# Attachment 1

October 2, 2014 Follow

- Up LetterLhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 October 2, 2014

Colleen McKaughan
Associate Director Air Division (AIR-2) EPA Region 9
75 Hawthorne Street San Francisco, CA 94105

Re: Summary of LNA Comments Following LNA/EPA Meeti ng at Region 9 Headquarters on September 4, 2014, Regarding Publication of “Promulgation of Air Quality Implementation Plans; Arizona; Regional Haze and Interstate Visibility Transport Federal Im plementation Plan; Final Rule” (Federal. Register, Vol. 79, No. 170, September 3, 2014).

Dear Ms. McKaughan;

Lhoist North America of Arizona, Inc. (LNA) would l ike to thank you for giving us the opportunity to meet with you and your staff at EPA Region 9 Headqu arters this past September 4 th to voice our concerns regarding the final Regional Haze rules re ferenced above. As promised in the meeting, this letter provides a summary of LNA’s comments and con cerns as expressed during the meeting along with EPA’s responses, as interpreted by LNA. Our c omments are organized into two sections. The first section provides a summary of our position on the various aspects of the final rule as discussed in the meeting, along with some of our questions which did not get addressed during the meeting due to time constraints. The second section provides some technical corrections regarding the actual text of
the final rule.

Summary of LNA’s Comments and Concerns

1. Specific Emission Limits Listed in Final Rule

LNA is in agreement with the emission limits listed in the final rule published September 3, 2014
which are as follows:

a. NO X limits:

 3.80 lb/ton lime for Kiln 1 - 12-month rolling ave rage

 2.61 lb/ton lime for Kiln 2 -12-month rolling aver age

 Short term limit for both kilns combined of 3.27 t ons NOx per day based on a 30-kilnoperating-day rolling average

b. SO 2 limits:

 9.32 lb/ton lime for Kiln 1 - 12-month rolling ave rage

 9.73 lb/ton lime for Kiln 2 - 12-month rolling ave rage

 Short term limit for both kilns combined of 10.10 tons SO 2 per day based on a 30-kilnoperating-day rolling average

2. Specific Compliance Deadlines

As specified in the final rule, LNA must comply wit h the SO 2 limits, including installation of Continuous Emission Monitoring Systems (CEMS), no l ater than March 3, 2016 and must comply
with the NO X limits no later than September 4, 2017.Colleen McKaughan, October 2, 2014 Page 2

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 a. As stated by EPA in the meeting, the above compl iance dates mark the beginning of the data collection period such that after 30 days and 12 months, respectively, compliance with the 30-day and 12-month rolling average limits will be demonstrated.

b. This is a critical determination as the collecti on of compliance data over the first 30 days and 12 months after the compliance dates affects ot her stated reporting requirements as
discussed further below.

3. Design Report

As specified in the final rule, a Design Report mus t be submitted to EPA for review at least 6 months prior to commencing construction of an ammon ia injection system used to comply with the
limits.

a. During the meeting LNA asked if there was any sp ecific deadline for submittal of the Design Report other than the requirement that it be submitted at least 6-months in advance of construction of the Selective Non-Catalytic Redu ction (SNCR) for NO X control. EPA responded “No”.

b. LNA then asked EPA what its time commitment was for providing approval/disapproval of the Design Report.

i. EPA responded that they did not intend to approv e or disapprove the Design Report (or any of the other required documents such as the Optimization Protocol and Report) and that they didn’t expect LNA to dela y in moving forward with installation of the SNCR system because they were w aiting for an EPA response.

ii. LNA then pointed out that Item 13 in Appendix B of the final rule (FR Vol. 79, No. 170, Page 52497, Column 2) that outlines Optimizati on Targets specifically states: “... with its maximum design stoichiometric rate iden tified in the Design Report approved

pursuant to Item 3 of this appendix”

.

iii. EPA acknowledged that the rule would need to b e revised to resolve this conflict between the rule language and EPA’s intent.

c. LNA pointed out that the SNCR system will be des igned by the contracted vendor with a great deal of input from LNA. LNA then asked what level of detail EPA was expecting in the Design Report.

i. EPA responded that they did not have a specific level of detail in mind but that they were interested in having general design infor mation such as the injection
locations.

ii. LNA then asked how EPA proposed to resolve disa greements between LNA and the Agency regarding the Design Report. EPA respon ded that there was no resolution process in place and that EPA did not in tend to offer comments on the Design Report. This matter may need to be addresse d by a change in the published rules.

iii. EPA then stated that their intent was to gathe r as much information as possible regarding the use of SNCR on lime kilns because of the lack of information
available.

1). This led to further discussion with LNA pointin g out that SNCR has been
installed on two LNA kilns in Alabama and on anothe r lime kiln in Alabama at one of LNA competitor’s plant. LNA also pointed out that LNA’s Five-Colleen McKaughan, October 2, 2014 Page 3

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Factor BART analysis contained information document ing that a NO X control efficiency of 50% is possible on preheater lime kilns. Furthermore, the estimated SNCR costs contained in the Five-Fact or BART analysis were based on information derived from the SNCR sys tems installed at
LNA’s facilities

2). EPA stated that they misinterpreted that inform ation and thought the information was based on SNCR systems installed at Lhoist plants outside of the USA. EPA reiterated that they were under the assumption that no lime kilns in the USA currently utilize SNCR for NO X control.

3). EPA then asked LNA to provide additional detail s regarding the installation of the SNCR systems at the Alabama plants and to ex plain under what permitting circumstances the systems were installed . LNA explained that the SNCR system was installed on the new and existi ng lime kilns as part of a capacity expansion project in what was at the time an ozone nonattainment area (Jefferson/Shelby County, Alabam a). The SNCR systems on the two kilns allowed LNA to more than d ouble our existing capacity without a significant increase in NOx emis sions.

d. LNA reiterated that the anticipated approach to NO X control at the Nelson Plant may incorporate several equipment and operational chang es as was the case at LNA’s O’Neal Plant in Alabama. These may include changes to the solid fuel milling system, burner pipe modifications, installation of an SNCR system, and other operational changes. The SNCR system and other changes may incorporate proprietar y technology and equipment and will need to be treated by both LNA and EPA as confident ial business information. EPA acknowledged the possible need to designate certain information that may be provided by
LNA as confidential business information.

