for pure CaCO3, the cost of limestone use would be higher than $25.5/ton
of SO2 removed, taking into consideration the impurities in limestone.

Page 28, DLI: The reagent for this system would normally be hydrated
lime (which is what is quoted in the example in the second-last
paragraph). The cost of $75/ton appears to be for pebble lime, not
hydrated lime.

Page 33, Table 9: Suggest that you resolve the following concerns that
have been taken from other analyses on kilns, especially the above
BART-related document:

SCR and SNCR may not work on all wet and long dry kilns.

Dry lime injection may not work on all wet and long dry kilns.

In many cases only a tail-end type SCR system, with requirement for
reheating of flue gas, may be required. This may result not only in
additional costs, but also additional air emissions, if fuel is used for
the reheating.

Spray dryer technology may also be used for kilns other than wet type
kiln. Depending on site specific factors, this may be a more viable
option.

Page 34, Process Modifications: It appears that the performance
improvement options that may help reduce CO2 emissions have not been
fully developed. Options that may improve performance of raw material
preparation systems and clinker grinding systems have not been mentioned
at all. While conversions from one type of kiln to another, more
efficient type have been covered, they have not been included in the
input file. Such conversions may not be viable at all sites. However,
such limitations are not addressed. Use of high efficiency motors is
included in the input file. However, such motors may already exist in
some (or parts of some) newer kilns. It appears that a study to identify
a reasonable level of performance improvement that would apply to most
kilns on an average basis would be highly beneficial.

Is there any plan for showing the indirect effect on air emissions of
changes in the electricity consumption caused by modifications required
by policy decisions at cement plants?

Attachment F

Review Comments from

Andy O'Hare, Portland Cement Association

EPA is in the process of receiving the peer review comments from the
Portland Cement Association.

Attachment G

Review Comments from

Hendrik van Oss, US Geological Survey

Hendrik G. van Oss, Cement Commodity Specialist

U.S. Geological Survey, Reston, VA 20192

January 29, 2009

I have broadly reviewed the ISIS document package that you sent to me on
a CD ROM (as well as the ancillary/replacement Excel tables). As I noted
to you earlier, I did not have time to run the actual software. I am not
trained in finance, so I have not looked at your costing algorithms in
detail.

Overall, the package is impressive—it represents a lot of work! I have
made a number of general and specific comments (see below), but,
overall, and assuming certain changes are made, I think that the project
will prove to be very useful in evaluating options/estimating the costs
of various (chiefly environmental-related) upgrades at plants.

General Comments

Editing

The text needs some editing, with especial attention to the use of
commas (you need more commas) and the common omission of the indefinite
article “the”.

The word “data” is always plural: thus “data are/were/show….”,
never “data is/was/shows…”.

There is no need to capitalize portland cement (c.f., Portland cement),
although it is certainly OK to do so.

The word “since” has a time context and should be avoided where the
meaning really is “because”.

Global

It is the U.S. Geological Survey, not U.S. Geological Service.

Very important: the U.S. Govt. has a mandate to use metric units as much
as possible. This report has taken data that are largely published as
metric tons (e.g., recent PCA data, USGS data, Census trade data) and
converted them to short tons. Then, in the text, you have always
provided a parenthetical conversion: “…9,217,487 tons (8,361,966
metric tons)…” –this is not only visually distracting (to the flow
of the text) but greatly adds to the length of the text. The use of
short tons in the tables has prevented me from conveniently checking
many of your data against my own (USGS) publications. I think that the
whole report (maybe not the Anderson addendum report) needs to be recast
in (only) metric units. One exception can be the use of Btus instead of
joules—as Btus are almost universally understood.

Use degrees Celsius (T°C), not °F.

All units, in all tables, must be defined. “Ton” does not imply
short ton.

All (certainly most) tables need to be checked to see that they include
citations for the data source(s).

As much as possible, avoid the use of acronyms in the text.

As much as possible, recast the equations into standard mathematical
notation rather than “computer printout” notation. For example: IPG
* CAPACITY ^0.4 is not as clear as it should be. Probably CAPACITY was
defined near the equation, as was IPG, and * is fairly universally
understood. But ^0.4 is not: is it the CAPACITY0.4 or is it CAPACITY x
100.4? At least define it somewhere.

Virtually everywhere, you use SO2, where SOx would probably be the
better term. But you could state that, for computational purposes, you
have used SO2 because it is “rigid” stoichiometrically and, in any
case, makes up the majority of the SOX. Ditto for CO2 including CO.

In many places, you have used PCA data instead of the USGS data. In some
cases, this is fine—the PCA does its own survey of energy use & plant
capacity (and the USGS holds all plant-specific data proprietary). But
you may wish to point out to the reader (potentially familiar with both
data sets) that there are some important differences. On the kiln count,
for example, the USGS counts all kilns active for at least 1-day during
the year, whereas the PCA only counts the kilns that were active at
yearend (we count 183 kilns in 2005, the PCA just 181). Many of the PCA
energy data exclude white (portland) cement, whereas these are included
in the USGS data. The PCA provides the cement companies with heat
conversion factors for the various fuels, whereas the USGS asks the
industry to directly supply the Btus realized (at whatever HHV (gross
heat) conversion factor the plant normally uses). Any State-level (and
USA overall) consumption or production data published by the PCA are
taken from USGS data and you should cite the USGS for such data, not the
PCA.

Avoid using MM for million, just use M. I think this is an issue only
with your Btu discussions. In my experience, M for thousand survives in
the world only in old Latin texts and for Copyrights, and in billing for
natural gas (MCF).

Somewhere, you should discuss the issue of data accuracy. In general,
the cement industry calculates, but does not weigh, its clinker and
cement production. They weigh their sales, however! In many places, data
ought to be rounded. Few data reported are good to better than +/- 1%.

Specific Comments

Summary

The summary is a little casually written. Although it is debatable as to
what constitutes “pyroprocessing,” it is generally more applicable
to the combination of calcination and sintering (clinkering), and not so
much to preheating and drying.

You talk about “criteria pollutants” and HAP almost as if they are
interchangeable. It reads as if NOx and SOx are HAP.

The Summary seems to lack discussion of CO2—you need to at least
mention it (and then you can say that your cost modeling was confined to
NOx and SOx.

Sec. 1.1

Introduce this with portland and blended cement (both are used in
concrete), and then state that you will focus on portland. But be
careful: the USGS monthly data (1/98 onwards) split out the two (Table
2a vs. 2b) and they should be added together for discussions of
consumption. I do not know if the PCA, in using our data, has combined
these in all cases. The USGS annual data includes blended cement within
the portland umbrella. The annual report (Mineral Yearbook) shows the
combined monthly sales (consumption) data in Table 9.

Para 1: say calcium aluminate hydrate, not calcium aluminum hydrate.

Sec. 1.1.1

“….rotary kiln…cylindrical furnace…”—I presume that the
latter is an explanation of the former, so put it in parentheses. The
material temperature is generally taken to 1450°C, not 1500°C (white
cement kilns probably do bring the material to 1500°C).

“…the heart of the process generally is the rotary kiln….”

The low end of the length range would more typically be c. 150 ft for a
precalciner kiln of c. 0.7 Mt/yr capacity.

You state that the kiln is fired at the lower end, but you might wish to
also mention midkiln firing.

The term “clinkerization” is not much used; more commonly, you see
“clinkering” or “sintering”. (Also “burning” but this is to
be avoided as too ambiguous).

Very important (Global): it is certainly OK to distinguish wet vs. dry
kilns. But it is NOT acceptable to use “dry” to mean (only) a dry
kiln lacking a preheater and/or preheater/precalciner. You should call
this type of kiln a “long dry” kiln. The 3 general categories for
dry kilns are: 1) long dry kiln; 2) preheater kiln; 3)
preheater/precalciner kiln (which, after spelling out the first time,
you may shorten to precalciner kiln).

(Semiwet vs. semidry: frankly, these kilns can go either way. If the
kiln has a preheater and/or precalciner, the USGS lumps them within the
overall Dry kiln category. I am aware of only 1 plant of this type
(Buzzi’s Greencastle, IN plant).

Figure 1-2: in the caption, you might want to state that the schematic
for a precalciner kiln would be essentially identical.

Table 1.1: The data are typical averages, but are not universal. The
reader may think these are fixed data. The EPA source sited likely used
either USGS or PCA data.

Global: if at all possible, avoid using PC for “precalciner” as it
is a common acronym for portland cement.

p. 1-5: last para: make sure it is understood that “smaller” means
lower capacity, not smaller dimensions on the kiln tube.

I would note that the USGS Minerals Yearbook chapters on cement (MYB)
also allow the average capacity to be discerned: it would calculate as
0.577 Mt/yr (million metric tons per year) in 2005 (MYB, table 5).

It may be useful to discuss what is meant by “capacity” anyway!
Daily capacity means per 24 hrs (and implies 24 hrs of continuous
operations) and is more or less unambiguous…except that you don’t
know whether the cited number is the manufacturer’s rating on the kiln
(usually a conservative figure), or actual “full blast—but normal
operating—conditions. Commonly, the rated capacity is lower than the
actual operational capacity. Annual capacity is not well defined. The
USGS calculates an “apparent annual capacity” as follows:

Apparent annual capacity = (Reported daily capacity) * (X-Y) where:
capacity is in tons; X is 365 days (or 366 in leap years) and Y is the
number of days of downtime for routine, scheduled, maintenance. Thus,
(X-Y) is the scheduled operational year. The PCA, I believe, uses the
same formula, but (in my opinion) does not always check to distinguish
routine maintenance downtime from total downtime. Clearly, there can be
a large variation in apparent annual capacity if there is any
mischaracterization of the routine maintenance downtime or the daily
capacity. The USGS calculates—for the plant overall—the capacity
utilization wrt. the actual clinker output: we query (question) any
utilization percentages in excess of 100%.

