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 West Jackson Boulevard 

Chicago, Illinois 60604 

Re: EPA Docket ID No. EPA-ROS-OAR-2010-0954 

Comments of St. Marys Cement Inc. (U.S.) Regarding Notice of Proposed 

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 if you have any questions. 

Sincerely, 

7~ ~1v~tj~ Fredrick J. Dindoffer 

FJD/ttv 

Attachments 

DETROIT TROY ANN ARBOR CHEBOYGAN DALLAS 

Detroit_12227041 
ST MARYS CEMENT 

Via Overnight U.S. Mail 

September 4, 2012 

Ms. Pamela Blakley, Chief 

Control Strategies Section 

Air Programs Branch (AR-18) 

United States Environmental Protection Agency 

77 West Jackson Boulevard 

Chicago, IL 60604 

Re: EPA Docket 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 of St. Marys Cement Inc. (U.S.) ("SMC"), in opposition to USEP A's 

Notice of Proposed Rulemaking, entitled "40 CPR Part 52 --Approval and Promulgation of Air 

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").St. Marys Cement Inc. (U.S.)-

BART- Response to August 2, 2012 email 

Dear Ms. Blakley: 

I am writing in behalf of St. Marys Cement Inc. (U.S.) ("SMC") to provide comments of SMC to 

the above-captioned U.S. EPA NPRM. Accordingly, enclosed please find the following 

documents: 

!. Comments of St. Marys Cement Inc. (U.S.) ("SMC"), in opposition to USEPA's Notice 

of Proposed Rulemaking, entitled "40 CPR Part 52 --Approval and Promulgation of Air 

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 letter to Mr. Douglas Aburano and Mr. Vincent Hellwig (along 

with attachments and appendixes); and 

3. SMC's August 8, 2012letter to Mr. John Surnmerhays, responding to his August 2, 2012 

email to Cortney Schmidt. 

SMC requests that each of the 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 of the 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. 

If you have 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 of St. Marys Cement Inc. (U.S.) ("SMC"), in opposition to USEPA's Notice of 

Proposed Rulemaking, entitled "40 CFR Part 52 --Approval and Promulgation of Air 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 of the 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 of the Charlevoix plant. If these 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 greater extent 

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. 

2 
The 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 of Appeals decisions: 

(1) EME Homer City Generation, LP v. EPA, No. 11-1302 (D.C. Cir. August 21, 2012), in which the U.S. 

Court of Appeals for the 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 5

1

h 

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 of control 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 of the EPA for a particular control measure." I d. 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." I d. 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) of this section." 42 USC 7491(b)(2) (emphasis added). 

For these reasons alone, EPA should withdraw its NPRM. and approve the portions of the 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 of compliance, [4] any pollution control equipment in use or in existence at the source, [5] the 

remaining useful life of the source, and [6] the degree of improvement in visibility which may reasonably 

be anticipated to result from the use of such 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 of technology 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 Michigan] which according 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 a first 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 inlet, 

riser, bypass take-off, orifice, tertiary air inlet, swirl, round drop, fl ash furnace (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..o und D r o p-o ut -

Ki ln In let. 

LoNer Riser 

..._ ___ Flash Furnace 

Kiln Gas Bypass Take-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 emission 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 

5 
a supplemental environmental project (SEP)1 for 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 of an enforcement action, United States v. CEMEX 

Inc. and St. Marys Cement Inc. (U.S.), taken on behalf ofthe U.S. Environmental Protection Agency and the 

Michigan Department of Environmental Quality under the Clean Air Act and the Michigan Natural Resources and 

Environmental Protection Act. 

6 
EPA Report on ='JOx \·ariability 1n Cetnent 

1\ Ian ufacturing 

:.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 of the Charlevoix plant's specific NOx emissions per ton of clinker produced from 2006 to 

2008. The average of this data is 4.56 lbs/ton, but there is a significant standard deviation of 0.64 

lbs/ton leading up to a 99.7% confidence number of 6.47 lbs/ton. 

