the entire plant process, and is not cost effective. Nonetheless, SMC is prepared to improve its control ofNOx and S02 emissions. As stated in the opening paragraph, SMC is a good corporate citizen and neighbor. Therefore, SMC proposes to reduce its permitted emissions limits to meet a 30-day rolling average limit for NOx of 4.85 lbs/ton, which is better than the rate that will be met by its competitor, Lafarge, in Alpena Michigan [ 4.89 lbs/ton]. This value represents a 25% reduction in potential NOx emissions. To achieve this reduction consistently SMC will have to operate additional control measures to reduce NOx emissions.

### Also SMC proposes that it meet a 30-day rolling average limit for S02 of7.5 lbs/ton, with an annual cap of 3700 tons per year. This value represents a 16% reduction in potential S02 emiSSIOnS. Finally, SMC will agree to implement a cap onits clinker production of 1.6 million tons per year, which is a 9.4% reduction from its current maximum of 1.766 milliontons per year. To evaluate the effect ofthese steps, SMC conducted the CALPUFF model using those inputs. The results are shown in Table 3, along with the CALPUFF results from the currentpermit limits operated at full potential. The results show an improvement of greater than 1.6 dv at Seney, which is significantly better than the 0.4 dv improvement EPA projected would be achieved with its proposedNOx limit. SMC's proposed limitations result in an improvement ofthe dv at Seney by43% and also decrease the days ofimpactby 47%.
SMC will need time to implement steps to achieve these limitations, and so it proposes that they imposed over the next four years.

Ifyouhave any questions about this, please contact me. Sincerely,

# ~5_[)- Cortney Schmidt Environmental Manager 231-237-1342
Cc: DirkCoxTable3CALPUFFModelResultsImpactsatSeneywithCurrentImpactsatSeneywithProposedpermittedemissionslimits(6.5emissionslimits(4.85NOx;7.5NOx;13.9S02);andfullproductionS02);productionlimitof1.6millionof1.766milliontons/vearofClinkertons/vearofClinkerModeled98thNo.ofDaysModeled98thNo.ofDaysMeteorologicalDataInputsIPercentileExceeding0.5PercentileExceeding0.5DeciviewValueDeciviewDeciviewValueDeciview20025.26302.821620033.64392.292720042.48621.39262002-2004CombinedAverage3.79442.1623NetreductionfromSMCcontrolmeasures43.0%47.3%

# Appendix A

# NOx RemovalMeasurementswith a Urea Based SNCRSystem atthe St. Mary's Cement CharlevoixFacility

DraftReport

Prepared By: 

# De-NOX Technologies, LLC 22 Partridge Lane East Hampstead, NH 03826

MAY2005

# INTRODUCTION St.Mary's Cement Company operates a 4450 

## TPD (clinker) cement manufacturing facility in Charlevoix, Michigan. The Company retained De-NOxTechnologies to evaluatethe effectiveness ofan SNCR system for reducing NOx emissions. The test apparatus consisted ofa 5000 gallontank trailer to receive and store 40 wt% 

### urea, 4 DNTdual fluid reagent atomizing injectors, aportable pump skid, compressed air control system, reagent distribution assembly, and various hoses 

## in lieu ofpermanent piping. The pump skid contained flow meters to measure reagent flow andthe main stack CEM system was used to monitor performance. SNCRrequires injection ofeither ammonia or urea into the furnace gas atjustthe right temperature to react withNOx to form N2. Ifurea is used, the hightemperatures inthe comhuster breaks down eachmol ofurea into two mols ofammonia and one mol ofCO. Proper reagent atomizationis also critical to assure complete dispersion and mixing with the NO molecule. The reactionrequires atemperature of 1600-2000degF, in the presence ofoxygen. Residence time and mixing are critical factors for obvious reasons and the presence ofCO will lower the optimum temperature window.

