Phoenix Cement Company, a Division of the Salt River Pima-Maricopa Indian Community

March 6, 2013 Comments on Proposed SIP Disapproval – Arizona

ATTACHMENT 1

EPA’S OCTOBER 3 ANALYSIS
Technical Analysis for Arizona and Hawaii Regional 

Haze FIPs: Task 9: Five-Factor RP Analyses

Contract No: EP-D-07-102

Work Assignment: 5-12

Version: 1

Prepared for: Thomas Webb

Air Planning Office

U.S. EPA Region 9

75 Hawthorne Street

San Francisco, CA 94105

Prepared by: Uma Shankar, Elizabeth Adams, Mohammad Omary, 

Brian Naess and Saravanan Arunachalam

Institute for the Environment

University of North Carolina at Chapel Hill

Mark Lee, Juanita Haydel and Thomas Meyers

ICF International

Jim Staudt

Andover Technology Partners

Date delivered: October 3, 2012 
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Contents

Figures..................................................................................................................................... iii

Tables....................................................................................................................................... iv

Document Change Record ........................................................................................................v

1 Introduction........................................................................................................................1

2 Work Performed and Deliverable Summary ....................................................................1

2.1 General Considerations for Visibility Modeling ...........................................................2

2.2 Five-Factor Analyses...................................................................................................3

2.2.1 CalPortland Cement Rillito Plant Units 1 - 4....................................................4

2.2.2 Phoenix Cement Plant Unit 4.........................................................................10

2.3 Conclusions...............................................................................................................17

References................................................................................................................................18

Appendix A................................................................................................................................1

Emissions Data Tables .........................................................................................................1

Appendix B................................................................................................................................1

Andover Technology Partners Report Chapter 5: Reasonable Progress Analysis ..................1
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Figures

Figure 4. Kilns at the CalPortland Cement Rillito Plant ...............................................................4

Figure 5. Phoenix Cement Plant, Clarkdale, AZ ........................................................................11
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Tables

Table 1. CIAs Within 300 km of the Five RP Facilities. ..............................................................2

Table 26. CalPortland Kiln Data..................................................................................................4

Table 27. Estimated Emissions and Production Rates for CalPortland Cement Kilns 1-4.............4

Table 28(a). NOx Control Technologies for CalPortland Kilns 1-3 ..............................................6

Table 28(b). NOx Control Technologies for CalPortland Kiln 4...................................................6

Table 29. Base and Control Scenarios for NOx Used in CalPortland Units 1-4 RP Analyses........7

Table 30. Stack Parameters for CalPortland Units 1-4 .................................................................8

Table 31. 98th Percentile Visibility Impairment (∆-dv) for CalPortland Units 1-4 Base Case and 

Control Scenarios: (a) IMPROVE Method 6(a); (b) IMPROVE Method 8(b). .............................9

Table 32. Visibility Benefits (dv) for CalPortland Units 1-4 for the Control Scenarios 

Corresponding to Table 31. .........................................................................................................9

Table 33. Control Effectiveness (million $/dv) for the Calculation Methods of Table 31 ...........10

Table 34. Summary of Control Effectiveness for the Calculation Methods of Table 31..............10

Table 35. Phoenix Cement Kiln Data ........................................................................................11

Table 36. Estimated Emissions and Production Rates for Phoenix Cement Kilns 1-4.................11

Table 37. NOx Control Options for Phoenix Cement Kiln 4.......................................................13

Table 38. Base and Control Scenarios for NOx Used in Phoenix Cement Unit 4 RP Analyses ...14

Table 39. Stack Parameters for Phoenix Cement Kiln................................................................14

Table 40. 98th Percentile Visibility Impairment (∆-dv) for Phoenix Cement Base Case and 

Control Scenarios: (a) IMPROVE Method 6(a); (b) IMPROVE Method 8(b). ...........................15

Table 41. Visibility Benefits (dv) for Phoenix Cement Kiln 4 for the Control Scenarios 

Corresponding to Table 40 ........................................................................................................15

Table 42. Control Effectiveness (million $/dv) for the Calculation Methods of Table 40 ...........16

Table 43. Summary of Control Effectiveness for the Calculation Methods of Table 40..............16

Table A-4(a). NOx, SO2 and PM emission inputs for base and control scenarios for CalPortland 

Cement Units 1-3 and Unit 4 visibility modeling........................................................................2

Table A-4(b). Speciated PM emission inputs for base and control scenarios for CalPortland 

Cement Units 1-3 and Unit 4 visibility modeling........................................................................2

Table A-5(a). NOx, SO2 and PM emission inputs for base and control scenarios for Phoenix 

Cement Kiln 4 visibility modeling...............................................................................................3

Table A-5(b). Speciated PM emission inputs for base and control scenarios for Phoenix Cement 

Kiln 4 visibility modeling............................................................................................................3
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Document Change Record

Revision Date Remarks

0.1 October 3, 2012 Draft version submitted to EPA
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1 Introduction

This report describes the 5-factor analyses of all technically feasible NOx control options on the 

applicable units at the five facilities as listed below: 

• CalPortland Cement Rillito Plant Kilns 1-4

• Phoenix Cement Plant Kiln 4

The five factors considered in these analyses are as follows:

1. Cost of compliance;

2. Energy and non-air quality impacts of compliance;

3. Any existing pollution control technology in use at each source;

4. Remaining useful life of the source, and 

5. Degree of visibility improvement that may be reasonably expected from the use of 

emissions controls.

Andover Technology Partners (ATP) estimated the cost of compliance for these units using 

EPA Control Cost Manual (EPA, 2002), cost estimation methods based on the latest Integrated 

Planning Model [IPM]) documented online by EPA (2010), and other reasonable engineering 

approaches. The control options were analyzed not only for the feasibility of implementation 

but also the first four factors listed above to estimate the total cost per year of each control 

technology, and the cost of emission reductions in $/TPY for each.

Once all the feasible control options were identified, EPA reviewed and recommended control 

configurations on all applicable units to examine the visibility impacts of their emissions. UNC 

performed these impact assessments using the base configuration of existing controls as well as 

all EPA-approved control configurations for each BART facility at all Class I Areas (CIAs) 

within a 300-km radius through the use of dispersion modeling. Per EPA requirements these 

analyses used the following models and processors, and EPA-provided meteorological inputs 

available from a previous BART analysis done by ENSR (2009) using CALMET version 5.8:

• CALPUFF version 5.8 (v5.8) level 070623 puff dispersion model was used to estimate 

concentrations of visibility-impairing pollutants emitted by each facility at the relevant 

CIAs.

• The POSTUTIL utility version 1.56 was used to adjust these concentrations for the 

phase-partitioning of HNO3 between gas and particle based on additional input 

information.

• The adjusted concentrations were used in the CALPOST visibility post-processor 

version 6.221 (v6.221) to calculate the visibility impairment in deciview (dv) relative to 

the background visibility at each CIA. 

The change in deciview, or delta-dv, corresponding to the NOx emission reduction for each 

control option relative to the base configuration was used along with the yearly cost of control 

to estimate the control option cost effectiveness in $/dv at each CIA, as a maximum of all the 

CIAs, and as a total over all the CIAs. 

2 Work Performed and Deliverable Summary

In the five-factor analysis performed in this task ATP examined NOx control options and their 

costs for each of the five facilities considering the first four factors listed in Section 1. These 
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cost estimates have been used along with the visibility impact assessments performed by UNC 

for each facility to estimate the control option effectiveness in a combined metric specified by 

EPA, namely, $/dv. The overarching considerations for the visibility impact assessments, 

including the CIAs that are potentially affected by these facilities are provided in Section 2.1. 

The five-factor analyses for each plant are described in Section 2.2.

2.1 General Considerations for Visibility Modeling

In Task 4 of this WA we used GIS software to determine the nearest distances to the boundaries

of CIAs within a 300-km radius of the major emitting facilities in Arizona. The 19 CIAs and 

their nearest mean distances (as determined in the Task 4 screening) from the applicable

facilities identified for Reasonable Progress analysis are listed in Table 1. The domain 

description, Lambert Conformal grid specifications and meteorological inputs to CALPUFF 

required for this analysis are from CALMET v5.8 inputs and outputs provided by EPA from a 

BART analysis for 2001-2003 performed by ENSR Corporation for the Navajo Generating 

Station (ENSR, 2009).

Table 1. CIAs Within 300 km of the Five RP Facilities.