Because there is commonly downtime in excess of routine maintenance
(extended upgrades, shutdowns for unplanned repairs…), the USGS feels
that a utilization rate of 85% or more represents full practicable
capacity operations.

[The industry reports to the USGS, for each kiln, the daily capacity,
the total downtime, the subset downtime for routine maintenance, and the
remainder for “other downtime”. We also ask for the dimensions of
the kiln, whether it is wet or dry, whether it has a preheater, whether
it has a precalciner, and whether dust control is via a baghouse or an
ESP.]

p. 1-6: Figure 1-3: the color scheme would be improved by using blue for
wet and red(dish) for dry. Cite the data source.

Para 1 below Figure 1-3: Here’s where you are tripping over your
misuse of the term “Dry” kiln. First, our table 5 did show 16.3%
from wet plants, but this is NOT quite the same thing as saying that wet
kilns did 16.3% of the clinker. This is because there is a separate line
for the relatively small output from “combination” plants (those
that operate both wet and dry kilns). Likewise, the 11.8 Mt of clinker
form Dry plants understates the output of the dry kilns because a couple
of these are in the line for combination plants. And you misstate the
11.8 Mt “Dry” as being from dry kilns lacking a preheater or
precalciner. Not so—the datum is for dry plants of all 3 types (long
dry, preheater kilns, preheater/precalciner kilns).

The USGS, not the PCA, should be cited as the source of the value data
and the consumption numbers. For 2005, portland cement sales to final
customers (these are the data that the PCA calls “consumption” were
worth $11 billion; masonry cement sales $0.68 billion; total about $12
billion.

Cite the USGS also for the statement that the top 10 cement companies
had 80% of the production; ditto for all production by State data.

Figure 1-4: this plant location map is incomplete because it fails to
adequately discern localities with more than one plant in a cluster. For
example: WA has 3 plants (2 integrated plants @ Seattle and a grinding
plant at Bellingham); CA has 11 plants; FL has 6 plants, etc…

p. 1-7: your discussion of imports is misleading: imports can be by
domestic producers seeking to feed markets where domestic (particularly
their own domestic) production is inadequate (or where they wish to
capture market share) AND by independent importers who compete against
domestic production in some markets, and help feed markets not easily
serviced by domestic production.

Oddly enough, there is a lot of flexibility in how the industry views
the cost of imports vs. cost of local production. A company might
continue to import—even at a loss or minimal profit—for at least a
while if this is the only way they can keep their customers happy (i.e.,
not going to another supplier).

The existence of imports can affect where domestic production is
targeted for marketing. A good example is the Los Angeles basin: a big
chunk of the demand there is met by imports, which then free up a lot of
the actual S-CA production to be sent into the Las Vegas market and, to
a smaller extent, into Arizona.

Table 1-3: The data in this table represent U.S. Census trade data (as
supplied to and then compiled by the USGS). The original data were in
metric tons. DO NOT CONVERT THESE TO SHORT TONS!!! Also, as best I can
tell, the data are for imports of “hydraulic cement and
clinker”—meaning, all types of hydraulic cement, and all types of
hydraulic clinker--so they are not just portland cement imports. This
(cement and clinker) issue applies, I think, to all import data that you
use in this report and represents a fairly serious problem for your
model.

The percentage column needs clarification: percentage of what (USA total
imports).

Figure 1-5 needs a citation for the data source (USGS I presume). The
curve for import share is misleading and represents a problem with the
USGS data: we compare the level of cement imports to that of total
consumption (apparent consumption calculated as cement production +
cement imports – cement exports – change in cement stocks). We
exclude the imports of clinker because the production of cement includes
cement made in the USA from imported clinker. But we do not include
changes in clinker stockpiles (but should) mainly because we did not
collect such data prior to a few years ago. Done “properly” the
import reliance would be 1-2% higher than what we show currently in the
data series.

Another related issue is the cement stockpiles: the comparison is
between successive yearend (12/31) stocks. But you could have a
significant drawdown or buildup due entirely to the early arrival or
late arrival of a few ships—this would cause a stockpile shift
entirely UNRELATED to any economic forces. So I do not find apparent
consumption to be a very useful statistic.

Sec. 1.2: Emissions

Para 1: a bit clumsy explaining where S comes from—it is from
sulfur-bearing compounds in both the fuels and the raw materials. Many
organic compounds (in fuels) contain sulfur, as do kerogens in
sedimentary rocks like limestone. Both fuels (especially coal) and raw
materials can contain sulfide minerals (chiefly pyrite or marcasite);
and sedimentary rocks may contain sulfates like gypsum.

If you are going to quote the total weight of PM10 emissions, put it in
the context of something—such as the weight of the total raw materials
and fuels.

Figure 1-6 is small to the point of uselessness. Why not make it into 3
Figures (1-6a, 1-6b, 1-6c)?

The text in this area ought to mention CO2. In fact, the whole section
is awfully brief—but perhaps you could refer the reader to the
discussion in the Appendix.

Sec. 1.3: ISIS

Figure 1-7: should you add (flowsheet box for emissions) HAP and PM?

References: I am always a bit nervous when I see the USGS Mineral
Commodities Summaries cited—these are “quick & dirty” summaries
that are meant to be just that. We prefer, where possible, that data be
obtained from the Minerals Yearbook, as this is a MUCH more
authoritative publication.

Ch. 2: Data used in ISIS

<IP_ADDRESS>: The USGS has a kiln count of 183, not 181 (=PCA number?)—but
the difference is likely kilns active during year (183) vs still active
at yearend (181).

Figure 2.1: I suppose that your market grouping has its virtues, but
there are some very strange groupings re. the cement plants. For
example:

Why on Earth is Ash Grove, Leamington, UT grouped into Phoenix, but
Holcim Devil’s Slide is Salt Lake City? Let me assure you that the
Leamington plant feeds markets primarily in UT (incl. SLC) and NV (Las
Vegas) (plus v. minor tonnage, only, into CO and NM; nothing into AZ).
In Las Vegas it competes with the S-CA producers. Why is Ash Grove,
Durkee, OR grouped with Salt Lake City—its market is primarily OR, WA,
ID.

Some plants straddle more than one markets: Lafarge’s Sugar Creek, MO
plant can indeed feed westward into the Kansas City area, but it also
ships a lot of cement down the Missouri River (i.e., eastward).
Buzzi’s Cape Girardeau plant probably has the widest geographic
dispersal of its cement than any other plant.

Overall, there are all sorts of flows up and down, in and around, the
entire Mississippi-Missouri-Ohio River system. Not sure some of these
market breakouts in the midcontinent make any sense.

<IP_ADDRESS>: The 2005 demand for portland in 2005 was 122.4 Mt (million
metric tons), and for portland + masonry, it was 127.9 Mt. Thus I
question the 127.6 portland number in your report.

I would urge extreme caution in using the PCA demand forecasts. First,
they change them at least quarterly. Second, it is likely that you have
used reports predating the recent collapse of the economy. Cement sales
fell nearly 10% in 2007, another 10-11% in 2008, and will likely drop
around 15% in 2009. The PCA has revised its forecasts downwards.

The fall in sales in 2007 was accommodated by a huge drop in imports and
just a small drop in production. There was less flexibility in
2008—imports continued to plummet, but production has fallen
substantially, as well. Both will likely fall further in 2009.

Secondly (and related), we have had plant closures in 2008 (I think 3)
and announcements of about 7 more in 2009, and all/most but the most
advanced expansion/greenfields projects are now on hold or have been
cancelled. American Cement’s (FL) brand new plant is just sitting
there; the kiln as yet unfired. Sumter Cement (FL) is on indefinite
hold. Votorantim near Macon, GA will likely never materialize. Titan in
NC will likely be delayed. Cemex at Seligman, AZ was probably never more
than a bluff, anyway. Ash Grove at Moapa (Las Vegas) was cancelled a
year ago.

Of the closures, it is as yet unclear how many are permanent—but the
closures include Buzzi’s Independence, KS plant and Fredonia (I
think), St Marys Dixon, IL, plant, Holcim’s Dundee, MI and
Clarksville, MO plants (both are wet plants), Cemex @ Brooksville, FL;
TXI at Crestmore, CA and, temporarily, at Oro Grande; Cemex at
Davenport, CA (likely temporary); some of the kilns at TXI (or was it
Ash Grove) @ Midlothian, TX; Essroc at Frederick, MD (no surprise--is
due to upgrade project at their nearby Martinsburg, WV
plant)…etc…And lots of plants are taking extended maintenance
shutdowns, which augurs for lower capacity utilization percentages in
2008 and 2009. So any forecasts of capacity growth would be of dubious
merit, at the moment; you need to use caution in relying on the PCA
forecasts.

Table 2-3: put the data back into mt. Data include clinker. These are
U.S. Census trade data (the USGS just compiles them into convenient
tables).

p. 2-5: Cement plants can certainly be older than 50 years! There is a
definitional issue. You could have had a cement plant on site for nearly
a century, but it may have been upgraded along the way. Generally, you
wouldn’t build a plant on a site having < 100 years of limestone
reserves. So the age can be a “site age” or an “equipment age”.