Accordingly, any discussion of NOx control at Charlevoix must recognize 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 limit for 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 industry. 

EPA will expect compliance with its emission limit every day, not just 110n average" over several years. 

Therefore, EPA also was incorrect when it derived its proposed NOx emission limit of 2.3 lbs/ton for the 

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 half of 

the actual performance is greater than that average. Therefore, when setting an emissions limit, any 

7 
proposed 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 that was recently used by the EPA in its agreement with Holcim's Montana Plant. 

Consequently, in this instance, if there was to be any reduction, it must be applied against the 6.5 

lbs/ton value which represents the 99.7% confidence value of SMC'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 of the 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 the temperature profile of the remaining system. This heat sink and other design inefficiencies 

8 
requires 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 af kiln versus diameter and the extremely short gas 

retention time within the calciner vessel, are reasons why the Charlevoix plant cannot be expected to 

have NOx emissions that only the most modern 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 of oxygen in the combustion 

zone and a longer retention time at elevated temperatures lead to greater amounts of NOx formation. 

SMC's Charlevoix facility is affected by all of these conditions. The plant has to operate in an oxidizing 

atmosphere due to the inherent sulfur content in the raw materials, and the plant has a longer kiln 

shell than would be designed today, because of the manner in which it was modified in 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) if they 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 

10 
plants in Montana, at 6.5 lbs/ton and 8.0 lbs/ton, respectively. Each of these 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 of a joint 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 temperature profiles to implement t he most effect ive 

location and operation of an SNCR system. 

SNCR Tria l Locations 

Gas b.it or 

lo '· est Cyclone 

J;.11 er Duct after 

T.:..Ouct 

J;.is er Duct prie>r to 

'f-::llll"ijJI>-- TA Duct 

1 2 and 4 Nozzlc$1 

11 
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 actual NOx reduction efficiencies. Below are the summarized results of 

the DeNox trials based location and reagent inject rate. 

DeN ox Trials c:ha.rle\Toix: T\II 

s :: 38 I S 8\ I ) 60 9 ~ {) .:. ,, - . ,, 

1s:: 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 of either 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 

highlighting 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 Facility. 

12 
Arnrnonia Slip during DeN ox 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 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 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 of SNCR, and even at this low rate of NOx reduction the plant will expect to experience 

ammonia slip. 

As previously mentioned, according to the EPA "Relatively high concentrations of NH3 slip can react with 

502 and sulfur trioxide (S03) in the flue gas and form ammonium sulfates and bisulfates, 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 sulfur content in the raw materials. Given this fact, and what has been 

experienced at Charlevoix, there is a high propensity to have ammonia slip while utilizing SNCR, and 

dealing with build-up should be expected. 

13 
EPA'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 of SNCR. 

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 for the Charlevoix facility. 

Typical Tin1e an d Ternperature Profile 

.:.:: = 

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

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

~ !: : " : : 

Charlevoix does not have temperatures necessary to support SNCR Reactions. According to an EPA 

report "Nitrogen Oxides Emission Control Options for Coal-Fired Electric Utility Boilers", corroborated by 

a separate report from the PCA, entitled "Summary of Control Techniques for Nitrogen 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 it to 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 of operation for the 

Charlevoix facility. 

S:-JCR Reagent Efficiency Cun·es based on 

-:-emperature \\·ith Charle\·oix Oper2.ting Ranges 

100 

90 

2~ 

7':. 

t>O 

sc 

40 

30 

20 

10 

0 

12CO 

- Urea 

JC·O 

Arnro inia 

S Nirllnlet 

Terrperature 

Peak 

Efficiency 

1900 

The typical temperature profile for the Charlevoix operation is shown above, and illustrates that 

nowhere in the Kiln riser, or flash calciner regions of the system does the plant reach the optimum 

temperature profile to support an 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 Options for Coal-Fired Electric Utility Boilers", which is corroborated 

by a separate report from the PCA entitled "Summary of Control Techniques for Nitrogen Oxide" 

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 of the riser, swirl chamber, and flash calciner at the Charlevoix facility does not have 

enough retention time to support an effective SNCR reaction. 