CIA Short 

Name State

Bandelier NM band NM

Bryce Canyon brca UT

Capitol Reef care UT

Chiricahua NM chir AZ

Chiricahua chrw AZ

Galiuro gali AZ

Gila gila NM

Grand Canyon grca AZ

Mazatzal maza AZ

Mesa Verde meve CO

Mount Baldy moba AZ

Petrified Forest pefo AZ

Pine Mountain pimo AZ

Saguaro sagu AZ

San Pedro Parks sape NM

Sierra Ancha sian AZ

Superstition supe AZ

Sycamore Canyon syca AZ

Zion zion UT

The CALPUFF model set-up for the five facilities followed the guidance of the modeling 

protocol that was initially delivered to EPA on March 19, 2012 as a Task 5 deliverable. This 

modeling protocol invokes almost all the model input settings provided in the WRAP BART 
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Subject Protocol provided in its Appendix A. Differences in model set-up from the 

recommendations of the WRAP protocol due to the CALPUFF version used, or other direction 

from the EPA are noted in this protocol. UNC verified and reconciled any discrepancies in the 

CALPUFF inputs through a series of test runs. Of note, CALPUFF modeling used a constant 

value of 1 ppb throughout for ammonia per EPA guidance. Further facility-specific details on

the visibility analysis performed under Task 9 are provided in Section 2.2.

2.2 Five-Factor Analyses

This section describes the control options analysis, followed by the details of the visibility 

modeling and the results of the five-factor analysis for each facility. The visibility modeling 

used combinations of control technologies (control “scenarios”) specified by the EPA with 

respect to the emissions inputs, which were also provided by the EPA with extensive source 

documentation. The costs of compliance and visibility impacts for each scenario were estimated 

based on the following assumptions:

• The costs and emission reductions (in tons reduced) for the individual technologies that 

make up each control configuration are additive, i.e., the control scenario costs and 

emission reductions can be expressed, respectively, as the sum of the component 

technology costs, and the sum of the associated emission reductions (in tons reduced). 

• The control efficiencies determined in the cost of control analyses are applicable to the 

baseline emission values used in the visibility modeling. 

• The baseline periods used vary by source and unit, in order to account for differences in 

dates of installation of controls. This approach reflects a more realistic assessment of 

“existing pollution control technology in use at each source” than using a uniform 

baseline for all units.

• The baseline emissions used in the CALPUFF modeling are not identical to those used 

in the control options analyses because the BART Guidelines on which these analyses 

are based provide different methods for calculating baseline emissions for these two 

purposes. 

• The baseline emission inputs for NOx for the electricity generating facilities use the 24-

hour average emission rate from the highest emitting day of a representative most 

recently available baseline period (excluding start-up, shutdown or malfunction). These 

data were extracted from the Clean Air Market Division (CAMD) Continuous Emission 

Monitoring System (CEMS) database. CEMS data are also used for the cement kilns, as 

indicated by the Emission Inventory submittals. 

• The baseline emission inputs for PM and SO2 for purposes of visibility modeling are 

derived from the hourly plant heat input (from the CAMD CEMS database) multiplied 

by emission limits specified in ADEQ’s BART determinations for these units.

• The control costs analyses use the annual average emission values in tons per year 

(TPY) based upon actual emissions from baseline periods that reflect future anticipated 

annual emissions.

Specifics of the emissions used and the visibility impacts of base case and control scenarios are 

discussed in the sections on visibility and control effectiveness analysis for each facility.
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2.2.1 CalPortland Cement Rillito Plant Units 1 - 4

Formerly known as Arizona Portland Cement, the CalPortland Cement Rillito Plant (Figure 4) 

has three long kilns and one precalciner kiln. The type and rated capacities are shown in 

Table 26. It is currently understood that these kilns have fabric filters, but have no SO2 or NOx

controls. It is understood that the three smaller kilns are not currently being operated and it is 

unclear if these three kilns will be operated in the future. However, all 4 kilns are being 

included in this RP analysis.

Figure 4. Kilns at the CalPortland Cement Rillito Plant

Table 26. CalPortland Kiln Data1

Year on Line Fuel Type Capacity, TPD Capacity, 1000 

TPY

1949 CGk Long DRY 408 121

1951 CGk Long DRY 408 121

1955 CGK Long DRY 408 121

2002 CGKA PreCaliner 3084 969

Fuels: C=Coal; G=Gas; K=Coke; A=Alternative

Facility emissions data developed by EPA for this facility are presented in Table 27. Annual 

emissions estimates and emission rates were determined by estimating a representative output 

(tons of clinker per year) from reported data and multiplying by representative emission rate in 

lb/ton. With regard to existing controls, kiln number 4 is new enough that it likely has some 

form of low NOx combustion controls, but it is unlikely that kilns 1-3 have any NOx controls

Table 27. Estimated Emissions and Production Rates for CalPortland Cement Kilns 1-4 

Kilns1-3 (each)* Kiln 4 Units Source

 1 Portland Cement Association, “US and Canadian Portland Cement Industry: Plant Information Summary”, 

December 31, 2006.
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NOx Rate 8.70 3.59 lb/ton clinker EPA6

TPY clinker 121,000 969,000 Ton/yr PCA5

TPY clinker 143,157 1,053,932 Ton/yr EPA6

TPY NOx 623 1,894 Ton/yr Calculated 

* Data for kilns 1-3 is per kiln, not total.

2.2.1.1 NOx Control Options Analysis

2.2.1.1.1 Available NOx Control Technologies

Available Technologies include MAT, LNB, mid-kiln firing, SNCR, and SCR, and 

combinations of these technologies. In addition, kiln 4, as a precalciner kiln, could implement 

low NOx combustion controls in the calciner. Thus low NOx calciner is another option for kiln 

4. The cost of a Low NOx Calciner (LNC) is expected to be in the same range as MAT 7.

2.2.1.1.2 Feasible NOx Control Technologies

All of the technologies cited above are feasible. mid-kiln firing provides similar levels of 

reduction as other combustion technologies such as MAT, but is more costly than MAT unless 

alternative fuels are available. Since information regarding the availability of alternative fuels 

(such as tires) was not available, mid-kiln firing was not evaluated. LNC is feasible for kiln 4. 

SCR, while available, has had very limited use on cement kilns and will not be evaluated 

further. For kiln 4, it is unclear if it currently has LNB with indirect firing. If it already has such 

controls, it could likely still achieve further NOx reductions through MAT or LNC.

2.2.1.1.3 Evaluation of Control Technologies

Tables 28(a) and 28(b) show estimated cost of controlling NOx from the CalPortland Cement 

Kilns. LNB is more expensive than MAT or LNC for kiln 4 and it would therefore be 

conservative to use that as the basis for 30% reduction, although MAT may be applicable at a 

lower cost. SNCR can be used to provide 50% NOx reduction whether used alone or in 

combination with combustion controls (assumed here to be LNB, although MAT may be 

applied at a lower cost). The cost and emissions information on Table 28(a) is per kiln.

 6 RP_Cement_modeling_runs - EPA 20120912.xlsx 7 Memo from J. Staudt to R. Srivastava, S. Vijay, E. Torres, Re: Costs and Performance of Controls – revised from 

comments, March 10, 2009 at page 14
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Table 28(a). NOx Control Technologies for CalPortland Kilns 1-3

(a)

Table 28(b). NOx Control Technologies for CalPortland Kiln 4

(b)

2.2.1.1.4 Energy and Environmental Impacts

All these technologies can have a modest impact. MAT can have a beneficial impact on CO and 

SO2 emissions. SNCR and SCR can result in ammonia slip, which is generally well controlled, 

and therefore not a major concern.

2.2.1.2 Visibility Modeling

The modeling included emission inputs from all four kilns. However, due to special 

requirements for capturing the output concentration files from CALPUFF for later sensitivity 

studies that may be done by EPA, the CALPUFF setup involved two streams of dispersion 

calculations. The calculation steps are described in Section 2.2.4.2.2. 

For Kilns 1-3, maximum 24-hr average baseline emissions needed for the visibility modeling 

are based on NOx and SO2 emission factors representing the highest values reported over 2005-

MAT LNB SNCR LNB and SNCR

capital $676,001 $2,708,493 $383,535 $3,092,028

Annualized Capital $63,810 $255,663 $36,203 $291,866

FOM (incl. admin, insu $102,045 $183,345 $90,347 $198,686

Reagent $115,120 $80,584

Total Cost, $/year $165,855 $439,008 $241,669 $571,136

Percent Reduced 30% 30% 50% 51%

tons reduced 187 187 312 318

$/ton reduced $887 $2,349 $776 $1,798

Incremental $/ton (compared to MAT) $608 $3,098

Incremental $/ton (compared to LNB) ($1,584) $1,010

lb/hr emission rate 111 111 79 77

MAT or LNC LNB SNCR LNB and SNCR

capital $1,188,275 $3,427,320 $1,336,373 $4,763,693

Annualized Capital $112,165 $323,515 $126,144 $449,659

FOM (incl. admin, insur, taxe $122,536 $212,098 $128,460 $265,553

Reagent $349,978 $244,985

Total Cost, $/year $234,701 $535,613 $604,583 $960,197

Percent Reduced 30% 30% 50% 51%

tons reduced 568 568 947 966

$/ton reduced $413 $943 $638 $994

Incremental $/ton (compared to MAT) $976 $1,824

Incremental $/ton (compared to LNB) $182 $1,067

lb/hr emission rate 336 336 240 235
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2007, which was the most recent 3-year period of continuous operation. Annual emissions 

needed for the control cost estimates on these units were based on the NOx and SO2 emission 

factors representing the average over the reported emission inventory (EI) values for 2005-2007.