4. Baseline Data Collection

As stated in the final rule, prior to commencement of continuous operation of the ammonia injection system, LNA shall either: (a) collect new baseline emissions and operational data for a 180-day period; or (b) submit for EPA review existing basel ine emissions and operational data collected from a period of time prior to the initiation of a baseline collection period. Such baseline emissions and operational data shall include the data require d by Item 8 below for periods of time representing the full range of normal kiln operatio ns.

a. During the meeting, LNA asked EPA to identify th e purpose for collecting 6 months of new
baseline data.

i. EPA responded that they had received comments th at the baseline data used in LNA’s BART Analysis was not adequate in length to b e considered representative data and therefore, EPA wanted to collect new basel ine data over a 6-month period to compare with the data used in the origina l analysis.

ii. LNA responded that even if there were some diff erences in the baseline averages,
there would be no other use for the new baseline da ta. In other words, the BART analysis would not be redone in any event.

iii. More importantly, LNA pointed out that collect ing new baseline data would shorten by more than 6 months the 18-month and 3-year compl iance windows for SO 2 and
NO
x compliance. During the 6-month baseline period, LN A would be prohibited from initiating any fuel switching, kiln operation control testing, or other emission reduction activities that will be required to meet the new emission limits.Colleen McKaughan, October 2, 2014 Page 4

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 b. LNA re-emphasized that we do not object to colle cting the emissions data once the CEMS are in place but the requirement to operate for 6 m onths without testing and implementing emission reduction activities is unacceptable unles s EPA revises the rules to allow a 6- month extension of the compliance dates. As propos ed, the 6-month baseline data collection period is unacceptable simply because it does not leave LNA enough time to implement and test all of the control equipment and operational changes that will be required to comply with the new emission limits. L NA also discussed the fact that lime kiln emissions vary seasonally (due to changes in ambien t temperature, humidity, and moisture content of fuels) and that emissions during any 6-m onth period may differ from those observed during any subsequent 6-month period.

5. Optimization Protocol and Optimization Period

The final rule states that prior to commencement of the Optimization Period, LNA must submit for EPA review an Optimization Protocol for optimizing the ammonia injection system, including optimization of the operational parameters resultin g in the minimization of emissions of NO X to the greatest extent practicable without violating any l imits.

LNA and EPA discussed both the specific language of the final rule and EPA’s expectations with respect to the Optimization Protocol and Optimizati on Period. Major points included in this
discussion are outlined below:

a. LNA asked EPA to identify the Agency’s authority to require the Optimization “Study”. EPA responded that the definition of BART in the Region al Haze Rule and Section 114 of the Clean Air Act gives EPA broad authority to issue su ch requirements and that they would provide LNA with a written justification of their a uthority to require that LNA prepare and submit the Optimization Protocol and conduct the Op timization and Demonstration studies.

b. LNA explained that the company’s vision of “opti mization” was fundamentally different than
EPA’s definition.

i. EPA’s definition of optimization essentially req uires the NO
x control system, (SNCR), to be operated so as to minimize emissions of NOx. EPA’s approach would require that LNA inject the SNCR reagent (lik ely urea) at whatever amounts necessary to achieve the maximum NO
x emission reductions.

ii. LNA explained that their approach to reducing N O X emissions to meet the compliance limits will likely be a combination of S NCR, equipment modifications and operational controls so as to meet the numeric NOx emission limitation specified in the final rule. LNA believes “optimiz ation” means implementation of equipment and operational controls that minimize NO x emissions while also minimizing other possibly adverse environmental imp acts. LNA’s vision of optimization includes minimizing the use of urea an d energy consumption (including associated GHG emissions). LNA’s object ives include minimizing water consumption, avoiding waste production as well as c onsideration of costs, production losses and impacts on product quality.

iii. LNA emphasized that the fundamental difference s in how LNA and EPA perceive the concept of optimizing the NO X controls presents a serious problem for LNA with respect to complying with the specific optimiz ation requirements listed in the
final rule.

c. The final rule also requires that the Optimizati on Protocol describe procedures to be used during the Optimization Period to optimize facility processes to minimize emissions from the kiln and to adjust the ammonia injection system operating parameters. Item 10 inColleen McKaughan, October 2, 2014 Page 5

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305

Appendix B of the final rule (FR Vol. 79, No. 170, Page 52497, Column 1) states that the protocol shall specify:

 The range of reagent injection rates (as a molar ra tio of the average pollutant concentration);

 Sampling and testing programs that will be undertak en during the initial reagent injection rate period;

 A plan to increase the reagent injection rate to id entify the injection rates with the
maximum emission reduction effectiveness and associ ated sampling and testing programs for each increase in the reagent rate. The owner/operator shall test, at a minimum, the ammonia injection system at three mola r ratios of 0.75, 1.0, and 1.20;

 The factors that will determine the optimum reagent injection rates and pollutant emission reductions (including maintenance of Kiln, productivity, and product quality);

 Evaluation of any observed synergistic effects on K iln emissions, Kiln operation, reagent slippage, or product quality from the ammon ia injection system; and

 Any additional facility processes that the owner/op erator determines may reduce
NO X emissions in conjunction with the ammonia injectio n system.

i. Again, LNA pointed out how the above requirement s are in conflict with how LNA anticipates it will achieve compliance with the NO X emission limits.

ii. LNA also pointed out that kiln operating parame ters are not easily “optimized” as defined by EPA. As explained by LNA, kiln operatin g parameters are dynamic, constantly changing depending on various related pa rameters such as ambient temperatures, stone characteristics, fuel character istics, and normal operational changes that occur between major kiln outages. Fur thermore, as each operating parameter changes, other parameters are in-turn aff ected and may need to be adjusted accordingly. Thus, most kiln operating pa rameters don’t lend themselves to being “optimized” to a given operating value or range of values. The system is simply too dynamic and interdependent.

iii. LNA explained how they have substantial reserv ations about “optimizing kiln operations” for the purposes of operating the SNCR system. LNA went on to explain further that kiln operations are “optimized ” to meet production, fuel efficiency and quality demands and that BART applie s retrofit controls to the existing equipment and operations and conforms to t hose operations; it does not require the process operations to conform to BART e xcept to the extent necessary to meet the applicable emission limitations.

d. LNA stated that they assumed that the 180-day Op timization Period would occur after the compliance date. EPA stated they anticipated that i t would occur prior to the compliance
date.

i. LNA did not have a chance during the meeting to fully comment on this issue. LNA’s position is that the very prescriptive nature of the optimization requirements being imposed by EPA is in direct conflict with how LNA anticipates they will achieve compliance with the BART emission limits. LNA believes emission control and kiln operating parameters will be always changi ng in response to changes in related equipment conditions and ambient conditions . Thus, LNA anticipates it will fully utilize all of the time in the compliance win dow to study and adjust parameters in order to develop a compliance strategy by the co mpliance date. If LNA is forced to conduct the Optimization Period prior to complia nce date, their opportunity to develop a successful compliance strategy will be sh ortened by 6 months, much like what will happen if LNA is forced to collect n ew baseline data for 6 months as discussed above. Also, an optimization period of 6 months does not capture anColleen McKaughan, October 2, 2014 Page 6

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305

annual weather cycle and therefore, the information most likely will not represent the normal and anticipated range of weather conditi ons.

ii. This difference in interpretation regarding the conduct and scheduling of the Optimization Period was not resolved in the meeting

.

e. LNA believes the issues surrounding the Optimiza tion Protocol and Optimization Period must be formally resolved before moving forward. L NA suggested in the meeting that EPA remove the specific requirements of the Optimizatio n and Demonstration Programs from the final rule and transfer them into a separate wr itten agreement that can be negotiated outside the boundaries of the rule making process.

