Operating company Ash Grove Cement

Facility Montana City

State MT/EPA R-8

Contact Vanessa Hinkle EPA R8

Distance to nearest Class I Area (km) 30 Gates of the Mountains WA

# of Class I Areas evaluated/within 300 km 1 of 12

Proposed BART Control Option for long, wet kiln LNB&SNCR

Current Emissions (tpy) 1,891 Federal Register /Vol. 77, No. 77 

Capital Cost $ 1,191,633 Federal Register /Vol. 77, No. 77 

O&M Cost $ 1,989,187 Federal Register /Vol. 77, No. 77 

Total Annual Cost $ 2,238,892 Federal Register /Vol. 77, No. 77 

Reduction 58% Federal Register /Vol. 77, No. 77 

Reductions (tpy) 1,088 Federal Register /Vol. 77, No. 77 

New Emisison Rate (tpy) 803 Federal Register /Vol. 77, No. 77 

Cost-Effectiveness ($/ton) $ 2,058 Federal Register /Vol. 77, No. 77 

Proposed BART limit for long, wet kiln 8.0 lb NOx/ton clinker (30-day rolling 

Federal Register /Vol. 77, No. 77 

Visibility analyses

Visibility Impact before BART (dv at Max Class I) 4.446 Federal Register /Vol. 77, No. 77 

Visibility Impact after BART (dv at Max Class I) 3.198 calculated from EPA report

Visibility Improvement (dv at Max Class I) 1.248 Federal Register /Vol. 77, No. 77 

Cost-Effectiveness ($/98th % dv at Max Class I) $ 1,793,984 calculated from EPA report

Pollutant Control Effectiveness (dv/ton) 0.0011 calculated from EPA report

Visibility Impact before BART (dv at Summed Class I) 8.279 calculated from EPA report

Visibility Impact after BART (dv at Summed Class I) 5.508 calculated from EPA report

Visibility Improvement (dv at Summed Class I) 2.771 calculated from EPA report

Cost-Effectiveness ($/98th % dv at Summed Class I) $ 807,973 calculated from EPA report

Pollutant Control Effectiveness (dv/ton) 0.0025 calculated from EPA report
hinkle.vanessa@epa.gov (303) 312–6561

s of the Mountains WA

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

x/ton clinker (30-day rolling average)

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ated from EPA report

ral Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

ated from EPA report

ated from EPA report

ated from EPA report

ated from EPA report

ated from EPA report

ated from EPA report

ated from EPA report
Operating company CEMEX 

Facility Lyons

State CO

Contact

Distance to nearest Class I Area (km)

# of Class I Areas evaluated/within 300 km 2 of 2

Proposed BART Control Option for preheater/precalciner kiln SNCR

Current Emissions (lb/ton clinker) 7.39

Current Emissions (tpy) 1,747.1

Capital Cost

O&M Cost 

Total Annual Cost $ 1,636,636

Reduction (annual average) 48.4%

Reductions (tpy) 846.1

New Emisison Rate (lb/hr on a 30-day rolling average) 255.3

New Emisison Rate (tpy) 901.0

Cost-Effectiveness ($/ton) $ 1,934

Visibility analyses

Visibility Impact before BART (dv at Max Class I) 0.76

Visibility Impact after BART (dv at Max Class I) 0.38

Visibility Improvement (dv at Max Class I) 0.38

Cost-Effectiveness ($/98th % dv at Max Class I) $ 4,306,937

Pollutant Control Effectiveness (dv/ton) 0.00045

Visibility Impact before BART (dv at Summed Class I) 0.95

Visibility Impact after BART (dv at Summed Class I) 0.48

Visibility Improvement (dv at Summed Class I) 0.48

Cost-Effectiveness ($/98th % dv at Summed Class I) $ 3,445,549

Pollutant Control Effectiveness (dv/ton) 0.00056

The Lyons plant was originally constructed by Martin Marietta in the late 1960’s and utilized a long dry kiln to 

produce Portland cement. During the 1980’s the plant was operated by the Southdown Corporation and was 

later acquired by CEMEX in 2000. In 1980 a flash vessel was added to the kiln system, which destroys 

organic material (kerogen) present in the limestone and allows some of the calcination process to occur prior 

to entering the kiln. Along with this change the kiln was cut in half. The flash vessel was installed to allow 

kerogen to be combusted such that it is not vaporized and then emitted to the atmosphere where it can 

condense forming fine particulate matter that can result in a blue haze.