For Kiln 4, the maximum 24-hr average emission inputs needed for the visibility modeling were 

taken from the WRAP BART modeling for this facility, and converted from g/s to TPY. The 

annual emission values used in the cost estimates for this unit are based on emission factors for 

NOx and SO2 that represent the average of values reported over the entire 2005-2010 period. 

Due to the installation of a baghouse (FF) on each kiln per a Consent Decree of January 11, 

2011, the filterable PM emission rate is limited to 0.008 gr/dscf. The EPA6 provided a 

conversion of this value into lb/hr and g/s using stack exit temperatures and flow rates. PM 

emission factors for Kiln 1-3 used the NPS spreadsheets for a dry cement kiln with FF, and for 

Unit 4, the spreadsheet for a precalciner with FF.

The emissions for the NOx control cases are specified below, and tabulated in Table 29; in the 

base and control scenarios, EPA specified that the emissions of Units 1-3 should be lumped 

together as one source due to identical stack parameters and control technology on each. 

• Ctrl2-1uses LNB or MAT controls (as both have the same control efficiency) on each of 

Units 1-3, and baseline emissions on Unit 4. 

• Ctrl2-2 uses SNCR controls on each of Units 1-3, and baseline emissions on Unit 4.

• Ctrl2-3 uses baseline emissions on Units 1-3, and LNB or MAT controls on Unit 4.

• Ctrl2-4 uses baseline emissions on Units 1-3, and SNCR control on Unit 4.

• Costs are shown separately in the last two columns of Table 29 for MAT and for LNB 

for Ctrl2-1 and Ctrl2-3; the control cost is repeated in these columns for Ctrl2-2 and 

Ctrl2-4 strictly for consistency, as the only control for these scenarios is SNCR.

Table 29. Base and Control Scenarios for NOx Used in CalPortland Units 1-4 RP Analyses

2.2.1.2.1 Stack Parameters

Stack parameters for CalPortland were taken from the facility’s Kiln 5 Class permit application, 

Appendix G, Table G3-1, and provided to us by EPA. They are listed in Table 30. 

 6 RP_Cement_modeling_runs - EPA 20120912.xlsx

Base 0 0 0 $0 $0

Ctrl2-1 LNB or MAT 561 0 561 $497,565 $1,317,024

Ctrl2-2 SNCR 936 0 936 $725,007 $725,007

Ctrl2-3 0 LNB or MAT 568 568 $234,701 $535,613

Ctrl2-4 0 SNCR 947 947 $604,583 $604,583

$/year if 

using MAT

Control Option $/year if 

using LNB

All Units

Control

Unit 4

D-Emis (TPY) D-Emis 

(TPY) Control

Units 1-3

D-Emis 

(TPY)
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Table 30. Stack Parameters for CalPortland Units 1-4

2.2.1.2.2 CALPUFF and POSTUTIL Inputs

The EPA specified emission requirements for the CALPUFF modeling. The emissions data are 

also documented in Appendix A, and in the supporting spreadsheet documentation for this 

report. We performed extensive QA of these inputs using customized Unix scripts to ensure 

compliance with the data on the spreadsheets provided by EPA6. 

Per EPA’s specification the emissions of Units 1-3 were combined in CALPUFF inputs as a 

single source. Also, as separate CALPUFF output concentration files were requested by EPA 

for the resulting two sources (Units 1-3 and Unit 4) we set up CALPUFF run directories for 

CalPortland in two streams, one for each source. The rest of the CALPUFF input preparation 

for the 2001-2003 modeling period followed the procedure used in the Task 7 and Task 8 

visibility analysis of six BART facilities under this WA. Discrete receptor data for the CIAs 

within the 300-km radius of the CalPortland plant were obtained from NPS. The two sets of 

CALPUFF outputs were combined first in POSTUTIL for each scenario, and the nitrate was 

repartitioned between gas and particle phases in a subsequent POSTUTIL run for each scenario.

2.2.1.2.3 CALPOST Setup

We followed the modeling protocol delivered with the Task 5 report in setting up the 

CALPOST inputs for each of the 12 CIAs within 300 km of the CalPortland Cement Rillito 

plant. Results are available for each of the years 2001-2003 and the composite period 2001-

2003 using four visibility methods. They are reported here for Method 6(a) and Method 8(b) for 

the composite period. Due to the large number of post-processing runs required, we used 

customized scripts to extensively QA the CALPOST inputs.

2.2.1.2.4 Extraction of Visibility Results with POSTCALPOST

Table 31 summarizes the results for the 98th percentile visibility impairment due to CalPortland 

within the composite three-year period from 2000-2003 at all the affected CIAs for the base 

case and control options. Table 32 summarizes the visibility benefits for the control scenarios.

 6 RP_Cement_modeling_runs - EPA 20120912.xlsx

Unit # LON LAT

deg deg ft m ft m ft m F K ft/s m/s

Unit 1-3 -111.14965 32.40767 75.0 22.86 2060.0 627.89 10.0 3.05 425.00 491.48 52.70 16.06

Unit 4 -111.14977 32.40760 75.0 39.62 2060.0 627.89 16.0 4.88 399.99 477.59 47.83 14.58

Stack Height Stack Elevation Stack Diameter Stack Temperature Exit Velocity
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Table 31. 98th Percentile Visibility Impairment (∆-dv) for CalPortland Units 1-4 Base Case and 

Control Scenarios: (a) IMPROVE Method 6(a); (b) IMPROVE Method 8(b).

(a) (b)

Table 32. Visibility Benefits (dv) for CalPortland Units 1-4 for the Control Scenarios

Corresponding to Table 31.

(a) (b)

Table 31 shows the greatest impairment due to CalPortland at Saguaro for both visibility 

methods. The differences in impairment when applying the same control technology on Units 1-

3 vs. Unit 4 are slight, and the impairment is greater in the case of controls on Unit 4 than on 

Units 1-3.

Table 32 shows the greatest visibility benefits, as expected, at the most significantly impaired 

CIAs, namely, sagu, gila and gali, with the controls on Units 1-3 providing greater visibility 

benefits than on Unit 4 using the same technology.

2.2.1.3 Control Effectiveness Results

The results of the control effectiveness in $/dv (millions) for CalPortland are presented in 

Tables 33 and 34. Table 34 presents the control effectiveness at each CIA, and Table 34 

summarizes the results for the CIA with the maximum deciview impact, and for deciview 

impact summed over all CIAs.
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Table 33. Control Effectiveness (million $/dv) for the Calculation Methods of Table 31

(a) (b)

Table 33 and 34 separately report the control effectiveness between MAT and LNB controls due 

to their difference in cost. They show that the greatest effectiveness is for MAT on Unit 4, 

followed by SNCR on Unit 4. Table 33 shows that the control effectiveness for MAT is the 

greatest at the most significantly impaired CIAs nearby (sagu, gila and gali) and much less at 

the CIAs farther away such as pefo and Sierra Ancha (sian); LNB on Units 1-3 is the least 

effective. Method 8(b) is more effective than Method 6(a) due to its greater visibility benefits.

Table 34. Summary of Control Effectiveness for the Calculation Methods of Table 31

(a)

(b)

2.2.2 Phoenix Cement Plant Unit 4

At Phoenix Cement, one new precalciner kiln replaced older kilns and is the only kiln in 

operation at this site. The facility as seen in Google Maps is shown in Figure 5. Data from the 

Portland Cement Association 8 on kiln capacity and characteristics are shown in Table 35.
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Figure 5. Phoenix Cement Plant, Clarkdale, AZ

Table 35. Phoenix Cement Kiln Data5

Year on Line Fuel Type Capacity, TPD Capacity, 1000 

TPY

2002 CK PreCaliner 2721 912

Fuels: C=Coal; G=Gas; K=Coke; A=Alternative

The reported emissions and kiln data are shown in Table 36. Annual emissions and emission 

rates were estimated using a representative output (tons of clinker per year) from reported data 

and multiplying by representative emission rate in lb/ton.

Existing controls likely include some form of combustion controls since the kiln is only ten 

years old, but it is unclear at this time if LNB with indirect firing is currently utilized at the kiln.