6. Optimization Report

As stated in the final rule, within 60 days followi ng the termination of the Optimization Period, LNA shall submit to EPA for review an Optimization Repo rt demonstrating conformance with the Optimization Protocol for the ammonia injection sys tem and establishing the optimized operating parameters for the facility processes and the ammon ia injection system determined under the Optimization Protocol, including optimized injectio n rates for all reagents.

 Optimization Targets: Except as otherwise provided in this Item and in the next item below, the ammonia injection system shall be deemed to be opti mized if the Optimization Report demonstrates that the ammonia injection system duri ng periods of normal operation has
achieved emission reductions consistent with its ma ximum design stoichiometric rate identified in the Design Report approved pursuant to the condi tions listed above.

 Notwithstanding the provisions listed above, the a mmonia injection system may be deemed to be optimized at a lower rate of emission reductions than that identified above if the Optimization Report demonstrates that, during peri ods of normal operation, a lower rate of emission reductions cannot be sustained after all p arameters and injection rates are optimized during the Optimization Period without creating a meaningful risk of impairing product quality, impairing Kiln system reliability, impairing compli ance with a maximum ammonia slip emissions limit of 10 ppm or other permitted levels, or formi ng a detached plume.

a. LNA explained that a 180-day Optimization Period provides no guarantee that optimized operating parameters can be established for the fac ility processes and the ammonia injection system. LNA reiterated the fact that env ironmental factors and operating conditions change throughout the year. Winter cond itions, such as below zero temperatures, snow, and frozen fuel, present much d ifferent operating challenges than summer conditions consisting of temperatures above 100°F, monsoon rains and frequent power bumps. Thus, the optimization of parameters “optimized” during one part of the year may not be sustainable during another part of the y ear because of constantly changing environmental and operational conditions, not to me ntion forced changes due to such things as inventory control and customer demands.

b. LNA noted that that continuous ammonia slip meas urement systems are not readily available. Usually, compliance with ammonia slip l imits is demonstrated through an initial
stack test and then annual stack tests thereafter. LNA asked that EPA define the requirements for demonstrating compliance with the ammonia slip limit of 10 ppm. LNA also asked how EPA expected LNA to collect ammonia slip data throughout the optimization period. These issues were not resolve d in the meeting.

c. Due to time constraints, several questions regar ding the Optimization Program that LNA presented to EPA before the meeting did not get dis cussed. One question concerned the mechanism for LNA and EPA to resolve disagreements concerning any proposed optimization parameter values, particularly if base d on LNA’s knowledge and experienceColleen McKaughan, October 2, 2014 Page 7

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305

such conditions are considered unachievable or non- sustainable by LNA or LNA's equipment design and supply firms? This question w as not resolved.

7. Demonstration Period:

The Demonstration Period shall commence within 7 da ys after the owner/operator’s receipt of the final comments from EPA on the Optimization Report. During the Demonstration Period, the owner/operator shall operate the ammonia injection system for a period of 360 Operating Days consistent with the optimized operations of the Fac ility and the ammonia injection system as contained in the Optimization Report.

a. LNA’s position is that whether or not the Optimi zation Period is before or after the NO X compliance date, the requirement to begin the Demon stration Period within 7 days after receipt of final comments from EPA on the Optimizat ion Report is unreasonable. First, EPA has no stated time commitment to provide commen ts on the Optimization Report. Consequently, LNA could be waiting for weeks with n o idea when comments might be received and then will have to act within 7 days af ter receiving the comments. Additionally, the rules as written, provide no mechanism for LNA and EPA to discuss any conclusions from the Optimization Period. Likewise, the rules as finalized do not provide a mechanism for rebutting or resolving disagreements between EP A and LNA. At a minimum, LNA requests this requirement be revised to a more reas onable time period in the order of 45 to 60 days and that EPA revise the rules to provide a dispute resolution mechanism related to technical and regulatory matters.

b. If EPA determines that the rules as promulgated require that the Optimization Period must be completed before the NO X compliance date and even if LNA receives timely co mments from EPA on the Optimization Report, LNA will be fo rced to begin the Demonstration Period before the compliance date. Again, like the collection of new baseline data, this will take away valuable time from LNA’s compliance windo w, time needed to develop a sustainable compliance strategy.

c. LNA requests that if a Demonstration Period is u ltimately required, it be explicitly required to begin after the NO X compliance date.

8. Demonstration Report

Within 60 days following completion of the Demonstr ation Period for the ammonia injection system, shall submit a Demonstration Report to EPA, based u pon and including all of the data collected during the Demonstration Period including data from Startup, Shutdown and Malfunction events that identifies a proposed rolling 12-month emissio n limit for NO X . The rolling 12-month emission
limit for NO X shall be based upon an analysis of CEMS data and l ime production data collected during the Demonstration Period, while the process and ammonia injection system parameters were optimized in determining the proposed Emission Limit(s) achievable for the Facility.

 The owner/operator shall propose a rolling 12-mont h emission limit for NOx in the Demonstration Report(s) as provided in the precedin g Paragraph. This rolling 12-month limit
shall be calculated in accordance with the followin g formula:

X= μ + 1.65 σ

Where:

X = Rolling 12-month Average Emission Limit (lb/ton of lime product) μ = arithmetic mean of all of the Rolling 12-month averages

σ = standard deviation of all of the rolling 12-mont h averagesColleen McKaughan, October 2, 2014 Page 8

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 a. LNA demonstrated during the meeting that the equ ation as presented in the final rule is in error as there will be only one (1) 12-month rollin g average upon which to calculate the value of “μ”. This fact is explained in the next s ection of this letter.

b. LNA then pointed out that an emission limit base d upon an average plus 1.65 standard deviations statistically captures 90% of the normal distribution, with 5% of the values being on the low end of the normal bell-shaped distributi on and 5% of the values being on the high end of the distribution. Statistically, this m eans that 5% of the values would be above the calculated emission limit and thus, excess emis sions would be expected to be
exceeded 5% of the time.

c. LNA reiterated that they must be in compliance 1 00% of the time and that proposing a limit based on the equation in the final rule, which pred icts non-compliance 5% of the time, was simply unacceptable.

d. LNA requests that EPA revise the rule regarding submittal of a Demonstration Report to specify that the report shall contain the data coll ected but without the proposed methodology for calculating a revised limit. LNA d oes not believe that this requirement conforms to BART and that LNA cannot be required to propose a limit that statistically predicts the source will be out of compliance 5% of the time.