The predominantreaction is described as follows:

UREA+NITROGEN OXIDE NITROGEN + CARBON DIOXIDE+ WATER

# TEST SCOPE AND METHODOLOGY
The objectives ofthe test were threefold: I. Optimize injection location and settings. 2. Generate stoichiometric performance curves, and 3. Generate some continuous run data
Figure 1has sectional side views ofthe kiln outlet, calciner, and Stage 4 Cyclone. Gasses exiting the kiln at 1700 degF flow up through a riser duct where 1) approximately 10% the gas is removed (bypassed) from the system, 2) TertiaryAir at 1500 degF is added (from the clinker cooler), and directed tangentially into the bottom ofthe calciner. In the calciner, more fuel (coal) is added before flowing into the lowest offour cyclone pre-heaters. This drawing also identifies the four locations at which injection was tested. Location 1 was after bypass and before Tertiary Air. Location 2 was after Tertiary Air butbefore coal addition. Location 3 was in the crossover duct between the calciner vessel and the Stage 4 cyclone. Location 4 was in the outlet ofthe Stage 4 cyclone.

# TEST RESULTS
The summarized data is presented in Table 1and Figure 2. In general, the data was taken inten minute increments- usually 10 minute baseline, 10 minute at Inj #1, 10 min at Inj 2, then back to abaseline. In general,a step change in reagent injectiontook 2-3 minutes to be fully developed at the CEM. Location 3 was dismissed immediately since NOxreduction was near zero. Ofthe other three, there was no clear winner. Overall, SNCRperformance was lower than expected. Typically, NOx reduction at a NSR of 1.0 is 40- 60%; Charlevoix demonstrated 25-30%. Figure 3 illustrates the Charlevoix test results for the three positive test locations and compares them to a European cementplant and typical small electric power boilerplants. Ofparticular interest is that the location ofinjection did not appear to significantly affect the result, eventhough they reportedly represent significantly different 02 and CO conditions. As well, several data points were conducted at Location #1 

### with 2 injectors and with 4 

### injectors- and contrary to common logic and historical fact- the runs with 2 injectors had statistically better results. Limited gas conditions data is available atthe actual points ofinjection- in particular CO and 02. A couple explanations for the relatively poorresults is high CO and/or poor gas mixing. It

### is fairly well known that CO enhances the kinetics ofthe SNCRreaction (shifts the optimum temperature windowto a lowerrange). Since the levels ofCO in the injection zone may be very high, the most likely explanation for the poor results could be that much ofthe ammonia could be converted to NO (which is then reduced to N2 by reaction with a second NH3 molecule). The SNCRreaction does notperform well in zones ofincomplete (or active) combustion/oxidation. DNT's experience with a similar coal fired process suggests that reagent utilization in active combustion zones will be low (or zero) -butmoving injection downstream after removal ofcombustion conditions canbe very effective.

# RECOMMENDATIONS The following is recommended:

• Ofthe four locations tested, the area after introduction ofTertiary Air seems to be the most promising from a chemical perspective. It

### has adequate 02 and residence timepriorto introduction ofcoal inthe calciner. • The specific location ofthe injectors in the "After Tertiary Air" zone should be changedto improve dispersion- See previous memo. • The 20% overall reduction can be achieved at a reagent NSR ofapproximately 0.7 • Annual reagent consumption should be approximately 3 GPM (of40%urea solution) at full load. The permanent system should be designed with adequate margin above that. • Considertesting and/or relocating the injection zone to the outlet duct ofthe Stage 4 Cyclone ifthe Vortex Finder is re-installed.

# AppendixBAppendixBFrom:Steven<SOCLP.USE@GAPAC.corn>To:SchmidtCortneyCc:Subject:GP4924[45%UreaSolution)CortneyJTheFOBBeaverCreekpriceforGP4924(45%UreaSolution)is$0.1759lb.The45%ureasolutionweightpergallonis9.51bspergallon.ThepricepergallonFOBBeaverCreekis$1.571Thanks,.Steuc0.8tuuc.GPChemicals,LLC·WoodAdhesives·Mobile-541.261.5496NOTE:ThedeliverypriceofthismaterialfromBeaverCreek,MltoCharlevoix,Mlvariedfrom"'$.08to$.10pergallon.

