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St. Lawrence Cement Company, LLC


Applicant: St. Lawrence Cement Company, LLC, 4303 US Route 9, Hudson, NY 12534

Application Number: DEC # 4-1040-00011/00001

Project Description: The applicant, St. Lawrence Cement Company LLC, (SLC), has applied for a State Facility Permit for Air Pollution control permit (Parts 201, et seq. of Title 6 of the New York Compilation of Codes, Rules and Regulations [6 NYCRR]) including a Prevention of Significant Deterioration (PSD) review/analysis pursuant to 40 CFR § 52.21. The proposed project involves construction and operation of a state-of-the-art, high efficiency, dry process cement manufacturing facility consisting of a raw mill system, kiln feed blending silo, preheater/precalciner tower, rotary kiln, clinker cooler, finish mill system and associated balance-of-plant systems and facilities. The capacity of the facility will be approximately 2.6 million US tons of clinker per year. The primary fuel will be a coal/coke blend. Distillate oil and natural gas will be used for pre-heating and start-up.

The proposed facility will utilize a large multi-chamber state of the art baghouse for controlling particulates from the clinker manufacturing process. Staged combustion, a low nitrogen oxides (NOx) burner(s), flame optimization, process optimization, reduced air combustion, and a selective non-catalytic reduction (SNCR) system will be used to reduce and control NOx emissions. Sulfur dioxide (SO2) emissions will be controlled by parallel wet/dry scrubber systems. An integrated continuous monitoring and recording system will also be used to monitor emissions. The monitoring data will be used to optimize operation of the facility and minimize emissions. The New York State Department of Environmental Conservation (NYSDEC) has conducted the PSD review contained in 40 CFR §§ 52.21 and 124.

Project Location: The SLC Greenport Project will be located on property owned by St. Lawrence Cement Co. in both the Town of Greenport and the City of Hudson and is generally bounded on the north by the City of Hudson, on the east by Newman Road, on the south by NYS Route 23 and on the west by the Hudson River. The proposed cement manufacturing facility will be physically located within the life-of-mine boundary of an existing 1222-acre quarry located between Newman Road on the east and US Route 9 on the west.

Public Notice: The NYSDEC has made a tentative determination that the proposed construction and operation of a 2.6 million US tons (per year) cement manufacturing facility is subject to and satisfies the federal requirements for the PSD contained in 40 CFR § 52.21. The air emissions will result from the new kiln with a precalciner which has a 123.3 meter stack and two new cement mills which have a 50 meter stack heights.

The source is subject to PSD for carbon monoxide (CO), NOx, particulate matter (PM and PM-10), SO2 and sulfuric acid mist (H2SO4). The best available control technology (BACT) has been established by a comprehensive review and analysis of current standards which SLC included in their application. The facility is also subject to new source performance standards (NSPS) and maximum achievable control technology (MACT) in accordance with the national emissions standards for hazardous air pollutants (NESHAP), applicable to Portland cement plants. NYSDEC staff has also verified that the emissions of these PSD regulated air pollutants will not cause or significantly contribute to an exceedence of any national primary or secondary ambient air quality standards, and will not consume more than the allowable PSD air quality increment, where one exists.

The permit conditions include requirements that owners or operators of a new major stationary source or major modification: meet applicable State Implementation Plan (SIP) emission limitations and emission standards under 40 CFR Parts 60 and 61; apply (BACT) for each pollutant subject to regulations under 40 CFR § 51.21 (j); and conduct air quality analyses under 40 CFR § 52.21 (k)-(p) to demonstrate that emissions would not violate any National Ambient Air Quality Standard (NAAQS) or PSD increment. Conditions based on the new MACT for Portland Cement plants require emission limits on particulate matter, total hydrocarbons (THC) and dioxins and furans (D/F). The proposed BACT and MACT limitations in the draft permit ensure that the projected emissions will not result in any NAAQS being exceeded. The proposed BACT and MACT limitations are subject to review by the U.S. Environmental Protection Agency, which has the authority to modify the limitations.

Separate from the PSD review which is the subject of this public notice, the NYSDEC has conducted a comprehensive review of the proposed project under applicable state programs and has made tentative determinations under those programs. Those determinations include an evaluation of NOx and volatile organic compounds (VOC) under the New Source Review Program (6 NYCRR Part 231-2) and the imposition of lowest achievable emissions rate (LAER) relative to NOx and VOC's. The application has met the Department and EPA requirements for assessment of facility air impacts and the proposed facility will meet all ambient air quality standards (AAQS), and NYSDEC Air Guide-1 Guideline toxic values.

SEQRA Status: Pursuant to 6 NYCRR Part 617 of the implementing regulations for Environmental Conservation Law (ECL) Article 8, (State Environmental Quality Review Act -SEQRA), NYSDEC, as lead agency, determined the project may have significant impact on the environment and issued a SEQR Positive Declaration on April 8, 1999 requiring the preparation of a Draft Environmental Impact Statement (DEIS). On May 2, 2001 the NYSDEC has accepted the DEIS for the project described above.