9. Data Collection

The data to be collected during the Baseline Data C ollection Period and the Optimization Period will include the following information either deriv ed from available direct monitoring or as estimated
from monitored or measured data:

 Kiln flue gas temperature at the inlet to the fabr ic filter or at the Kiln stack (daily average);

 Kiln production rate in tons of lime product (dail y total) by type;

 NOx and CO concentrations (dry basis) and mass rat es for the Kiln (daily average for concentrations and daily totals for mass rates) as measured at the Kiln stack gas analyzer location;

 Flue gas volumetric flow rate (daily average in dr y acfm);

 Sulfate in feed (calculated to a daily average per centage);

 Feed burnability (C3S) (at least daily). In the ev ent that more than one type of lime product is produced, the feed burnability for each type of lime product will be included;

 Temperatures in or near the burning zone (by infra red or optical pyrometer);

 Kiln system fuel feed rate and type of fuel by wei ght or heat input rate (calculated to a daily average);

 Fuel distribution, an estimate of how much is inje cted at each location (daily average);

 Kiln amps (daily average);

 Kiln system draft fan settings and primary air blo wer flow rates;

 Documentation of any Startup, Shutdown, or Malfunc tion events;

 An explanation of any gaps in the data or missing data; and

 Amount of oxygen generated and introduced into the Kiln (lb/day).

a. LNA explained that the parameters "Sulfate in fe ed", "Feed burnability" and "Fuel distribution" are common cement industry operating parameters and are not applicable to the lime industry. Consequently, LNA will not be a ble to provide data on these parameters. Additionally, the "Amount of oxygen generated and i ntroduced into the kiln" is a cement industry practice not used at the Nelson Plant. C onsequently, LNA will not be able to provide data on this parameter as well. EPA acknow ledged that some of the parametersColleen McKaughan, October 2, 2014 Page 9

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305

were drawn from a cement industry consent order and that EPA understood that data for some of the parameters listed could not be collecte d.

b. LNA contends that it is inappropriate and unnece ssary for EPA to extrapolate from a cement industry enforcement action to LNA’s BART em ission limitations and that the requirements for the Optimization Protocol, Optimiz ation Period, Demonstration Period and Demonstration Report should be removed from the rul es applicable to the Nelson Plant.

10. Installation of CEMS

The final rule states that at all times after the c ompliance dates, LNA shall maintain, calibrate, and operate a CEMS, in full compliance with the require ments found at 40 CFR 60.13 and 40 CFR Part 60, Appendices B and F, to accurately measure dilue nt, stack gas volumetric flow rate, and concentration by volume of NO X and SO 2 emissions into the atmosphere from kilns 1 and 2. The CEMS shall be used to determine compliance with the emission limitations, in combination with data on actual lime production. LNA must operate th e monitoring system and collect data at all required intervals at all times that an affected ki ln is operating, except for periods of monitoring system malfunctions, repairs associated with monito ring system malfunctions, and required monitoring system quality assurance or quality cont rol activities (including, as applicable, calibration checks and required zero and span adjus tments).

a. LNA requested that EPA clarify whether the above condition means that the CEMS must be operated during periods when the units are down. It should not, but the language literally says they must. The obligation to operat e CEMS should be limited to when the units themselves are operating. This is implied by the third sentence, but there is a conflict. EPA confirmed LNA’s interpretation is co rrect.

11. Compliance Determination for ton per day NO X and SO 2 limits

As stated in the final rule, compliance with the NO X and SO 2 emission limits shall be determined based on a rolling 30-kiln-operating-day basis. The rolling 30-kiln operating day emission rate for the kilns shall be calculated for each kiln operati ng day in accordance with the following procedure. The rule then goes on to explain the procedure.

a. Unlike the provisions for the lb/ton limits, EPA does not state when LNA needs to have these values calculated. LNA suggested three busin ess days or within a calendar week to complete the 30-day calculation. There was some dis cussion about these data being automatically derived by the CEMS data acquisition system but since the limit is a combined kiln limit, this possibility could not be confirmed. Thus, this issue was not fully resolved in the meeting.

12. Recordkeeping

The owner/operator shall maintain operating conditi ons at the time of measurement or monitoring equipment maintenance activity.

a. Although not discussed in the meeting, LNA reque sts that the specific “operating conditions” to be measured and monitored be specifi ed.

13. Reporting:

The final rule states that all reports required und er this section shall be submitted by the owner/operator to the Director, Enforcement Divisio n (Mail Code ENF-2-1), U.S. Environmental Protection Agency, Region 9, 75 Hawthorne Street, S an Francisco, California 94105-3901. All reports required under this section shall be submit ted within 30 days after the applicableColleen McKaughan, October 2, 2014 Page 10

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 compliance date(s) in paragraph (i)(4) of this sect ion and at least semiannually thereafter, within 30 days after the end of a semiannual period. The fina l rule states that the following reports need to be
submitted.

 The owner/operator shall submit a report that list s the daily rolling 30-kiln operating day
emission rates for NO X and SO 2 , calculated in accordance with paragraphs (i)(6)(i ii) and (iv) of
this section.

 The owner/operator shall submit a report that list s the monthly rolling 12-month emission rates
for NO X and SO 2 , calculated in accordance with paragraphs (i)(6)(v ) and (vi) of this section.

a. As explained in the discussion above, LNA and EP A both agreed that collecting the first 30-day and 12-month compliance data will begin afte r the compliance dates. Consequently, the above reporting requirements need to be revised. With the first report due within 30 days, a full set of 30-day and 12-mon th rolling average data will not have been collected yet. Likewise, the first two semi-a nnual reports will not include a full set of 12-month rolling data as that data will not have be en collected yet.

14. Startup, Shutdown and Malfunction Emissions

LNA notes that EPA has deleted the startup, shutdow n and malfunction provisions from the proposed rule. LNA notes that the development of t he limits in this matter only reflected routine startup and shutdown and short-term malfunctions (e .g., those resolvable in a 5 hour or shorter period). It is not clear what regulatory basis exi sts for extending the proposed limits to long-term
malfunctions. Because LNA cannot foresee such issu es, LNA reserves its rights to contest the attempt by any party, including EPA, to apply these BART limits against LNA in the event of a longterm malfunction situation.

General Editorial and Technical Corrections

1. The table in the first column on page 52480 of the Federal Register, Vol. 79, No. 170, under § 52.145(i)(3)(i) has incorrect column headings.

The table should be corrected from:

Kiln ID Pollutant
emission limit NOx SO 2 Kiln 1 ........... 3.80 .......... 9.32
Kiln 2 ........... 2.61 .......... 9.73

To:

Pollutant Emission Limits
Kiln ID NOx SO 2 Kiln 1 ........... 3.80 .......... 9.32 ..........
Kiln 2 ........... 2.61 .......... 9.73 ..........Colleen McKaughan, October 2, 2014 Page 11

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 2. Consistent with the discussion above, the introd uctory language of paragraph (i)(5) in the center column on page 52480 of the Federal Register , Vol. 79, No. 170, needs to be revised because it suggests that the process should be opti mized to the SNCR system rather than the SNCR system optimized to the process. LNA suggests the following change:

(5) Control technology demonstration requirements. If the owner/operator of a kiln installs an ammonia injection system to comply with the limits specified in paragraph (i)(3) of this section, the owner/operator must com ply with the following requirements for implementing combustion and process optimizatio n measures:

In subparagraph (ii), “for the purpose of adjusting ammonia injection operating parameters and minimizing emissions.