Table 36. Estimated Emissions and Production Rates for Phoenix Cement Kilns 1-4

Kiln 4 Units Source

NOx Rate 3.25 lb/ton clinker EPA 2

TPY clinker 888,680 Ton/yr PCA 5

TPY clinker 996,265 Ton/yr EPA 6

TPY NOx 1,620 Ton/yr Calculated 

 8 Portland Cement Association, “US and Canadian Portland Cement Industry: Plant Information Summary”, 

December 31, 2006. 2 US EPA, RP_Cement_modeling_runs - EPA 20120912.xls 5 Portland Cement Association, “US and Canadian Portland Cement Industry: Plant Information Summary”, 

December 31, 2006.
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2.2.2.1 NOx Control Options Analysis

2.2.2.1.1 Available NOx Control Technologies

Available technologies include MAT, LNB, Mid-Kiln firing, LNC, SNCR, and SCR, and 

combinations of these technologies.

2.2.2.1.2 Feasible NOx Control Technologies

All of these technologies are feasible except possibly LNB, if it is already deployed. Mid-kiln 

firing provides similar levels of reduction as other technologies such as MAT but is more costly 

than MAT unless alternative fuels are available, which can make mid-kiln firing very attractive. 

Since information regarding the availability of alternative fuels (such as tires) was not available, 

mid kiln firing was not evaluated. SCR, while available, has had very limited experience on 

cement kilns and a more comprehensive technical review should be performed prior to using 

this approach. It is unclear if the kiln currently has LNB with indirect firing. If it already has 

such controls, it could likely still achieve further NOx reductions through MAT or LNC.

2.2.2.1.3 Evaluation of Control Technologies

Table 37 provides NOx control technologies and cost estimates for Phoenix Cement Kiln 4. 

Information on the type of NOx control technologies currently deployed on this kiln was not 

available. It is likely that the kiln uses some form of low-NOx technology, although it is unclear 

what form is used.. Shown in this table are MAT or LNC, LNB, SNCR alone (50% reduction) 

and LNB plus SNCR. MAT or LNC and LNB are both shown to provide 30% NOx reduction, 

although for cost estimations LNB is more conservative. For 50% NOx reduction, both SNCR 

and SNCR in combination with combustion controls (in this case LNB, with MAT or LNC as a 

less expensive alternative) are shown. SNCR is by itself expected to be capable of 50% NOx 

reduction; therefore in combination with combustion controls it should certainly be capable of 

that level of reduction (given a 30% reduction from combustion controls and an additional 30% 

from SNCR). Thus a more conservative control cost estimate for 50% reduction would result 

from LNB in combination with SNCR.
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 13 October 3, 2012

Table 37. NOx Control Options for Phoenix Cement Kiln 4

Item MAT or LNC LNB SNCR LNB and SNCR

capital $1,155,839 $3,300,783 $1,268,764 $4,569,547

Annualized Capital $109,103 $311,571 $119,762 $431,333

FOM $121,239 $207,037 $125,756 $257,787

Reagent $299,348 $209,543

Total Cost, $/year $230,342 $518,607 $544,866 $898,663

Percent Reduced 30% 30% 50% 51%

tons reduced 486 486 810 826

$/ton reduced $474 $1,067 $673 $1,088

Incremental $/ton (compared to 

MAT) $971 $1,964

Incremental $/ton (compared to LNB) $81 $1,117

lb/hr emission rate 288 288 205 201

2.2.2.1.4 Energy and Environmental Impacts

Each of the evaluated control measures has a modest energy impact. MAT can have a beneficial 

impact on CO and SO2 emissions. SNCR and SCR can result in ammonia slip, which is 

generally well controlled.

2.2.2.2 Visibility Modeling

The visibility modeling considered the single kiln that is being evaluated for NOx controls at 

Phoenix Cement Plant. The NOx and SO2 emission rates for this plant for the maximum 24-hour 

average were based on the highest value from the entire 2005-2010 period of available data 

from the facility’s EI submittals. Annual emissions needed for the cost estimates were also 

based on emission factors representing the average over this entire period. However the average 

clinker production rate used in converting these emission factors to annual emission rates for

SO2and NOx excluded the lower production rates from 2008-2010 as not being representative of 

future operations. 

PM emission rates were calculated by the EPA using the PM emission factors averaged over the 

EI values for the years 2005-2010, and the flow rate and stack parameters from the facility EI 

submittals. PM speciation used the NPS spreadsheet for a precalciner with FF. 

The emissions for the NOx control cases are specified as follows, and tabulated in Table 38; in 

the base and control scenarios:

• Ctrl-1 uses LNB or MAT on Kiln 4 (they both have 30% control efficiency).

• Ctrl-2 uses SNCR on Kiln 4. 

• Costs are shown separately in the last two columns of Table 38 for MAT and for LNB 

for Ctrl-1; the control cost is repeated in these columns for Ctrl2 strictly for consistency, 

as the only control for this case is SNCR.
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 14 October 3, 2012

Table 38. Base and Control Scenarios for NOx Used in Phoenix Cement Unit 4 RP Analyses

2.2.2.2.1 Stack Parameters

Stack parameters for Phoenix Cement were provided by EPA from the Title V permit 

application Permit No. 35426, submitted June 29, 2006. They are shown in Table 39.

Table 39. Stack Parameters for Phoenix Cement Kiln

2.2.2.2.2 CALPUFF Emissions Inputs

The EPA specified emission requirements for the CALPUFF modeling. The emissions data are 

also documented in Appendix A, and in the supporting spreadsheet documentation for this 

report. We performed extensive QA of these inputs using customized Unix scripts to ensure 

compliance with the data on the spreadsheets provided by EPA6. 

2.2.2.2.3 CALPOST Setup

We followed the modeling protocol delivered with the Task 5 report in setting up the 

CALPOST inputs for each of the 12 CIAs within 300 km of the Phoenix Cement Plant. Results 

are available for each of the years 2001-2003 and the composite period 2001-2003 using four 

visibility methods. They are reported here for Method 6(a) and Method 8(b) for the composite 

period. We used customized scripts to extensively QA the CALPOST inputs.

2.2.2.2.4 Extraction of Visibility Results with POSTCALPOST

Table 40 summarizes the results for the 98th percentile visibility impairment due to Phoenix 

Cement within the composite three-year period from 2000-2003 at all the affected CIAs for the 

base case and control options. Table 41 summarizes the visibility benefits for the control 

scenarios.

 6 US EPA, RP_Cement_modeling_runs - EPA 20120912.xls

Control D-Emis (TPY) if using MAT if using LNB

Base 0 $0 $0

Ctrl-1 LNB or MAT 486 $230,342 $518,607

Ctrl-2 SNCR 810 $544,866 $544,866

Control Option

Unit 4 $/year

Unit # LON LAT

deg deg ft m ft m ft m F K ft/s m/s

Kiln 4 -112.08302 34.77763 213.25 65.0 3816.57 1163.29 9.09 2.77 211.73 373.0 66.6 20.3

Stack Height Stack Elevation Stack Diameter Stack Temperature Exit Velocity
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 15 October 3, 2012

Table 40. 98th Percentile Visibility Impairment (∆-dv) for Phoenix Cement Base Case and 

Control Scenarios: (a) IMPROVE Method 6(a); (b) IMPROVE Method 8(b).

(a) (b)

Table 40 shows the greatest visibility impairment due to Phoenix Cement at Sycamore Canyon 

for all scenarios and both methods. The impairment is greater for Method 8(b) than for Method 

6(a). SNCR controls provide the greatest benefit of all technologies, as confirmed by the results 

in Table 41.

Table 41. Visibility Benefits (dv) for Phoenix Cement Kiln 4 for the Control Scenarios 

Corresponding to Table 40

(a) (b
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 16 October 3, 2012

2.2.2.3 Control Effectiveness Results

The results of the control effectiveness in $/dv (millions) for Phoenix Cement are presented in 

Tables 42 and 43. Table 42 presents the control effectiveness at each CIA, and Table 43

summarizes the results for the CIA with the maximum deciview impact, and for the deciview 

impact summed over all CIAs.

Table 42. Control Effectiveness (million $/dv) for the Calculation Methods of Table 40

(a) (b)

Table 43. Summary of Control Effectiveness for the Calculation Methods of Table 40

(a)

(b)

Tables 42 and 43 separately present the control effectiveness for MAT and LNB due to their 

difference in cost. They show that the greatest effectiveness is for MAT, followed by SNCR. 

Table 42 shows that the control effectiveness for MAT is the greatest, i.e., has lowest $/dv 

values at the most significantly impaired CIAs (Sycamore Canyon) and much less at the farther 

CIAs such as sagu and sian. LNB is found to be the least effective control technology due to its 
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 17 October 3, 2012

relatively high cost. Method 8(b) is found to be more effective than Method 6(a) due to its 

greater visibility benefits.