Cemex has a single stage preheater/precalciner type system. 

Particulate emissions are controlled by fabric filter baghouses and wet dust suppression techniques.

NOx: Installation of selective non-catalytic reduction (SNCR) on the kiln system to reduce existing actual NOx 

levels by 40% on a 30-day rolling hourly average basis. This is approximately 60% below the existing permit 

limit. Compliance will be demonstrated by use of a continuous emission monitor as defined in the operating 

permit.

The Division is also aware that Cemex may be able to do better than 40% and will require 

that 50% reduction be met on an annual ton per year (rolling 12-month) basis. The Division will propose that 

the 12-month rolling total emissions be reduced 50% from the 2005-2006 annual average total of 1801.5 tons 

of NOx to 901.0 tons of NOx per year (12-month rolling total). This means that there will be a 40% reduction 

required on 30-day rolling hourly average and a 50% reduction on a 12-month rolling total basis from actual 
levels. These reductions are also 66% lower than the current allowable NOx limit contained in the operating 

permit. The Division also notes that the flash vessel at Cemex is unique and may affect how well SNCR will 

perform at the plant. Because of this uncertainty the Division will not specify the ammonia injection or slip rate 

but will allow Cemex to meet the NOx limits through SNCR technology and process controls. Improving 

process controls may allow Cemex to limit formation of NOx in the kiln and thus meet the NOx limits while 

reducing ammonia use. 

SO2: No additional control because the cement manufacturing process inherently controls SO2 through 

interaction of sulfur compounds with the limestone in the kiln and the dust cake inside the fabric filter 

baghouses. New allowable emission rates will be established based on the process control of SO2. 

Compliance will be demonstrated by use of a 

continuous emission monitor as defined in the operating permit. 

Particulate Matter: Cemex will continue to utilize particulate controls including fabric filter baghouses and dust 

suppression techniques, currently required to meet the MACT standard for Portland cement plants. 

Compliance will be demonstrated by continuous opacity monitors, periodic stack testing, and work practice 

requirements. 
Rocky Mountain National Park

single-stage flash calciner preceding dry kiln

CDPHE report

CDPHE report

not available

not available

CDPHE report

CDPHE report

CDPHE report

CDPHE report Accordingly, as part of its five factor consideration the state has elected to generally

CDPHE report employ criteria for NOx post-combustion control options to aid in the assessment and

CDPHE report determinations for BART – a $/ton of NOx removed cap, and two minimum applicable

Δdv improvement figures relating to CALPUFF modeling for certain emissions control

types, as follows.

CDPHE report - For the highest-performing NOx post-combustion control options (i.e., SCR

CDPHE report systems for electric generating units) that do not exceed $5,000/ton of pollutant

CDPHE report reduced by the state’s calculation, and which provide a modeled visibility benefit

calculated on 0.50 Δdv or greater at the primary Class I Area affected, that level of control is

calculated generally viewed as reasonable.

calculated - For lesser-performing NOx post-combustion control options (e.g., SNCR

calculated technologies for electric generating units) that do not exceed $5,000/ton of

calculated pollutant reduced by the state’s calculation, and which provide a modeled

calculated visibility benefit of 0.20 Δdv or greater at the primary Class I Area affected, that

calculated level of control is generally viewed as reasonable.