In subparagraph (iv), strike “as well as other faci lity processes.”

In subparagraph (v), strike “with the optimized ope rations of the facility and.” LNA also notes that this requirement is extremely vague.

In subparagraph (vi), as discussed above, LNA has s ignificant problems with the proposed calculation methodology and the requiremen t that it “propose” an approach with which it disagrees. LNA believes that this di sagreement can be minimized by striking everything after “shall submit a Demonstra tion Report” or, if EPA wishes for LNA to propose a limit, striking everything startin g with the following sentence: “In a subsequent regulatory action...” EPA may, obviously, start a regulatory action at any time so the language is not needed.

3. The equation in the third column on page 52480 o f the Federal Register, Vol. 79, No. 170,
under § 52.145(i)(5)(vi) is incorrect based on the BART req uirements of the Clean Air Act. See
discussion above. It is also incorrect as a statis tical matter based on the requirement to solve this equation following the Demonstration Period wh ich is 360 days. The equation is stated as
follows:

X = μ + 1.65 σ

Where:

X = Rolling 12-month emission limit, in pounds of N O X per ton of lime product; μ = Arithmetic mean of all of the rolling 12-month emission rates;

σ = Standard deviation of all of the rolling 12-mont h emission rates, as calculated in the following manner:

Where:

N = The total number of rolling 12-month emission r ates;

x i = Each rolling 12-month emission rate;

̅ = The mean value of all of the rolling 12-month em ission rates.Colleen McKaughan, October 2, 2014 Page 12

Lhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 After 360 days, there will be only one (1) 12-month average (short by 5 days) making the value of N equal to 1. With only one average, the values of x i and ̅ will be the same making the value of (x i – ̅ ) 2 zero. This in turn will make the value of σ zero, rendering the value of X simply equal to the single 12-month average with no added standard deviation value to account for variability.

The above equation becomes meaningful as written on ly after 12 months or so of data is collected after the 360-day Demonstration Period, m aking the value of N equal to 12.

4. On page 52481 of the Federal Register, Vol. 79, No. 170, column 3, in subparagraph (i)(7)(v)(C), the “operating conditions at the time of measurement or monitoring equipment maintenance activity” is vague. It should be rewor ded as “whether the equipment controlled or monitored is operating” or something similar.

Again, LNA appreciates the opportunity to submit th ese comments. If you have any questions or need any additional information please do not hesitate t o contact me. I can be reached at (928) 769-2271 extension 645104 or by email at Herbert.Verville@Lhoist.com

.

Sincerely,

Herbert J. Verville Environmental Manager

# Attachment 2

October 2, 2014 O ’ Neal Plant DataLhoist North America – Nelson Plant

P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 October 2, 2014

Colleen McKaughan
Associate Director Air Division (AIR-2) EPA Region 9
75 Hawthorne Street San Francisco, CA 94105

Re: LNA Response to EPA Request for Information Re garding SNCR Control Efficiencies at the O’Neal
Lime Plant.

Dear Ms. McKaughan;

This letter provides the NOx emissions data from Lh oist North America’s (LNA) O’Neal Alabama Lime Plant. These data demonstrate a range of Selective Non-Catalytic Reduction (SNCR) performance values as requested in your email to LNA dated Sept ember 5, 2014. Also included is the additional information you requested regarding a description o f similarities between the Alabama kilns and the Nelson kilns. The purpose of these data is to supp ort the use of the O’Neal kiln SNCR data as being sufficiently representative of the expected perform ance of SNCR and other NOx emission reduction techniques to be implemented on the Nelson kilns to achieve the emission limitations contained in EPA’ s September 3, 2014 rulemaking. From LNA’s industria l experience, we feel that O’Neal Kiln 1 is more similar to the two Nelson Plant kilns. Consequentl y, the data regarding SNCR control efficiencies are
from Kiln 1 at the O’Neal Plant.

Kiln Comparison Data

Nelson Kiln 1

a) Fuel Mill Type: 9 foot x 12 foot (diameter x le ngth) roller mill operating at 22 revolutions per
minute b) Fuel Blend: approximately 72% coke / approximate ly 28% coal c) Burner Pipe: single channel burner pipe d) Kiln: KVS 15 foot x 155 foot (diameter x length) rotary kiln e) Preheater: 14 plunger polygon preheater f) Production: Design = nominal 850 tons per day li me production; Permitted = No enforceable limit; Actual = approximately 850 tons per day g) Fuel Efficiency: Range = 4.7 to 5.2 MMBtu/ton of lime; Average = 4.97 MMBtu/ton of lime (2014 year-to-date)

Nelson Kiln 2

a) Fuel Mill Type: 10 foot x 10 foot (diameter x l ength) roller mill operating at 21 revolutions per
minute b) Fuel Blend: approximately 72% coke / approximate ly 28% coal c) Burner Pipe: single channel burner pipe d) Kiln: KVS 17 foot x 178 foot (diameter x length) rotary kiln e) Preheater: 18 plunger polygon preheater f) Production: Design = nominal 1100 tons per day lime production; Permitted = No enforceable limit; Actual = approximately 1100 tons per day g) Fuel Efficiency: Range = 4.3 to 5.0 MMBtu/ton o f lime; Average = 4.58 MMBtu/ton of lime (2014 year-to-date)Colleen McKaughan, October 2, 2014 Page 2

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 O’Neal Kiln 1

a) Fuel Mill Type: AB Raymond Model 633 roller mil l with a nominal capacity of 10 tons per hour b) Fuel Blend: 99.9% Coal / 0.1% Natural Gas c) Burner Pipe: Multi-channel d) Kiln: 16 foot x 210 foot (diameter x length) rot ary kiln e) Preheater: 20 plunger f) Production: Design = Nominal 1500 tons per day; Permitted = 1500 tons per day; Actual = approximately 1000 tons per day based on current pr oduction demand. Higher production rates have previously been demonstrated g) Fuel Efficiency: Range = 5.0 to 6.0 MMBtu/ton o f lime; Average = 5.2 MMBtu/ton of lime

O’Neal Kiln 2

a) Fuel Mill Type: AB Raymond Model 623RS roller m ill with a nominal capacity of 15 tons per hour b) Fuel Blend: 98% Coal / 2% Natural Gas c) Burner Pipe: Multi-channel d) Kiln: 16 foot x 241 foot (diameter x length) rot ary kiln e) Preheater: 16 plunger f) Production: Design = 1500 tons per day; Permitte d = 1500 tons per day; Actual = approximately 1000 tons per day based on current production deman d. Higher production rates have previously
been demonstrated g) Fuel Efficiency: Range = 5.0 to 6.0 MMBtu/ton o f lime; Average = 5.9 MMBtu/ton of lime

SNCR Control Efficiencies

As shown in the kiln comparison data presented abov e, Kiln 1 at the O’Neal Plant is more similar to th e two Nelson Plant kilns when considering the kiln di mensions and solid fuel use. The preheater on Kiln #2 at O’Neal is a modular or canister design. The pre heater on Kiln #1 at O’Neal is more similar in desi gn to the preheaters used at the Nelson Plant. Kiln 1 is also the kiln that LNA used to establish baseline emissions as part of the permitting process for Kil n 2. Consequently, the data regarding SNCR control efficiencies presented below are from Kiln 1 at the O’Neal Plant.