2.3 Conclusions

The five-factor BART analysis of the five facilities that we analyzed led to the following 

conclusions:

• The visibility impacts are greatest for each facility at the nearest CIAs, and the control 

options are least effective (greatest in million $/dv) at the farthest ones. The CIAs which 

experience the greatest visibility impacts and show the greatest benefits are listed below

for the respective facilities; the number of CIAs with impairment > 0.5 dv due to that 

facility, averaged over all scenarios, is listed in parentheses

o for CalPortland, Saguaro; Gila in the case of controls on Kilns 1-3 using Method 

8(b) (3 of 12), and

o for Phoenix Cement, Sycamore Canyon (2 of 12)

• Tables 9, 17, 25, 34, and 43 summarize the aggregated results for each facility as a sum 

over all the relevant CIAs of the $/dv (in millions) for each control option for Method 

6(a) and Method 8(b). In general, the control effectiveness increases for

o the nearest CIAs

o SNCR control compared to LNB and SCR

o MAT control compared to LNB and SNCR
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 18 October 3, 2012

References

EPA, 2010: Documentation of EPA’s IPM Base Case v4.10, U.S. Environmental Protection 

Agency. http://www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev410.html#documentation

EPA, 2002: EPA Air Pollution Control Cost Manual (Sixth Edition), Report No. EPA/452/B02-001, U.S. Environmental Protection Agency. 

ENSR, 2009: Revised BART Analysis for the Navajo Generating Station Units 1-3, ENSR 

Corporation, Document No. 05830-012-300, January 2009, Salt River Project – Navajo 

Generating Station, Tempe, AZ.

Staudt, J., and C. Erickson, 2008: Selective Catalytic Reduction System Performance and 

Reliability Review. Presented at the 2008 International Power Generation Conference, 

December 2-4, 2008, Orlando, FL.

Western Regional Air Partnership (WRAP), 2006: CALMET/CALPUFF Protocol for BART 

Exemption Screening Analysis for Class I Areas in the Western United States. Western 

Regional Air Partnership Air Quality Modeling Forum, Regional Modeling Center, August 

15, 2006; 

http://pah.cert.ucr.edu/aqm/308/bart/WRAP_RMC_BART_Protocol_Aug15_2006.pdf
Appendix A 

Emissions Data Tables
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 A-2 October 3, 2012

This appendix provides the emissions data for CALPUFF modeling of the base case(s) and control scenarios analyzed for the three 

EGU facilities. These data were extracted from a master spreadsheet that is being delivered as part of the documentation for this task. 

Table A-4(a). NOx, SO2 and PM emission inputs for base and control scenarios for CalPortland Cement

Units 1-3 and Unit 4 visibility modeling 

Table A-4(b). Speciated PM emission inputs for base and control scenarios for CalPortland Cement 

Units 1-3 and Unit 4 visibility modeling 
EMAQ LOE (EPA Contract EP-D-07-102) WA 5-12: Task 9 Five-Factor Analyses for RP Facilities

UNC-EMAQ 5-12-025.v1 A-3 October 3, 2012

Table A-5(a). NOx, SO2 and PM emission inputs for base and control scenarios for Phoenix Cement Kiln 4 visibility modeling 

Table A-5(b). Speciated PM emission inputs for base and control scenarios for Phoenix Cement Kiln 4 visibility modeling 
Appendix B

Andover Technology Partners Report Chapter 5:

Reasonable Progress Analysis
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

5. Reasonable Progress Analysis

Task 9: Conduct Reasonable Progress Analysis for Four Class I Areas

Under this task, Andover Technology Partners conducted a four-factor analysis of sources to 

identify whether there are additional reasonable NOx controls available. 

Cost estimates performed in this section utilize methods consistent with the US EPA Control 

Cost Manual,3 cost estimating methods used in EPA’s latest Integrated Planning Model (IPM) 

methods4

, and other reasonable engineering methods and are described in greater detail in 

associated spreadsheets provided with this document.

 3 EPA. 2002. EPA Air Pollution Control Cost Manual (Sixth Edition). EPA/452/B-02-001 4 Documentation of EPA IPM Base Case v4.10. http://www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev410.html#documentation
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

5.1 Arizona Portland Cement Company, Rillito, AZ 

This facility, shown in Figure 5-1 has three long dry kilns and one precalciner kiln. The type 

and rated capacities are shown in Table 5-1. It is currently understood that these kilns have 

fabric filters, but have no SO2 or NOx controls. It is understood that the three smaller kilns are 

not currently being operated and it is unclear if these three kilns will be operated in the future.

Figure 5-1. Arizona Portland Cement Company, Rillito Plant.

Table 5-1. Kilns at the Arizona Portland Cement Plant 5

Year on Line Fuel Type Capacity, TPD Capacity, 1000 TPY

1949 CGk Long DRY 408 121

1951 CGk Long DRY 408 121

1955 CGK Long DRY 408 121

2002 CGKA PreCaliner 3084 969

Fuels: C=Coal; G=Gas; K=Coke; A=Alternative

Facility emissions data was developed by EPA, and this is shown in Table 5-2. Annual 

emissions estimates and emission rates were determined by estimating a representative output 

(tons of clinker per year) from reported data and multiplying by representative emission rate in 

lb/ton.

With regard to existing controls, kiln number 4 is new enough that it likely has some form of low 

NOx combustion controls, but it is unlikely that kilns 1-3 have any NOx controls.

 5 Portland Cement Association, “US and Canadian Portland Cement Industry: Plant Information Summary”, 

December 31, 2006.
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

Table 5-2. Estimated emissions and production rates for Arizona Portland Cement Kilns 

1-4

Kilns 1-3

(each)* Kiln 4

Source

NOx Rate 8.70 3.59 lb/ton clinker EPA 6

TPY clinker 121,000 969,000 Ton/yr PCA 5

TPY clinker 143,157 1,053,932 Ton/yr EPA 6

TPY NOx 623 1,894 Ton/yr Calculated 

* Data for kilns 1-3 is per kiln, not total.

5.1.1 NOx Controls

Available Technologies

Available Technologies include MAT, LNB, Mid Kiln firing, SNCR, and SCR, and combinations 

of these technologies. In addition, kiln 4, as a calciner kiln, could implement low NOx 

combustion controls in the calciner. So, low NOx calciner is another option for kiln 4. The cost 

of a low NOx calciner (LNC) is expected to be in the same range as MAT.7

Feasible Technologies

All of these technologies are feasible. Mid Kiln firing provides similar levels of reduction as 

other combustion technologies such as MAT but is more costly than MAT unless alternative 

fuels are available. Since information regarding the availability of alternative fuels (such as 

tires) was not available, Mid Kiln Firing was not evaluated. LNC is feasible for kiln 4. SCR, 

while available, has very limited experience on cement kilns and will not be evaluated further. 

For kiln 4, it is unclear if it currently has LNB with indirect firing If it already has such controls, it 

could likely still achieve further NOx reductions through implementation of MAT or LNC.

Evaluation of Technologies

Tables 5-3a and 5-3b show estimated cost of controlling NOx from the Arizona Portland Cement 

Kilns. LNB is more expensive than MAT or LNC (for kiln 4) and it would be conservative to use 

that as the basis for 30% reduction, although MAT may actually be applicable at a lower cost. 

SNCR can be used to provide 50% NOx reduction whether used alone or in combination with 

combustion controls (assumed here to be LNB, although MAT may be applied at a lower cost). 

The cost and emissions informaton on Table 5-3a is per kiln, not total for the three kilns.

 6 US EPA, RP_Cement_modeling_runs - EPA 20120912.xls 7 Memo from J. Staudt to R. Srivastava, S. Vijay, E. Torres, Re: Costs and Performance of Controls – revised from 

comments, March 10, 2009 at page 14
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

Energy and Environmental Impacts of NOx Control Measures

Each of these measures has a modest energy impact. MAT can have a beneficial impact on 

CO and SO2 emissions. SNCR and SCR can result in ammonia slip, which is generally well 

controlled.

Table 5-3a. NOx Controls for Kilns 1-3 (values shown are per kiln)

MAT LNB SNCR LNB and SNCR

capital $676,001 $2,708,493 $383,535 $3,092,028

Annualized Capital $63,809.67 $255,663 $36,203 $291,866

FOM (incl. admin, insur, 

taxes) $102,045 $183,345 $90,347 $198,686

Reagent $115,120 $80,584

Total Cost, $/year $165,855 $439,008 $241,669 $571,136

Percent Reduced 30% 30% 50% 51%

tons reduced 187 187 312 318

$/ton reduced $887 $2,349 $776 $1,798

Incremental $/ton 

(compared to MAT) $608 $3,098

Incremental $/ton 

(compared to LNB) -$1,584 $1,010

lb/hr emission rate 111 111 79 77

Table 5-3b. NOx Controls for Kiln 4

MAT or LNC LNB SNCR LNB and SNCR

capital $1,188,275 $3,427,320 $1,336,373 $4,763,693

Annualized Capital $112,165 $323,515 $126,144 $449,659

FOM (incl. admin, insur, 

taxes) $122,536 $212,098 $128,460 $265,553

Reagent $349,978 $244,985

Total Cost, $/year $234,701 $535,613 $604,583 $960,197

Percent Reduced 30% 30% 50% 51%

tons reduced 568 568 947 966

$/ton reduced $413 $943 $638 $994

Incremental $/ton 

(compared to MAT) $976 $1,824

Incremental $/ton 

(compared to LNB) $182 $1,067

lb/hr emission rate 336 336 240 235
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

5.2. Phoenix Cement, Clarkdale, AZ

At Phoenix Cement, one new kiln replaced older kilns, so that only one precalciner kiln remains 

in operation at this site. The Phoenix Cement facility is shown in Figure 5-2 and data from the 

Portland Cement Association on kiln capacity and characteristics are shown in Table 5-4

Figure 5-2. Phoenix Cement, Clarkdale, AZ

Table 5-4 Phoenix Cement Plant Kiln 8

Year on Line Fuel Type Capacity, TPD Capacity, 1000 TPY

2002 CK PreCaliner 2721 912

Fuels: C=Coal; G=Gas; K=Coke; A=Alternative

The reported emissions and kiln data are shown in Table 5-5. Annual emissions estimates and 

emission rates were determined by estimating a representative output (tons of clinker per year) 

from reported data and multiplying by representative emission rate in lb/ton.