Avoid like the plague the use of the word “endogenous”. The phrase
“…ISIS endogenous capacity growth can also lead to endogenous
retirement of kilns.” conjures up all sorts of imagery unrelated to
cement…Couldn’t you just say something like: “capacity expansion
projects can include the retirement of existing kilns…”?

p. 2-6: “…such as coke…” Be sure specify petroleum coke
(petcoke). Our old tables showed for many years just “coke”, then we
attempted to differentiate petcoke from metallurgical coke (i.e., from
coal) without much success (not sure the respondents understood the
difference). Likely that all coke use (outside of major
blast-furnace/steel complex areas) has been of petcoke, and I am not
sure that metallurgical coke has ever been in common use even in the
steel areas—it’s too expensive.

Figure 2-2: awfully crude breakout of fuels. Where’s the petcoke (in
with the coal???). What is “Petroleum”---do you mean petroleum
products? Crude petroleum? If the former, do you just mean distillate
and/or residual fuel oil, or do you include all sorts of waste oils and
other petrochemical waste fuels? Where are the alternative fuels?

Also, do the percentage data refer to tonnages or to the heat
contribution (Btu)?

If I use actual industry-reported heats, my own data for 2005 show:

Natural gas (3.72% total Btu); fuel oil (0.76% [seems low]); coal
(64.1%); petcoke (19.3%); metallurgical coke (nil); tires (3.2%), other
solid wastes (0.5%); liquid wastes (8.4%).

Your report cites total heat (EIA) of 451.2 trillion Btu. My (USGS) data
for 2005 has 366.7 trillion Btu excluding electricity, or 375.4 trillion
Btu if I impose some “standard” heat conversions for the fuels.
Using actual data, if I include the electricity, then we jump to 413.4
trillion Btu. Thus, I suspect that the EIA data are either too high or
that they, at the very least, include electricity. Based on the rest of
your report, I do not think that you should be converting electricity
(kWh) into Btus; use the Btus just for the fuels burned at the cement
plant. That is, skip the electricity (in your heat analysis).

Table 2-4: shouldn’t these data match those of table 1-1 (or vice
versa)?

Important: as you may realize, the PCA data on unit consumption of heat
(Btu/mt—and be sure you know which ton they are using!) generally are
based on an “equivalent ton” which is a bit of an apples & oranges
mix. At one point, years back, I figured out why they use this, but I
have forgotten and they seem to have forgotten as well. You can
recalculate to a per-ton-of-clinker basis, but I do not know if you have
done this in table 2-4.

Also, I don’t recall the PCA’s Labor & Energy surveys mentioning gas
flows—so it is unclear if the NM3/kg data are from the PCA or some
other source. PCA 2004 (Bhatty et al.) is a huge tome (very good book!),
so you should cite the actual page(s) from which the data are taken.

Table 2-5: define “mg” (milligram or microgram?)

See my earlier comments on SOx. Regarding NOx, I thnk you should note
that it is extremely difficult to get precise data on NOx outputs, given
that output varies (wide swings) minute-by-minute. But your averages for
NOx and SOx are reasonable.

While I agree that raw materials play a significant role (and hence
there can be regional trends) in the SOx emissions, it really applies to
the potential emissions (actual emissions also vary with scrubber
technology, if any, kiln technology, and, of course, the fuels). Coal is
hugely important—is the plant burning a low- or high-S coal?

p. 2-8. Your calcination emissions factor of 0.53 t CO2 per ton of
clinker is slightly too high. Instead of adopting this Andover
Technology default (see my comments on Appendix A) you should use the
IPCC default (which is what the EPA usues for the USA GHG Inventory. The
Andover Technology average CaO content for clinker is a bit too high.

So use 0.51 or 0.52 (the latter includes a 2% addition for “lost”
[not returned to kiln] CKD).

The average CO2 emissions per ton of fuel noted in this section should
be rounded! Remember, fuel consumption data are not all that precise,
and one is never told if the reported weight is on a dry basis (as in
lab-dried), standard dry basis (i.e., actual dry feed to
kiln—typically has several % moisture), or is some wet slop at an
initial handling point. Further, one can ask for—but the reporting may
not always be—as gross or high heat. You may be getting net or low
heat.

These are among the (many) woes of data collecting!

Table 2-7: I’m not sure you’ve made clear why you are showing H2O
production.

Table 2-8: low-NOx burners are great, in theory, but lots of plants
report problems in their actual use (have lower clinker output when
using these burners).

Ch. 3: ISIS Mathematical Framework

p. 3.2: the factor: produ_r(t,r)/0.92 has a clinker ratio
(clinker/portland) of 0.92. This is too low for a good average. Even
including the blended cements and masonry cements, the USGS data show
the ratio to be right on at 0.946-0.950 (you can’t ignore these
cements because the USGS raw materials data is for portland & blended
cement). Anyway, 0.92 implies 8% gypsum and/or other additions, and this
is too high right now. If the up-to-5% limestone addition becomes
widespread (current version of ASTM C-150), then 8% may become
reasonable.

We can approach a 92% clinker factor hypothetically if we assumed that
we had a 95% market share for true portland cement @ 95% clinker + 5%
gypsum, and 5% market share of masonry cement averaging 50% clinker
(this is probably a bit low): (0.95 x 0.95) + (0.05 x 0.5) = 0.9275.

Again, the import data that you are using appear to be for both cement
and clinker.

The factor imports (t,r) is likely prone to large error because we
simply do not know how much cement coming into a certain Customs
District is consumed in that district. For example, there is
considerable barging of cement along the midAtlantic and Gulf Coasts;
ditto along the NW (Pacific) Coast. One of the few places where the
assumption (of local consumption) is valid is Florida. The worst case is
with New Orleans: imports into New Orleans can reach Chicago!

And then we have the whole issue--sadly, very common--of cement swaps
among companies.

Production and Capacity Changes: the lead-in sentence is a bit unclear:
“Regional production can be from existing kilns, kilns added at a
plant (i.e., expansion kilns), newer kilns replacing kilns at a plant
(i.e., replacement kilns), and new kilns.”

I think you mean to say something like: “…Future
production…existing kilns, upgrades of existing kilns
(debottlenecking, major technological upgrades), new kilns at existing
plants (perhaps replacing existing kilns), and new plants altogether.”

Here’s how I look at things:

Present kilns		Production?		Future production

Idle kilns:		No			Maybe will be restarted

Active			yes			yes (same capcity); and/or

						Upgrade kiln line; modify feeds (eg CemStar); and/or

						Debottlenecking; and/or

						New kiln at existing plant;

						Shut down old kiln; and/or

						New (greenfields) plant.

It is unclear if your discussion, and projected capacity changes, fully
account for plant shutdowns (now seen to be a much faster schedule than
was anticipated even 1-2 years ago). Have capacities been
properly/uniformly defined for all new kilns (are they summed on the
same basis)?

p. 3.2-3.3: Equation 3.1.3. for regional demand: I suggest using the
word “flows” instead of “trade” when referring to inter-State or
inter-market movements of domestic cement.

Equation 3.1.4 only holds if the import: total demand ratio is accurate,
and I’m not sure this is the case. Again, I would note the fact that
imports into the New Orleans Customs District feed the entire
Mississippi-Missouri-Ohio river system. How are you determining where
cement imported at location X is being consumed?

p. 3-3: the price data for imports (Equation 3.2.5.) are very weak. You
only have import values reported on a CIF basis (USGS monthly and annual
reports) and Customs Value (USGS annual reports). The CIF value does not
represent the actual price because it has not yet been offloaded from
the ship: that is, the true price is CIF + various port charges +
markup.

And the CIF (and Customs) value data themselves are full of errors: sad
but true. Not much that can be done about this.

Much of Ch. 3 is not exactly reviewer-friendly (!) and I really was
unable to do much with it absent detailed experience with running the
actual model.

Ch. 4: Calibration of Cement ISIS Model

<IP_ADDRESS>. I am not sure that the assumption that Priceimports = producer
price is at all valid. Dumping issues come to mind. I have found that
imports can be cheaper, the same, or higher than those from “local”
producers. One issue is transportation costs. Another may be differences
in the type of portland cement: local production might be Type I and the
imports Type III. One thing I will say is that “cheap” imports do
not necessarily equate to cheap sales prices—importers are very fond
of large margins.

You cite a VERY limited number of examples of import-dominated markets,
and without really defining what this means. What is the percentage
criteria for this designation? Seattle may not be an especially good
example.

USGS data for 2005 (MYB Table 9) show consumption in WA as 2.348 Mt and
OR as 1.237 Mt; against imports into Seattle Customs District (CD) of
1.489 Mt and 0.867 Mt into the Columbia-Snake CD. This looks like a high
import ratio, but do you really know where these imports are being
consumed?

Again, things fall apart for New Orleans and points upstream.

Table 4-1: why 2004 data and not 2005? Again, switch to metric tons!

What is the basis of the production data in table 4-1? The USGS data do
not allow for it, as our District groups do not match your market
groupings. The PCA normally does not publish production data other than
in broad groupings (kilns > 500,000 tpy, etc…).

High import ratios exist for Florida, Los Angeles, San Francisco, San
Antonio—yet the table designates (**) only Florida and Seattle as
having high ratios.

<IP_ADDRESS>. The PCA may have predicted higher import ratios in the future,
but hey certainly have fallen in 2007-09 and likely will stay down in
2010 as well. Thereafter, I venture not.

Table 4-2: where are you getting your price data; and why are you
showing 2003-2004 and not 2005? Need to cite a data source.

Table 4-3: The emissions shown are too precise.