LNA installed the SNCR system on Kiln 1 at O’Neal t o reduce NOx to the extent necessary to allow construction of Kiln 2 without triggering major new source review. For that purpose, the total reduct ion in tonnage of NOx, rather than the specific control ef ficiency, was most important and engineering was focused on achieving the needed reduction. Operati on of the plant has provided, however, some short term opportunities to assess the relative performan ce of the kiln due to interruptions in the SNCR sys tem while the CEMS was still operating. LNA has based its assessment of the likely control efficiencies achievable by an SNCR system on the Nelson kilns ba sed upon these periods, together with an understanding of additional steps that could be tak en to further improve efficiency based on lessons learned at O'Neal. The data are presented below, a s is LNA's analysis of why a slightly higher value
should be achievable at Nelson.

Background

The SNCR system at the O’Neal Plant is operated on a continuous basis. However, there are times when the system malfunctions. The majority of thes e malfunctions have occurred at night during the winter when ambient temperatures fall to the point where the 50/50 water/urea mixture freezes in the distribution pipes. This freezing prevents the SNC R system from working. It often takes several hour s before the pipes are thawed and SNCR operations res ume. NO X CEMS data associated with these freeze up periods can be evaluated to establish a r ange of SNCR performance values, at least under the conditions then present.Colleen McKaughan, October 2, 2014 Page 3

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 SNCR Control Efficiencies

Graphic presentations of six separate SNCR malfunct ions are presented in Figures 1 through 6. These figures show the NOx emissions data in pounds of NO x per hour (lb/hr). The raw CEMS data (in parts per million (ppm)) for these six time periods were extracted from the O’Neal data acquisition system a nd are summarized into hourly averages. These summari es are presented in Tables 1 through 6.

Figure 1. Graphic presentation of NOx emissions (l b/hr) for August 28, 2011 (see associated

hourly averages in Table 1).Colleen McKaughan, October 2, 2014 Page 4

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Table 1. Hourly NOx Averages for August 28, 2011
Date and Time NOx Hourly Avg (ppm) SNCR Status

8/28/11 1:00:00 AM 147.42 SNCR On

8/28/11 2:00:00 AM 124.21 SNCR On

8/28/11 3:00:00 AM 65.87 SNCR On

8/28/11 4:00:00 AM 98.05 SNCR On

8/28/11 5:00:00 AM 88.74 SNCR On

8/28/11 6:00:00 AM 110.44 SNCR On

8/28/11 7:00:00 AM 123.36 SNCR On

8/28/11 8:00:00 AM 115.02 SNCR On

8/28/11 9:00:00 AM 155.64 SNCR On

8/28/11 10:00:00 AM 108.10 SNCR On

8/28/11 11:00:00 AM 139.64 SNCR On

8/28/11 12:00:00 PM 114.27 SNCR On

8/28/11 1:00:00 PM 125.74 SNCR On

8/28/11 2:00:00 PM 146.04 SNCR On

8/28/11 3:00:00 PM 155.72 SNCR On

8/28/11 4:00:00 PM 64.95 SNCR On

8/28/11 5:00:00 PM 219.88 SNCR Malfunction

8/28/11 6:00:00 PM 248.71 SNCR Malfunction

8/28/11 7:00:00 PM 266.95 SNCR Malfunction

8/28/11 8:00:00 PM 261.90 SNCR Malfunction

8/28/11 9:00:00 PM 236.30 SNCR Malfunction

8/28/11 10:00:00 PM 249.38 SNCR Malfunction

8/28/11 11:00:00 PM 238.58 SNCR Malfunction

8/29/11 12:00:00 AM 226.32 SNCR MalfunctionColleen McKaughan, October 2, 2014 Page 5

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Figure 2. Graphic presentation of NOx emissions (l b/hr) for August 30, 2011 (see associated

hourly averages in Table 2).Colleen McKaughan, October 2, 2014 Page 6

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Table 2. Hourly NOx Averages for August 30, 2011
Date and Time NOx Hourly Avg (ppm) SNCR Status

8/30/11 1:00:00 AM 145.38 SNCR On

8/30/11 2:00:00 AM 128.05 SNCR On

8/30/11 3:00:00 AM 177.31 SNCR On

8/30/11 4:00:00 AM 207.63 SNCR Malfunction

8/30/11 5:00:00 AM 305.12 SNCR Malfunction

8/30/11 6:00:00 AM 341.27 SNCR Malfunction

8/30/11 7:00:00 AM 247.11 SNCR Malfunction

8/30/11 8:00:00 AM 266.96 SNCR Malfunction

8/30/11 9:00:00 AM 226.23 SNCR Malfunction

8/30/11 10:00:00 AM 295.71 SNCR Malfunction

8/30/11 11:00:00 AM 312.34 SNCR Malfunction

8/30/11 12:00:00 PM 236.44 SNCR Malfunction

8/30/11 1:00:00 PM 174.49 SNCR On

8/30/11 2:00:00 PM 188.99 SNCR On

8/30/11 3:00:00 PM 147.29 SNCR On

8/30/11 4:00:00 PM 161.18 SNCR On

8/30/11 5:00:00 PM 151.17 SNCR On

8/30/11 6:00:00 PM 148.31 SNCR On

8/30/11 7:00:00 PM 153.88 SNCR On

8/30/11 8:00:00 PM 148.61 SNCR On

8/30/11 9:00:00 PM 154.33 SNCR On

8/30/11 10:00:00 PM 151.53 SNCR On

8/30/11 11:00:00 PM 151.31 SNCR On

8/31/11 12:00:00 AM 153.71 SNCR OnColleen McKaughan, October 2, 2014 Page 7

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Figure 3. Graphic presentation of NOx emissions (l b/hr) for December 2, 2011 (see associated

hourly averages in Table 3).Colleen McKaughan, October 2, 2014 Page 8

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Table 3. Hourly NOx Averages for December 2, 2011
Date and Time NOx Hourly Avg (ppm) SNCR Status

12/1/11 11:00:00 AM 196.44 SNCR On

12/1/11 12:00:00 PM 85.40 SNCR On

12/1/11 1:00:00 PM 121.78 SNCR On

12/1/11 2:00:00 PM 94.26 SNCR On

12/1/11 3:00:00 PM 206.19 SNCR On

12/1/11 4:00:00 PM 142.46 SNCR On

12/1/11 5:00:00 PM 190.69 SNCR On

12/1/11 6:00:00 PM 160.62 SNCR On

12/1/11 7:00:00 PM 383.51 SNCR Malfunction

12/1/11 8:00:00 PM 400.21 SNCR Malfunction

12/1/11 9:00:00 PM 410.49 SNCR Malfunction

12/1/11 10:00:00 PM 393.59 SNCR Malfunction

12/1/11 11:00:00 PM 364.03 SNCR Malfunction

12/2/11 12:00:00 AM 369.14 SNCR MalfunctionColleen McKaughan, October 2, 2014 Page 9