16 
Ammonia 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 of Control Techniques for 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 pre heater 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 Options for 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 of achieving reductions of only~ 30%." 

A study conducted and presented for the IEEE found a similar tendency when dealing with Cement Kilns 

of various 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 

17 
nozzles 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 

plant should not be expected to have NOx reduction efficiencies of the smaller plants. 

[2] EPA did not correctly determine the costs of additional 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 DeN ox testing, the reagent application also hampered the operating system by 

18 
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 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 of the 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 

' Retention Time 

' 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 flash calciner, 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 

not justify 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 

19 
removed. 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 of would 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 of the 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 of these 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 of the 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 in visibility 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 not justified. EPA is not empowered to substitute its judgment for that of the state of Michigan as to 

22 
the 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 981

h No. of Days Modeled 981

h 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 of the 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 

24 
St 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) 

Direct IDrtall•tion Coot. 

Foundation.< & rupporL' 

Handlin~ & croction 

Electri<:.al 

Piping 

lnmJlotion 

Pain tin 

Dkred IDotallation C..oto 

Site \'reparation, o.< required 

Build in[!..>. a.< required 

Totall:lired Cooto, l:IC 

IDdired Com 

En],!ineering 

Pcrfotmnnco le.<l 

Conlin encios 

TotallDdired: Corn, JC 

Total Capital Investmmt DC+ IC 

ANNUAL COSTS 

Direot Annbal Coots, DC 

Operator 

Supervisor 

Operating Materlob 

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% of c<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% of purchased eguip cost (B) 

1% ofpurcha<e<l equip C<>.<l (B) 

1% of urchnsed e ui co<! (B) 

85% 

Site Specific 

Site Specific 

10% of purchased equip roSl (B) 

10% of purchased equip <:OS! (B) 

10% ofpurcho .. d equip C<>.<l (B) 

I% of purcho.=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% of operator 

$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 of dueling- 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 

Indirect Annual 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 of N 0:~: removed 

60% of tot• I hbor :md material rosts 

!% of Total Copilallnvc<tmenl 

0% of Total 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 !he Environ 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 Air Pollution Control Cost Manuol 

EPA Air Pollution Control C"'l Manual 

E<limoted ooSl for now in line 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 Polloi ion 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 of cleon-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 max 
St 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 

Direct Alu>nal CooU, DC 

OperodiDg Labor 

Open!or 

Supervisor 

Operating Material• 

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

MaioleDnce 

Lo»m 

Table 2 

10% of<=Jtroldovie<ocost(A) 

5% of oonlrol de\'icc cost {A) 

50% 

21% 

12% of purcha•od equip coS! (B) 

40% of purcha.ed equip ca&t (B) 

1% of purch>-<cd "'!"iP co.t (B) 

JO% of porcha•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% of purchosed equip co<! (B) 

]0% of pumh.,ed equip ooSl (B) 

10% ofpuroh"ed equip cost (B) 

1% of purchased 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% of operator 

Sl7_77 lhrper•hifi.8760hrlyr 

Materials 100% of mointonance lob!r 

Electricity 0.0732 $/kW-hr, 100 kW, 6570 hrlyr {for healing urea solution in cooler"""""") 

Clean out cemcntic build np on sides of dueling- 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 oil owed in Michigan) 

Insurance 

Copital Recovery 14.24% for a 10 veor equipment life ond a 7% inl=<t rnte 

Total Indirect Aluoual Colto, IC 

Total Annual Co5ts- DC+ IC 

Polbrtont Removed {loDolp) 

]cost per ton ofNO:o: removed 

60% of tolallahor and motcriol oo•t• 

2% of Total Capilol!nve•lment 

0% of Total Capitallnvestmenl 

1% of Total 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 Air Pollution 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 Air Pollution Control Co.<! Manual 

EPA Air Pollution Control Co;t Manuol 

EPA Air Pollution Control Com Monuol 

EPA Air Pollution Control Co•! Manual 

EPA Air Pollution Conkrol Co<! Manual 

Thi• i.< b"ed on past history of c\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 Removal Measurements with a Urea Based SNCR System 

at the St. Mary's Cement Charlevoix Facility 

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-N Ox Technologies to 

evaluate the effectiveness of an SNCR system for reducing NOx emissions. 

