**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

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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 Sarav anan 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 , 20 1 2EMAQ LOE (EPA Contract EP

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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

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## Figures

Figure 4. Kilns at the CalPortland Cement Rillito Plant

................................ ............................... 4 Figure 5. Phoenix Cement Plant, Clarkdale, AZ

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## Tables

Table 1. CIAs Within 300 km of th e 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). NO
x Control Technologies for CalPortland Kilns 1

- 3

................................ .............. 6 Table 28(b). NO
x Control Technologies for CalPortland Kiln 4

................................ ................... 6 Table 29. Base and Control Scenarios f or NO
x Used in CalPortland Units 1

- 4 RP Analyses

........ 7
Table 30. Stack Parameters for CalPortland Units 1

- 4

................................ ................................ . 8
Table 31. 98 th Percentile Visibility Impairment ( ∆

- dv) for CalPortland Units 1

- 4 Base Case and Control Scenarios: (a) IMPROVE Method 6(a); (b) IMPROVE Metho d 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. NO
x Control Options for Phoenix Ceme nt Kiln 4

................................ ....................... 13
Table 38. Base and Control Scenarios for NO
x Used in Phoenix Cement Unit 4 RP Analyses

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

................................ ................................ 14
Table 40. 98 th 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). NO
x , SO 2 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). NO
x , SO 2 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

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## Document Change Record

Revision Date Remarks

0.1 October 3 , 2012 Draft version submitted to EPAEMAQ LOE (EPA Contract EP

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## 1 Introduction

This report describes the 5

- factor analyses of all technically feasible NO
x 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. E nergy and non

- air quality impacts of compliance;
3. A ny existing pollution control technology in use at each source ; 4. R emaining useful life of the source

, and
5. D egree of visibility improvement that may be reasonably expected from the use of
emissions controls.
Andover Technology Partners (ATP) estimate d the c ost of compliance for these units using
EPA Control Cost Manual (EPA, 2002) , cost estimation methods based on the latest I ntegrated Planning Model [IPM] ) documented online by EPA (2010)

, and other reasonable engineering approaches . The control options were analyzed not only for th e 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 feasibl e c ontrol options were identified, EPA reviewed and recommended control configurations on all applicable units to examine the visibility impact s of their emissions . UNC performed the se impact assessment s using the base configur ation of existing controls as well as

a ll EPA

- approved control configurations for each BART facility at all Cla ss I Areas (CIAs)
within a 300

- km radius through the use of dispersion modeling. Per EPA requirements t he se analys e s used the following models and processors

, and EPA

- provided meteorol ogical 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 facilit y at the relevant
CIA s.

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

- partitioning of HNO 3 between gas and particle based on additional input
information

.

• The adjusted concentrations were used in the CALPOST visib ility 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 NO
x 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 C IAs.



## 2 Work Performed and Deliverable Summary

In t he five

- factor analysis performed in this task ATP examined NO
x control options and their
costs for each of the five facilities considering the first four factors listed in Section 1. TheseEMAQ LOE (EPA Contract EP

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- 0 25 .v 1 2 October 3, 2012 cost estimates ha ve been used along with the visibility impact assessment s 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 assessme nts, including the CIAs that are potentially affect ed by these facilities are provided in Section 2.1

. T he 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 sof tware to determine the nearest distance s to the boundaries
of CIAs within a 300

- km radius of the major emitting facilities in Arizona

. T he 19 CIAs and
their nearest mean distances (as determined in the Task 4 screening) from the applicable
fa cilities 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 200 1

- 2003 performed by ENSR Corporation for the Navajo Generating
Station (ENSR, 2009).

Table 1

. C IA s Within 300 k m o f 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 BARTEMAQ LOE (EPA Contract EP

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- 0 25 .v 1 3 October 3, 2012 Subject Protocol provided in its Appendix A. Differences in model set

- up from the
recommendations of th e 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 det ails 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 als o 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 technologi es 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 reduc ed)

.

