July 28, 2010

Mr. Richard Sebastianclli LaHtrge North America, Inc. 5400 West Marginal Way Southwest Seattle, WA 981 06-1517 Dear Mr. Sebastianelli : Regional Haze Best Available Retrofit Technology (BART) Determination Final December 201 0

Best Available Retrofit Technology (BART) is required to reduce the regional haze in1pacts of emissions ofyour facility. The enclosed Revised Order#7841 contains ourBARTdetermination tor your facility including a schedule for compliance. This revision replaces OrderNo. 7841 dated July 7, 2010. Ifyou have questions orrequests relating to this order, please contact Alan Newman at (360) 407-6810 oralan.newman@ecy.wa.gov. Sincerely,

# J:!ston~L- Manager, Science and Engineering Section Air Quality Progrmn jj/te Enclosure By certified mail
cc: Alan Newman, Ecology Steve VanSlyke, PSCAA

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### STATE OFWASHINGTON DEPARTMENT OFECOLOGY
IN THE MAITER OF AN ADMINISTRATIVE ORDER AGAINST: Final December 2010



### ] ] ] ] REVISED ORDERNO. 7841 Lafarge North Alnerica, Inc.

### --~~-------------------------] TO: Richard Sebastianelli Lafa e North America, Inc. 5400 st Marginal Way Southwest 98106-1517
This is an Administrati Order requiring your company to comply wi WAC 173-400-151 by taking the actions that are escribed below. Chapter 70.94 RCW au orizes the Washington State DepartmentofEcolog 'sAir Quality Program (Ecology) to · sue Administrative Orders to require compliance with there irements ofChapter 70.94 RC and regulations issued to implen1ent it. Ecology has determined·that portions fyour facility are**~ect** to the provisions ofthe federal and state visibility protection program ( AC 173-400- 1 and 40 CFR Part 51, Subpart P). The rules require that the State detennine what chnologi and level ofemission control constitutes Best Available Retrofit Technology (BART) orthe ·ligible emission units atyour facility. The rules also require the installation and use oftho· mission controls on the BART-eligible e1nission units. The emission controls are to be · talled as expeditiously as possible, but in no event canthe State allowthem to start operati n lat than five years after the State's Regional Haze SIP amendment is approved·by the U ted State nvironmental Protection Agency (EPA). 

### FINDINGS A. The Lafarge North America, In ., Seattle Plant (Lafarge) is wet process cement plant subjectto BART. B. BART emission lin1itatio
. for the plant are based on:
a. Use ofexisting b houses and electrostatic**pr~cipitators** for the con ·ol ofparticulate matter. 

### b. ormid-kiln tiring ofwhole tires for control ofnitrogen oxid
. c. Use of e existing wet process rotary kiln process plus dry sorbent injection fo ofsu ur dioxide (S02) emissions. C. The afarge North America Seattle Cement plant is included in federal Consent Decree ving Case 3:10-cv-00044-JPG-CJP, Filed 03/18/10 in United States District Court for

L- 250Final December201 0 Lafarge North An1erica, Inc. Page 2 of7 vised BARTCompliance Order#7841 July ,2010
the Southern istrict ofIllinois. This Consent Decree establishes co tance schedules and emission limitatt s for a number ofcement kilns owned and oper d by Lafarge North America. In additio o emission litnitations and dates to achie compliance with those limitations, the Consent cree contains provisions related tetnporary cessation of operation ofa kiln. Thesep isions require that a kiln mp]y with the en1ission lilnits applicable to it when the kiln is tarted (provided t restart is after the date establishedto comply with the new emission limit · ns) orift kiln is not operated for more than two years, a restart ofthe kiln is to be treate D. On July 27, 2010, Lafarge North Arne · a reque d the BART Compliance Orderbe revised primarily to reflect specific criteria · eluded in the ral Consent Decree, eliminate some initial stacktestingperformanc equirements, and to eh ·nate compliance schedule dates that occurred prior to issuan ofthe Order. No emission lin · ation is being changed as part ofthis request, nor is the erformancc test using EPA reference thods being deleted. The request also included veral administrative changes such as the na ofthe plant tnanager, which have been de
.