# Appendix C

# u X


# ·-- '""0



# c (]) 

# c.. c.. <:( -1-J



# c 

# ro



# - a..

X


# ·-

0 

# > (])



# -

!a.... 

# ro 

# ....c 

# u u**~** V")

# Document 3

# ST MARYS CEMENT

ViaU.S. Mail August 8, 2012 Mr. John Summerhays United States Environmental Protection Agency 77 West Jackson Boulevard Chicago, IL 60604-3590 Phone: 231-237-1342 St. Marys Cement Inc. (U.S.) 16000 Bells Bay Road Charlevoix, Michigan 49720 www.stmaryscement.com



### Re: St. Marys Cement Inc. (U.S.)- BART- Response to August 2, 2012 email Dear Mr. Summerhays:
I am writing in behalfof St. Marys Cement Inc. (U.S.) ("SMC") to respond to your August 2, 2012 email to me, a copy ofwhich is enclosed for your convenient reference. In that email you requested a copy ofa report from SMC's testing ofselective non-catalytic reduction ofNOx and you posed some follow-up questions to our July 19, 2012 meeting at your offices in Chicago. The report on SNCR was already submitted to the USEPA in an August 3, 2012 email and in the follow up August 6, 2102.
The balance of this letter provides SMC's response to your follow-up questions. For ease of reference and understanding, I have repeated each of your questions below and then provided SMC's response below each. Ofcourse, SMC reserves the right to supplement or correct these responses in the event SMC becomes aware of additional pertinent information or if it later discovers errors that mustbe corrected.

I. Is SMC Charlevoix' kiln system equipped with a supplemental burner (i.e., supplemental to the primary kiln burner), the heat from which is used only to heat feed material before it enters the kiln (i.e., equipment we would call a pre-calciner)?
Yes, SMC Charlevoix has a flash Calciner as of 1977 rebuild.

2. Ifthe answer to I is yes: Yes.

a.Does SMC routinely operate its pre-calciner?

A VCNA Company VCNA is the North American subsidiary of Votorantim Cimentos, a leading international basic building materials company headquartered in Brazil.

### Yes, the flash Calciner is used as often as the kiln is used, they are in series

.
b. Onanannual averagebasis, what approximate percentage oftheplant'sheat input is provided by thepre-calciner burner versus the primary (kiln) burner? The split range is 40%/60% to 60%/40% butusually the split is closer to 50% to 50% yet slightlyhigher onthe kiln.

c.Does the plantroutinely operate with approximately a fixed proportion ofheatinputfrom the pre-calcinerburner? Iftheplant operates in different modes under different circumstances, please describe these different modes and identify the approximate percentage oftheplant's heat inputprovided by the pre-calcinerburner for each mode ofoperation. Alternately, ifthepre-calciner burner operating rate is highly variable, and cannot be describedinterms ofstandard operatingmodes, pleaseidentifythe normal range ofoperation ofthe pre-calcinerburner as a percentage ofthe plant's totalheat input. There is no suchthing as "fixed" in a cementplant process. However, The plantroutinely operates withthe flash furnace being controlledto an exit temperature setpoint. That temperature setpointis rarely changed so from thatperspective the answer to your question is yes, the fuel is "approximately fixed"

. Butthetotal quantity offuel inputinterms oftons fired into the calcinervaries depending onthe calorific value ofthe fuel beingused

. 3. Ifthe answer to 1is no, please identify whetherthe plant description provided inthe attached documentremains an accurate description withrespect to the presenceof equipmentlabeled as a calciner. N/A

Ifyouhave any questions about this, please contactme. Sincerely, 

# Q)__,sa

Cortney

# ~chrnidt Environmental Manager 23 1-237-1342 Cc: Dirk Cox