New York State Department of Environmental Conservation 

Best Available Retrofit Technology Determination 

Facility Holcim (US) Inc. – Catskill Plant 

Location Catskill, NY 

Greene County 

Permit ID 4-1926-00021 

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. 

Emission sources that are deemed eligible by the above criteria may be exempted by the BART 

analysis through several means, as follows: 

1. A permit condition may be accepted which restricts the eligible source’s potential to emit 

to less than 250 tons per year for each visibility-impairing pollutant, as per Part 

249.1(c)(1). 

2. A permit condition may be accepted that requires the source to permanently shut down 

the unit by January 1, 2014, as per Part 249.1(c)(2). 

3. The facility may show through modeling or other means acceptable to the Department 

that it does not or will not emit any combination of visibility-impairing pollutants that 

results in a visibility impairment equal to or greater than 0.1 deciviews in any federal 

Class I area, as per Part 249.1(c)(3). 

II. Proposed BART Compliance Method 

Holcim (US) Inc. submitted a BART analysis for their Catskill Plant, dated September 2010. 

The plant’s kiln had been identified as a BART-eligible unit, and this analysis presented the 

technical and economic considerations of NOx, SO2, and PM10 controls. 

The Catskill Plant had been “mothballed” since October 2010, and Holcim had planned on 

retaining the plant’s permits in case it wished to resume operations in the future. Recently, 

however, Holcim made the decision to permanently close the plant, and surrender the plant’s 

permits. Holcim is also currently beginning the demolition of the plant. 

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III. BART Determination 

The Department finds that the closure of the Catskill Plant meets the requirements of Part 

249.1(c)(2). On February 8, 2012, Holcim sent a letter to the Department’s Michael Higgins 

(Division of Environmental Permits) announcing, per Part 621.11(d)(1), that it was relinquishing 

its Title V and State Facility Air Permits. The facility’s permits were expired by the Department, 

effective February 12, 2012. 

Since the Department cannot include the shutdown provision in a permit condition (since the 

permit is being relinquished), this proof of permanent closure letter is being submitted to EPA as 

proof of shutdown and as a revision to the New York Regional Haze State Implementation Plan.