July 28, 2010 

Mr. Richard Sebastianclli 

LaHtrge North America, Inc. 

5400 West Marginal Way Southwest 

Seattle, W A 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 of your facility. The enclosed Revised Order #7841 contains our BART determination 

tor your facility including a schedule for compliance. This revision replaces Order No. 7841 

dated July 7, 2010. 

If you have questions or requests relating to this order, please contact Alan Newman at 

(360) 407-6810 or alan.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 OF WASHINGTON 

DEPARTMENT OF ECOLOGY 

IN THE MA ITER OF AN 

ADMINISTRATIVE ORDER AGAINST: 

Final December 201 0 

] 

] 

] 

] 

REVISED ORDER NO. 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 Department of Ecolog 's Air Quality Program (Ecology) to · sue Administrative Orders to 

require compliance with there irements of Chapter 70.94 RC and regulations issued to 

implen1ent it. 

Ecology has determined· that portions f your facility are ~ect to the provisions of the 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 of emission control constitutes 

Best Available Retrofit Technology (BART) or the ·ligible emission units at your facility. The 

rules also require the installation and use of tho· mission controls on the BART-eligible 

e1nission units. The emission controls are to be · talled as expeditiously as possible, but in no 

event can the State allow them 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 

subject to BART. 

B. BART emission lin1itatio . for the plant are based on: 

a. Use of existing b houses and electrostatic pr~cipitators for the con ·ol of particulate 

matter. 

b. or mid-kiln tiring of whole tires for control of nitrogen oxid . 

c. Use of e existing wet process rotary kiln process plus dry sorbent injection fo 

of su 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- 250 
Final December 201 0 

Lafarge North An1erica, Inc. Page 2 of7 

vised BART Compliance Order #7841 

July ,2010 

the Southern istrict of Illinois. This Consent Decree establishes co tance schedules and 

emission limitatt s for a number of cement 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 of a kiln. These p 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 established to 

comply with the new emission limit · ns) or ift kiln is not operated for more than two 

years, a restart of the kiln is to be treate 

D. On July 27, 2010, Lafarge North Arne · a reque d the BART Compliance Order be revised 

primarily to reflect specific criteria · eluded in the ral Consent Decree, eliminate some 

initial stack testing performanc equirements, and to eh ·nate compliance schedule dates 

that occurred prior to issuan of the Order. No emission lin · ation is being changed as part 

of this request, nor is the erformancc test using EPA reference thods being deleted. The 

request also included veral administrative changes such as the na of the 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 Best Available Retrofit Technology (BART) fort 

Lafi e Plant in Seattle, Washington, prepared by RTP Environmental Associates on behalf of 

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 

of Approval N urn her 562 7. 

1.2. Compliance will be determined as specified in Air Operating Permit Number 14046. 

2. Nitrogen Dioxide Emissions 

2. I. Starting no later than the date in Condition 5, emissions of nitrogen 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 of control system malfunction. 

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Lafarge North America, Inc. 

Revised BART Compliance Order #7841 

July 28,2010 

Final December 2010 

Page 3 of7 

·2.1.2. During documented periods of emission 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 of a continuous e1nission n1onitoring system. 

2.3. An initial performance test utilizing EPA Reference Method 7E will be perfom1ed 

within 180 days of the start of operation of the NOx control systen1. 

3. Sulfur Dioxide Emissions 

3.1. Starting no later than the date in Condition 5, emissions of sulfur dioxide fron1 the wet 

process rotary cement kiln are limited to a maximum of: 

3.1.1. 8,620 lb/calendar day, except during periods of emission control system 

malfunction. 

3 .1.2. 1 000 ppmdv, 1-hour average. 

3.1.3. During documented periods of emission 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 of a continuous emission monitoring system. 

3.3. An initial perfonnance test utilizing EPA Reference Method 6C will be performed 

within 180 days of the start of operation ofthe so2 control system. 

SCHEDULE FOR COMPLIANCE 

4. Particulate Matter Emissions 

4.1. Compliance with the emission limitations is required upon the effective date of this 

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 of the 

federal Consent Decree. 

L- 252 
Lafarge North America, Inc. 

Revised BART Cmnpliance Order #784I 

·July 28,2010 

Final December 201 0 

Page 4 of7 

5. I .2. If the kiln is in temporary cessation on February I, 2011, then installation and 

operation of S02 and NOx controls no later than the date that the ~iln is restarted 

after February I, 2011. 

5.2. Operate in compliance with the S02 emission limitations no later than April 30, 201I, or 

90 days after the kiln is restarted if the kiln is in temporary cessation on February 1, 

20I1. 

