UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop Street DENVER, CO 80202-1129 Phone 800-227-8917 http://www.epa.gov/region08 

## NOV 2ti 

## 2007 Ref: 8P-AR Ned Pettit Environmental Manager Ho1cim, Inc. 4070 Trident Road Three Forks, MT 59752 Re: BestAvailableRetrofit Technology (BART) Analysis, Holcim (US) Inc. Dear Mr. Pettit: On February 28, 2007, EPA Region 8 sent a letterto Ho1cim (US) Inc. (Ho1cim) that provided the results ofour "subjectto" modeling for Best Available Retrofit Technology (BART) and requested that Ho1cim perform a BART analysis and submit it to EPA Region 8. On July 6, 2007, Ho1cim submitted a BART analysisto EPA that was performed by Bison Engineering, Inc. We would like to thankyou for your submittal and want to recognize the effort that has gone into developing the BARTanalysis for Ho1cim. We havecompleted our initial review ofthe July 6, 2007 submittal and have determined that there is additional information and analysis needed from Ho1cim in order for us to complete ourreview. Following are EPA Region 8'scomments. With the exception ofthe EPA Control Cost Manual, documents referenced in our comments have been attached for your convenience. In addition, we are providing a copy ofcomments onthe Ho1cim BART analysis submitted to EPA onNovember 9, 2007 from the USDA Forest Service Northern Region. 

### 802 Emissions and Controls

• The analysis used 10 years as the basis for the remaining useful life ofthe scrubber, however the useful life ofthese control technologies is expected to be 15 years basedon information from the EPA Control Cost Manual ("EPA Air Pollution Control Cost Manual", Sixth ed., EPA-452-02-00I, January 2002, Section 5.2, Chapter 2, page 2-51). Ho1cim needs to reanalyze the annualized costs for the scrubber using fifteen years as provided inthe EPA Control Cost Manual. • In section 4.3.2, Ho1cim eliminates fuel substitution as a means for reducing S02 referencing a statement inthe BARTGuidelines which reads: "Pollution prevention: use ofinherently lower-emitting processes/practices, including the use ofcontrol techniques (e.g. low-NOX burners) and work practices that prevent emissions and result inlower "production specific" emissions (note that itis not our intent to direct States to switch fuel forms, e.g. from coal to gas)" (see 70 FR 39164, July 6, 2005). EPA did not intendthis to mean that sources shouldnot be looking at potentially switching to a lower sulfurcontent coal (or coke) ifthe source is already using coal (or coke) for fuel. The language is meant for situations where a facility would be looking at switching from one type offuel to another, such as coal to natural gas. Fuel substitution to lower the fuel sulfurcontent can be a very cost effective means for reducing S02 emissions and should be analyzed. • The BART analysis estimates the purchase cost for a venturi scrubber at $14,500,500. We have cost estimate information for venturi scrubbers that is significantly less than the cost estimate you provided. Please provide documentation for this purchase cost. • The conclusions presented inTable 4-2 and other parts ofthis document are driven by the high capital equipment costs for the wet scrubber. Ifthe informationrequested above differs from the original estimated cost of$14,500,500, we ask that Holcim reanalyze the part$ of the BART analysis that are affected by this figure. NO

### xEmissions and Controls

• Section4.4 ofyour analysislists properkiln design and operation asone ofthe possible control options and as the baseline in the analysis for other control optionsbutdoes not provide information onthe current design and operation ofthe kiln. Please provide information onthe current kiln design and operation and an analysis on whetheradditional reductions canbe achieved through proper kiln.design and operation. • In addition to the installation ofa fixed inlet to the clinkercoolerand the installation ofa low NOx burner, Ho1cim should continue to considermid-kiln firing and Selective Non-Catalytic Reduction (SNCR) as viable BARTcontrol technologies for NOx emissionreduction:. Midkiln firing is expected to achieve an emissionreduction of45% or more (see Hansen, Eric R. Technical Consultant, Cadence Environmental Energy Inc. "StagedCombustion for NOx Reduction Using High Pressure Air Injection." IEEE2002). SNCR has beenapplied to wet kilns and canreliably attain a NOx emission rate of800 mg/m3, and in most cases attain a rate of500 mg/m3 (see Scw, P. Cemex Ostzement, Redersdorf. Hoppe, Dr. Forchunginstitut der Zementindustrie, Dusseldorf. "The Present State ofNOx Abatement with the SNCR Process." Cement International No. 2/2006, Volume 4., ISSN 1610-6199 andAssessmentof NOx Emissions Reduction Strategies for Cement Kilns

