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 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).

12 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 Se ptember 30, 2010. The two long wet kilns at this Lafarge plant had previous ly been identified as the BART-eligible units.

Lafarge entered into a consen t decree with EPA (Case 3:10-cv-000440JPG-CJP, filed January 21, 2010), which contains a compliance schedule fo r the Ravena plant to modernize the existing plant by retrofitting the existing kilns with NO

x and SO 2 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 re quirements under the consent decree be accepted in lieu of a BART analysis.

III. BART Determination

The Department accepts Lafarge’s proposal for re tiring 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 usef ul life of these units beyond the BART compliance date is therefore likely to be less than a year.

• Cost of controls: In conducting economic a ssessments 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 pres ent 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 k iln (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.