1 New York State Department of Environmental Conservation Best Available Retrofit Technology Determination

Facility Lehigh Northeast Cement Company

Location Glens Falls, NY Warren County
Permit ID 5-5205-00013 Source Category Portland Cement Plant

I. Introduction

The above referenced facility contains at least one emission source that falls under the requirements of the federal Best Available Retr ofit Technology (BART) rule under 40 CFR Part 51 and Appendix Y, and the New York State BA RT regulation as codified under 6 NYCRR Part 249. These requirements affect an emission s ource which fulfills the following criteria:

1. Falls within one of 26 sp ecific source categories,
2. Was not in operation prior to August 7, 1962 and was in existence on August 7, 1977, or underwent reconstruction between August 7, 1962 and August 7, 1977, and
3. Has a potential to emit (collectively, with ot her emission sources at the facility which fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant.

In accordance with BART requirements, each BART-eligible facility performed a BART analysis of controls for sulfur dioxide, nitrogen oxides and particul ate matter. This analysis took into account such factors as the cost of c ontrols, energy and non-air quality environmental impacts of compliance, any existing pollution co ntrol technology in use at the source, the remaining useful life of the source, and the de gree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

This document summarizes the reasoning be hind the Department’s BART determination, including the level of cont rols and emission limits that constitute BART for this facility’s eligible emission source(s). Each analysis and BART determination was submitted to the Federal Land Managers (FLMs) for their review in accordance with Regional Haze State Implementation Plan (SIP) requirements. Comments received from the FLMs on this determination will be included with its official submission to the U.S. Environmental Protection Agency (EPA).

The Department has modified this facility’s Title V permit to include the enforceable BART limits. The modified permit was initially issued on February 28, 2012. A second permit modification was necessary for two additional changes (including an additional BART SO 2 emission limit as requested by EPA, and removi ng a reference to the in stallation of a baghouse after the Portland Cement MACT rule was delayed).

The facility’s Title V permit was re-proposed with these modifications on May 30, 2012. The draft permit was submitted to EPA for review on July 2, 2012, and was issued on July 5, 2012. This permit is now being submitted to EPA as a revision to the New York Regional Haze SIP.2 II. BART Analysis Summary

Lehigh Northeast Cement Company submitted a BART analysis for their Glens Falls plant dated September, 2010. The following emission source had previously been identified as BARTeligible and was therefore included in the analysis:

Rotary Kiln – Emission Unit 0-UKILN; Emission Source

• This unit is a short, dry preheater kiln ra ted at 160 tons per hour. The unit began operation in 1971. Coal is the primary fuel used in the kiln, with natural gas used as a startup or backup fuel. The clinker cooler por tion of the kiln was al so analyzed in this BART plan for its PM emissions.

A summary of the analysis’ findings for each pollutant follows:

• SO 2

The rotary kiln reduces SO 2 emissions through an inherent dry scrubbing (IDS) process. As a result of the SO 2 scrubbing that occurs within the raw mill when operating, the SO 2 concentration in the flue gas at the Glens Falls plant is typically 20 parts per million, which is equivalent to an SO 2 reduction efficiency of great er than 85 percent versus operation with the raw mill off. Conservative ly, the raw mill is estimated to be operating approximately 80 percent of the time.

For raw mill off conditions, the Glens Falls plant employs lime spray drying using a lime slurry system to reduce SO 2 ; this also operates for detached plume abatement. This lime spray drying system achieves an SO 2 reduction of up to 74 percent compared to typical concentrations of SO 2 in the flue gas during raw mill off conditions. Upgrading this system to achieve additional SO 2 reduction was considered as part of the BART analysis. It was determined that the current system is adequately sized, and that it would be technically infeasible to install more spray lances to inject more slurry into the gas conditioning tower.

Other SO 2 reduction options were consider ed for the Glens Falls plant:

o Fuel Substitution – While technically feasible, fuel substitution was eliminated as a control option because it would have no appreciable impact on SO 2 emissions,
as SO 2 from the fuel is absorbed in th e internal cycle through IDS.

o Raw Material Substitution – An on-site qu arry currently provides the limestone used for cement production. Purchasing a nd shipping limestone from another site was ruled out as being economically prohibitive.

o Dry Lime Injection – This option is cons idered technically feasible. A study was undertaken at the Glens Falls plant in 2008 to determine the effectiveness of this technology. Dry lime injection during raw mill off conditions reduced SO 2 by up to 60 percent, less than that of the existing lime spray dryer. SO 2 reductions for operation with the raw mill on were great er through IDS than with dry lime injection. Since existing controls are more effective at reducing kiln SO 2 emissions, this option was removed from further consideration.3 o Wet Lime Scrubbing (WLS) – WLS is consid ered to be technically feasible, and can yield an SO 2 reduction efficiency up to 90 per cent. Because this is greater than the efficiencies currently achieved, an economic analysis was performed. A WLS unit of sufficient size for the kiln e xhaust would lead to annualized costs up to $9.3M per year. When factoring in a 90 percent control efficiency, the cost effectiveness would be approximately $39,600 per ton. This option was therefore ruled out due to economic infeasibility.