• 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 option s 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 NO
x for the electricity gene rating 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 ( C AMD ) 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 SO 2 for purposes of visibility modeling are
derived from t he 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 analys es use the annual average emission values in tons per year (TPY) based upon actual emis sions from baseline period s that reflect future anticipated
annual emissions

. Specifics of the emissions used and t he visibility impacts of base case and control scenarios are discussed in the sections on visibility and control effectiveness analysis for each facility.EMAQ LOE (EPA Contract EP

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- 0 25 .v 1 4 October 3, 2012 2.2.1 CalPortland Cement Rillito Plant Units 1

- 4 Formerly known as Arizona Portland Cement, the CalPortland Cement Rillito P lant (Figure 4) has three long kilns and one precalciner kiln

. The type and rated c apacities are shown in
Table 26

. It is currently understood that these kilns have fabric filters, but have no SO 2 or NO
x controls. It is understood that the three smaller kilns are not currently being operated and it is
unclear if the se 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 Data 1

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 NO
x combustion controls, but it is unlikely that kilns 1

- 3 have any NO
x 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.EMAQ LOE (EPA Contract EP

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x 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 NO

x 623 1,894 Ton/yr Calculated

* Data for kilns 1

- 3 is per kiln, not total.



### 2.2.1.1 NO
x 

### Control Options Analysis

2.2.1.1.1 Available NO
x 

### 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 NO
x combustion controls in the calciner. Thus low NOx cal ciner is another option for kiln
4. The cost of a L ow NOx C alciner (LNC) is expected to be in the same range as MAT 7

.



### 2.2.1.1.2 Feasible NO
x 

### 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, m id

- k iln f iring 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 f urther NO
x 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 NO
x 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% NO
x reduction whether used alone or in combination with combustion controls (assumed here to be LNB, although MAT m ay 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 14EMAQ LOE (EPA Contract EP

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. NO
x Control Technologies for CalPortland Kilns 1

- 3

(a)

Table 28 (b)

. NO
x 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
SO 2 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 mod eling 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

c alcu lations. The calculation steps are described in Section 2.2.4.2.2.

For Kilns 1

- 3, maximum 24

- hr average b aseline emissions needed for the visibility modeling
are based on NO
x and SO 2 emission factors representing the highest value s 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 235EMAQ LOE (EPA Contract EP

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- year period of continuous operation . A nnual emissions
needed for the control cost estimates on these units were based on the NO
x and SO 2 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. T he
annual emission values used in the cost estimates f or this unit are based on emission factors for
NO
x and SO 2 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 EPA 6 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 NO
x control cases are specified below , and tabulated in Table 29; in the
base and control scenarios , EPA specified that the emissions of U nits 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 base line 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 NO
x 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

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### 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 i nputs using customized Unix scripts to ensure compliance with the data on the spreadsheets provided by EPA 6

. Per EPA’s specification the emissions of Units 1

- 3 were combined in CALPUFF inputs as a single source. Also, as separate CALPUFF output concentrat ion 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 summarize s the results for the 98 th 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 VelocityEMAQ LOE (EPA Contract EP

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- 0 25 .v 1 9 October 3, 2012 Table 31

. 98 th Percentile V isibility I mpairment ( ∆

- d v) f or 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) f or 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 im pairment is greater in the case of controls on Unit 4 than o n 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 vi sibility 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.EMAQ LOE (EPA Contract EP

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(a) (b)

Table 33 and 34 separate ly 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 3 3 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 vi sibility 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 chara cteristics are shown in Table 35

.EMAQ LOE (EPA Contract EP

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Table 35

. Phoenix Cement Kiln Data 5

Year on L ine 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”,
De cember 31, 2006.