The test apparatus consisted of a 5000 gallon tank trailer to 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 of permanent 

piping. The pump skid contained flow meters to measure reagent flow and the main 

stack CEM system was used to monitor performance. 

SNCR requires injection of either ammonia or urea into the furnace gas at just the right 

temperature to react with NOx to form N2. If urea is used, the high temperatures in the 

combuster breaks down each mol of urea into two mols of ammonia and one mol of CO. 

Proper reagent 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 of oxygen. Residence time and mixing are critical factors for obvious reasons 

and the presence of CO will lower the optimum temperature window. 

The predominant reaction is described as follows: 

UREA+ NITROGEN OXIDE NITROGEN+ CARBON DIOXIDE+ WATER 
TEST SCOPE AND METHODOLOGY 

The objectives of the 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 of the kiln outlet, calciner, and Stage 4 Cyclone. 

Gasses exiting the 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 directed tangentially into the bottom of the 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 Tertiary Air but before 

coal addition. Location 3 was in the crossover duct between the calciner vessel and the 

Stage 4 cyclone. Location 4 was in the outlet of the Stage 4 cyclone. 
TEST RESULTS 

The summarized data is presented in Table 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 back to a baseline. In general,a step change in reagent injection took 2-3 minutes 

to be fully developed at the CEM. 

Location 3 was dismissed immediately since NOx reduction was near zero. Of the other 

three, there was no clear winner. 

Overall, SNCR performance 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 cement plant and typical small electric power boiler plants. 

Of particular interest is that the location of injection did not appear to significantly affect 

the result, even though 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 at the actual points of injection- in particular CO 

and 02. A couple explanations for the relatively poor results is high CO and/or poor gas 

mixing. It is fairly well known that CO enhances the kinetics of the SNCR reaction 

(shifts the optimum temperature window to a lower range). Since the levels of CO in the 

injection zone may be very high, the most likely explanation for the poor results could be 

that much of the ammonia could be converted to NO (which is then reduced to N2 by 

reaction with a second NH3 molecule). 

The SNCR reaction does not perform well in zones of incomplete (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) -but moving 

injection downstream after removal of combustion conditions can be very effective. 
RECOMMENDATIONS 

The following is recommended: 

• Of the four locations tested, the area after introduction of Tertiary Air seems to be 

the most promising from a chemical perspective. It has adequate 02 and 

residence time prior to introduction of coal in the calciner. 

• The specific location of the injectors in the "After Tertiary Air" zone should be 

changed to improve dispersion- See previous memo. 

• The 20% overall reduction can be achieved at a reagent NSR of approximately 0.7 

• Annual reagent consumption should be approximately 3 GPM (of 40% urea 

solution) at full load. The permanent system should be designed with adequate 

margin above that. 

• Consider testing and/or relocating the injection zone to the outlet duct of the Stage 

4 Cyclone if the Vortex Finder is re-installed. 
AppendixB 
Appendix B 

From: C!ausenr Steven 

T a: Schmidt Cortney 

Cc: 

Subject: GP4924 [45% Urea Solution) 

Cortney, 

The FOB Beaver Creek price for GP 4924145% Urea Solution) is $0.1759lb. The 4J.% urea solution weight per gallon is 9.5lbs per gallon. The price 

. Thanks, 

• Ste#c 0. (jk.zu,. 