.Additional intl ation and analysis is available in the BART Determination Suppo ocument for Lafarge orth America, Seattle Plant, prepared by the Washington State Departmen Ecolog ctober 2008, and the Proposed BestAvailable Retrofit Technology (BART) fort Lafi e Plant in Seattle, Washington, prepared by RTP Environmental Associates onbehalfof arge North America, December 2007. YOU ARE ORDERED: To install and operate emission control equipment in accordance with the following conditions: BART EMISSION LIMITATIONS 1. Particulate Matter Emissions 1.1. Meet the emission limitations for particulate matter found in Puget Sound Clean Air Agency's (PSCAA) Regulation I, Section 9.09 (in effect on June 30, 2008), and Order ofApproval Nurnher 5627. 1.2. Compliance will be determined as specified in Air Operating PermitNumber 14046. 2. Nitrogen Dioxide Emissions 2. I. Starting no later than the date in Condition 5, emissions ofnitrogen dioxide from the wet process rotary cement kiln arc limited to a maximum of: 2.1.1. 22,960 lb/calendar day, except during periods ofcontrol system malfunction.

L • 251Lafarge North America, Inc. Revised BART Compliance Order#7841 July 28,2010 Final December 2010 Page 3 of7

·2.1.2. During documented periods ofemission control system malfunction (as defined in 40 CFR 60.2), Lafarge shall utilize good operating practices to n1inin1ize nitrogen dioxide emissions. 2.2. Compliance will be determined by use ofa continuous e1nission n1onitoring system. 2.3. An initial performance test utilizing EPA Reference Method 7E will beperfom1ed within 180 days ofthe start ofoperation ofthe NOx control systen1. 3. Sulfur Dioxide Emissions 3.1. Starting no later than the date in Condition 5, emissions ofsulfurdioxide fron1 the wet process rotary cement kiln are limited to a maximum of: 3.1.1. 8,620 lb/calendar day, except during periods ofemission control system malfunction. 3.1.2. 1 000 ppmdv, 1-hour average. 3.1.3. During documented periods ofemission control system malfunction (as defined in 40 CFR 60.2), Lafarge shall utilize good operating practices to minimize sulfur dioxide emissions. 3.2. Compliance will be determined by usc ofa continuous emission monitoring system. 3.3. 

### An initial perfonnancetest utilizing EPA Reference Method 6C will be performed within 180 days ofthe start ofoperation ofthe

## so2 control system. SCHEDULE FOR COMPLIANCE 4. Particulate Matter Emissions 4.1. Compliance with the emission limitations is required upon the effective date ofthis Order. 5. Schedule for Compliance.with Sulfur Dioxide and Nitrogen Dioxide Emissions 5.1. Compliance with the sulfur dioxide and nitrogen dioxide emission limitations is required. Compliance will be assured by meeting the following milestones: 5.1.1. Installation and operation of

### S02 and NOx controls no later than February I, 2011, unless the kiln is in temporary cessation on that date per Section VII ofthe federal Consent Decree.

L- 252Lafarge North America, Inc. Revised BART Cmnpliance Order#784I ·July28,2010 Final December 201 0 Page 4 of7

5.I.2. Ifthe kiln is in temporary cessation on February I, 2011, then installation and operation ofS02 and NOx controls no later than the date that the**~iln** is restarted after February I, 2011. 5.2. Operate incompliance with the S02 emission limitations no laterthan April 30, 201I, or 90 days afterthe kiln is restarted ifthe kiln is in temporary cessation on February 1, 20I1. 5.3. Operate in compliance with the NOx emission limitation no laterthanthe date Lafarge completes optimization ofthe NOx control system perthe criteriain paragraph 10 ofthe Appendix to the Consent Decree. MONITORING AND RECORDKEEPING REQUIREMENTS 6. Particulate Matter 6.1. Monitoring and recordkeeping requirements are contained in Air Operating Permit Number 14046, issued to Lafarge North America, Seattle Plant on May 15, 2004, and modified July 28, 2004, by the PSCAA. 7. SulfurDioxide 7.1. Sulfurdioxide emissions are to be quantified by means ofa continuous en1ission monitoring system, consisting ofa continuous sulfur dioxide monitor, and a continuous flow rate monitor. 7.2. The sulfurdioxide monitormust n1eet the requirements of40 CFR Part 60, Appendix B, Performance Specification 2. 7.3. The flow rate 1nonitor must meet the requirements of40 CFR Part 60, Appendix B, Performance Specification 6, except for location ofthe flow rate monitor. The flow rate n1onitor may be collocated with the nitrogen dioxide or sulfur dioxide monitor'sprobe, provided that location is demonstrated to meet the otherrequirements in Performance Specification 6 and the quality assurance requirements referenced in Condition 7

### .4. 7.4. As a minimum, the continuous emission monitors must meet the annual quality assurance requirement of40 CFR Part 60, Appendix F. 7.5. Each calendarday's sulfurdioxide emissions will be calculated and recorded daily. 8. Nitrogen Dioxide Emissions

