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 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). 

The Department has modified this facility’s Title V permit to include the enforceable BART 

limits. The modifications were noticed in New York State’s Environmental Notice Bulletin on 

November 23, 2011. Upon completion of this public notice period, the modified permit was 

submitted to EPA for review on January 13, 2012. The final modified permit was issued on 

February 28, 2012. This permit is now being submitted to EPA as a revision to the New York 

Regional Haze SIP. 

 

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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 rated 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 portion of the kiln was also analyzed in this 

BART plan for its PM emissions. 

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

• SO2 

The rotary kiln reduces SO2 emissions through an inherent dry scrubbing (IDS) process. 

As a result of the SO2 scrubbing that occurs within the raw mill when operating, the SO2

concentration in the flue gas at the Glens Falls plant is typically 20 parts per million, 

which is equivalent to an SO2 reduction efficiency of greater than 85 percent versus 

operation with the raw mill off. Conservatively, 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 SO2; this also operates for detached plume abatement. This lime 

spray drying system achieves an SO2 reduction of up to 74 percent compared to typical 

concentrations of SO2 in the flue gas during raw mill off conditions. Upgrading this 

system to achieve additional SO2 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 SO2 reduction options were considered 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 SO2 emissions, 

as SO2 from the fuel is absorbed in the internal cycle through IDS. 

o Raw Material Substitution – An on-site quarry currently provides the limestone 

used for cement production. Purchasing and shipping limestone from another site 

was ruled out as being economically prohibitive. 

o Dry Lime Injection – This option is considered 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 SO2 by up 

to 60 percent, less than that of the existing lime spray dryer. SO2 reductions for 

operation with the raw mill on were greater through IDS than with dry lime 

injection. Since existing controls are more effective at reducing kiln SO2

emissions, this option was removed from further consideration. 

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o Wet Lime Scrubbing (WLS) – WLS is considered to be technically feasible, and 

can yield an SO2 reduction efficiency up to 90 percent. Because this is greater 

than the efficiencies currently achieved, an economic analysis was performed. A 

WLS unit of sufficient size for the kiln exhaust 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 SO2 reduction methods, and the costs and technical 

issues associated with additional control options, Lehigh proposes that the Glens Falls 

plant meets BART for SO2 through existing operations. 

• NOx

Lehigh identified five potential NOx control technologies for BART for the rotary kiln. 

Flue gas recirculation, selective catalytic reduction, and cement kiln dust insufflation 

were ruled out due to technical infeasibility, as these options have not been demonstrated 

as effective for cement kilns. Selective non-catalytic reduction (SNCR) and low NOx

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 the cost effectiveness of an SNCR unit to be 

$1,145 per ton of NOx removed. Because of the favorable costs and the high rate of NOx

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 NYCRR Part 220, under which portland cement 

plants are regulated. This revision updated the RACT requirements for such plants, and 

required that each plant submits an updated RACT analysis for gaseous emissions (i.e., 

NOx) from kiln stacks. Due to the common economic threshold and similar evaluation 

methodologies used for RACT and BART, Lehigh is proposing that the installation of 

SNCR satisfy both requirements. 

• PM 

Lehigh currently controls PM emissions from the kiln through an electrostatic 

precipitator (ESP), and from the 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 method 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 the finalized revisions to 40 CFR Part 60 Subpart LLL, 

National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland 

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Cement Manufacturing Industry. Lehigh later cited the uncertainty of the NESHAP 

compliance deadline in deciding to delay installation 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: 

• SO2

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 SO2. Lehigh has 

demonstrated that alternate or additional control options are either technically infeasible, 

economically infeasible, or result in lesser control efficiencies than existing controls. 

• NOx

The Department accepts the installation of an SNCR unit as BART for NOx. This type of 

control has been deemed the “Best Demonstrated Technology” for NOx control at cement 

plants according to the NSPS under 40 CFR Part 60, Subpart F. 

Lehigh did not propose a specific emission rate on a “pound of NOx per ton of clinker 

produced” basis in its BART or RACT plan. In subsequent communications, Lehigh and 

the Department established a RACT/BART emission rate of 2.88 pounds of NOx per ton 

of clinker produced. Standard practice is for the limit to be adjusted, if necessary, once 

installation and testing has been completed. 

Part 220 requires the control unit to be installed 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 submittals, 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 Lehigh Glens Falls plant. Lehigh adequately 

demonstrated that a baghouse for the kiln was economically infeasible, though it plans to 

install a baghouse by the compliance deadline for the final portland cement NESHAP 

(PC MACT) rule. 

Note that the currently issued Title V permit states that installation of a baghouse will 

represent BART. The Department will be modifying this requirement, based on a request 

from Lehigh, to have the existing ESP represent BART control. It should be reiterated 

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that Lehigh found the installation of a baghouse to be economically infeasible for BART 

purposes, but committed to it based on the upcoming PC MACT rule. Lehigh is still 

intending to install a baghouse by the PC MACT compliance date. 

EPA, in its final BART rule, stated that MACT standards could be relied upon for the 

purposes of BART. The clinker cooler is currently complying with its applicable MACT 

limit through the use of the baghouse. The kiln’s baghouse will be installed for 

compliance with the upcoming portland cement MACT. 

BART for PM will be continued compliance with the existing particulate emission limits 

of 0.150 grains of particulates per dry standard 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.