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Figure 4. Graphic presentation of NOx emissions (l b/hr) for December 5, 2011 (see associated

hourly averages in Table 4).Colleen McKaughan, October 2, 2014 Page 10

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Table 4. Hourly NOx Averages for December 5, 2011
Date and Time NOx Hourly Avg (ppm) SNCR Status

12/5/11 1:00:00 AM 317.16 SNCR Malfunction

12/5/11 2:00:00 AM 248.86 SNCR Malfunction

12/5/11 3:00:00 AM 270.39 SNCR Malfunction

12/5/11 4:00:00 AM 289.12 SNCR Malfunction

12/5/11 5:00:00 AM 363.57 SNCR Malfunction

12/5/11 6:00:00 AM 359.70 SNCR Malfunction

12/5/11 7:00:00 AM 350.14 SNCR Malfunction

12/5/11 8:00:00 AM 293.90 SNCR Malfunction

12/5/11 9:00:00 AM 274.23 SNCR Malfunction

12/5/11 10:00:00 AM 187.52 SNCR On

12/5/11 11:00:00 AM 184.18 SNCR On

12/5/11 12:00:00 PM 207.46 SNCR On

12/5/11 1:00:00 PM 185.17 SNCR On

12/5/11 2:00:00 PM 183.99 SNCR On

12/5/11 3:00:00 PM 187.29 SNCR On

12/5/11 4:00:00 PM 133.09 SNCR On

12/5/11 5:00:00 PM 156.10 SNCR On

12/5/11 6:00:00 PM 132.43 SNCR On

12/5/11 7:00:00 PM 162.11 SNCR On

12/5/11 8:00:00 PM 162.85 SNCR On

12/5/11 9:00:00 PM 171.22 SNCR On

12/5/11 10:00:00 PM 150.76 SNCR On

12/5/11 11:00:00 PM 144.79 SNCR On

12/6/11 12:00:00 AM 149.78 SNCR OnColleen McKaughan, October 2, 2014 Page 11

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Figure 5. Graphic presentation of NOx emissions (l b/hr) for January 23-24, 2012 (see associated

hourly averages in Table 5).Colleen McKaughan, October 2, 2014 Page 12

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305

Table 5. Hourly NOx Averages for January 23-24, 20 12
Date and Time NOx Hourly Avg (ppm) SNCR Status

1/23/12 7:00:00 PM 163.67 SNCR On

1/23/12 8:00:00 PM 161.47 SNCR On

1/23/12 9:00:00 PM 201.69 SNCR On

1/23/12 10:00:00 PM 184.17 SNCR On

1/23/12 11:00:00 PM 190.43 SNCR On

1/24/12 12:00:00 AM 175.74 SNCR On

1/24/12 1:00:00 AM 313.46 SNCR Malfunction

1/24/12 2:00:00 AM 374.28 SNCR Malfunction

1/24/12 3:00:00 AM 349.30 SNCR Malfunction

1/24/12 4:00:00 AM 189.10 SNCR On

1/24/12 5:00:00 AM 196.08 SNCR On

1/24/12 6:00:00 AM 188.13 SNCR On

1/24/12 7:00:00 AM 167.47 SNCR On

1/24/12 8:00:00 AM 163.69 SNCR On

1/24/12 9:00:00 AM 204.70 SNCR On

1/24/12 10:00:00 AM 184.15 SNCR On

1/24/12 11:00:00 AM 134.22 SNCR On

1/24/12 12:00:00 PM 175.09 SNCR On

1/24/12 1:00:00 PM 179.87 SNCR On

1/24/12 2:00:00 PM 166.96 SNCR On

1/24/12 3:00:00 PM 155.04 SNCR On

1/24/12 4:00:00 PM 173.76 SNCR On

1/24/12 5:00:00 PM 169.36 SNCR On

1/24/12 6:00:00 PM 157.05 SNCR On

1/24/12 7:00:00 PM 177.28 SNCR On

1/24/12 8:00:00 PM 172.28 SNCR On

1/24/12 9:00:00 PM 158.79 SNCR On

1/24/12 10:00:00 PM 196.19 SNCR On

1/24/12 11:00:00 PM 161.20 SNCR On

1/25/12 12:00:00 AM 251.66 SNCR OnColleen McKaughan, October 2, 2014 Page 13

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Figure 6. Graphic presentation of NOx emissions (l b/hr) for January 3, 2014 (see associated

hourly averages in Table 6).Colleen McKaughan, October 2, 2014 Page 14

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 Table 6. Hourly NOx Averages for January 3, 2014
Date and Time NOx Hourly Avg (ppm) SNCR Status

1/3/14 1:00:00 AM 153.44 SNCR On

1/3/14 2:00:00 AM 150.14 SNCR On

1/3/14 3:00:00 AM 151.69 SNCR On

1/3/14 4:00:00 AM 151.10 SNCR On

1/3/14 5:00:00 AM 289.42 SNCR Malfunction

1/3/14 6:00:00 AM 304.72 SNCR Malfunction

1/3/14 7:00:00 AM 306.40 SNCR Malfunction

1/3/14 8:00:00 AM 261.90 SNCR Malfunction

1/3/14 9:00:00 AM 351.54 SNCR Malfunction

1/3/14 10:00:00 AM 400.68 SNCR Malfunction

1/3/14 11:00:00 AM 245.07 SNCR Malfunction

1/3/14 12:00:00 PM 312.04 SNCR Malfunction

1/3/14 1:00:00 PM 195.85 SNCR On

1/3/14 2:00:00 PM 190.27 SNCR On

1/3/14 3:00:00 PM 171.01 SNCR On

1/3/14 4:00:00 PM 185.01 SNCR On

1/3/14 5:00:00 PM 150.27 SNCR On

1/3/14 6:00:00 PM 142.76 SNCR On

1/3/14 7:00:00 PM 149.07 SNCR On

1/3/14 8:00:00 PM 151.02 SNCR On

1/3/14 9:00:00 PM 151.05 SNCR On

1/3/14 10:00:00 PM 149.20 SNCR On

1/3/14 11:00:00 PM 149.29 SNCR On

1/4/14 12:00:00 AM 152.66 SNCR OnColleen McKaughan, October 2, 2014 Page 15

Lhoist North America – Nelson Plant
P.O. Box 370 Peach Springs, Arizona 86434 Phone: (928) 769-2271 Fax: (928) 769-2305 SNCR control efficiencies were evaluated based on t he hourly average NOx summaries presented in Tables 1 through 6 above. These hourly averages we re calculated separately for the time periods when the SNCR system was malfunctioning and when the sys tem was on. The average NOx value for the time period when the SNCR system was malfunctioning was then considered as the baseline for the SNCR control efficiency calculations. The final calcula ted efficiencies are summarized in Table 7.

