UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 

REGION 8
 

1595 Wynkoop Street 

DENVER, CO 80202-1129 

Phone 800-227-8917 

http://www.epa.gov/region08 

NOV 2 ti 2007 Ref: 8P-AR 

Ned Pettit 

Environmental Manager 

Ho1cim, Inc. 

4070 Trident Road 

Three Forks, MT 59752 

Re: Best Available Retrofit Technology (BART) Analysis, Holcim (US) Inc. 

Dear Mr. Pettit: 

On February 28, 2007, EPA Region 8 sent a letter to Ho1cim (US) Inc. (Ho1cim) that 

provided the results of our "subject to" 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 analysis to EPA that was performed by Bison 

Engineering, Inc. We would like to thank you for your submittal and want to recognize the effort 

that has gone into developing the BART analysis for Ho1cim. 

We have completed our initial review of the July 6, 2007 submittal and have determined 

that there is additional information and analysis needed from Ho1cim in order for us to complete 

our review. Following are EPA Region 8's comments. With the exception of the EPA Control 

Cost Manual, documents referenced in our comments have been attached for your convenience. 

In addition, we are providing a copy ofcomments on the Ho1cim BART analysis submitted to 

EPA on November 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 of the scrubber, however 

the useful life of these control technologies is expected to be 15 years based on information 

from the EPA Control Cost Manual ("EPA Air Pollution Control Cost Manual", Sixth ed., 

EPA-452-02-00 I, 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 in the EPA 

Control Cost Manual. 

•	 In section 4.3.2, Ho1cim eliminates fuel substitution as a means for reducing S02 referencing 

a statement in the BART Guidelines which reads: "Pollution prevention: use of inherently 

lower-emitting processes/practices, including the use of control techniques (e.g. low-NOX 

burners) and work practices that prevent emissions and result in lower "production specific" 

emissions (note that it is 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 intend this to mean that sources should 
not be looking at potentially switching to a lower sulfur content coal (or coke) if the 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 of fuel to another, such as coal to natural gas. 

Fuel substitution to lower the fuel sulfur content 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 in Table 4-2 and other parts of this document are driven by the 

high capital equipment costs for the wet scrubber. If the information requested 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. 

NOx Emissions and Controls 

•	 Section 4.4 of your analysis lists proper kiln design and operation as one of the possible 

control options and as the baseline in the analysis for other control options but does not 

provide information on the current design and operation ofthe kiln. Please provide 

information on the current kiln design and operation and an analysis on whether additional 

reductions can be achieved through proper kiln .design and operation. 

•	 In addition to the installation of a fixed inlet to the clinker cooler and the installation of a low 

NOx burner, Ho1cim should continue to consider mid-kiln firing and Selective Non-Catalytic 

Reduction (SNCR) as viable BART control technologies for NOx emission reduction:. Midkiln firing is expected to achieve an emission reduction of 45% or more (see Hansen, Eric R. 

Technical Consultant, Cadence Environmental Energy Inc. "Staged Combustion for NOx 

Reduction Using High Pressure Air Injection." IEEE2002). SNCR has been applied to wet 

kilns and can reliably attain a NOx emission rate of 800 mg/m3, and in most cases attain a 

rate of 500 mg/m3 (see Scw, P. Cemex Ostzement, Redersdorf. Hoppe, Dr. Forchunginstitut 

der Zementindustrie, Dusseldorf. "The Present State of NOx Abatement with the SNCR 

Process." Cement International No. 2/2006, Volume 4., ISSN 1610-6199 and Assessment of 

NOx Emissions Reduction Strategies for Cement Kilns - Ellis County - Final Report. 

Prepared by ERG, Inc. for Texas Commission on Environmental Quality. TECQ Cntract No. 

582-04-65589, Work Order No. 05-06. July 14,2006). Please provide additional analyses 

and documentation for both of these potential control measures. 

•	 Table 4-4 lists the efficiency for mid-ls:iln injection oftires as 30%. A value of 40% for wet 

kilns has been documented and we request that Ho1cim provide a revised analysis for this 

control option using a value of 40% for the wet kiln or an analysis of why 40% is not 

achievable (see NOx Control Technologies for the Cement Industry. Battye, R., S Walsh, J. 