d a long dry kiln to 

orporation and was 

hich destroys 

cess to occur prior 

nstalled to allow 

 where it can 

existing actual NOx 

the existing permit 

d in the operating 

n will propose that 

total of 1801.5 tons 

e a 40% reduction 

basis from actual 
ed in the operating 

ow well SNCR will 

 injection or slip rate 

ls. Improving 

NOx limits while 

s SO2 through 

baghouses and dust 

nd work practice 
has elected to generally

id in the assessment and

d two minimum applicable

certain emissions control

ptions (i.e., SCR

000/ton of pollutant

eled visibility benefit

hat level of control is

s (e.g., SNCR

 $5,000/ton of

de a modeled

Area affected, that
Operating company Holcim Cement

Facility Florence

State CO

Contact

Distance to nearest Class I Area (km) 66

# of Class I Areas evaluated/within 300 km

Proposed RP Control Option for Preheater/Precalciner kiln SNCR

Current Emissions (tpy) 2,628

Current Emissions (tpy) 3,186

Capital Cost $ 1,000,000

O&M Cost 

Total Annual Cost $ 2,520,000

Reduction 45%

Reductions (tpy) 1,099

New Emisison Rate (tpy) 2,087

Cost-Effectiveness ($/ton) $ 2,293

Visibility analyses

Visibility Impact before BART (dv at Max Class I) 0.814

Visibility Impact after BART (dv at Max Class I) 0.526

Visibility Improvement (dv at Max Class I) 0.288

Cost-Effectiveness ($/98th % dv at Max Class I) $ 8,750,000

Pollutant Control Effectiveness (dv/ton) 0.00026

Visibility Impact before BART (dv at Summed Class I)

Visibility Impact after BART (dv at Summed Class I)

Visibility Improvement (dv at Summed Class I)

Cost-Effectiveness ($/98th % dv at Summed Class I)

Pollutant Control Effectiveness (dv/ton)
Great Sand Dunes

CDPHE report

permit limit--CDPHE report

CDPHE report

CDPHE report

CDPHE report

CDPHE report

CDPHE report

CDPHE report

CDPHE report

CDPHE report

CDPHE report

calculated

calculated
Operating company Holcim Cement

Facility Trident

State MT/EPA R-8

Contact Vanessa Hinkle EPA R8

Distance to nearest Class I Area (km) Gates of the Mountains WA

# of Class I Areas evaluated/within 300 km 2

Proposed BART Control Option for long, wet kiln SNCR

Current Emissions (tpy) 1,112 Federal Register /Vol. 77, No. 77 / 

Capital Cost $ 5,698,107 Federal Register /Vol. 77, No. 77 / 

O&M Cost $ 447,946 Federal Register /Vol. 77, No. 77 / 

Total Annual Cost $ 985,845.00 Federal Register /Vol. 77, No. 77 / 

Reduction 58% Federal Register /Vol. 77, No. 77 / 

Reductions (tpy) 645 Federal Register /Vol. 77, No. 77 / 

New Emisison Rate (tpy) 467 Federal Register /Vol. 77, No. 77 / 

Cost-Effectiveness ($/ton) $ 1,528 Federal Register /Vol. 77, No. 77 / 

Proposed BART limit for long, wet kiln 5.5 lb NOx/ton clinker (30-day rolling a

Federal Register /Vol. 77, No. 77 / 

Visibility analyses

Visibility Impact before BART (dv at Max Class I) 0.980 Federal Register /Vol. 77, No. 77 / 

Visibility Impact after BART (dv at Max Class I) 0.556 calculated from EPA report

Visibility Improvement (dv at Max Class I) 0.424 Federal Register /Vol. 77, No. 77 / 

Cost-Effectiveness ($/98th % dv at Max Class I) $ 2,325,106 calculated from EPA report

Pollutant Control Effectiveness (dv/ton) 0.00066 calculated from EPA report

Visibility Impact before BART (dv at Summed Class I) 1.391 calculated from EPA report

Visibility Impact after BART (dv at Summed Class I) 0.796 calculated from EPA report

Visibility Improvement (dv at Summed Class I) 0.595 calculated from EPA report

Cost-Effectiveness ($/98th % dv at Summed Class I) $ 1,656,882 calculated from EPA report

Pollutant Control Effectiveness (dv/ton) 0.00092 calculated from EPA report
hinkle.vanessa@epa.gov (303) 312–6561

Gates of the Mountains WA

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

lb NOx/ton clinker (30-day rolling average)

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

calculated from EPA report

Federal Register /Vol. 77, No. 77 / Friday, April 20, 2012 / Proposed Rules

calculated from EPA report

calculated from EPA report

calculated from EPA report

calculated from EPA report

calculated from EPA report

calculated from EPA report

calculated from EPA report
Operating company LaFarge North America (cement)