2 US EPA, RP_Cement_modeling_runs

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5 Portland Cement Association, “US and Canadian Portland Cement Industry: Plant Information Summary”, December 31, 2006.EMAQ LOE (EPA Contract EP

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### 2.2.2.1 NO
x 

### Control Options Analysis

2.2.2.1.1 Available NO
x 

### 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 NO
x 

### 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 ava ilable, 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 NO
x reductions throu gh 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 NO
x control technolo gies currently deployed on this kiln was not
available. It is likely t hat 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% NO
x reduction, although fo r cost estimations LNB is more conservative. For 50% NO
x 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% NO
x 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

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. NO
x 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 measur es has a modest energy impact. MAT can have a beneficial impact on CO and SO 2 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 NO
x controls at
Phoenix Cement Plant. The NO
x and SO 2 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. A nnual emission s needed for the cost estimates were also
based on e mission 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
SO 2 and NO
x 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 NO
x control cases are specified as follows, and tabulated in Table 38; in
the base and control scenarios:

• Ctr l

- 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

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Table 38. Base and Control Scenarios for NO
x Used in Phoenix Cement Unit 4 RP Analys e s



### 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 3 9

. 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 EPA 6

.



### 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 CALPOS T inputs.



### 2.2.2.2.4 Extraction of Visibility Results with POSTCALPOST

Table 40 summarizes the results for the 98 th 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

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- 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 VelocityEMAQ LOE (EPA Contract EP

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. 98 th Percentile V isibility I mpairment ( ∆

- d v) f or 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) f or Phoenix Cement Kiln 4 for the Control Scenarios Corresponding to Table 40

(a) (bEMAQ LOE (EPA Contract EP

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### 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)

Table s 42 and 43 separate ly present the control effectiveness for MAT and LNB due to their difference in cost. They show that the great est 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 m ost significantly impaired CIAs ( Sycamore Canyon ) and much less at the farther
CIAs such as sagu and sian

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### 2.3 **Conclusi ons** 

The five

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

• The visibility i mpacts are greatest for each facility at the nearest CIAs, and the control options are least effective (greatest in million $/dv) at the farthest ones. T he CIAs which experience the greatest visibility impacts and show the greatest benefits are listed belo w 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 f or Phoenix Cement, Sycamore Canyon ( 2 of 12)

• Table s 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 SNCREMAQ LOE (EPA Contract EP

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## References

EPA, 2010: Documentati on of EPA’s IPM Base Case v4.10, U.S. Environmental Protection Agency. http://www.epa.gov/airmarkets/progsregs/epa

ipm/BaseCasev410.html#documentation

EPA

, 2002 : EPA Air Pollution Control Cost Manual (Sixth Edition) , Report No. EPA/4 52/B

02

- 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: CAL MET/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

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- 2 October 3, 2012 This appendix provides the emissions data for CALPUFF modeling of the base case(s) and control scenarios analyzed for the thr ee EGU facilities. These data were extracted from a master spreadsheet that is being delivered as part of the documentation for thi s task.

Table A

- 4 (a). NO
x , SO 2 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 modelingEMAQ LOE (EPA Contract EP

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- 5 (a). NO
x , SO 2 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 Phoeni x Cement Kiln 4 visibility modeling

## Appendix B

**Andover Technology Partners Report Chapter**  **5 :**  **Reasonable Progress Analysis**UNC

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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)

methods 4 , 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/epa

ipm/BaseCasev410.html#documentationUNC

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- 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 uncl ear 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 representat ive 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 Port land Cement Industry: Plant Information Summary”, December 31, 2006.UNC

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- 2. Estimated emissions and production r ates 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 expec ted 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 kil n, not total for the three kilns.

6 US EPA, RP_Cement_model ing_runs

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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 14UNC

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Each of these measures has a modest energy impact. MAT can have a beneficial impact on
CO and SO 2 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 235UNC

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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

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- 1 October 3, 2012 Table 5

- 5. Est imated 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 a lternative 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 expe rience 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, alt hough 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, al though 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 sh own. 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). There fore, a more conservative estimate of control costs for
50% reduction would result from the combination of LNB with SNCR.

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Each of these measures has a modest energy impact. MAT can have a beneficial impact on
CO and SO 2 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 a sked 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
VII I.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 vis ibility

- 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 offic e 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 0 9 , 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 an d 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 quest ions 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: L indsay, 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 del ayed 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 yo u 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 requirem ents 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. AD EQ 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 issu es.