Lee-Greco, EC/R Incorporated prepared for U.S. EPA under contract No. 68-D-98-026. 

September 19, 2000. Table 5-7). 

•	 The document states that details of the 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 of the cost analysis for 10w-NOx burners and mid-kiln injection. 

•	 Using the permitted NOx emission rat~ to determine tons ofNOx removed is problematic. 

The permitted value is very high relative to the actual emissions. The maximum NOx 

2 
emission rate during the three year period of 2001-2003 was reported as 784 lbs/hour. The 

permitted value is 1,568 lbslhour, or twice the maximum value reported for the three year 

period. Using the permitted value as the baseline could give a calculated post control 

emission rate larger than the actual uncontrolled emissions. For example proposing a 20% 

NOx reduction with a permit limitation of 1,254 Ibs/hour would allow an emission increase 

from the currently reported maximum hourly rate of 784 Ibs/hour. It is appropriate to use 

actual emissions if those are representative of how Holcim has been operating in the past. In 

addition, Holcim used actual emissions to model visibility for the BART analysis and the 

emissions used in the modeling and the rest of the analysis need to be consistent. Please 

revise the analysis using actual emissions. 

Particulate Matter Emissions and Controls 

•	 Holcim did not provide any design parameters for the existing PM control technologies on 

the ESP on the kiln and the baghouse on the clinker cooler. It is possible that BART for PM 

for these two sources could include additional controls and/or increased performance of the 

existing technologies. The BART Guidelines state that "For emission units subject to a 

BART review, there will often be control measures or devices already in place. For such 

emission units, 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 of control devices" (see 70 FR 39164, July 6,2005). We ask that 

Holcim submit the design parameter information for PM controls on the kiln and clinker 

cooler and evaluate the possibility of additional controls and increased performance of the 

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 of these demonstrated options would offer 

substantial emissions reductions at potentially reasonable costs (see Assessment ofNOx 

Emissions Reduction Strategies for Cement Kilns - Ellis County - Final Report. Prepared by 

ERG, Inc. for Texas Commission on Environmental Quality. TECQ Cntract No. 582-04­

65589, Work Order No. 05-06. July 14,2006 and A Unique Approach. Menke, T., Jepsen, 

O.L., and Keefe, B.P. Review No. 136. Reprint from IEEE-IASIPSCA 2001 Cement 

industry Technical Conference May 2001 and published in International Cement Review, 

July 2001). Please include an analysis that addresses a conversion from a wet kiln to a semidry or dry kiln. 

There are also several locations in ,the document that may have typographical errors. 

•	 On page 3-3 in Section 3.3 it states that the BART modeling analysis performed for 

Holcim used the permitted NOx 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 BART process, we ask that you submit the requested 

information and analysis to our office within thirty days from the date of this 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. If you have any questions, 

please contact Laurel Dygowski at (303) 312-6144. 

Sincerely, J /" 

. 

~~.~ --.-- A. Videtich, Director . 

Air and Radiation Program . 

4 *

Printed on Recycled Paper 
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 provide the following comments in 

regards to the BART Analysis submitted by Holcim Cement. 

•	 Hokim should be required to include fuel substitution as a viable option for S02 control. 

The Forest Service believes that their interpretation of Appendix Y is incorrect, and that 

they should consider switching to 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 emerging technology and thus not an available 

BART technology. The Forest Service disagrees and would like Ho1cim to redo its 

analysis assuming that SNCR is a viable technology. This is relevant considering other 

cement companies have agreed to install this technology in order to achieve BART. 

•	 The Forest Service is concerned that one of the technologically feasible options for NOx 

control presented by Holcim is mid-kiln injection oftires. Holcim submitted a pennit 

request to the Montana Department of Environmental 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 of tires, this should not be 

considered a technologically feasible option. 

•	 When assessing deciview improvements or costs perdeciview for improvements, 

Holcim should consider all Class I areas, not just Gates ofthe Mountains. 

Thank you for the opportunity to provide comments on this analysis. 

Sincerely, 

c*,M/hk-A·/11t1JJl;irV' 

/	 THOMAS L. TIDWELL .
 

Regional Forester
 

Caring for the Land and Serving People	 Printed on Recycled Paper