GP Chemicals, LLC 

: Wood Adhesives 

Mobile- 541.261.5496 

NOTE: The delivery price of this material from Beaver Creek, Ml to Charlevoix, 

from"' $.08 to $.10 per gallon. 
Document2 
ST MARYS CEMEN T 

Via U.S. Mail 

August 2, 2012 

Mr. Douglas Aburano 

Attainment Planning and Maintenance Section 

United States Environmental Protection Agency 

77 West Jackson Boulevard 

Chicago, IL 60604-3590 

Mr. Vincent Hellwig, Chief 

Air Quality Control Division 

Michigan Department of Environmental Quality 

P.O. Box 30260 

Lansing, MI 48909 

Dear Messrs. Aburano and Hellwig, 

Phone: 231 -237-1342 

St. Marys Cement Inc. (U.S.} 

16000 Bells Bay Road 

Charlevoix, Michigan 

49720 

www.stmaryscement.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 of the May 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 or if it later discovers errors that must 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 of EPA's proposal, SMC hereby offers to reduce its emissions in 

an amount that will 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. Using this alternative approach, the 

matter will be resolved amicably and will result in an improved condition for Seney. 

Accordingly, SMC would appreciate your earliest response to this approach. 

A VCNA Company 

VCNA is the North Am erican subsidiary of Votorantim Cimentos, a leading international 

basic building materials company headquartered in Brazil. 

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

As an initial matter, it is unfortunate that this critical review of EPA'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 if EPA 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 of BART 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 of 2.3 pounds ofNOx per ton of Clinker produced (2.3 lbs/ton) for the 

Charlevoix facility. 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 must be 

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 of compliance, [3] the energy and nonair quality environmental impacts of compliance, [ 4] any pollution control equipment in use or in 

existence at the source, [5] the remaining useful life of the source, and [6] the degree of 

improvement in visibility which may reasonably be anticipated to result from the use of such 

technology." 40 CPR 51.301. 

Analysis 

[I] EPA did 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 N Ox 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 of technology 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/ton produced at Charlevoix prior to SMC' s purchase of the 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 of multiple environmental stewardship awards from industrial· 

associations. 

Upon the acquisition of the 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 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. 

Also upon the acquisition of the Charlevoix facility in 2005, even though it was not required, 

SMC hired DeN ox 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 of an 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 

DeN ox were only able to achieve short term reduction efficiencies of 25 - 30%. The DeN ox 

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 even the best circumstances. DeNox's 

owner noted (just as EPA stated) that he had seen SNCR effectively solve NOx issues in multiple 

1 This project was undertaken in connection with the settlement of an enforcement action, United States v. Cemex, 

Inc. and St. Marvs Cement Inc. (U.S.), taken on behalf of the U.S. Environmental Protection Agency and the 

Michigan Department of Environmental 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 of your calciner design." 

So, over the years, SMC has reduced its NOx emissions by 40%, through the use of these 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 of 4.56 lbs/ton. 

[2] EPA did not correctly determine the costs of additional 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 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. 

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 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% armual NOx reduction. In this scenario, as a result of the calciner 

improvements, SMC removed any cost associated with buildup and downtime losses. However, 

the improvements in operating efficiency of the SNCR system still do not justifY 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 ofNOx removed. 

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 of reagent, and different nozzle designs, but 

none of the 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) 

Dired IDrtallatinn Com 

Foundation< & rupports 

Hondilng & erection 

Electrical 

Piping 

Paint in 

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 

Direct Annnal Com, DC 

Operath•g Lab<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% of rontrol device""'! (A) 

21% 

12% ofpurchasedequipeos!{B) 

40% nfpurchase<l equip rost (B) 

1% of purchased equip cost (B) 

30% of purchased equip oos! (B) 

1% of purchased equip cmt (B) 

I% of urchased e ui cost (B) 

85% 

Site Spcdfic 

S!le Specific 

10% ofpurcha'"d equip cost (B) 

10",4, of purchased equ1p oost (B) 

10% ofpurcha.cd equip cost (B) 

1% ofpurch.sed equip COS! (B) 

I% of purchased equip rost (B) 

3% Gf urchosede ui cost (B) 

35% 

$25.38 112 hr per shift. soon hrlyr 

15% of operator 

$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 eementic build 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 ofN01 removed 

60% of total labor and material cost' 

2% of Total 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 of this 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 in line 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 SNCR for 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 max 
St 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 

Dlnct A=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% nf oontrol device coot (A) 