Table 7. Calculated SNCR Control Efficiencies

Date Average NOx -

SNCR Off (ppm) Average NOx - SNCR On (ppm) SNCR Control Efficiency (%)

08/28/2011 243.50 117.70 51.66

08/30/2011 270.98 155.70 42.54

12/02/2011 386.83 149.73 61.29

12/05/2011 307.45 166.58 45.82

01/23-24/2012 345.68 177.75 48.58

01/03/2014 308.97 158.99 48.54

Averages 310.57 154.41 49.74

The six time periods evaluated above show SNCR effi ciencies between 42% and 61% with an average of 49.74%. These efficiencies are comparable to the 5 0% control efficiency used by LNA in the Five-Facto r Bart Analysis presented to EPA. LNA selected the 5 0% value in the BART Analysis based on information provided by LNA’s corporate engineers familiar with the SNCR system at O’Neal and by LNA engineers in Europe who have experimented with NOx controls on l ime kilns there. LNA believes a 50% NOx control efficiency is reasonable and achievable at the Nels on Plant based on LNA’s experience with implementing SNCR systems for NOx control on lime k ilns at its facilities.

If you have any questions or need any additional in formation please do not hesitate to contact me. I can be reached at (928) 769-2271, extension 645104 or b y email at Herbert.Verville@Lhoist.com

.

Sincerely,

Herbert J. Verville Environmental Manager

# Attachment 3

UNIMIN presentation

# Mick Britton, Unimin Lime Corp. 

# NLA Environmental Committee Meeting

November 3, 2011

1

#  

# Preheater rotary kiln Title V limit:



# ◦ 3.2 lb NOx/ton lime

 

# NOx trending up

 

# Combustion modifications explored

◦ New KFS burner installed in 2006

 

# Calera Plant Goals:
1. Ensure continued compliance with current limit


# 2. F acilitate compliance with possibly more restrictive future limit 

# 3. Avoid NOx CEMS

 

# Decision: Evaluate post

- combustion controls

2

#  

# Mid Kiln Air Injection

 

# Selective Non

- Catalytic Reduction

3

#  

# Ambient air (typically 10% of theoretical combustion air) blown into kiln through 

# injection pipes, typically located 2/3 down the kiln from the burner

◦ Allows area between flame & air injection point to run with reducing atmosphere, which destroys NOx or prevents its formation

4

### 5

#  

# Mechanically vulnerable

◦ Motor & fan fastened to kiln



# ◦ Electricity fed through slip rings

 

# Repair of motor, impeller, injector nozzles or slip rings requires kiln shutdown

 

# NOx reduction rates variable

◦ Requires all elements to be in good working order

6

#  

# Reagent injected into kiln exhaust gases

 

# For systems using urea solution primary


# reaction is:



# CO (NH 2 

# ) 2 

# + 2NOx + 1⁄2 O 2 

# = 2N 2 

# + CO 2 

# + 2H 2 

# O

 

# Reductions up to 50%

 

# Mechanical & control elements located away from kiln

 

# Injection lances can be repaired on

- line

7

#  

# Ammonia Slip

◦ Unreacted ammonia reacts with SO 3 

# to form sticky


# ammonium bisulfite

– could coat bags

 

# Urea crystallization

◦ 32.5% urea solution must be kept above 30°F

◦ 50% solution must be above 70°F

8

# MKAI SNCR

Capital Cost Moderate Moderate

Operating Costs Low Moderate

NOx Reduction Effectiveness <30% <50%



# NOx Reduction Reliability Medium High

NOx Reduction Controllability Low High

Repairs 

# Costly

– Involve Downtime 

# Low Cost

–

No Downtime

9

#  

# Vendor: Combustion Components Associates (CCA)

 

# Seven stainless steel pipes installed in expansion joint of transfer chute during annual kiln maintenance, February 2010

◦ Kiln exhaust gases around 2100 ° F

◦ Residence time about 2/3 second

 

# Testing lasted two days

10

### 11

# 1. 

# Establish baseline NOx emissions using CCA portable monitor

2. 

# Increase u rea concentrations to identify level at which ammonia slip occurs

3. 

# Identify NOx reduction rates associated with 

# varying urea dilution & injection rates

12

#  

# 32.5% urea solution used because at this

concentration it:

◦ will not crystallize out until 12°F

◦ is readily available as it is used by over

- the

- road


# diesel trucks

 

# NOx reduction up to 50% achieved with no ammonia slip

13

# Two Urea Injection Lances

14

# Control Rack for Five of the Lances

15

# Water and Urea Pump Unit with

Urea Tote Behind

16

### 17

#  

# October 2010 Commissioning

 

# Trial lance location in expansion joint worked 

# so well that permanent system also located
there

 

# Same 3 objectives as with 2

- day trial

 

# Following commissioning Southern Lime adjusted urea addition rates to achieve
desired 10% NOx reduction:

◦ 14 gal/hr of 32.5% urea solution

◦ 40 psi dilution water pressure

18

# Urea Storage Tank

19

# Urea and Water Pump Skid

20

# Air Compressor

21

# Flowmeter Rack

22

# Urea Solution I njection Lances

23

### 24



# Control Screen

#  

# Week one:

◦ Buildup in injector rotometer tubes

 

# Two days later:

◦ R otometer floats jammed

◦ No flow in some nozzles

 

# Had been anticipated; not expected to manifest for several months

 

# Limescale removed with industrial grade vinegar

25

#  

# NOxOUT A = 50% urea solution with acidic additive

 

# 50% urea not used initially because salt

- out temperature is 62 ° F, requiring storage 

# temperatures above 70 ° F

 

# Permanent installation has heater pads in double



# walled storage tank and heater in recirculation line from urea pump, so ambient temperature below 

# 70 ° F not a problem

◦ One minor incident: Power failure caused urea pump to go 

# down for 15 minutes when ambient temp 17 °F; return line plugged with urea crystals. When heated, line cleared.

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#  

# Costs less per unit product than 32.5%
solution

 

# More readily available (truckers allocated almost all 32.5% solution)

 

# One caveat: substantial price fluctuation for 

# all grades of urea solution.

 

# Price for NOxOUT A

◦ Oct. 2010: $1.09/gal

◦ Mar. 2011: $1.95/gal

◦ Oct. 2011: $2.20/gal

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#  

# 8 gal/hr required to assure compliance (about 10% reduction)

 

# Reduced injection rate & lower unit cost of 50% urea resulted in operating costs 25% of 

# projected

 

# Bottom line:

◦ Capital costs: approx. $500K (Substantial amount of Capital cost was licensing fee. Patent has expired, so fee no longer payable)

◦ Operating costs: less than 0.5% per ton lime 

# produced

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# Clean Air Technology

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