Ch. 5: Illustrative Analysis

Figure 5-1 and the discussion of it lead to the conclusion that the NOx
cap may be too restrictive. Whether this is valid or not, however, is
hard to determine. Apart from the difficulty for a plant in precisely
controlling NOx emissions, in typical operation, the emissions from a
given plant typically swing rather widely on a minute-by-minute basis.
Because of this, it has always been an issue as to how one is to
determine the actual emissions volumes over a specified period, as it
could affect whether a plant exceeds its NOx cap or not. I think this
report needs to discuss this.

In contrast, Figure 5-2 would seem to illustrate the relative ease in
controlling SOx.

Figure 5-3: Figures should stand alone—thus it is confusing why the
emissions caps and banking are not shown (I know the answer—just, for
now, leave these off the caption).

I do not know if the projections in Figure 5-3 have made allowance for
clinker imports and changes therein.

Given a likelier harsher reality re. plant closures, these projections
may need to be redone.

5.1.2.: In the text, it is important to minimize the use of acronyms,
especially for readers not conversant with these technologies. The
savings of space are not that much!

One important issue with CemStar is that steel slag may not be available
locally.

Figure 5-4 is impossible to read for those of us equipped with standard
or substandard human eyesight. After staring at this long enough, I am
left wondering as to why there is such a huge drop in LNB + TDF in 2011
wrt. 2010. Are the subsequent (2011--) years in addition to the 2010
levels? (i.e., are they just shown as margins?). Was their a scale
change post-2010?

5.1.3: The total demand in the near term has now likely been revised
downwards by the PCA.

Figure 5-5: it is not immediately clear why the red dot has been
displaced rightwards (I can guess, but it looks strange). And what
happened to the red dot for 2025?

Looking at this figure, I do not see much difference between the base
case and the policy levels.

Figure 5-6: Unless I am missing something, the blue dots are not needed
at all—the sum is always the top of a stacked bar graph. The Legend is
confusing, as I only see one market that has either a trade-in or
trade-out (and, again, I would urge calling this an inflow or outflow)
and that is Birmingham. Surely, there are more intermarket flows than
that! And the data for imports are either essentially all missing or you
are projecting zero imports. I do not understand how you have determined
the (foreign) imports into the various markets—such as Dallas. The
trade data for that area are under the Houston-Galveston Customs
District, which is in your San Antonio Market area (yes?). Why are no
foreign imports shown for Birmingham? Florida???, Phoenix?? St. Louis??

So this figure needs some work….

5.1.4. the cost analysis seems to show that, of the total increase in
costs ($1.58 billion), all but $0.01 billion is due to control
technology. What about increased fuel costs?

Ch. 6: Summary

Basically OK. Perhaps you need to again mention here here why CO2
emissions could drop under SO2-reduction strategies (somewhere earlier
it was stated that there could be decreased CO2 using limestone wet
scrubbers (LWS)—it is unclear why this would be so. I would think that
reduced CO2 would instead be—as stated elsewhere—from changes in the
fuel types that might occur in a SOx-reduction program.

Appendix A: Staudt, Jim, Andover Technology Partners, “NOX, SO2, and
CO2 emissions from Cement Kilns”:

This is a rather good report with a few places that bothered me.

Table 1: the exit flow gas rates would show a lot of variation; not sure
how “good” an average these rates are. By the way, Bhatty et al.
(PCA 2004) cited is a huge volume, so a page reference would have been
helpful.

Table 2: although the heat values shown are reasonable, it should be
pointed out that, in reality, most fuel categories have a range of heat
values, and that it is NOT guaranteed that the coal burned by plant X in
year Y will be the same coal as burned in year Z. Further, the reporting
of fuels by cement plants has problems, among which are:

who is reporting: a lab technician, a plant manager, a
controller/accountant? Same person each year?

is the weight of (e.g., coal) the actual weight going into the kiln? In
it expressed as the actual mass or converted to a constant moisture (>
0%) content basis or to a zero moisture basis?

Is the heat value provided or not? If so, is it a gross (= HHV) basis or
net (LHB) basis?—the former is preferred for emissions calculations.

Is the heat value provided as a Btu/st (or other unit) ratio (USGS then
multiplies it out), or did the plant report the full Btus? If the former
(Btu/t), was it “real” or simply calculated by the plant: tons x
Btu/t = Btu – and if so, was the same Btu/t used for all the coal used
during the year, or were periodic checks/adjustments made to the Btu/t?

for whole-tire fuel, the moisture content can vary dramatically.

Have any waste fuels been identified properly: if no heat was provided,
how do you impose a heat estimate for “liquid waste?”
(undifferentiated). How about for an identification given simply as:
“used solvents?” Or “off-spec oil and lubes, inks, and
solvents”. What about things like: “(solid wastes: oily rags, street
sweepings; contaminated soils)”. Or even “high-carbon fly ash”?

These are significant problems because the carbon factors for fuels are
generally expressed as “ amount of carbon per X amount of heat”

Anyway, I would also comment that the values in Table 2 are expressed
with more precision than is warranted.

From table 2: coal at 12,456 Btu/lb becomes 27,460,772 Btu (HHV)/mt and
26,340,824 Btu (LHV)/mt. USGS data (asked for as HHV) typically show a
range of 22-28 MBtu/mt. So table 2 appears to be at the upper end of the
range.

CO2 from calcination: Although Staudt’s calculation is arithmetically
sound (within rounding parameters), I do not like the default he derives
(0.53 t CO2/ t clinker) because it is based on an average CaO content of
clinker of 67.6%. This is too high—it is near the upper end of the CaO
range in modern clinkers. As was exhaustively dealt with by the IPCC,
the average is a bit lower. No great precision is justified owing to
variation in the chemistry of clinker at various plants and among
plants, but 65% is a better, more useful average. This drops the default
(using the same assumptions as to CaO source) to 0.51. If you
incorporate the IPCC-suggested 2% additional CO2 for CKD “lost” (not
returned to the kiln) to the system, it becomes 0.52%. Neither protocol
adjusts for MgO contributed from a carbonate source, but this is OK
because the assumption that the CaO is 100% from CaCO3 already causes a
compensating overestimate; MgO is always kept low anyway (0.5-2%; seldom
higher), and MgO is commonly from silicate phases instead of/in addition
to a carbonate phase.

In any case, the EPA in the USA GHG emissions inventory uses the IPCC
default (w/ CKD) of 0.52 and I would suggest that the ISIS model do the
same.

It should be noted that the CaO content of the actual “limestone”
burned by the cement industry varies a lot, both across country and even
within some individual quarries. Staudt has been incautious in equating
“limestone” and calcium carbonate (calcite): the former is a rock
mostly made up of calcite; the latter is a mineral of formula CaCO3. His
stoichiometry applies to calcite or calcium carbonate, not to limestone.

least efficient → 4 most efficient) as follows: total heat (total fuel
consumption): 1 wet→ 2 long dry → 3 preheater → 4
preheater/precalciner (precalciner). Electricity: 1 precalciner → 2
preheater → 3 long dry → 4 wet. But we see other patterns: for two
plants of 1 Mt/yr capacity where each has similar technology kilns, a
plant having a single kiln will be more efficient than the plant with
multiple kilns. This relates not only to economies of scale but, for
electricity, on the fewer motors needed for the single kiln.

p. 8: while it is true that, to some degree, flame temperatures in
precalciners may be a bit lower than in the kiln tube itself, the
different proportion of NOx type (mostly thermal NOx in the kiln tube;
mostly fuel and/or feed NOx in the calciner) also derives from the fact
that: 1) the burner for the calciner generates a shorter flame, which
may reduce thermal NOx, and the calciner is dealing with higher surface
area particles, so does the calcining far more efficiently than the kiln
tube could do. Thus there will be less NOx overall for the calciner on a
per ton of clinker basis. And, because of this efficiency, the kiln tube
itself will be smaller on a precalciner kiln line, which makes for
better efficiencies all around (for example, reduced heat loss through
the kiln shell).

The higher NOx/MBtu for wet kilns mentioned by Staudt may also be
related to the fact that wet kilns these days almost invariable burn a
relatively high proportion of waste fuels. Also, there could be some
correlation with things like the use of primary vs secondary air. And,
many of the wet plants operate multiple kilns. And, being older, and
larger tubes, with more motors/tires (hence kinking), there may be more
frequent stoppages, hence more use of warmup fuels (natural gas, for
example, makes a lot of thermal NOx because of the exceptionally high
flame temperature). Finally, the wet kiln plants may have older NOx
monitors and maybe these are skewing data (???).

I agree with Staudt that the NOx data show a lot of scatter. I would
note that his observation that the larger kilns are more efficient
(lower NOx) is perhaps not supported by his graph—yes it shows this,
but there are only 3 data points for the kilns > 1 Mt/yr capacity. Is
this statistically valid?

Figures 5a-5c: Author is being “kind” in his characterization of the
data: the correlations would appear to be not statistically significant.

In his discussion of SOx capture, the author says that synthetic gypsum
is useful to the cement plant (saves them buying outside gypsum). Yes
and no. In realitity, some syngyp is dirty. A common complaint about its
use in the finish mill is that it is sticky. So far, not that many
plants are using it (but, in fairness, they are not required to split
syngyp from natural gypsum in their raw materials reporting to the USGS,
so we may not be seeing the full extent of syngyp use).

p. 15: perhaps this is a semantic point, but Dragon Cement’s switch to
dry technology involved shortening the existing kiln tube, not by
bringing in a new tube.

While it is true that there is regional variation in the sulfur content
of “limestone” (and the sulfur in “limestone” is from 3 main
sources: sulfide minerals such as pyrite; kerogens; and
gypsum/anhydrite.), there is as much, or greater variation from the
S-contribution from the coals: there is a major difference in the
S-content of coals (S in coal is from kerogens and sulfides like pyrite
and marcasite).