5% of control de,•ioe co" (A) 

50% 

21% 

12% of purchased eqllip cost (B) 

40% of purchased 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% of purchased equip coot (B) 

10% of purchased eqlllp cost (B) 

1% of purchased 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 Indirect AnnuoJ Coot1, IC 

Total Annual Co~Q; DC+ IC 

Pnllutant Removed (tnuolyr) 

I cost per ton of NO~: removed 

60% oftotallahor and material costs 

2% ofTmnl Capitol Investment 

0% of Total 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 of this 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 

EPA Air 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 of clean-out 

whik usin~' SNCRfor the ozone system 

EPA Air Pollution Control Cos\ Manual 

EPA Air Pollution Control Cost Manu"! 

EPA Air Pollution Control Cos! Manual 

EPA A1r Pollution Control Cost Manuol 

5741.5 6.5 # Nox per Ton clinker annualized with permit 

efforced plant max 
Within the May 24letter the EPA lists several 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 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 of compliance 

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. Appendix C 

provides a photograph taken during the DeN ox trials and 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 of the 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 in visibility which may reasonably be anticipated to result from 

the use of such technology 

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 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, by (1) reducing its 

permitted NOx emissions rate; (2) by reducing 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 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%. 

SMC will need time to implement steps to achieve these limitations, and so it proposes that they 

imposed over the next four years. 

If you have any questions about this, please contact me. 

Sincerely, 

~5_[)-

Cortney Schmidt 

Environmental Manager 

231-237-1342 

Cc: DirkCox 
Table 3 CALPUFF Model Res

Impacts at Seney with Current Impacts at Seney 

permitted emissions limits (6.5 emissions limits 

NOx; 13.9 S02); and full production S02); production l

of 1. 766 million tons/vear of Clinker tons/vear o

Modeled 98th No. of Days Modeled 98th 

Meteorological Data Inputs I Percentile Exceeding 0.5 Percentile 

Deciview Value Deciview Deciview Value 

2002 5.26 30 2.82 

2003 3.64 39 2.29 2004 2.48 62 1.39 

2002- 2004 Combined 

Average 3.79 44 2.16 

Net reduction from SMC control measures 43.0% 
Appendix A 
NOx Removal Measurements with a Urea Based SNCR System 

at the St. Mary's Cement Charlevoix Facility 

Draft Report 

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-N Ox Technologies to 

evaluate the effectiveness of an SNCR system for reducing NOx emissions. 

The test apparatus consisted of a 5000 gallon tank trailer to 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 of permanent 

piping. The pump skid contained flow meters to measure reagent flow and the main 

stack CEM system was used to monitor performance. 

SNCR requires injection of either ammonia or urea into the furnace gas at just the right 

temperature to react with NOx to form N2. If urea is used, the high temperatures in the 

comhuster breaks down each mol of urea into two mols of ammonia and one mol of CO. 

Proper reagent 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 of oxygen. Residence time and mixing are critical factors for obvious reasons 

and the presence of CO will lower the optimum temperature window. 

The predominant reaction is described as follows: 

UREA+ NITROGEN OXIDE NITROGEN + CARBON DIOXIDE+ WATER 
TEST SCOPE AND METHODOLOGY 

The objectives of the test were threefold: 

I. Optimize injection location and settings. 

2. Generate stoichiometric performance curves, and 

3. Generate some continuous run data 

Figure 1 has sectional side views of the 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) Tertiary Air at 1500 degF is 

added (from the clinker cooler), and directed tangentially into the bottom of the calciner. 

In the calciner, more fuel (coal) is added before flowing into the lowest of four 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 but before 

coal addition. Location 3 was in the crossover duct between the calciner vessel and the 

Stage 4 cyclone. Location 4 was in the outlet of the Stage 4 cyclone. 
TEST RESULTS 

The summarized data is presented in Table 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 Inj 

2, then back to a baseline. In general,a step change in reagent injection took 2-3 minutes 

to be fully developed at the CEM. 

Location 3 was dismissed immediately since NOx reduction was near zero. Of the other 

three, there was no clear winner. 