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 followi ng 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 Calciner4. 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 so **lutions 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 Co nsultants, 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 ad dition of selective no n

- 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 o f 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. T he 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 AN D DEFICIENCIES

This section discusse s the approac h the EPA used to model visibility impairment in the SCWA that is
attributable to PCC and certain deficiencies in t he 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 (“ **Equat ion 1**  ”):

b ext (Mm

- 1 ) = 3[(NH 4 ) 2 SO 4 ] f(RH) + 3[NH 4 NO 3 ] f(RH) + 4[OC] + 1[Soil] + 0.6[Coarse Mass] +10[EC] + Raleigh Scattering (10 Mm

- 1 by default) + 0.33[NO 2 (ppb)]

IMPROVE Method 8 (“ **Equation 2** ”):

b ext (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

- specifi c) + 0.33[NO 2 (ppb)]
Where:

f(RH) = relative humidity scattering enhancement factor from monitoring data representative of SCWA during 1988

- 1997 2 [ ] All concentrations in μg/m 3 except [NO 2 ] 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 Report 3 , 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/NRR

20 10/232. 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

Th e EPA ’s approach described in the previous section is inappropriate for at least two re asons.

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 gu idance , 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
det ermined 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 2 0% 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 t o visibility in the SCWA that may result from the addition of SNCR at PCC.

The EPA failed, in addition, to consider that nitrogen oxides (“ **NO X**  ”) in the ambient air that are attributable to PCC would not convert predominantly to NO 2 by the time they reach the SCWA. Stack emissions are largely NO and then gradually convert to NO 2 as the plume disperses downwind

. 6 Whereas perhaps a complete conversion of NO to NO 2 can be assumed to occur in typical CALPUFF runs (in which the distance traveled by the NO X 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 modeli ng techniques should be used to a ccount for representative NO

- NO 2 conversion chemistry. 7 Given the presence of the NO 2 term in Equation 1 and Equation 2, above, an
overestimation of NO 2 concentrations in the modeling yields unrealistically high light extinction values.
This notwithstan ding, the EPA assumed that all NO X in the ambient air that are attributable to PCC are
100% NO 2 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 improvemen ts 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 oth er technique to account for representative NO

- NO 2 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 est imates 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

– Re vised (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

- NO 2 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 NO**  **2**

The modeling outputs underlying Table 2

- 1 are enclosed as electronic files with this report

.

8 There is significant diurnal variability in NO X - NO 2 conversion rates . Trinity’s preliminary modeling for one 24

- hour day indicates that: (a) hourly NO

- NO 2 di stribution varies significantly based on temperature, ozone level, and sunlight intensity; (b) NO 2 concentrations generally are highest at night and lowest during the day; and (c) nighttime predictions can greatly influence daily average visibility impairm ent.

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 NO X emissions rate that appears not to reflect steady

- state operating conditions during peri ods 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 NO 2 Without NO 2 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 System 1 2 838,489

b. Taxes, 3% of a 3 25,115

Subtotal Pu rchased Equipment Costs ( B) 863, 6 44

2. Installation Direct Costs 3

a. F oundations 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 Costs 3

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 1,744,560Cost Item Estimated Cost ($)

Direct Annual Costs
Operating and Supervision 4
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 Costs 4

Energy 94,334
Reagent 5 563,439

Total Direct Annual Costs 8 85,064

Indirect Annual Costs 3

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 costs 6 248,386

Total Indirect Annual Costs 40 2,725

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:

Cost B = Cost A (Capacity B /Capacity A ) 0.65 (Cooper 1986) 2005 Dollars

2 Cost Escalation estimate: from the Bureau of Labor Statistics (BLS) Producer Price Index (PPI) for Support Activiti e s 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/hr B = MMBtu/hr A (Capacity B /Capacity A )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 NH 3 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 year s 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)