Facility Alpena

State MI

Contact

Distance to nearest Class I Area (km) 250 Seney NWR

# of Class I Areas evaluated/within 300 km 1 of 1

Kiln #19 Kiln #20

Proposed BART Control Option for long, dry process kilns SNCR SNCR

Current Emissions (tpy) 3,459 3,459

Reductions (tpy) 1,210 1,210

Reductions 35% 35%

Capital Cost $ 2,526,285 $ 2,526,285

O&M Cost $ 323,804 $ 323,804

Total Annual Cost $ 884,867 $ 884,867

Cost-Effectiveness ($/ton) $ 731 $ 731

New Emisison Rate (lb/day)

New Emisison Rate (tpy)

Visibility analyses

Visibility Impact before BART (dv at Max Class I)

Visibility Impact after BART (dv at Max Class I)

Visibility Improvement (dv at Max Class I)

Cost-Effectiveness ($/98th % dv at Max Class I)

Pollutant Control Effectiveness (dv/ton)

Visibility Impact before BART (dv at Summed Class I)

Visibility Impact after BART (dv at Summed Class I)

Visibility Improvement (dv at Summed Class I)

Cost-Effectiveness ($/98th % dv at Summed Class I)

Pollutant Control Effectiveness (dv/ton)
erica (cement)

Kiln #21 Kiln #22 Kiln #23 Kiln #22 Kiln #23

SNCR SNCR SNCR wet FGD wet FGD Totals

 3,459 5,742 5,742 12,093 12,093 $ 46,046

 1,210 2,297 2,297 10,884 10,884 $ 29,992

35% 40% 40% 90% 90%

$ 2,526,285 2,250,080 2,250,080 $ 63,136,000 $ 63,136,000 $ 138,351,015

$ 323,804 516,011 516,011 $ 1,503,034 $ 1,503,034 $ 5,009,502

$ 884,867 1,143,871 1,143,871 $ 11,830,426 $ 11,830,426 $ 28,603,195

$ 731 $ 498 $ 498 $ 1,087 $ 1,087

1.301

0.746

0.555

$ 51,537,288

NOx Controls SO2 Controls
calculated

calculated

company report

company report

company report

sum of company reports

company report

company report

company report

calculated

calculated
Operating company St. Mary's Cement

Facility Charlevoix

State MI

Contact

Distance to nearest Class I Area (km)

# of Class I Areas evaluated/within 300 km 1 of 1

Proposed BART Control Option for preheater/precalciner kiln existing LNB

Current Emissions (tpy) 5,243

Reductions (tpy)

Reductions

Capital Cost

O&M Cost 

Total Annual Cost 

Cost-Effectiveness ($/ton)

New Emisison Rate (lb/day)

New Emisison Rate (tpy)

Visibility analyses

Visibility Impact before BART (dv at Max Class I) 5.26

Visibility Impact after BART (dv at Max Class I)

Visibility Improvement (dv at Max Class I)

Cost-Effectiveness ($/98th % dv at Max Class I)

Pollutant Control Effectiveness (dv/ton)

Visibility Impact before BART (dv at Summed Class I)

Visibility Impact after BART (dv at Summed Class I)

Visibility Improvement (dv at Summed Class I)

Cost-Effectiveness ($/98th % dv at Summed Class I)

Pollutant Control Effectiveness (dv/ton)
Mary's Cement

Seney NWR

rejected SNCR EPA SNCR

 5,243 company report 2,518 EPA 5/24/12

10% company report 50% EPA FR Notice

 524 company report 1,259 EPA FR Notice

$ 3,470,224 company report $ 4,979,017 EPA 5/24/12

$ 2,486,096 company report $ 541,063 EPA 5/24/12

$ 3,967,626 company report $ 1,237,597 calculated

$ 7,568 company report $ 983 EPA FR Notice

company report

0.4 EPA FR Notice

$ 3,093,993 calculated

Operating company

Facility

State

Contact

Distance to nearest Class I Area (km)

# of Class I Areas evaluated/within 300 km

Proposed BART Control Option for wet process kiln

Current Emissions (tpy)

Reductions (tpy)

Reductions

Capital Cost

O&M Cost 

Total Annual Cost 

Cost-Effectiveness ($/ton)

New Emisison Rate (lb/day)

New Emisison Rate (tpy)

