MEMORANDUM
 

SUBJECT: Meeting Between Holcim and EPA Region 8/ ! • 

. . I /~ , / :J-·n· -fl-Jt..e FROM: Vanessa Hinkle, Environmenta 1 SCIentIst V[.vVLA.·/ "­ A 

TO: EPA Region 8 Montana Regional Haze FIP Docket 

DATE: June 5, 2012 

Holcim (US), Inc. (Holcim) requested a meeting with EPA Region 8 to discuss controls required 

by the proposed Montana regional haze Federal Implementation Plan (FIP) for their kiln in Three 

Forks, Montana. The meeting was held on June 5, 2012 and consisted of the following 

individuals representing Holcim: Greg Gannon, Hector Ybanez, Jason Morin, Bill Bumpers, and 

Debra Jezouit and the following individuals representing EPA Region 8: Carl Daly, Vanessa 

Hinkle, Mike Owens, and Steve Odendahl. 

Particulate Matter (PM) 

Representatives from Holcim stated that the PM limits and test methods were not consistent 

throughout the FIP. EPA Region 8 staff suggested that they review the correction notice that 

was published in the Federal Register on May 17,2012. 

Representatives from Holcim asked for an extension of the time period to comply with the PM 

standard so that it would align with their next stack test. Region 8 staff suggested that Holcim 

include their request in their written comments. 

NOx 

Representatives from Holcim stated that they installed a multi-channel burner and a fixed inlet to 

the clinker cooler in 2008 and that the baseline emissions in the BART analysis reflected the new 

emission rate. They stated that in 2009, there was discussion between Region 8 staff and Holcim 

regarding indirect firing. They explained that the petroleum coke system already employed 

indirect firing, but that the coal mill has not been converted to indirect firing. Holcim stated that 

they would provide copies of letters to Montana Department ofEnvironmental Quality (MDEQ) 

regarding the upgrades that were made in 2008. Region 8 staff suggested in their written 

comments, Holcim should describe the difference between the 2008 upgrades and the upgrades 

that Holcim estimated in 2009, quantify the emission reductions achieved, and explain the reason 

for the upgrades. 

Holcim stated that they believed Region 8's analysis for the percentage reduction for selective 

noncatalytic reduction (SNCR) was flawed. Holcim expressed concern that the data in the FIP 

did not demonstrate that all three Midlothian kilns had achieved a 50% reduction. They also 

explained that the Midlothian kilns had higher CO emission rates compared to the Holcim kiln in 
Three Forks and that CO could impact the amount of ammonia slip. Holcim also expressed 

concern that emissions limits reflecting application of SNCR be applied equitably. 

Holcim provided infonnation on SNCR application at their Hagerstown, Maryland kiln which is 

about twice the size of their Three Forks kiln. On that long dry kiln emissions were required to 

be reduced to 5.1 lbs/ton of clinker. The emission reduction calculated from a baseline average 

from 2006 to 2010 of 8.5 lbs/ton clinker resulted in a 38% reduction after six months of 

operation. 

Holcim expressed concerns with producing a detached plume and provided an example from 

their Hagerstown kiln. Region 8 representatives suggested that Holcim explain those concerns in 

detail and relate them to the requirements of the Regional Haze Rule and five factor analysis in 

their written comments. 

Holcim stated that they believe that they could achieve a 35% reduction with SNCR, but that 

SNCR should only be required when ammonia slip would not be a concern (wanner weather). 

They suggested the following options: 

•	 Requiring SNCR only during the wann months; 

•	 Establishing two emission limits: one when SNCR is used and another when it is not; or 

•	 Establishing an annual limit rather than a 30 day limit (that would reflect only using 

SNCR during wann weather). 

Region 8 suggested that Holcim review the BART guidelines regarding emission limits to 

ensure their written comments will be in compliance with those requirements.