- Ellis County

- FinalReport. Prepared by ERG, Inc. for Texas Commission on Environmental Quality. TECQ CntractNo. 582-04-65589, Work OrderNo. 05-06. July 14,2006). Please provide additional analyses and documentation for both ofthese potential control measures. • Table 4-4 lists the efficiency for mid-ls:iln injection of tires as 30%. A value of40% for wet kilns has been documented and we request that Ho1cim provide a revised analysis for this control optionusing a value of40% for the wet kiln oran analysis ofwhy 40% is not achievable (seeNOx Control Technologiesfor the CementIndustry. Battye, R., S Walsh, J. Lee-Greco, EC/R Incorporated prepared for U.S. EPA under contractNo. 68-D-98-026. September 19, 2000. Table 5-7). • The document states that details ofthe cost analysis for 10w-NOx burners, and mid-kiln fuel injection are included in Appendix C. However, Appendix C did not include these analyses. Please submit the details ofthe cost analysis for 10w-NOxburners and mid-kiln injection. • Using the permittedNOx emission**rat~** to determinetons ofNOxremoved is problematic. The permitted value is very high relative to the actual emissions. The maximumNOx 2emissionrate during the three year period of2001-2003 was reported as 784 lbs/hour. The permitted value is 1,568 lbslhour, ortwice the maximum value reported for the three year period. Using the permitted value as the baseline could give a calculatedpost control emission rate larger thanthe actual uncontrolled emissions. For example proposing a 20% NOx reduction with a permit limitation of 1,254 Ibs/hourwould allow an emission increase from the currently reported maximum hourly rate of784 Ibs/hour. Itis appropriate to use actual emissions ifthose are representative ofhow Holcim has been operating in the past. In addition, Holcim used actual emissions to model visibility for the BART analysis andthe emissions used in the modeling and the rest ofthe analysis need to be consistent. Please revise the analysis using actual emissions. Particulate Matter Emissions and Controls

• Holcim did not provide any designparameters for the existing PMcontrol technologies on the ESP on the kiln and the baghouse on the clinker cooler. It is possible that BARTfor PM for these two sources could include additional controls and/or increased performance ofthe existing technologies. The BART Guidelines state that "Foremission units subject to a BARTreview, there will often be control measures or devices already in place. For such emissionunits, it is important to include control options that involve improvements to existing controls and not to limit the control options only to those measures that involve a complete replacement ofcontrol devices" (see 70 FR 39164, July 6,2005). We askthat Holcim submit the design parameter information for PM controls on the kiln and clinker cooler and evaluate the possibility ofadditional controls and increased performance ofthe existing equipment. Overall Comments

• Your analysis did not include a conversion from a wet kiln to a semi-dry or dry kiln. Several documents in the literature indicate that both ofthese demonstrated options would offer substantial emissions reductions at potentially reasonable costs (seeAssessmentof NOx Emissions Reduction Strategies for Cement Kilns

- Ellis County

- FinalReport. Prepared by ERG, Inc. for Texas Commission on Environmental Quality. TECQ CntractNo. 582-04­ 65589, Work OrderNo. 05-06. July 14,2006and A UniqueApproach. Menke, T., Jepsen, O.L., and Keefe, B.P. ReviewNo. 136. Reprint from IEEE-IASIPSCA 2001 Cement industry Technical Conference May 2001 and published in International Cement Review, July 2001). Please include an analysisthat addresses a conversion from a wet kiln to a semidry or dry kiln. There are also several locations in,the document thatmay have typographical errors.

• On page 3-3 in Section 3.3 it states that the BART modeling analysis performed for Holcim used the permittedNOx PTE to establish the baseline visibility impacts. The permitted value is given as 1,568 lbslhr on a rolling 30-day average (6,868 tons/year). As provided in Table 3-2, the rate that was modeled is 784 Ibs/hour.
3• On page 4-11 the second technology analyzed 'wet S02 scrubber impacts' begins with a (c) rather than a (b). Is there a missing analysis? • On page 4-23 the web address for the 

## cpr multiplier does not work. In order to move forward with the BARTprocess, we ask that you submit the requested information and analysis to our office within thirty days from the date ofthis letter. Once again, we would like to thank you for submitting the BART analysis and acknowledge the work that has gone into preparing this analysis. Ifyou have any questions, please contact Laurel Dygowski at (303) 312-6144. Sincerely, J /"

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. --.-- A. Videtich, Director

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Air and Radiation Program

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## USDA United States Forest Region One Northern Region Department of Service 200 East Broadway Agriculture Missoula, MT 59802
File Code: 2580 Date: 

### NOV ,':;**2UO~** Laurel Dygowski

. Regional Haze Coordinator Air Quality Planning and Management Unit US EPA

- Region 8 1595 Wynkoop Street Denver, CO 80202-1129 Dear Ms. Dygowski: The USDA Forest Service Northern Region is pleased to providethe following comments in regards to the BARTAnalysis submitted by Holcim Cement.

• Hokim should be required to include fuel substitution as a viable option for S02 control. The Forest Servicebelieves that their interpretationofAppendix Y is incorrect, and that they should consider switchingto a low sulfur fuel.

• We are concerned that Ho1cim does not consider SNCR as a viable control technology for NOx• Ho!cim claims that this is emergingtechnology and thus not an available BART technology. The Forest Service disagrees and would like Ho1cim to redo its analysis assuming that SNCRis a viable technology. This is relevant considering other cement companies have agreed to installthis technology in order to achieve BART.

• The Forest Service is concerned that one ofthe technologically feasible options for NOx control presented by Holcim is mid-kiln injection oftires. Holcim submitted a pennit request to the Montana Department ofEnvironmental Quality in 2003 for this technology and has yet to receive approval. Since there remain questions as to whether Holcim will even be permitted to add mid-kiln injection oftires, this should not be considered a technologically feasible option.

• When assessing deciview improvements orcosts perdeciview for improvements, Holcim should consider all Class I areas, notjust Gates ofthe Mountains. Thankyou for the opportunity to provide comments on this analysis. Sincerely, 

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# A· /11t1JJl;irV' / THOMAS L. TIDWELL

. Regional Forester

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