New York State Department of Environmental Conservation 

Best Available Retrofit Technology Determination 

Facility Lafarge Building Materials, Inc. 

Location Ravena, NY 

Albany County 

Permit ID 4-0124-00001 

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 Retrofit Technology (BART) rule under 40 CFR Part 

51 and Appendix Y, and the New York State BART regulation as codified under 6 NYCRR Part 

249. These requirements affect an emission source which fulfills the following criteria: 

1. Falls within one of 26 specific 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 other 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 particulate matter. This analysis took 

into account such factors as the cost of controls, energy and non-air quality environmental 

impacts of compliance, any existing pollution control technology in use at the source, the 

remaining useful life of the source, and the degree of improvement in visibility which may 

reasonably be anticipated to result from the use of such technology. 

This document summarizes the reasoning behind the Department’s BART determination, 

including the level of controls 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). 

 

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II. Proposed BART Compliance Method 

Lafarge submitted their BART compliance recommendation for their portland cement plant in 

the village of Ravena in a letter dated September 30, 2010. The two long wet kilns at this 

Lafarge plant had previously been identified as the BART-eligible units. 

Lafarge entered into a consent decree with EPA (Case 3:10-cv-000440JPG-CJP, filed January 

21, 2010), which contains a compliance schedule for the Ravena plant to modernize the existing 

plant by retrofitting the existing kilns with NOx and SO2 controls, or otherwise retire the kilns. 

The plant's current Title V permit already contains these requirements and deadlines. 

In response to the consent decree, Lafarge opted to retire its existing kilns and replace them with 

one short dry kiln and pre-heater pre-calciner tower. The target completion date for the project is 

during 2014. Lafarge recommends that these requirements under the consent decree be accepted 

in lieu of a BART analysis. 

III. BART Determination 

The Department accepts Lafarge’s proposal for retiring the BART-eligible kilns pursuant to its 

consent order. The Department did not require a complete BART analysis as per Part 249.3 for 

the following reasons: 

• Remaining useful life of the source: The BART-eligible kilns are on schedule to be 

replaced during 2014. The Department had established a January 1, 2014 date for 

compliance with BART. The remaining useful life of these units beyond the BART 

compliance date is therefore likely to be less than a year. 

• Cost of controls: In conducting economic assessments for control equipment, the average 

life of a unit is typically considered to be 10 years. Control costs would be overly 

excessive when considering the short amount of time they would be operating on these 

eligible units. 

• Unit efficiency: The operation of the short dry kiln required under the consent order will 

produce much lower emissions than the present long wet kilns—at least equal to, and 

likely well beyond, the reductions that could have been gained with any BART controls. 

• BART deadline: Under the regional haze rule, BART must be implemented within five 

years of SIP action by EPA. The existing BART-eligible kilns will be retired within this 

timeframe pursuant to the consent decree. 

The Title V permit for Lafarge contains a requirement under condition 12-14 that “[u]pon 

commencing production of clinker from the new kiln (EU 41100), the facility shall immediately 

discontinue use of the old kilns (EU 41000).” This permit is being submitted to EPA as a 

revision to the New York Regional Haze SIP.