5.3. Operate in compliance with the NOx emission limitation no later than the date Lafarge 

completes optimization of the NOx control system per the criteria in paragraph 10 of the 

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. Sulfur Dioxide 

7.1. Sulfur dioxide emissions are to be quantified by means of a continuous en1ission 

monitoring system, consisting of a continuous sulfur dioxide monitor, and a continuous 

flow rate monitor. 

7.2. The sulfur dioxide monitor must n1eet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 2. 

7.3. The flow rate 1nonitor must meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 6, except for location of the flow rate monitor. The flow rate 

n1onitor may be collocated with the nitrogen dioxide or sulfur dioxide monitor's probe, 

provided that location is demonstrated to meet the other requirements 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 of 40 CFR Part 60, Appendix F. 

7.5. Each calendar day's sulfur dioxide emissions will be calculated and recorded daily. 

8. Nitrogen Dioxide Emissions 

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Lafarge North America, Inc. 

Revised BART Compliance Order #7841 

July 28, 20 I 0 

Final December 2010 

Page 5 of7 

8.1. Nitrogen dioxide emissions are to be quantified by means of a continuous emission 

monitoring system, consisting of a continuous nitrogen oxides monitor, and a continuous 

flow rate monitor. 

8.2. The nitrogen oxides monitor must meet the requirements of 40 CFR Part 60, Appendix 

B, Perfom1ance Specification 2. 

8.3. The flow rate monitor must meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 6, except for location of the flow rate monitor. The flow rate 

monitor may be collocated with the nitrogen dioxide or the sulfur dioxide n1onitor' s 

probe, provided that location is demonstrated to meet the other requirements 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 of 40 CFR Part 60, Appendix F. 

8.5. Each calendar day's nitrogen oxides emissions will be calculated and recorded daily. 

REI)OI~TING REQUIREMENTS 

9. Initial perfom1ance testing of the 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 of completion. 

I 0. Documentation of each action or activity listed in Condition 5, including notification of the 

start and end of temporary cessation of kiln operation, will be provided by Lafarge by 

certified mail to Ecology and to PSCAA within 30 days of completion. 

II. Malfunction of the etnission control system must, at a minimum, be documented in writing 

and submitted to PSCAA and Ecology with the emissions monitoring data per Condition 12. 

Additional rccordkeeping and notifications related to excess emissions may also be required 

by Ecology rule or PSCAA 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 BART emission limits 

in this order for a continuous 36-month period. 

L- 254 
Lafarge North America, Inc. 

Revised BART Compliance 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 of three years after the date in Condition 5.2. 

13.2. The emission limitations in this Order.have been incorporated into a nforceable 

order o ermit issued under the criteria of RCW 70.94.152 or 70.94.153 nd PSCAA 

regulatio implementing these provisions. 

13.3. The em ion limitations in the enforceable order or pem1· 1ave been 

incorporated into e Air Operating Permit issued by PSCAA Lafarge. 

This revision replaces Order 

Failure to comply with this Order 

whetheradministrative or judicial, to 

result in the issuanc of civil penalties or other actions, 

this Order. 

You have a right to appeal this Order. 

Q File your appeal with the Pollution C tr Hearing Board within 30 days of the '"date of 

receipt" of this docun1ent. Filing 1 ans act I receipt by the Board during regular office 

hours. 

$ Serve your appeal on the pm1ment of Ecology w 1in 30 days of the "date of receipt" 

of this document. Serv· e may be accomplished by a of the procedures identified in 

WAC 371-08-305(1 . "Date of receipt" is defined at R W 43.21B.001(2). 

• py of this document with your Notice of Appeal. 

• a file 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 A venue SE Rowe Six, Bldg 

Lacey, W A 98503 
Latarge North America, Inc. 

Revised BART Con1pliance Order #7841 

July 28, 201 0 

our appeal on the Department of Ecology: 

Department o cology 

Appeals Coordina r 

P.O. Box 47608 

Olytnpia, W A 98504-

And send a copy of your appeal 

Alan Newman 

Department of Ecology 

Air Quality Program 

P.O. Box 47600 

Olympia, W A 98504-7600 

For additional information, go to the 

http:/ /www.eho. wa. gov. 

OR 

Department fEcology 

Appeals ordinator 

300 De 1ond Drive SE 

Lace , W A 98503 

Final December 201 0 

Page 7 of7 

Your appeal alone will ot stay the effectiveness of this Order. Stay r uests must be submitted 

in accordance with W 43.21B.320. These procedures are consistent · h Chapter 43.21B 

RCW. 

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