The sulfur content of the “limestone (BTW—Dragon actually burns
marble; and much of the limestone burned in N-CA is also a marble, or
nearly so) would not normally be a criteria for selection of a new
quarry.

Given the small number of kilns in most of the markets, I am not sure
that one ought to read too much in the mean vs. median emissions data in
tables 8 and 9.

Appendix A continued: Re: Costs and Performance of Controls

This is also a good report.

Regarding the use of tires, I would comment that not all plants burn
tires because:

there can be local competition for tires—you need an “abundant”
supply, not just the occasional tire;

permitting issues

the requisite tire supply may not be available in all areas (not near
enough to a large city);

Capex for the tire-burning and feeding equipment.

I am not sure that I agree that tires yield slightly less CO2 than coal:
perhaps on a dry weight basis they yield slightly more. Depends on how
you relate the emissions: per weight of fuel, per ton of clinker…

I agree that tires are not fossil fuel, per se, but most involve a
considerable input of the products of the petrochemical industry in
their manufacture.

p. 13: Preheaters and precalciners are described as “post-kiln”
combustion technologies. I guess that they would be if you are looking
up-kiln (i.e., from the flame and gas flow directional perspective), but
most people would follow the raw materials and clinker instead and would
call preheaters and precalciners: “pre-kiln” technologies (that’s
why “pre-“ is in their name!).

I think most calciners are designed to burn about 60% of the (total kiln
line) fuel, not 50%; though perhaps the oft’ quoted 60% includes riser
duct firing.

As stated in para 1 of p. 13, there is an implication that most thermal
NOx is avoided in preheater and precalciner kilns—as stated, this is
incorrect. First, there is a lot of thermal NOx generated in the kiln
tube from the main burner. Secondly, a preheater kiln commonly uses hot
combustion air for the preheating (which is full of thermal NOx but this
may be destroyed if reducing conditions exist in the preheater). What is
true is that NOx generated in the calciner (and hence also carried into
the preheater cyclones in a preheater-precalciner system) is dominated
by fuel and/or feed NOx. So the issue is that the precalciner (location)
doesn’t generate a lot of thermal NOx—the same cannot be said for
the whole precalciner kiln line.

p. 26: LWS scrubber: basically fine. Here and elsewhere, use calcite, or
calcium carbonate, instead of limestone. Limestone is a rock, only very
rarely is it pure calcium carbonate.

∙2H2O .

p. 30: CKD is described as being made up of oxides of Ca, K, and Mg.
You’ve left out Si!

Para. 2 states that CKD disposal is not an issue with dry-technology
kilns. This is not true. Any kiln technology can burn CKD and any can
have a problem burning CKD—it depends primarily on things like the
alkali content of the CKD and the resulting clinker. If there is a
regional ASR problem with the local aggregates (in concrete) then you
need to keep the alkali content of the clinker down. This may be
well-controlled if you have an alkali bypass system, but if you do not,
then your ability to burn CKD may be severely limited.

You can certainly burn CKD in a wet kiln: the slurry viscosity can be an
issue, but you can also add a bit more water. CKD was burned at
Dragon’s wet kiln, for example, but only in relatively modest amounts
(they did not burn all of it).

CemStar: I would add a bullet for the CO2 reduction!

On the negative side, CemStar may add to a plants emissions of Cr+6. I
think this is why Cemex’s Davenport (N-CA) plant is presently idle.

Good for you in getting the $16/ton royalty figure: I am in the business
of collecting proprietary data and I never could get anyone to tell me
this number (I heard grunts and mutterings about it, it was high; I
heard $12 mentioned once but it was not definitive). The high royalty
definitely limited interest in the technology. But, there is an
important difference between what TXI got/continues to get for the
CemStar contracts that were signed with TXI, and what the slag
processing company Levy (who bought the CemStar patent in 2004) gets for
contracts it develops. Levy is primarily interested in promoting the
slag use (and selling the slag to the cement plant) and charges (they
tell me) a much lower royalty (but they don’t tell me what it is). My
point is that, in your cost analysis, it is likely that future (new)
users of CemStar will be paying <<$16/ton royalty (if any) for the
process.

At $16/st, CemStar becomes quite expensive relative to the cost of the
steel furnace slag (a few dollars per ton only, + transportation) and
its handling.

I do not understand this $72.59/st cost for clinker (seems excessively
high), nor why it is even relevant. If I understand the report
correctly, it is being said that this clinker cost minus $10/ton for the
slag, yields a savings of $62.59/ton or $45-50/ton including the CemStar
royalty. I just don’t see how this relates to evaluating the use of
CemStar. What you seem to be doing is pretending that you stick slag
into the finish mill to make cement (that it competes with clinker)
when, in fact, it is “competing” with (some of the) limestone as a
feed to the kiln.

What you need to do is to compare the cost of making clinker without
using CemStar vs the cost to make clinker using CemStar. CemStar always
involves incorporating steel slag into the raw mix as a partial (3-10%)
substitute for limestone (etc…).

Without CemStar: cost = A (cost to quarry, comminute, & blend the raw
feed materials) plus P (the cost of pyroprocessing (fuel costs etc…)
to make clinker. This is the cost to make the clinker, period.

With CemStar: for every ton of clinker made, you are quarrying,
comminuting, and blending less “normal” feed, so A is lower by an
amount B. But, against this, is the cost (A’) of: buying the slag, the
royalty for the process, crushing the slag to 1-2” size, and blending.
So the resulting feed cost becomes (A-B + A’).

The pyroprocessing cost is the cost of calcining the original feed mix
(in the now smaller amount), plus the cost of melting/disassociating the
slag, plus the cost of sintering. Because there is less carbonate to
calcine (per ton of clinker), the fuel (heat) required for calcination
will be less. (Calcination is where 60% or more of the heat is
consumed). Also, because the slag melts/disassociates easily, you are
getting some of your silica, iron, and aluminum (oxide) for less heat
(and maybe faster) than would be the case burning clays, shale, and
quartz sand. So the cost savings are related to the reduced heat/fuel
charges of the pre-sintering stages of pyroprocessing (P’). For the
sintering part of the clinker-forming process, there probably will not
be any savings. So the pyroprocessing cost becomes P-P’.

So the overall comparison is A + P vs. (A-B + A’ + P – P’). And
the overall savings will be nowhere near $45-50/ton of clinker!

The reduction in CO2 emissions will be, on a per-ton-of-clinker basis,
will be something like: for calcination emissions: (1-C’)*C, where C
is the calcination CO2 for the carbonates burned in feed that does not
incorporate CemStar, and C’ is the percentage of carbonate
substitution by slag. That is, 5% (C’=0.05) substitution yields:
(1-.05)*C = 0.95C. i.e., this reduction is stoichiometrically
straightforward. The fuel emissions reduction is a bit less so. If F is
the non-CemStar fuel emission for the pre-sintering stages, the new
emission (w/ CemStar) becomes something like: ((1- C’)*F) + G + S
where the first term relates to the reduced heat of calcination and
low-temperature pyroprocessing of the normal feed mix; G is the low
temperature fuel requirements to deal with the pre-sintering
disassociation of the slag; and S is the fuel requirement for sintering.
I am assuming that S does not change (i.e., fuel emissions without
CemStar = F + S). The CemStar savings on fuels stems from the fact that
G << C’*F.

What this all means is that the statement on p. 36 that the CO2
reduction (overall, on a per ton clinker or cement basis) will be
directly proportional to the percent slag substitution is not quite
safe—it will hold for the calcination part of the emissions, but may
be different for the fuel side of the emissions.

p. 35: Again, if I am reading this correctly, it appears that a claim is
made that CemStar increases the electricity consumption by the finish
mill. Well, if you assume that you get 5% more clinker for a 5% CemStar
(slag) introduction, then, yes, it will take 5% more electricity to
grind that extra clinker. But so what? This is like saying that if you
get a salary increase, you will pay more taxes even though the tax rate
doesn’t change. This is not interesting. What would be interesting is
if the use of slag (CemStar) made a clinker (perhaps a harder clinker)
that was costlier to grind (more electricity per ton). But I do not
think that this is the case: the cost (either per ton of clinker or per
ton of cement) to grind the clinker into cement does not change as a
result of using CemStar. There may be some additional electricity in the
raw mill end of the plant to handle the extra ingredient (slag) but this
is likely to be more than offset by the reduced electricity costs of
comminution of the feed: unlike the limestone and other feeds, the slag
does NOT need to be ground, just coarsely crushed. [the CemStar patent
“discovery” was not the chemical contribution to the clinker-making
process. It is the fact that you don’t need to grind it—only crush
it to 1-2” diameter. The utility of slag had been known for many
decades, but it had not been popular earlier because it was assumed that
you had to grind it like everything else, and slag is indeed hard
(costly) to grind].

p. 37 Conversion from wet to dry

The wording is a bit imprecise. You can convert a plant from wet to dry
by replacing wet kilns with dry kilns and/or by converting wet kilns to
dry technology. Dragon Cement in Maine was a true kiln conversion: the
old wet kiln tube was retained (but about 1/3 of its length was cut
off), and a preheater/calciner tower was added. Holcim @ Holly Hill, SC
was a replacement of the 2 wet kilns (which were shut down) with a
completely new, unrelated, dry kiln (precalciner kiln).