Existing controls likely include some form of combustion controls since the kiln is only ten years 

old, but it is unclear at this time if LNB with indirect firing is currently utilized at the kiln.

 8 Portland Cement Association, “US and Canadian Portland Cement Industry: Plant Information Summary”, 

December 31, 2006.
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

Table 5-5. Estimated Uncontrolled Emissions Rates

NOx Rate 3.25 lb/ton clinker EPA 9

TPY clinker 888,680 Ton/yr PCA 8

TPY clinker 996,265 Ton/yr EPA 2

TPY NOx 1,620 Ton/yr Calculated 

5.2.1 NOx Controls

Available Technologies

Available Technologies include MAT, LNB, Mid Kiln firing, low NOx Calciner (LNC), SNCR, and 

SCR, and combinations of these technologies.

Feasible Technologies

All of these technologies are feasible except possibly LNB if it is already deployed. Mid Kiln 

firing provides similar levels of reduction as other technologies such as MAT but is more costly 

than MAT unless alternative fuels are available, which can make mid kiln firing very attractive. 

Since information regarding the availability of alternative fuels (such as tires) was not available, 

Mid Kiln Firing was not evaluated. SCR, while available, has limited experience on cement kilns 

and a more comprehensive technical review should be performed prior to utilizing this approach.

It is unclear if the kiln currently has LNB with indirect firing If it already has such controls, it 

could likely still achieve further NOx reductions through implementation of MAT or LNC.

Evaluation of Technologies

Information on the type of NOx control technologies currently deployed on this kiln was not 

available. It is likely that the kiln utilizes some form of low NOx technology, although it is 

unclear what form is used.. Table 5-6 shows estimated cost of controlling NOx from the 

Phoenix Cement kiln. Shown here are MAT or LNC, LNB, SNCR alone (50% reduction) and 

LNB plus SNCR. MAT or LNC and LNB are both shown for 30% reduction, although for cost 

estimating LNB should be used since it is more conservative. For 50% NOx reduction, both 

SNCR and SNCR in combination with combustion controls (in this case LNB, but MAT or LNC 

are possible alternatives that would be less expensive) are shown. Although SNCR is generally 

expected to be capable of 50% NOx reduction alone, in combination with combustion controls it 

would certainly be capable of 50% NOx reduction (30% reduction from combustion controls plus 

an additional 30% from SNCR). Therefore, a more conservative estimate of control costs for 

50% reduction would result from the combination of LNB with SNCR.

 9 US EPA, RP_Cement_modeling_runs - EPA 20120912.xls
UNC-EMAQ 5-12.025.v1 B-1 October 3, 2012

Energy and Environmental Impacts of NOx Control Measures

Each of these measures has a modest energy impact. MAT can have a beneficial impact on 

CO and SO2 emissions. SNCR and SCR can result in ammonia slip, which is generally well 

controlled. Table 5-6 shows the results of a cost analysis for Phoenix cement.

Table 5-6. NOx Control options for Phoenix Cement

MAT or LNC LNB SNCR LNB and SNCR

capital $1,155,839 $3,300,783 $1,268,764 $4,569,547

Annualized Capital $109,103 $311,571 $119,762 $431,333

FOM $121,239 $207,037 $125,756 $257,787

Reagent $299,348 $209,543

Total Cost, $/year $230,342 $518,607 $544,866 $898,663

Percent Reduced 30% 30% 50% 51%

tons reduced 486 486 810 826

$/ton reduced $474 $1,067 $673 $1,088

Incremental $/ton 

(compared to MAT) $971 $1,964

Incremental $/ton 

(compared to LNB) $81 $1,117

lb/hr emission rate 288 288 205 201

 
Phoenix Cement Company, a Division of the Salt River Pima-Maricopa Indian Community

March 6, 2013 Comments on Proposed SIP Disapproval – Arizona

ATTACHMENT 2

Emails from EPA to PCC
From: <McKaughan.Colleen@epamail.epa.gov>

Date: December 14, 2012, 4:19:48 PM MST

To: "Martz, Verle" <vmartz@srmaterials.com>

Cc: <Nudd.Gregory@epamail.epa.gov>, <Webb.Thomas@epamail.epa.gov>, 

<Withey.Charlotte@epamail.epa.gov>, <Chen.Eugene@epamail.epa.gov>, 

<Kelly.Shaheerah@epamail.epa.gov>

Subject: Responses to Questions on EPA Process for Phoenix Cement

Hi, Verle, 

You had asked us some questions in an email dated 11/28/12. I have highlighted 

those questions and provided the responses below. 

(1) if the questions were asked pursuant to a particular statute or regulation; (2) 

what the EPA intends to do with our answers; and (3) if the EPA is getting ready 

to propose that the Clarkdale facility is a BART-eligible source. 

1) We are asking these questions in the context of our action on the 2018 

visibility goals for the Arizona Regional Haze program. As we state in Section 

VIII.B. of the proposed action, because Arizona’s 2018 visibility goals provide for 

a rate of improvement in visibility slower than the rate needed to show attainment 

of natural conditions by 2064, the Regional Haze Rule requires the state (or EPA 

in the case of a Federal plan) to demonstrate why its Reasonable Progress 

Goals are reasonable and why a rate of progress leading to attainment of natural 

visibility conditions by 2064 is not reasonable. [See 40 CFR 51.308(d)(1)(ii).] 

2) Given the rate at which visibility-impairing pollutants are emitted from the 

Phoenix Cement plant, and it's proximity to Class I areas, EPA is trying to 

determine if there are reasonably cost-effective controls that can be installed at 

the facility. Your information will help us to make an accurate estimate of the 

costs and benefits of additional controls at Phoenix Cement. 

3) We are not planning to propose that the Clarkdale faciilty is a BART-eligible 

source. 

I hope this information is helpful. I am going to be out of the office over the 

holidays. If you need information during that time, please contact Greg Nudd at 

415-947-4107; nudd.gregory@epa.gov. 

Colleen W. McKaughan 

Associate Director, Air Division 

USEPA, Region 9 

(520) 498-0118
* * * * *

From: McKaughan.Colleen@epamail.epa.gov 

[mailto:McKaughan.Colleen@epamail.epa.gov] 

Sent: Sunday, December 09, 2012 07:27 PM

To: "Enos, Diane (President)" Diane.Enos@SRPMIC-nsn.gov; Martz, Verle

Cc: Webb.Thomas@epamail.epa.gov; Nudd.Gregory@epamail.epa.gov; 

Ebbert.Laura@epamail.epa.gov

Subject: Proposed partial approval and partial disapproval of Arizona's regional 

haze plan

Good evening, President Enos and Mr. Martz,

Thank you for the opportunity to talk on Friday. The notice of proposed 

rulemaking for the remainder of the Arizona Regional Haze Plan (Phase 2) was 

signed late Friday evening, Dec. 7th. In this notice EPA is stating what we 

propose to approve and disapprove in the State's Regional Haze Plan. EPA is 

not proposing any federal measures at this time. However, we do have a consent 

decree deadline of March 8, 2023 to propose federal measures for those parts of 

the plan for which we proposed disapproval.

I am sharing a pre-publication copy of our Phase 2 action with you, so that you 

may take full advantage of the public comment period on the proposal. We have 

also sent a copy of the notice to ADEQ. I will be in touch with Mr. Martz regarding 

some questions he asked about the information that we have shared with him. If 

you have additional questions, or want to have another call about our action, 

please call me at the number below. I am available all week.

