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

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# -fl-Jt..e VanessaHinkle, Environmenta SCIentIst V [.vVLA.·/ "­ FROM: 1 A TO: EPA Region 8 Montana Regional Haze FIP Docket DATE: June 5, 2012 Holcim (US), Inc. (Holcim) requested ameeting with EPA Region 8 to discuss controls required by the proposed Montanaregional haze Federal Implementation Plan (FIP) for theirkiln in Three Forks, Montana. The meeting was held onJune 5, 2012 and consisted ofthe following individuals representing Holcim: Greg Gannon, Hector Ybanez, Jason Morin, Bill Bumpers, and DebraJezouit and the following individuals representing EPA Region 8: Carl Daly, Vanessa Hinkle, Mike Owens, and Steve Odendahl. Particulate Matter (PM) Representatives from Holcim statedthatthe PM limits and test methods were not consistent throughout the FIP. EPA Region 8 staffsuggested that they reviewthe correction notice that waspublished in the Federal Register on May 17,2012. Representatives from Holcim asked for an extension ofthe time period to comply with the PM standard so that it would align with their next stacktest. Region 8 staffsuggested that Holcim include their request in their written comments. NOx Representatives from Holcim statedthatthey installed a multi-channel burner and a fixed inletto the clinker coolerin 2008 and that the baseline emissionsin the BART analysis reflected the new emissionrate. They statedthat in 2009, there was discussionbetween Region 8 staffand Holcim regarding indirect firing. They explained that the petroleum coke system already employed indirect firing, butthat the coal mill has not been converted to indirect firing. Holcim stated that they would provide copies ofletters to Montana DepartmentofEnvironmental Quality (MDEQ) regarding the upgradesthatwere made in 2008. Region 8 staffsuggested 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 explainthe reason forthe upgrades. Holcim stated that they believed Region 8'sanalysis 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 thatthe Midlothian kilns had higher CO emissionrates compared to the Holcim kiln inThree Forks and that CO could impactthe amount ofammonia slip. Holcim also expressed concern that emissions limits reflecting application ofSNCRbe applied equitably. Holcim provided infonnation on SNCR application at their Hagerstown, Maryland kiln which is abouttwice the size oftheir Three Forks kiln. Onthat long dry kiln emissions were required to bereduced to 5.1 lbs/ton ofclinker. The emission reduction calculated from a baseline average from 2006 to 2010 of8.5 lbs/ton clinker resulted in a 38% reduction after six months of operation. Holcim expressed concerns withproducing 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 ofthe 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 SNCRonly during the wannmonths; • 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 reviewthe BART guidelines regarding emission limits to ensure their written comments will be incompliance with those requirements.