Regarding the 300,000 ton example—I would only comment that one would
never build a kiln of such small capacity today, nor would it be
worthwhile anymore to convert a 300,000 t wet to a 300,000 dry kiln.

p. 38: states: “Water consumption would also drop. Moisture added to
the materials of a wet kiln

amount to about 0.75 tons per short ton of clinker.” This is too high
(too much water). Wet and dry kilns both need about 1.6-1.7 tons of raw
materials per ton of clinker. Typical water content of wet kiln slurries
is 35-40% by weight. So a 35-40% water slurry containing 1.6-1.7 t of
raw materials (destined to make 1 ton of clinker) would contain 0.56 –
0.68 t water.

But, of course, water is also used in cement plants as a motor coolant
and in the finish mill (as a spray) to make sure the calcium sulfate in
the cement remains (mostly) gypsum and does not dehydrate to plaster or
to anhydrite.

p. 42: The question is asked why haven’t all the existing preheater
kilns been converted to preheater-precalciner technology? There are at
least 3 answers to this:

if the preheater kiln is small (capacity), the conversion boost in
capacity might be insufficient to justify the cost;

significant projects like this typically require a litmus test of the
plant still having at least 50 years of limestone reserves.

significant projects like this likely will put the plant into a stricter
regulatory framework re. emissions (the existing plant may have
grandfathered in).

General comment: One significant omission from this study—unless I
missed it somewhere (it is a long report!) are certain upgrades to
capacity that simply involve debottlenecking. This could involve things
like:

upgrade/replace clinker cooler

upgrade raw mill

upgrade finish mill (e.g., install roller mill instead of ball mill—it
will greatly reduce electricity consumption)

Upgrade storage facilities (raw feeds, clinker, cement) and overall
materials handling.

Upgrade dust collectors

p. 44: don’t need to capitalize greenfield(s) and brownfield(s).

p. 45: Not sure that “attainment” status is clear to all
eaders—may be environmental jargon.

Item #2 (reserves). 100 years for a greenfields project is about right.
To this I would again note that major capex projects need c. 50 years of
remaining reserves or more (some companies may be satisfied with 35
years).

Item #3 labor: I do not think labor is important…Look, they have
cement plants all over the world. Labor can always be found. The more
skilled positions will draw engineers (et al.) from far away. When I
have visited cement plants, I am commonly struck by the fact that most
of the workers have been there for ages—they have had or are planning
on having their whole career there. They evidently like the work. The
pay is adequate and steady; it’s relatively clean, and relatively
safe. It’s a more recession-proof industry than most. So there’s not
necessarily a lot of overturn (oddly enough, except for the plant
managers). People learn the work; they get trained.

Modern plants do not need a huge workforce anyway. And, normally, you
would not cite a cement plant in the middle of the Arctic wilderness.
Unlike certain metals mines (where you simply must put the mine where
the deposit is located or else the mine will fail badly), you generally
have a choice as to where you site the cement plant (limestone is
abundant). Generally, there will be some sort of community nearby the
proposed cement plant that can supply the “blue-collar” labor.

You offer the notion that the USGS has/will map out suitable limestone
deposits. Unlikely. Cement companies have their own staff of geologists,
or will hire a consulting geologist, for this purpose (they may use USGS
and/or State geological maps to broadly identify where the limestone may
be found).

p. 46: Decision tree: add: consider adding a terminal (instead of a
plant); consider swap arrangements (to supply cement to customers
outside your own plant’s “range”.)

Round the midpoint costs to 2 significant-figures: e.g., $280 instead of
$277.

Appendix B: (memo from RTI)

p. 3-4: I would note that the USGS data pertaining to prices for crushed
stone ($/t) are for sales by crushed stone quarries. Thus, they would be
broadly applicable to prices for some of the raw materials that are
purchased by the cement company, but likely exceed what a cement company
“pays” for its own limestone. I would think that the basic limestone
cost (quarry, primary crushing, convey to raw mill) would be typically
≤ $5/st.

The average hourly wage table look a bit low for a cement plant, but I
am not sure. Need to get some actual cement plant data. My main issue is
that the typical cement plant worker has 10+ years of experience, I
would think, and so would likely draw a higher wage.

Table 6: The electricity data seem high. First, whereas the logic of the
PCA’s “equivalent tons” may be sound for heat, it makes less sence
as the denominator for cement, given that roughly 1/3 of the consumption
is in the finish mill. The USGS data relate the unit consumption to
total cement (not just portland) production. We show for 2005: wet
plants = 135.4 kWh/mt; dry plants (all types) = 139.0 kWh/mt;
combination plants (using wet & dry kilns) = 153 kWh/mt; and all
integrated plants combined = 138.8 kWh/mt. Grinding plants = 84 kWh/mt.

Table 7: the unit electricity prices may not be valid for large
industrial customers (they may get a lower rate).

Table 10: a few comments (reflecting newer info):

The Dixon, IL and Charlevoix, MI plants are now owned by St. Marys
Cement.

Hanson plant, CA is now owned by Lehigh SW

RMC plant in CA is now owned by CEMEX

Lehigh Allentown, PA plant is actually their Evansville plant

Holcim (US) now controls all St. Lawrence facilities in the USA.

Essroc’s Nazareth III plant in PA shut its kilns in 2005 (only kilns
are at Naz. I)

Lafarge’s Atlanta, GA plant shut its kiln in 2004; now only grinds
some clinker to make masonry cement, regrinds Type I into Type III
portland cement, and grinds granulated slag.

Dragon Cement was a dry plant in 2005 (the wet to dry conversion was
completed 4/04).

This completes my review comments.

Attachment H

Review Comments from

Hector Ybañez, Holcim

Transcription of comments submitted verbally to EPA during the meeting
on January 29, 2009

Page 1-3 and 1-4: Figures 1-1 and 1-2 Update cement diagram – add
fabric filters (for PM controls) instead of ESPs and simplify the
diagram with just the cement making process

Page 1-5: Statement about PC fuel efficiency in the first paragraph…
replacement of both wet and certain dry process kiln capacity with
modern kiln processes yield substantial reductions in fuel use.  This is
true in term of fuel efficiency but not in the absolute amount of fuel
use.  Newer kilns tend to be bigger kilns and are going to use more
fuel.

Page 1-7: Figure 1-4 Add import’s custom districts to the map

Page 1-8: Do these imports include imports from Mexico (imports by rail
and trucks)?

Page 1-9: Are the PM emissions (36,000 tons) emissions from the kiln or
for the whole plant (including grinding)/

Page 1-11: Figure 1-7 – Emissions as inputs to the model are baseline
uncontrolled emissions at baseline levels of production.

Holcim will provide EPA with capital recovery cost for 15-20 years old
kilns and some information on capital cost and interest rates

Page 2-3 and 2-4: Tables 2-2 and 2-3 specify the units

k

·

û

8

®

J

K

e

f

g

i

j

k

–

—

±

²

³

µ

¶

·

Ú

ࠆᘁ䁨夔唀Ĉ䡭Ѐ䡮Ѐࡵ⸁Ú

Û

õ

ö

÷

ù

ú

û

2

3

4

6

7

8

Ž

¨

©

ª

¬

.

®

h

h

h

h

摧寓°

_H

 h

 h

 h

 h

–

 h

 h

 h

 h£K

jÜ

਀&䘋

0

6

U

 h

 h£K

 h

 h£K

 h£K

 h£K

 h£K

 h£K

/Kg for dry seems low.  Hector will share Holcim’s calculation method
at 10% oxygen to recalculate the EGFW.

Page 2-7: Table 2-5 Update with the most recent ACT data (2008 ACT) and
show data in lb/ton clinker

Page 2-8: Table 2-6 Change red color to be light green.

Page 2-9: Table 2-7 Label symmetrically, lbmolesH2O/MMBtu, H2O is
missing in some places

Page 2-10: Table 2-8 Are CO2 reductions total CO2 (process and fuel)?
If so, express it to be total CO2.  Are numbers absolute #s or
intensities? Can sewage impacts be included? PCA has given EPA a
workbook with the fuel and power use for the cement industry.  This
workbook can be used to compare #s.  The workbook is part of the WBCSD
initiative.  Hector will find out who at EPA PCA sent the workbook data.

Page 2-11: Table 2-9 Are these #s fuel intensity or absolute?  We might
think that the #s are intensity related not absolute.  When going from a
wet to a PC you have more capacity, you produce more and therefore you
will have more emissions in the absolute no matter that the process is
more efficient.

Page 2-12: Table 2-10 Specify in the model that these parameters are to
be chosen by the user.

Page 5-6: Table 5-1 control cost #’s need to be updated to
differentiate between new capacity in the business-as-usual vs. policy
scenario.

Comments on Spreadsheet

Add plot on retirement, new capacity, etc.

  PAGE   \* MERGEFORMAT  4

  PAGE   \* MERGEFORMAT  54

  PAGE   \* MERGEFORMAT  60

  PAGE   \* MERGEFORMAT  62

  PAGE   \* MERGEFORMAT  64

  PAGE   \* MERGEFORMAT  69

  PAGE   \* MERGEFORMAT  70


[Federal Register Volume 84, Number 51 (Friday, March 15, 2019)]
[Proposed Rules]
[Pages 9468-9470]
[FR Doc No: 2019-04813]

========================================================================
Proposed Rules
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.

========================================================================

Federal Register / Vol. 84, No. 51 / Friday, March 15, 2019 /
Proposed Rules

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

DEPARTMENT OF HOMELAND SECURITY

Coast Guard

33 CFR Part 165

[Docket Number USCG-2019-0113]
RIN 1625-AA00

Safety Zone; Lake of the Ozarks, Osage Beach, MO

AGENCY: Coast Guard, DHS.

ACTION: Notice of proposed rulemaking.