Colleen W. McKaughan

Associate Director, Air Division

USEPA, Region 9

(520) 498-0118

* * * * *

From: McKaughan.Colleen@epamail.epa.gov 

[mailto:McKaughan.Colleen@epamail.epa.gov] 

Sent: Thursday, December 06, 2012 10:35 AM

To: Martz, Verle

Cc: Lindsay, Brett; Nudd.Gregory@epamail.epa.gov; Kuehner, Pete; Smith, 

Roger; Webb.Thomas@epamail.epa.gov
Subject: Re: EPA Information for Salt River Materials Group_RE: FW: 2012 

Phoenix Cement Plant ENERGY STAR Certification

Hi, Verle, 

I'm sorry for my delayed response. As you can imagine, we are working hard to 

meet our December 7th consent decree deadline where we will proposing 

approval of some parts of the State's Regional Haze SIP and disapproving other 

parts. I will call you upon signature and send you a pre-publication copy of the 

Federal Register notice so you have that information right away. We will also be 

sharing this information with the Salt River Pima Maricopa Tribe, and arranging 

for formal consultation. 

We are not looking at Phoenix Cement as a BART source, but rather a source 

that should be looked at under the reasonable progress requirement. EPA's 

responsibility at this time is to evaluate the Arizona Regional Haze SIP against 

the Regional Haze requirements in both the Clean Air Act and the Regional Haze 

Rule. These include three major elements: BART, Reasonable Progress Goals 

for the 12 Class I areas, and Arizona's Long Term Strategy. 

We would be glad to talk to you whenever you are ready to do so. ADEQ has 

indicated a desire to talk to us early next week and we will be setting up that 

meeting. Please give me a call at the number below if you have additional 

questions. 

Colleen W. McKaughan 

Associate Director, Air Division 

USEPA, Region 9 

(520) 498-0118

* * * * *

From: McKaughan.Colleen@epamail.epa.gov 

[mailto:McKaughan.Colleen@epamail.epa.gov] 

Sent: Tuesday, November 06, 2012 4:34 PM

To: Martz, Verle

Cc: Nudd.Gregory@epamail.epa.gov; Kelly.Shaheerah@epamail.epa.gov

Subject: EPA Information for Salt River Materials Group 

Hi, Verle,

Here is the information that I promised - a summary sheet of information for the 

two cement plants, plus our contractor report. Our staff engineers are in the 
process of reviewing this material now, so if you notice any errors in the 

documents, we would be interested in that information. We wanted to give you an 

opportunity to look at the materials, and then we would like to schedule a 

conference call with you at your convenience to go over any questions that you 

might have.

We also have some questions (below) that would help our understanding of your 

facility. 

Regarding next steps, we have to propose action on the Arizona Regional Haze 

Plan by December 8, 2012. If we disapprove any portions of the plan we will 

have to propose federal measures. Our deadline to propose federal measures is 

March 8, 2013. If the Salt River Materials Group would like to submit information 

to EPA for our consideration, we would like to receive that information no later 

than the first week of January, 2013.

I am going to Navajo tomorrow, but I'm back on Thursday. If you have questions 

in the meantime, Greg Nudd is the project lead. Greg can be reached at 415-

947-4107. Thank you for your cooperation on these issues.

Colleen W. McKaughan

Associate Director, Air Division

USEPA, Region 9

(520) 498-0118

Phoenix Cement Company

1. Kiln 4 was installed in 2002. What is the expected lifetime of the kiln?

2. Does the facility use any of the following methods for controlling NOx emissions from 

Kiln 4 or the pyroprocessing system? If so, which are used? 

 Combustion zone control of temperature and excess air 

 Feed mix composition 

 Reduction of alkali content of raw feed 

 CemStar process 

 Kiln fuel change 

 Increasing thermal efficiency 

3. Does Kiln 4 or the pyroprocessing system use any of the following NOx combustion 

controls? If so, which are used? 

 Staged combustion 

 Low-NOx burner system

 Staged combustion in calciner (SCC) 

 Low NOx Calciner 
4. Does Kiln 4 use any of the following NOx add-on controls? If so, which are used? 

 SNCR

 SCR
Phoenix Cement Company, a Division of the Salt River Pima-Maricopa Indian Community

March 6, 2013 Comments on Proposed SIP Disapproval – Arizona

ATTACHMENT 3

Trinity Consultants’ Report

(Electronic Data Files Under Separate Attachment/Enclosure)
Environmental solutions delivered uncommonly well

PROJECT REPORT

Review of EPA’s October 3, 2012 “Five-Factor” Analysis 

Concerning Phoenix Cement Company

Prepared for: 

Phoenix Cement Company, a Division of the

Salt River Pima-Maricopa Indian Community

Prepared By:

TRINITY CONSULTANTS

One Copley Parkway

Suite 310

Morrisville, NC 

(919) 462-9693

March 4, 2013

Project 120301.0082
Trinity Consultants Page 1 of 4

Review of EPA’s October 3, 2012 “Five-Factor” Analysis Concerning Phoenix Cement Company

1. INTRODUCTION

Trinity Consultants, Inc. (“Trinity”) has reviewed the model described in the EPA’s October 3, 2012 report 

concerning the Salt River Pima-Maricopa Indian Community—Phoenix Cement Company cement kiln in 

Clarkdale, Arizona (“PCC”). Trinity has determined that certain assumptions in the EPA’s model resulted in 

an over-estimation of impacts on visibility in the Sycamore Canyon Wilderness Area (“SCWA”) that are 

attributable to PCC and an overestimation of improvements to visibility in the SCWA that may result from 

the addition of selective non-catalytic reduction emissions control technology (“SNCR”) at PCC.

The EPA estimated impacts on visibility in the SCWA for three different PCC emissions scenarios:

Base Case – emissions estimates reported for the period 2005-2010;

Ctrl-1 – emissions estimates for the same period, assuming the addition of low-NOx burner emissions 

control technology (“LNB”) or mixing air emissions control technology (“MAT”); and

Ctrl-2 – emissions estimates for the same period, assuming the addition of SCNR.

The EPA modeled the three emissions scenarios in order to estimate improvements to visibility in the 

SCWA that may result from the addition of LNB/MAT or SNCR at PCC.1

PCC already employs LNB. Therefore, the Ctrl-1 scenario has no relevance. The only possibly relevant 

additional emissions control technology scenario is Ctrl-2, i.e., SNCR. Accordingly, the remainder of this 

report focuses on the Base Case and SNCR scenarios.

 

1 Table 40 of EPA Report.
Trinity Consultants Page 2 of 4

Review of EPA’s October 3, 2012 “Five-Factor” Analysis Concerning Phoenix Cement Company

2. MODELING APPROACH AND DEFICIENCIES

This section discusses the approach the EPA used to model visibility impairment in the SCWA that is 

attributable to PCC and certain deficiencies in the EPA’s approach.

2.1. EPA’S MODELING APPROACH

The EPA ran each emissions scenario in CALPUFF using meteorological data from the period 2001-2003 to 

estimate resulting ambient air concentrations of pollutants in the SCWA. The EPA then used CALPOST 

processing to estimate light extinction in the SCWA that would result from those concentrations, using two 

different methods:

IMPROVE Method 6 (“Equation 1”):

bext (Mm-1) = 3[(NH4)2SO4]f(RH) + 3[NH4NO3]f(RH) + 4[OC] + 1[Soil] + 0.6[Coarse Mass]

+10[EC] + Raleigh Scattering (10 Mm-1 by default) + 0.33[NO2 (ppb)] 

IMPROVE Method 8 (“Equation 2”):

bext (Mm-1) = 2.2[small sulfates] fs(RH) + 4.8[large sulfates] fL(RH) + 2.4[small nitrates] fs(RH)

+ 5.1[large nitrates] fL(RH) + 2.8[small organics] + 6.1[large organics]

+ 10[elemental carbon] + 1[fine soil] +1.7][sea salt] fss(RH)

+ 0.6[coarse mass] + Raleigh Scattering (site-specific) + 0.33[NO2 (ppb)]

Where:

f(RH) = relative humidity scattering enhancement factor from monitoring data representative of 

SCWA during 1988-19972

[ ] All concentrations in μg/m3 except [NO2] which is in ppb

Based on these estimated light extinction values and the background light extinction values derived from 

the Federal Land Managers’ Air Quality Related Values Workgroup (FLAG) Phase I Report3, the EPA 

calculated the deciviews of visibility impairment theoretically attributable to PCC for the Base Case and 

SNCR scenarios.

In calculating the deciviews of visibility impairment using IMPROVE Method 8, the EPA paired the 

estimated light extinction values with the 20% best days background light extinction values. 

 2 U.S. EPA, Interpolating Relative Humidity Weighting Factors to Calculate Visibility Impairment and the Effects of 

IMPROVE Monitor Outliers, prepared by Science Applications International Corporation, Raleigh, NC, EPA Contract No. 

68-D-98-113, August 30, 2001.

3 U.S. Forest Service, National Park Service, and U.S. Fish and Wildlife Service, Federal Land Managers’ Air Quality 

Related Values Work Group (FLAG) Phase I report – Revised (2010). National Resource Report NPS/NRPC/NRR2010/232. National Park Service, Denver, Colorado. November 2010.
Trinity Consultants Page 3 of 4

Review of EPA’s October 3, 2012 “Five-Factor” Analysis Concerning Phoenix Cement Company

2.2. DEFICIENCIES IN EPA’S APPROACH

The EPA’s approach described in the previous section is inappropriate for at least two reasons.