Tentative DEC Staff Position: The NYSDEC staff has completed a review of the PSD analysis and the construction permit application for the proposed SLC facility in Columbia County, Town of Greenport and determined it is complete pursuant to 6 NYCRR Part 621. Staff has determined that all statutory and regulatory criteria can be met through the imposition of special conditions. A draft PSD determination and draft construction permit are being made available for comment.

The emissions limits and special permit conditions imposed on the SLC facility's construction permit reflect those proposed in the air permit application and the supplemental documents submitted by the SLC in response to NYSDEC's comments.

Public Comments/Appeal Procedure: NYSDEC invites public comment regarding this tentative determination. NYSDEC's final determination will be made only after full consideration of all public comment received. Comments are to be limited to PSD concerns and must be in writing, and must be accompanied with adequate supporting information. All comments must be filed with the NYSDEC Office of Hearings and Mediation Services, 50 Wolf Road, Albany, NY 12233-1550, Attn: Administrative Law Judge Helene Goldberger. All written comments must be submitted (postmarked) by no later than June 20, 2001.

The PSD aspects, as noted above, address the proposed emissions of NOx, SO2, CO, PM, PM-10, and H2SO4. The final determination may be appealed administratively within 30 days of SLC's receipt of the final PSD permit determination. Only those persons who file comments on this PSD preliminary determination may petition the EPA Environmental Appeals Board for administrative review of the PSD determination. Persons who fail to file comments may petition for review only to the extent of any changes from the draft to the final permit decision regarding PSD issues. If no comments are received and NYSDEC makes no changes to the PSD determination from the draft to the final decision, no opportunity for further review or appeal will be available.

Any petition for EPA review must be made within thirty (30) days of the service of notice of the final decision. The procedures for administrative review are defined in the Consolidated Permit Regulations at 40 CFR Part 124. Any such petition for review shall include a statement of the reasons supporting that review and shall adhere to the standards outlined in 40 CFR §§124.19(a)(1) and (2).

Upon completion of the administrative review process (if applicable), the final decision will become the final agency action and will be published in the Federal Register. Those who appealed for administrative review may petition for judicial review within 60 days of the final EPA decision.

Document Availability: All filed application materials and the preliminary PSD determination will be available for public inspection beginning on Monday, May 7, 2001 at the following locations:

1) NYSDEC Office of Hearings and Mediation Services, 50 Wolf Road, Albany, NY 12233-1550

2) NYSDEC Region 4 Headquarters, 1150 North Westcott Road, Schenectady, NY 12306. (518) 357-2069

3) St. Lawrence Cement Offices, 4303 US Route 9, Hudson, NY 12534, (518) 828-8478

4) St. Lawrence Cement Offices, 3 Columbia Circle, Albany, NY 12203. (518) 452-3001

5) Town of Greenport, Town Hall, 600 Town Hall Drive, Hudson, NY 12534. Contact: Town Clerk (518) 828-4656

6) City of Hudson, City Hall, 520 Warren St., Hudson, NY 12534. Contact: City Clerk; (518) 828-1030

7) Hudson Area Library, 400 State Street, Hudson, NY 12534.(518) 828-1792

8) Chatham Public Library, Woodbridge Ave., Chatham, NY 12037. (518) 392-3666

9) Germantown Library, 50 Palatine Park Rd., Germantown, NY 12526. (518) 537-5800

10) Hillsdale Public Library, 2609 Route 23, Hillsdale, NY 12529. (518)325-4101

11) Livingston Free Library, Old Post Road, Livingston, NY 12541. (518) 851-2270

12) Catskill Public Library, 1 Franklin Street, Catskill, NY 12414. (518) 943-4230

13) Kinderhook Memorial Library, 18 Hudson Street, Kinderhook, NY 12106. (518) 758-6192

14) Valatie Free Library, 3203 Church Street, Valatie, NY 12184. (518) 758-9321

15) Claverack Library, 629 Route 23B, Claverack, NY 12513. (518) 851-9120

16) D.R. Evarts Library, 80 2nd Street, Athens, NY 12015. (518) 945-1417

17) Philmont Public Library, 124 Main Street, Philmont, NY 12565. (518) 672-5010

18) Egremont Free Library, 2 Button Ball Lane, Great Barrington, MA 01230. (413) 528-1474

19) Mason Public Library, 231 Main Street, Great Barrington, MA 01230. (413) 528-2403

20) Pittsfield Public Library, 1 Wendell Avenue, Pittsfield, MA 01201. (413) 499-9480

21) Austen Fox Riggs Library, 25 Main Street, Stockbridge, MA 01262. (413) 298-5511

22) West Stockbridge Library, 9 Main Street, West Stockbridge, MA 01266. (413) 232-0308

For further information please contact: Michael Higgins, Project Manager, NYSDEC Region 4 Headquarters, 1150 North Westcott Road, Schenectady, NY 12306, (518) 357-2069.

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