                             Summary of Meetings 
                          With St. Marys Cement (SMC)
                                       
Following the publication on August 6, 2012 of the notice of proposed rulemaking regarding Michigan's regional haze plan, EPA held three meetings with St. Marys Cement:
      
October 10, 2012 meeting
   	SMC attendees: Cortney Schmidt, Matt Gower, Celso Martini (by phone), Ann Straw, Fred Dindoffer (outside counsel)
   	EPA attendees: Douglas Aburano, John Summerhays, Jane Woolums, Dan Schaufelberger
   	Michigan attendees: Bob Irvine, Asad Khan (by phone)
   	Synopsis:  SMC presented its views on EPA's proposed BART requirements.  SMC asserted that the existing facility cannot achieve more than 15 percent reduction from selective noncatalytic reduction (SNCR) on a sustained basis, that the problems of material buildup that arise from use of SNCR could be solved by replacing the plant's pre-calciner, but SMC did not have the $18 million that such a project would require.  EPA noted the possibility of injecting lime to reduce the flue gas sulfur associated with material buildup; SMC responded that lime injection would not work.  SMC proposed that EPA set a limit of 4.85 pounds per ton of clinker, reflecting a 25 percent reduction from a value 3 standard deviations above mean emissions, to be achieved by reducing emissions 15 percent by SNCR and 10 percent by system changes.  EPA asked what system changes SMC contemplated;  SMC responded that it would investigate water injection, process control, staged combustion, and other options.  EPA primarily listened to SMC.

October 24, 2012 call
   	SMC attendees: Cortney Schmidt, Matt Gower, Ann Straw, Fred Dindoffer (outside counsel)
   	EPA attendees: Douglas Aburano, John Summerhays, Jane Woolums, Dan Schaufelberger
   	Michigan attendees: Bob Irvine
   	Synopsis:  SMC retracted its prior offer to achieve 25 percent NOx emission reduction.  SMC described a bypass system between its second and third stage preheater to reduce alkali in the flue gas.  SMC presented a graph showing that three standard deviations above and below the mean (in a normal distribution) account for 99.73 percent of the values.  EPA responded that the relevant statistic is not the percent of values within a set distance from the mean, but rather the total percent of values below a point the set distance above the mean, including all values down to zero.  SMC continued to characterize the value three standard deviations above the mean as the 99.73 percentile value.  SMC characterized SNCR efforts at its Bowmanville, Ontario plant as achieving 30 percent reduction with injection of ammonia with an equal molar ratio with flue gas NOx.  (This plant, identified as Plant A in a paper by Joe Horton of Suwannee American Cement (a sister company of SMC) was reported as achieving 53.5 percent reduction when tested with 0.56 moles ammonia per mole of NOx.)  SMC indicated that it believed that significant plant modifications in 1979, based on a February 1978 permit, meant that the plan as current configured was not operational in the BART eligibility period, so that the plant should not be considered subject to a requirement for BART.  SMC made arrangements with Michigan to visit the Michigan offices for historical information on the 1978 permit.

November 2, 2012 Meeting
   	SMC attendees: Celso Martini, Cortney Schmidt, Dirk Cox, Ann Straw, Fred Dindoffer (outside counsel)
   	EPA attendees: George Czerniak, Douglas Aburano, John Summerhays, Jane Woolums, Dan Schaufelberger
   	Michigan attendees: Bob Irvine (by phone)
   	Sypnosis:
   