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

SUMMARY: The Coast Guard is proposing to establish a temporary safety
zone for certain waters of the Lake of the Ozarks. This action is
necessary to provide for the safety of life on these navigable waters
near the Tan-Tar-A Resort, Osage Beach, MO during a fireworks display
on May 4, 2019. This proposed rulemaking would prohibit persons and
vessels from entering the safety zone unless authorized by the Captain
of the Port Sector Upper Mississippi River or a designated
representative. We invite your comments on this proposed rulemaking.

DATES: Comments and related material must be received by the Coast
Guard on or before April 15, 2019.

ADDRESSES: You may submit comments identified by docket number USCG-
2019-0113 using the Federal eRulemaking Portal at https://www.regulations.gov. See the ``Public Participation and Request for
Comments'' portion of the SUPPLEMENTARY INFORMATION section for further
instructions on submitting comments.

FOR FURTHER INFORMATION CONTACT: If you have questions about this
proposed rulemaking, call or email Lieutenant Commander Christian
Barger, Waterways Management Division, Sector Upper Mississippi River,
U.S. Coast Guard; telephone<PHONE_NUMBER>, email
<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

I. Table of Abbreviations

CFR Code of Federal Regulations
COTP Captain of the Port Sector Upper Mississippi River
DHS Department of Homeland Security
FR Federal Register
NPRM Notice of proposed rulemaking
Sec.  Section
U.S.C. United States Code

II. Background, Purpose, and Legal Basis

    On February 18, 2019, the Premier Pyrotechnics Inc. notified the
Coast Guard that it would be conducting a fireworks display from 9 to
9:30 p.m. on May 4, 2019, for a private event taking place at the Tan-
Tar-A Resort in Osage Beach, MO. The fireworks are to be launched from
a barge in the Lake of the Ozarks approximately 250 feet southeast of
the southern point of the resort near mile marker 26. Hazards
associated with firework displays may include accidental discharge of
fireworks, dangerous projectiles, and falling hot embers or other
debris. The Captain of the Port Sector Upper Mississippi River (COTP)
has determined that these potential hazards would be a safety concern
for anyone within a 300-foot radius of the fireworks barge.
    The purpose of this rulemaking is to ensure the safety of vessels
and the navigable waters within a 300-foot radius of the fireworks
barge before, during, and after the scheduled event. The Coast Guard is
proposing this rulemaking under authority in 46 U.S.C. 70034.

III. Discussion of Proposed Rule

    The COTP is proposing to establish a safety zone from 8:45 to 9:45
p.m. on May 4, 2019. The safety zone would cover all navigable waters
within 300 feet of a barge in the Lake of the Ozarks located
approximately 250 feet southeast of the southern point of the resort
near mile marker 26. The duration of the zone is intended to ensure the
safety of vessels on these navigable waters before, during, and after
the scheduled fireworks display. No vessel or person would be permitted
to enter the safety zone without obtaining permission from the COTP or
a designated representative. The regulatory text we are proposing
appears at the end of this document.

IV. Regulatory Analyses

    We developed this proposed rule after considering numerous statutes
and Executive orders related to rulemaking. Below we summarize our
analyses based on a number of these statutes and Executive orders and
we discuss First Amendment rights of protestors.

A. Regulatory Planning and Review

    Executive Orders 12866 and 13563 direct agencies to assess the
costs and benefits of available regulatory alternatives and, if
regulation is necessary, to select regulatory approaches that maximize
net benefits. Executive Order 13771 directs agencies to control
regulatory costs through a budgeting process. This NPRM has not been
designated a ``significant regulatory action,'' under Executive Order
12866. Accordingly, the NPRM has not been reviewed by the Office of
Management and Budget (OMB), and pursuant to OMB guidance it is exempt
from the requirements of Executive Order 13771.
    This regulatory action determination is based on the duration of
the rule and the location of the safety zone within the waterway. This
regulatory action would be in place for a period of 1 hour, within a
300 foot radius of the fireworks barge, close to the shoreline of the
Tan-Tar-A Resort in Osage Beach, MO. The majority of the waterway would
remain open to traffic during the fireworks display.

B. Impact on Small Entities

    The Regulatory Flexibility Act of 1980, 5 U.S.C. 601-612, as
amended, requires Federal agencies to consider the potential impact of
regulations on small entities during rulemaking. The term ``small
entities'' comprises small businesses, not-for-profit organizations
that are independently owned and operated and are not dominant in their
fields, and governmental jurisdictions with populations of less than
50,000. The Coast Guard certifies under 5 U.S.C. 605(b) that this
proposed rule would not have a significant economic impact on a
substantial number of small entities.
    While some owners or operators of vessels intending to transit the
temporary safety zone may be small entities, for the reasons stated in
section IV.A above, this proposed rule would not have a significant
economic impact on any vessel owner or operator.

    If you think that your business, organization, or governmental
jurisdiction qualifies as a small entity and that this rule would have
a significant economic impact on it, please submit a comment (see
ADDRESSES) explaining why you think it qualifies and how and to what
degree this rule would economically affect it.
    Under section 213(a) of the Small Business Regulatory Enforcement
Fairness Act of 1996 (Pub. L. 104-121), we want to assist small
entities in understanding this proposed rule. If the rule would affect
your small business, organization, or governmental jurisdiction and you
have questions concerning its provisions or options for compliance,
please contact the person listed in the FOR FURTHER INFORMATION CONTACT
section. The Coast Guard will not retaliate against small entities that
question or complain about this proposed rule or any policy or action
of the Coast Guard.

C. Collection of Information

    This proposed rule would not call for a new collection of
information under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-
3520).

D. Federalism and Indian Tribal Governments

    A rule has implications for federalism under Executive Order 13132,
Federalism, if it has a substantial direct effect on the States, on the
relationship between the national government and the States, or on the
distribution of power and responsibilities among the various levels of
government. We have analyzed this proposed rule under that Order and
have determined that it is consistent with the fundamental federalism
principles and preemption requirements described in Executive Order
13132.
    Also, this proposed rule does not have tribal implications under
Executive Order 13175, Consultation and Coordination with Indian Tribal
Governments, because it would not have a substantial direct effect on
one or more Indian tribes, on the relationship between the Federal
Government and Indian tribes, or on the distribution of power and
responsibilities between the Federal Government and Indian tribes. If
you believe this proposed rule has implications for federalism or
Indian tribes, please contact the person listed in the FOR FURTHER
INFORMATION CONTACT section.

E. Unfunded Mandates Reform Act

    The Unfunded Mandates Reform Act of 1995 (2 U.S.C. 1531-1538)
requires Federal agencies to assess the effects of their discretionary
regulatory actions. In particular, the Act addresses actions that may
result in the expenditure by a State, local, or tribal government, in
the aggregate, or by the private sector of $100,000,000 (adjusted for
inflation) or more in any one year. Though this proposed rule would not
result in such an expenditure, we do discuss the effects of this rule
elsewhere in this preamble.

F. Environment

    We have analyzed this proposed rule under Department of Homeland
Security Directive 023-01 and Commandant Instruction M16475.1D, which
guide the Coast Guard in complying with the National Environmental
Policy Act of 1969 (42 U.S.C. 4321-4370f), and have made a preliminary
determination that this action is one of a category of actions that do
not individually or cumulatively have a significant effect on the human
environment. This proposed rule involves a temporary safety zone
lasting 1 hour that would prohibit entry within 300 feet of a fireworks
barge. Normally such actions are categorically excluded from further
review under paragraph L60(a) of Appendix A, Table 1 of DHS Instruction
Manual 023-01-001-01, Rev. 01. A preliminary Record of Environmental
Consideration supporting this determination is available in the docket
where indicated under ADDRESSES. We seek any comments or information
that may lead to the discovery of a significant environmental impact
from this proposed rule.

G. Protest Activities

    The Coast Guard respects the First Amendment rights of protesters.
Protesters are asked to contact the person listed in the FOR FURTHER
INFORMATION CONTACT section to coordinate protest activities so that
your message can be received without jeopardizing the safety or
security of people, places, or vessels.

V. Public Participation and Request for Comments

    We view public participation as essential to effective rulemaking,
and will consider all comments and material received during the comment
period. Your comment can help shape the outcome of this rulemaking. If
you submit a comment, please include the docket number for this
rulemaking, indicate the specific section of this document to which
each comment applies, and provide a reason for each suggestion or
recommendation.
    We encourage you to submit comments through the Federal eRulemaking
Portal at http://www.regulations.gov. If your material cannot be
submitted using http://www.regulations.gov, contact the person in the
FOR FURTHER INFORMATION CONTACT section of this document for alternate
instructions.
    We accept anonymous comments. All comments received will be posted
without change to https://www.regulations.gov and will include any
personal information you have provided. For more about privacy and the
docket, visit https://www.regulations.gov/privacyNotice.
    Documents mentioned in this NPRM as being available in the docket,
and all public comments, will be in our online docket at https://www.regulations.gov and can be viewed by following that website's
instructions. Additionally, if you go to the online docket and sign up
for email alerts, you will be notified when comments are posted or a
final rule is published.

List of Subjects in 33 CFR Part 165

    Harbors, Marine safety, Navigation (water), Reporting and
recordkeeping requirements, Security measures, Waterways.

    For the reasons discussed in the preamble, the Coast Guard proposes
to amend 33 CFR part 165 as follows:

PART 165--REGULATED NAVIGATION AREAS AND LIMITED ACCESS AREAS

0
1. The authority citation for part 165 continues to read as follows:

    Authority: 46 U.S.C. 70034; 46 U.S.C. 70051; 33 CFR 1.05-1,
6.04-1, 6.04-6, and 160.5; Department of Homeland Security
Delegation No. 0170.1.