Given the efficiency of the existing SO 2 reduction methods, and the costs and technical issues associated with additional control opt ions, Lehigh proposes that the Glens Falls plant meets BART for SO 2 through existing operations.

• NO x

Lehigh identified five potential NO
x control technologies for BA RT for the rotary kiln. Flue gas recirculation, select ive catalytic reduction, and ce ment kiln dust insufflation were ruled out due to technical infeasibility, as these options have not been demonstrated as effective for cement kilns. Selectiv e non-catalytic reduction (SNCR) and low NO
x burners (LNB) were considered further.

The estimated control effectiveness of SNCR is 50 percent, while LNB were estimated at 15 to 25 percent control. Lehigh calculated th e cost effectiveness of an SNCR unit to be $1,145 per ton of NO
x removed. Because of the favorab le costs and the high rate of NO
x control, Lehigh is committing to install an SNCR unit on the rotary kiln. The LNB option was not investigated further because of its much lower control efficiency.

The Department recently revised 6 NYC RR Part 220, under which portland cement plants are regulated. This revision updated the RACT requi rements for such plants, and required that each plant submits an updated RACT analysis for gaseous emissions (i.e.,
NO x ) from kiln stacks. Due to the common economic threshold and similar evaluation methodologies used for RACT and BART, Lehi gh is proposing that the installation of SNCR satisfy both requirements.

• PM

Lehigh currently controls PM emissions fr om the kiln throug h an electrostatic precipitator (ESP), and from th e associated clinker cooler through a baghouse. Potential control technologies identified were ESPs, baghouses, and cyclone units. Wet scrubbing was deemed technically infeasible as these units are not found at modern cement plants for PM control.

Baghouses were cited as the most effective met hod of PM control, with efficiencies at 99 to 99.9 percent. The cost-effectiveness of a baghouse on the kiln would be nearly $17,000 per ton. Lehigh initially committed to replacing the existing ESP unit with a baghouse in anticipation of th e finalized revisions to 40 CFR Part 60 Subpart LLL, National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland4 Cement Manufacturing Industry. Lehigh late r cited the uncertain ty of the NESHAP compliance deadline in deciding to delay in stallation of the baghouse. It proposes continued operation of the ESP unit as BART until the baghouse is installed, when the applicable PM limitations of §63.1343 will be met.

III. BART Determination

The Department finds that the following shall constitute BART for the Lehigh Northeast Cement Company Rotary Kiln:

• SO 2

The Department accepts Lehigh’s demonstration that current controls at the Glens Falls plant, including the operation of the lime spray dryer as specified in Lehigh’s “Detached Plume Control” plan (last modified July 16, 2010), represent BART for SO 2 . Lehigh has demonstrated that alternate or additional control options are either technically infeasible, economically infeasible, or result in lesser co ntrol efficiencies th an existing controls.

The Department also worked with Lehigh to agree upon an SO 2 emission limit for the kiln, equal to 1.50 lb/mmBtu. Compliance w ill be demonstrated based on a weighted average from three one-hour runs in both roll er mill on (80% of the time) and roller mill off (20% of the time) modes annually.

• NO x

The Department accepts the installati on of an SNCR unit as BART for NO
x . This type of control has been deemed the “Bes t Demonstrated Technology” for NO
x control at cement plants according to the NSPS unde r 40 CFR Part 60, Subpart F.

Lehigh did not propose a specific emission rate on a “pound of NO
x per ton of clinker produced” basis in its BART or RACT plan. In subsequent comm unications, Lehigh and the Department established a RACT/B ART emission rate of 2.88 pounds of NO
x per ton of clinker produced. Standard practice is fo r the limit to be adjusted, if necessary, once installation and testing has been completed.

Part 220 requires the control unit to be in stalled and operating by July 1, 2012, with testing completed shortly after. Although this differs from the timeframe Lehigh proposed in its initial BART and RACT submitta ls, Lehigh later agreed to meet the Part 220 deadline.

• PM

The Department accepts the existing ESP on the kiln and the existing baghouse on the clinker cooler as BART for PM at the Le high Glens Falls plant. Lehigh adequately demonstrated that a baghouse for the kiln was economically infeasible. (Lehigh does5 intend to install a baghouse by the compliance deadline for the final portland cement NESHAP (PC MACT) rule, though th at will be dealt with at the appropriate time.)

EPA, in its final BART rule, stated that MACT standards could be relied upon for the purposes of BART. The clinker cooler is cu rrently complying with its applicable MACT limit through the use of the baghouse.

BART for PM will be continued compliance w ith the existing particulate emission limits of 0.150 grains of particulates per dry standa rd cubic foot, and 0.3 pounds per ton of feed (on a 1-hour average). BART for PM will be further ensured through compliance with the emission limits under 6 NYCRR Part 225-1, 40 CFR Part 63.1343, and the upcoming
PC MACT.