Overall, SNCR performance 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 cement plant and typical small electric power boiler plants. 

Of particular interest is that the location of injection did not appear to significantly affect 

the result, even though 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 at the actual points of injection- in particular CO 

and 02. A couple explanations for the relatively poor results is high CO and/or poor gas 

mixing. It is fairly well known that CO enhances the kinetics of the SNCR reaction 

(shifts the optimum temperature window to a lower range). Since the levels of CO in the 

injection zone may be very high, the most likely explanation for the poor results could be 

that much of the ammonia could be converted to NO (which is then reduced to N2 by 

reaction with a second NH3 molecule). 

The SNCR reaction does not perform well in zones of incomplete (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) -but moving 

injection downstream after removal of combustion conditions can be very effective. 
RECOMMENDATIONS 

The following is recommended: 

• Of the four locations tested, the area after introduction of Tertiary Air seems to be 

the most promising from a chemical perspective. It has adequate 02 and 

residence time prior to introduction of coal in the calciner. 

• The specific location of the injectors in the "After Tertiary Air" zone should be 

changed to improve dispersion- See previous memo. 

• The 20% overall reduction can be achieved at a reagent NSR of approximately 0. 7 

• Annual reagent consumption should be approximately 3 GPM (of 40% urea 

solution) at full load. The permanent system should be designed with adequate 

margin above that. 

• Consider testing and/or relocating the injection zone to the outlet duct of the Stage 

4 Cyclone if the Vortex Finder is re-installed. 
AppendixB 
Appendix B 

From: Steven <SOCLP.USE@GAPAC.corn> 

To: Schmidt Cortney 

Cc: 

Subject: GP4924[45% Urea Solution) 

CortneyJ 

The FOB Beaver Creek price for GP 4924 (45% Urea Solution) is $0.1759lb. The 45% urea solution weight per gallon is 9.51bs per gallon. The price p

Thanks, 

. Steuc 0. 8tuuc 

. GP Chemicals, LLC 

· Wood Adhesives 

· Mobile- 541.261.5496 

NOTE: The delivery price of this material from Beaver Creek, Ml to Charlevoix, 

from"' $.08 to $.10 per gallon. 
Appendix C 
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Document 3 
ST MARYS CEMENT 

Via U.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 behalf of St. Marys Cement Inc. (U.S.) ("SMC") to respond to your August 2, 

2012 email to me, a copy of which is enclosed for your convenient reference. In that email you 

requested a copy of a report from SMC's testing of selective 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. Of course, 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 must be 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. If the 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. On an annual average basis, what approximate percentage ofthe plant's heat input is 

provided by the pre-calciner burner versus the primary (kiln) burner? 

The split range is 40%/60% to 60%/40% but usually the split is closer to 50% to 50% yet 

slightly higher on the kiln. 

c.Does the plant routinely operate with approximately a fixed proportion of heat input from 

the pre-calciner burner? If the plant operates in different modes under different 

circumstances, please describe these different modes and identify the approximate 

percentage of the plant's heat input provided by the pre-calciner burner for each mode 

of operation. Alternately, if the pre-calciner burner operating rate is highly variable, and 

cannot be described in terms of standard operating modes, please identify the normal 

range of operation of the pre-calciner burner as a percentage of the plant's total heat 

input. 

There is no such thing as "fixed" in a cement plant process. However, The plant routinely 

operates with the flash furnace being controlled to an exit temperature set point. That 

temperature set point is rarely changed so from that perspective the answer to your question 

is yes, the fuel is "approximately fixed". But the total quantity of fuel input in terms of tons 

fired into the calciner varies depending on the calorific value of the fuel being used. 

3. If the answer to 1 is no, please identify whether the plant description provided in the 

attached document remains an accurate description with respect to the presence of 

equipment labeled as a calciner. 

N/A 

If you have any questions about this, please contact me. 

Sincerely, 

Q)__,sa 

Cortney ~chrnidt Environmental Manager 

23 1-237-1342 

Cc: Dirk Cox