--------------

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

NOV 1 7 2011 

Mr. David N. Bittel 

Arizona Portland Cement Company 

P. O. Box 338 

Rillito, Arizona 85654 

Dear Mr. Bittel: 

I am writing to infonn you that EPA Region 9 is developing a partial Regional Haze Federal 

Implementation Plan (FIP) for the state of Arizona. The purpose of the Regional Haze FIP is to improve 

visibility in national parks and wilderness areas in Arizona and surrounding states as required by Section 

169A of the Clean Air Act (Act). During the process of developing the Arizona Regional Haze State 

Implementation Plan (SIP), submitted to EPA on March 2, 2011, the Arizona Department of 

Environmental Quality (ADEQ) detennined that the Arizona Portland Cement facility was exempt from 

Best Available Retrofit Technology (BART) requirements. As part of the FIP development process, we 

will revisit that detennination, perfonning an analysis to detennine whether this facility is subject to 

BART requirements under section 169A(b)(2)(A) of the Act, and EPA's implementing regulations and 

BART guidelines at 40 CFR Part 51, Subpart P and Appendix Y. 

As we begin our FIP analysis, we have requested that ADEQ provide us with all background materials, 

including subject-to-BART analyses, that were perfonned by them or the affected facilities. We may also 

request that you provide us with additional infonnation on the Arizona Portland Cement facility as our 

analysis proceeds. In the meantime, we welcome the submission of any additional, relevant infonnation 

that you would like to provide to our office. Ifwe detennine that this facility is subject to BART 

requirements, we will perfonn a five-factor BART analysis to detennine whether any additional 

emissions controls are warranted. 

EPA has entered into a consent decree that requires the Agency to propose approval of Arizona's 

Regional Haze SIP and/or propose a Regional Haze FIP that meets the requirements of the Act and 

EPA's regional haze regulations by May 15,2012. The consent decree also requires the Agency to take 

final action on the Arizona Regional Haze SIP and/or FIP by November 15, 2012. EPA Region 9 will 

hold public hearings in Arizona and solicit public comments on a proposed Arizona Regional Haze FIP 

in the months preceding the November 15 deadline. 

If you would like to submit any additional information or analysis, we request that you send it by January 

31,2012. Any modeling of the facility should use the regulatory versions of CALPUFF (version 5.8, 

level 070623), CALMET (version 5.8, level 070623), and CALPOST (version 6.221). You may wish to 

prepare a modeling protocol and consult with EPA Region 9 about the preparation of modeling inputs in 

accord with EPA guidance. Submit any infonnation to: 
Thomas Webb 

US EPA (AlR-2) 

75 Hawthorne Street 

San Francisco, CA 94105 

You can also reach Thomas at webb.thomas@epa.go or by phone at 415-947-4139. 

Thank you for your attention to this matter. If you have any questions, please contact Thomas Webb or 

myself (mckaughan.colleen@epa.gov, 520-498-0118). 

;;;;~M~~ Colleen McKaughan 

Associate Director, Air Division 

cc:	 Henry R. Darwin, ADEQ 

Eric Massey, ADEQ