L- 253Lafarge North America, Inc. Revised BARTCompliance Order#7841 July 28, 20I0 Final December 2010 Page 5 of7

8.1. Nitrogen dioxide emissions are to be quantified by means ofa continuous emission monitoring system, consisting ofa continuous nitrogen oxides monitor, and a continuous flow rate monitor. 8.2. The nitrogen oxides monitor must meet the requirements of40 CFRPart 60, Appendix B, Perfom1ance Specification 2. 8.3. The flow rate monitormust meet the requirements of40 CFRPart 60, Appendix B, Performance Specification 6, except for location ofthe flow rate monitor. The flowrate monitor may be collocated with the nitrogen dioxide orthe sulfurdioxide n1onitor's probe, provided that location is demonstrated to meet the otherrequirements in Performance Specification 6 and the quality assurance requirements referenced in Condition 8.4. 8.4. As a minimum, the continuous emission monitors must meet the annual quality assurance requirement of40 CFR Part 60, Appendix F. 8.5. Each calendarday's nitrogen oxides emissions will be calculated and recorded daily.**REI)OI~TING** REQUIREMENTS 9. Initial perfom1ance testing ofthe NOx emission control systen1 required by Condition 2.3 and the S02 control system required by Condition 3.3 shall he submitted to Ecology and to PSCAA within 30 days ofcompletion. I0. Documentation ofeach action oractivity listed in Condition 5, includingnotification ofthe start and end oftemporary cessation ofkiln operation, will be provided by Lafarge by certified mail to Ecology and to PSCAA within 30 days ofcompletion. II. Malfunction ofthe etnission control system must, at a minimum, be documented in writing and submitted to PSCAA and Ecology with the emissions monitoringdata per Condition 12. Additional rccordkeeping and notifications related to excess emissions may also be required by Ecology rule orPSCAA regulation. 12. Continuous emission n1onitoring data shall be submitted to Ecology and to PSCAA in accordance with PSCAA's Regulation I, Section 12.03 (effective June 30, 2008). The submittal shaiJ be sent electronically in a format acceptable to PSCAA. Reporting to Ecology will end when Lafarge has demonstrated compliance with the BARTemission limits in this order for a continuous 36-month period.

L- 254Lafarge North America, Inc. Revised BARTCompliance Order#7841 July 28,2010 Final December 2010 Page 6 of7

The plant has continuously complied with the emissions limitations in Condi ·
, 2, and 3 for a period ofthree years after the date in Condition 5.2. 13.2. The emission limitations in this Order.have been incorporated into a nforceable ordero ermit issued under the criteria ofRCW 70.94.152 or70.94.153 nd PSCAA regulatio implementingthese provisions. 13.3. The em ion limitations in the enforceable orderorpem1· 1ave been incorporated into e Air Operating Permit issued 

### by PSCAA Lafarge. This revision replaces Order Failure to comply with this Order whetheradministrative orjudicial, to result in the issuanc ofcivil penalties orotheractions, this Order. You have aright to appeal this Order.

Q File your appeal with the Pollution C tr Hearing Board within 30 days ofthe '"date of receipt" ofthis docun1ent. Filing 1 ans act 

### I receipt by the Board during regular office hours.

$ Serve your appeal on the pm1ment ofEcology w 1in 30 days ofthe "date ofreceipt" ofthis document. Serv· e may be accomplished by a ofthe procedures identified in WAC 371-08-305(1
. "Date ofreceipt" is defined at R W 43.21B.001(2).

• py ofthis document with your Notice ofAppeal. 

# • afile your appeal in paper fom1; electronic copies are not ac To file y r appeal with the Pollution Control Hearing Board:

The Pollution Control Hearings Board P.O. Box 40903 Olympia, WA 98504-0903 OR

l- 255 Deliver your appeal in person to: The Pollution Control Hearings Boa 4224-6th Avenue SE Rowe Six, Bldg Lacey, W A 98503Latarge North America, Inc. Revised BART Con1pliance Order#7841 July 28, 2010

our appeal on the Department ofEcology:
Department o cology Appeals Coordina r P.O. Box 47608 Olytnpia, WA 98504- And send a copy ofyour appeal Alan Newman Department ofEcology Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 For additional information, go to the http:/ 

### /www.eho.wa.gov. OR Department fEcology Appeals ordinator 300 De 1ond Drive SE Lace , WA 98503 Final December 201 0 Page 7 of7

Your appeal alone will ot stay the effectiveness ofthis Order. Stayr uests must be submitted in accordance with 

### W43.21B.320. These procedures are consistent · h Chapter43.21B RCW.

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