Visibility analyses

Visibility Impact before BART (dv at Max Class I)

Visibility Impact after BART (dv at Max Class I)

Visibility Improvement (dv at Max Class I)

Cost-Effectiveness ($/98th % dv at Max Class I)

Pollutant Control Effectiveness (dv/ton)

Visibility Impact before BART (dv at Summed Class I)

Visibility Impact after BART (dv at Summed Class I)

Visibility Improvement (dv at Summed Class I)

Cost-Effectiveness ($/98th % dv at Summed Class I)

Pollutant Control Effectiveness (dv/ton)
LaFarge North America (cement)

Seattle

WA

Al Newman 360-407-6810 anew461@ecy.wa.gov

53 Alpine Lakes WA

1 of 9

NOx SO2

SNCR or mid-kiln firing of whole tires dry sorbent injection WA Ecology report

 2,172.5 570 WA Ecology report

 869 142.5 WA Ecology report

40% 25% WA Ecology report

$ 1,499,410 $ 6,090,000 WA Ecology report

$ 1,082,997 WA Ecology report

$ 1,224,541 $ 574,896 WA Ecology report

$ 1,409 $ 4,034 WA Ecology report

 22,960 8,620 WA Ecology report

 4,190 1,573 calculated from WA Ecology report

combined NOx + SO2 controls

2.96 WA Ecology report at Olympic NP

1.937 WA Ecology report at Olympic NP

calculated from WA Ecology report

$ 1,758,980 calculated from WA Ecology report

0.00101 calculated from WA Ecology report

12.96 calculated from WA Ecology report

8.254 calculated from WA Ecology report

 4.706 calculated from WA Ecology report

$ 382,371 calculated from WA Ecology report

0.00465 calculated from WA Ecology report

 1.02

$/ton

Essroc Cement PA Kiln #5 long, wet 35% $ 1,014

Lehigh Cement/York PA white cement 35% $ 1,505

Lehigh Cement Company/Evansville PA Kiln #1 dry preheater 60% $ 627

Lehigh Cement Company/Evansville PA Kiln #2 dry preheater 60% $ 627

Lafarge Corporation/Whitehall PA Kiln #2 dry preheater 25% $ 1,804

Lafarge Corporation/Whitehall PA Kiln #3 dry preheater 25% $ 2,144

Cemex/Wampum PA Kiln #3 long, dry kiln 35% $ 1,014

Keystone Cement PA Kiln #2 long, wet kiln 35% $ 1,014

Ash Grove Cement MT long, wet kiln 58% $ 2,058

CEMEX CO preheater/precalciner 48% $ 1,934

Holcim Cement CO preheater/precalciner 45% $ 2,293

Holcim Cement MT long, wet kiln 58% $ 1,528

LaFarge North America (cement) MI Kiln #19 long, dry process kilns 35% $ 731

LaFarge North America (cement) MI Kiln #20 long, dry process kilns 35% $ 731

LaFarge North America (cement) MI Kiln #21 long, dry process kilns 35% $ 731

LaFarge North America (cement) MI Kiln #22 long, dry process kilns 40% $ 498

LaFarge North America (cement) MI Kiln #23 long, dry process kilns 40% $ 498

St. Mary's Cement MI preheater/precalciner 50% $ 983

LaFarge North America (cement) WA wet process kiln 40% $ 4,190

Company Kiln Type

BART 

Unit

SNCR 

Reduction %

SNCR Cost

State
$/dv

$ 7,494,026 Seasonal NOX controls 

$ 10,606,000 Seasonal NOX controls 

$ 8,094,250 Seasonal NOX controls 

$ 8,094,250 Seasonal NOX controls 

$ 27,177,065 Seasonal NOX controls 

$ 24,336,753 Seasonal NOX controls 

$ 4,678,401 Seasonal NOX controls 

$ 23,431,248 Seasonal NOX controls 

$ 1,793,984 LNB&SNCR

$ 4,306,937 SNCR

$ 8,750,000 SNCR

$ 2,325,106 SNCR

SNCR

SNCR

SNCR

SNCR

SNCR

$ 3,093,993 EPA SNCR

$ 1,758,980 SNCR or mid-kiln firing of whole tires

BART

SNCR Cost