First, if the EPA used IMPROVE Method 8 because it is a method used in prevention of significant 

deterioration (“PSD”) modeling, then, consistent with PSD modeling guidance, the EPA should have paired 

the estimated light extinction values with the default annual average background light extinction values.4 

Second, the regional haze rules require the necessity of improvements to visibility in a Class I area to be 

determined also as a function of the most impaired days, which is defined as “the average visibility 

impairment (measured in deciviews) for the twenty percent of monitored days in a calendar year with the 

highest amount of visibility impairment,”5 i.e., the 20% worst visibility days.

By failing to calculate deciviews based on the annual average background and 20% worst visibility days, 

the EPA overestimated the impacts on visibility in the SCWA that are attributable to PCC and overestimated 

the improvements to visibility in the SCWA that may result from the addition of SNCR at PCC.

The EPA failed, in addition, to consider that nitrogen oxides (“NOX”) in the ambient air that are attributable 

to PCC would not convert predominantly to NO2 by the time they reach the SCWA. Stack emissions are 

largely NO and then gradually convert to NO2 as the plume disperses downwind.6 Whereas perhaps a 

complete conversion of NO to NO2 can be assumed to occur in typical CALPUFF runs (in which the distance 

traveled by the NOX is typically in excess of 50 kilometers), such a conversion cannot properly be assumed 

to occur over the mere 9 kilometers of distance between PCC and the SCWA. When such short distances 

are involved, photochemical modeling techniques should be used to account for representative NO-NO2

conversion chemistry.7 Given the presence of the NO2 term in Equation 1 and Equation 2, above, an 

overestimation of NO2 concentrations in the modeling yields unrealistically high light extinction values. 

This notwithstanding, the EPA assumed that all NOX in the ambient air that are attributable to PCC are 

100% NO2 in the SCWA. This led to a further overestimation of impacts on visibility in the SCWA that are 

attributable to PCC and a further overestimation of improvements to visibility in the SCWA that may result 

from the addition of SNCR at PCC. 

To correct for some of the deficiencies in the EPA’s analysis, described above, Trinity re-ran CALPOST to 

produce Method 8 deciview values that are based on the annual average background. These are presented 

in the last row in Table 2-1, below. 

In addition, the EPA and PCC may wish to consider: (a) re-running the CALPUFF model to include the 

results of photochemical modeling or other technique to account for representative NO-NO2 conversion 

chemistry; and (b) re-running CALPOST to produce also Method 8 deciview values that are based on the 

20% worst days. Pending such an exercise, the range of possible decreases in the deciview estimates for 

 4 40 C.F.R. § 52.21(p); U.S. Forest Service, National Park Service, and U.S. Fish and Wildlife Service, Federal Land 

Managers’ Air Quality Related Values Work Group (FLAG) Phase I report – Revised (2010). National Resource Report 

NPS/NRPC/NRR-2010/232. National Park Service, Denver, Colorado. November 2010.

5 40 C.F.R. § 51.308(d)(1), 51.301.

6 40 C.F.R. Part 51, Appendix W, § 6.2.4

7 CALPUFF also has improved chemical transformation modules currently under review; e.g., RIVAD.
Trinity Consultants Page 4 of 4

Review of EPA’s October 3, 2012 “Five-Factor” Analysis Concerning Phoenix Cement Company

the Base Case and SNCR scenarios that could result from taking representative NO-NO2 conversion 

chemistry into account is indicated by the last column in Table 2-1.8, 9

Table 2-1. Visibility Impairment at Sycamore Canyon with Varying NO2

The modeling outputs underlying Table 2-1 are enclosed as electronic files with this report. 

 8 There is significant diurnal variability in NOX-NO2 conversion rates. Trinity’s preliminary modeling for one 24-hour 

day indicates that: (a) hourly NO-NO2 distribution varies significantly based on temperature, ozone level, and sunlight 

intensity; (b) NO2 concentrations generally are highest at night and lowest during the day; and (c) nighttime 

predictions can greatly influence daily average visibility impairment.

9 Due to the short amount of time, Trinity has not fully evaluated other deficiencies in the EPA’s modeling, including 

the EPA’s use in its CALPUFF model of a NOX emissions rate that appears not to reflect steady-state operating 

conditions during periods of high capacity utilization or is otherwise not representative. In addition, Trinity did not 

evaluate the EPA’s estimates of the costs of installing and operating SNCR at PCC.

Impairment Impairment

Visibility With NO2 Without NO2

Approach Scenario (∆dv) (∆dv)

Base Case 3.99 2.32

SNCR 2.67 1.85

Net Improvement 1.33 0.46

Base Case 5.15 2.79

SNCR 3.30 2.09

Net Improvement 1.85 0.70

Base Case 4.10 2.17

SNCR 2.59 1.62

Net Improvement 1.52 0.55

* Impairment values are 22nd High Values over the 2001-2003 period

Method 8 - 20% 

Best Days

Method 8 -Annual 

Average Bkg

Method 6 - Annual 

Average Bkg
Phoenix Cement Company, a Division of the Salt River Pima-Maricopa Indian Community

March 6, 2013 Comments on Proposed SIP Disapproval – Arizona

ATTACHMENT 4

Summary of SNCR Costs for PCC
Capital Costs & Annual Cost Calculations

Selective Non-Catalytic Reduction

Cost Item Estimated Cost ($)

1. Purchased Equipment Costs

a. Selective Non-Catalytic Reduction System1 2 838,489

b. Taxes, 3% of a3 25,115 

Subtotal Purchased Equipment Costs (B) 863,644

2. Installation Direct Costs3

a. Foundations and Support, 8% of B 69,091

b. Handling & Erection, 14% of B 120,910

c. Electrical Installation, 4% of B 34,546

d. Piping, 2% of B 17,273

e. Insulation, 1% of B 8,636

f. Painting, 1% of B 8,636

Subtotal Total Construction Costs (TCC) 259,093

Total Direct Costs (TDC) 1,122,737

3. Installation Indirect Costs3

a. Engineering and Supervision, 10% of B 86,364

b. Construction and Field Expense, 5% of B 43,182

c. Construction Fees, 10% of B 86,364

d. Start-up, 2% of B 17,273

e. Performance Test, 5% of B 43,182

f. Contingencies, 40% of B 345,457

Total Indirect Costs (TIC) 621,823

Total Capital Cost, TCC = TDC + TIC 1,744,560
Cost Item Estimated Cost ($)

Direct Annual Costs

Operating and Supervision4

Operator (2 hr/shift @ $39.00/hr) 85,410

Supervisor (15% of Operator) 12,812

Maintenance

Labor (1 hr/shift @ $39.00/hr) 42,705

Parts and Material, 10% of B 86,364

Utilities and Other Costs4

Energy 94,334

Reagent5 563,439

Total Direct Annual Costs 885,064

Indirect Annual Costs3

Overhead, 60% sum operating, supervisory, maintenance labor 84,556

G & A Charges, 2% of total capital costs 34,891

Property Tax, 1% of total Capital costs 17,446

Insurance, 1% of total Capital costs 17,446

Annualized Capital costs6 248,386

Total Indirect Annual Costs 402,725

Total Annual Costs 1,287,789

1

Based on capital cost data provided by Arizona DEQ (2005 Drake Cement BACT analysis), corrected from 165,325 acfm 

design to 207,360 acfm as follows:

CostB = CostA (CapacityB/CapacityA)

0.65 (Cooper 1986) 2005 Dollars

2

Cost Escalation estimate: from the Bureau of Labor Statistics (BLS) Producer Price Index (PPI) for Support Activities for 

Non-Metallic Minerals, Industry Code 213115, from Table 5. PPI for Net Output of Selected Industries and their 

Products, not seasonally adjusted. October 2005 to October 2012 = 111.367%

3

Cost factors obtained from USEPA Control Cost Manual or PCC management

4

Based on data provided by Arizona DEQ (2005 Drake Cement BACT analysis) when applicable, corrected from 165,325 

acfm design to 207,360 acfm design as follows:

MMBtu/hrB = MMBtu/hrA (CapacityB/CapacityA)
5

Based on reagent data provided by Arizona DEQ (2005 Drake Cement BACT analysis): reagent cost = $0.60/lb and 

reagent requirement based on 1.1 to 1.0 ratio of NH3 to NOx, Nox removed with SNCR @ 1.75lb/ton compared to 3.5 

lb/ton without SNCR for total production of 4000 tpd & 330 days/year

6

Based on 10 years equipment life and average annual interest rate of 7% as follows:

Annualized Capital Costs = i (1+i)n / [(1+i)n

-1] * Total Capital Costs

Where i = interest rate (%)

n = equipment life (years)