0
2. Add Sec.  165.T08-0113 to read as follows:

Sec.  165.T08-0113   Safety Zone; Lake of the Ozarks, Osage Beach, MO.

    (a) Location. The following area is a safety zone: All navigable
waters of the Lake of the Ozarks within a 300-foot radius of a barge-
launched fireworks display located approximately 250 feet southeast of
the southern point of the Tan-Tar-A Resort near mile marker 26.
    (b) Period of enforcement. This section will be enforced from 8:45
p.m. through 9:45 p.m. on May 4, 2019.
    (c) Regulations. (1) In accordance with the general regulations in
Sec.  165.23, persons and vessels are prohibited from entering the
safety zone unless authorized by the Captain of the Port Sector Upper
Mississippi River (COTP) or a designated representative. A designated
representative is a

commissioned, warrant, or petty officer of the U.S. Coast Guard
assigned to units under the operational control of USCG Sector Upper
Mississippi River.
    (2) Persons or vessels desiring to enter into or pass through the
zone must request permission from the COTP or a designated
representative. They may be contacted by telephone at<PHONE_NUMBER>.
    (3) If permission is granted, all persons and vessels shall comply
with the instructions of the COTP or designated representative.
    (d) Informational broadcasts. The COTP or a designated
representative will inform the public of the enforcement date and times
for this safety zone, as well as any emergent safety concerns that may
delay the enforcement of the zone through Local Notices to Mariners
(LNMs), and/or actual notice.

     Dated: March 8, 2019.
S.A. Stoermer,
Captain, U.S. Coast Guard, Captain of the Port Sector Upper Mississippi
River.
[FR Doc. 2019-04813 Filed 3-14-19; 8:45 am]
BILLING CODE 9110-04-P


[Federal Register Volume 83, Number 78 (Monday, April 23, 2018)]
[Notices]
[Pages 17690-17691]
[FR Doc No: 2018-08368]

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

SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-83054; File No. SR-NASDAQ-2018-027]

Self-Regulatory Organizations; The Nasdaq Stock Market LLC;
Notice of Filing and Immediate Effectiveness of a Proposed Rule Change
To Delete Duplicative Rules Related to the Consolidated Audit Trail
From Its Rulebook

April 17, 2018.
    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that
on April 5, 2018, The Nasdaq Stock Market LLC (``Nasdaq'' or
``Exchange'') filed with the Securities and Exchange Commission
(``Commission'') the proposed rule change as described in Items I and
II below, which Items have been prepared by the Exchange. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------

    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------

I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change

    The Exchange proposes to delete the rules related to the
Consolidated Audit Trail (``CAT Rules'') currently under Chapter IX,
Sections 8 and 9 of Nasdaq's Options Rules, as further described below.
    The text of the proposed rule change is available on the Exchange's
website at http://nasdaq.cchwallstreet.com, at the principal office of
the Exchange, and at the Commission's Public Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the Exchange included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. The Exchange has prepared summaries, set forth in
sections A, B, and C below, of the most significant aspects of such
statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change

1. Purpose
    The purpose of the proposed rule change is to delete the CAT Rules
currently under Nasdaq's Options Rules, Chapter IX, Sections 8 and 9
because these rules are already located in General 7, entitled
``Consolidated Audit Trail Compliance,'' under the ``General Equity and
Options Rules'' in the Exchange's rulebook's shell structure.\3\ Given
that the CAT Rules contained in General 7 are non-product specific and
are identical to the CAT Rules in Nasdaq's Options Rules,\4\ the
Exchange proposes to delete the duplicative rules in Nasdaq's Options
Rules as market participants transacting on the Exchange's equity and
options markets are already governed by the CAT Rules in General 7.
---------------------------------------------------------------------------

    \3\ The Exchange added a shell structure to its rulebook with
the purpose of improving efficiency and readability and to align its
rules closer to those of its five sister exchanges: Nasdaq BX, Inc.;
Nasdaq PHLX LLC; Nasdaq ISE, LLC; Nasdaq GEMX, LLC; and Nasdaq MRX,
LLC (``Affiliated Exchanges''). See Securities Exchange Act Release
No. 82175 (November 29, 2017), 82 FR 57494 (December 5, 2017) (SR-
NASDAQ-2017-125).
    \4\ As part of its continued effort to promote efficiency and
conformity of its rules with those of the Affiliated Exchanges, the
Exchange recently relocated the CAT Rules previously under the 6800
Series of Nasdaq's Equity Rules to General 7 because the CAT Rules
apply across all markets and to all products. See Securities
Exchange Act Release No. 82604 (January 30, 2018), 83 FR 5154
(February 5, 2018) (SR-NASDAQ-2018-007).
---------------------------------------------------------------------------

2. Statutory Basis
    The Exchange believes that its proposal is consistent with Section
6(b) of the Act,\5\ in general, and furthers the objectives of Section
6(b)(5) of the Act,\6\ in particular, in that it is designed to promote
just and equitable principles of trade, to remove impediments to and
perfect the mechanism of a free and open market and a national market
system, and, in general to protect investors and the public interest by
removing the duplicative CAT Rules from Nasdaq's Options Rules. As
discussed above, Exchange members are already governed by the CAT Rules
in General 7 of the rulebook's shell structure. The Exchange believes
that the proposed changes will make the Exchange's rulebook easier to
read and eliminate any potential confusion to the benefit of its
members and investors.
---------------------------------------------------------------------------

    \5\ 15 U.S.C. 78f(b).
    \6\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------

B. Self-Regulatory Organization's Statement on Burden on Competition

    The Exchange does not believe that the proposed rule change will
impose any burden on competition not necessary or appropriate in
furtherance of the purposes of the Act. The proposed changes as
discussed above do not impose a burden on competition because they are
non-substantive and are intended to clarify the Exchange's rulebook in
order to eliminate any potential confusion.

C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others

    No written comments were either solicited or received.

III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action

    Because the foregoing proposed rule change does not: (i)
Significantly affect the protection of investors or the public
interest; (ii) impose any significant burden on competition; and (iii)
become operative for 30 days from the date on which it was filed, or
such shorter time as the Commission may designate, it has become
effective pursuant to Section 19(b)(3)(A)(iii) of the Act \7\ and

subparagraph (f)(6) of Rule 19b-4 thereunder.\8\
---------------------------------------------------------------------------

    \7\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \8\ 17 CFR 240.19b-4(f)(6). In addition, Rule 19b-4(f)(6)(iii)
requires the Exchange to give the Commission written notice of the
Exchange's intent to file the proposed rule change, along with a
brief description and text of the proposed rule change, at least
five business days prior to the date of filing of the proposed rule
change, or such shorter time as designated by the Commission. The
Exchange has satisfied this requirement.
---------------------------------------------------------------------------

    A proposed rule change filed under Rule 19b-4(f)(6) \9\ normally
does not become operative prior to 30 days after the date of the
filing. However, Rule 19b-4(f)(6)(iii) \10\ permits the Commission to
designate a shorter time if such action is consistent with the
protection of investors and the public interest. The Exchange has
requested that the Commission to waive the 30-day operative delay so
that the proposal will become operative upon filing. The Exchange
stated that removing the duplicative CAT Rules, as discussed above,
will bring greater clarity to its rulebook and will eliminate any
potential confusion to the benefit of its members and investors.
Therefore, the Commission believes that waiver of the 30-day operative
delay is consistent with the protection of investors and the public
interest. Accordingly, the Commission hereby waives the operative delay
and designates the proposed rule change as operative upon filing.\11\
---------------------------------------------------------------------------

    \9\ 17 CFR 240.19b-4(f)(6).
    \10\ 17 CFR 240.19b-4(f)(6)(iii).
    \11\ For purposes only of waiving the 30-day operative delay,
the Commission has also considered the proposed rule's impact on
efficiency, competition, and capital formation. See 15 U.S.C.
78c(f).
---------------------------------------------------------------------------

    At any time within 60 days of the filing of the proposed rule
change, the Commission summarily may temporarily suspend such rule
change if it appears to the Commission that such action is: (i)
Necessary or appropriate in the public interest; (ii) for the
protection of investors; or (iii) otherwise in furtherance of the
purposes of the Act. If the Commission takes such action, the
Commission shall institute proceedings to determine whether the
proposed rule should be approved or disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:

Electronic Comments

     Use the Commission's internet comment form (http://www.sec.gov/rules/sro.shtml); or
     Send an email to [email protected]. Please include
File Number SR-NASDAQ-2018-027 on the subject line.

Paper Comments

     Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to File Number SR-NASDAQ-2018-027. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's internet website (http://www.sec.gov/rules/sro.shtml).
Copies of the submission, all subsequent amendments, all written
statements with respect to the proposed rule change that are filed with
the Commission, and all written communications relating to the proposed
rule change between the Commission and any person, other than those
that may be withheld from the public in accordance with the provisions
of 5 U.S.C. 552, will be available for website viewing and printing in
the Commission's Public Reference Room, 100 F Street NE, Washington, DC
20549, on official business days between the hours of 10:00 a.m. and
3:00 p.m. Copies of the filing also will be available for inspection
and copying at the principal office of the Exchange. All comments
received will be posted without change. Persons submitting comments are
cautioned that we do not redact or edit personal identifying
information from comment submissions. You should submit only
information that you wish to make available publicly. All submissions
should refer to File Number SR-NASDAQ-2018-027 and should be submitted
on or before May 14, 2018.

    For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\12\
---------------------------------------------------------------------------

    \12\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2018-08368 Filed 4-20-18; 8:45 am]
 BILLING CODE 8011-01-P