Ash Grove Cement Company; Montana City Plant 

Wood, Thomas to: Vanessa Hinkle 11107/2011 06:45 PM 

Cc: "Curtis D. Lesslie (curtis.lesslie@ashgrove.com)" ,Sara Laumann 

From: "Wood, Thomas" <TRWOOD@stoel.com> 

To: Vanessa Hinkle/R8/USEPAlUS@EPA 

Cc: "Curtis D. Lesslie (curtis.lesslie@ashgrove.com)" <curtis.lesslie@ashgrove.com>, Sara 

Laumann/R8/USEPAlUS@EPA ._,"-'-"-'-'-- '~---""""""~--~_._--_. History: This message has been replied to and forwarded. 

Vanessa: Thanks for meeting with Curtis Lesslie and myself to discuss their 

Montana City response to your Regional Haze questions. Ash Grove understands 

that EPA is under tremendous time pressure and that the company's request for 

Confidential Business Information ("CBI") status for the October 5, 2011 

submittal creates timing issues for the agency that it can ill afford given 

the January deadline. Therefore, although Ash Grove considers the October 5, 

2011 submittal to include information it considers confidential, Ash Grove is 

willing to waive its request. This includes waiver of any CBI claim related 

to the modeling report submitted to you by Trinity Consultants on October 25, 

2011. In so doing, Ash Grove is not waiving its right to claim CBI status for 

future submittals, if any. We hope that this waiver assists EPA in meeting 

its deadlines. 

I also wanted to follow up on the discussion we had last Wednesday regarding 

the insignificance of the visibility improvements attributable to the S02 

controls. I understand that you have had a chance to discuss the modeling 

with Kasi Dubbs at Trinity and that she reiterated how little impact S02 

reductions have on the modeling results. As we discussed, we believe that 

semi-wet and wet scrubbers should not be considered technically feasible. 

Neither of these controls is in use at a wet kiln, such as the Montana City 

kiln and thus pilot studies and a tremendous amount of work would be required 

to determine how to adapt the technology to a wet kiln. As EPA stated in the 

Appendix Y BART guidelines, "we do not expect a source owner to conduct 

extended trials to learn how to apply a technology on a totally new and 

dissimilar source type." Given that these technologies are not in use on a 

wet kiln and that extended trials would be required to make the controls work, 

we do not believe them to be available technologies and, so, not technically 

feasible. Both technologies also are bad BART choices as they require large 

amounts of water in an area without available water resources. This is 

particularly true in relation to the wet scrubber, al~hough a semi-wet still 

consumes considerable water (roughly 2 million gallons/year) . 

Even if one considers the semi-wet scrubber to be technically feasible, we do 

not believe that there is a basis for considering a control that offers 

insignificant improvement over the control that Ash Grove is offering to 

install. Ash Grove is willing to install a dry scrubber ("DAA") on an 

experimental basis to see how it can be made to work. There is so little 

known about how a dry scrubber could work, that in discussion with EPA 

headquarters we are negotiating a testing process to determine the best the 

scrubber can do, rather than establishing a limit. The minimum performance of 

the DAA system is expected to be a 20% reduction in S02 emissions. By 

requiring the substantial extra cost and water consumption associa~ed with a 

wet or semi-wet scrubber, the visibility improvement gains would be only 0.16 

dv as compared to Ash Grove's proposed BART determination. As EPA said in 

footnote 28 of the final July 6, 2005 RH rule, "a 0.5 deciview change in 

visibility is linked to 'perceptibility,' or a just noticeable change in most 

landscapes." The difference in resources, both economic and environmental, 
between requiring a dry scrubber and a semi-wet scrubber is substantial. A 

semi-wet scrubber is projected to cost $12 million to install and $250,000/yr 

to operate. However, the improvement in visibility is one-third of the 

minimum perceptible change in visibility. We believe that regardless of the 

evaluation under the first four factors, the fifth factor mandates that there 

is too little improvement to justify requiring a semi-wet (or wet) scrubber. 

Ash Grove is not suggesting that it not do anything to improve visibility. 

The company has made great strides in the last two years to alter its process 

so as to reduce its 802 emissions. Ash Grove is also proposing the addition 

of SNCR, a baghouse and DAA. We believe that this package of improvements 

more than satisfies BART. 

Thanks again for your time and let me know if you need a more formal 

withdrawal of the CBI claim. 

Tom 

Thomas R. Wood 

STOEL RIVES LLP I 900 SW Fifth Ave, Suite 2600 I Portland, OR 97204-1268 

Direct: (503) 294-9396 I Mobile: (503) 349-4845 I Fax: (503) 220-2480 

trwood@stoel.com I www.stoel.com 

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