Lafarge is seeking both a Title V Air permit and a State Pollution Discharge Elimination System (SPDES) Permit for wastewater at the new plant.
DEC recently renewed the Lafarge air permit for its existing plant and the company is now focusing on moving forward with the modernization which requires its own set of permits.
On November 24, 2010, the DEC, the lead agency in the SEQR (State Environmental Quality Review) accepted the Lafarge DEIS document as “complete and adequate for public review.”
The public comment period also began on November 24 and extends until February 22, 2011.
DEC has scheduled a Legislative hearing on January 20 for all “persons, organizations, corporations, or government agencies which may be affected by the proposed project to submit oral or written comments.”
DEC will then determine whether “substantive or significant issues” were raised during the public comment period and legislative hearing warranting an Adjudicatory Hearing/Issues Conference.
If the DEC decides there are none, it will develop a response to comments for inclusion in a Final Environmental Impact Statement (FEIS).
They will also notify the public about approval of the permits, acceptance of the FEIS and issue the requested permits.
DEC and Lafarge staff spoke about the status and contents of the DEIS application.
Region 4 Permit Administrator William Clarke said the primary issues under consideration were replacing two wet cement kilns with one dry kiln and increasing production capacity from 1.7 million tons per clinker to 2.8 million tons.
DEC staff explained the permit process, the timeline of the past two years resulting in the Lafarge DEIS application and the FEIS process.
The FEIS will recommend one of three possible outcomes; issuing the permits, denying the permits or approving the permits with conditions.
Lafarge Environmental Manager John Reagan and a panel of five Lafarge staff spoke about the project in great detail.
“Our purpose is to modernize and expand the plant and make it more environmentally friendly and economically streamlined,” Reagan said.
He provided an overview of differences between the existing and proposed plants including which buildings would be torn down.
Scheduled for removal are the two existing slurry bins, the 350 foot stack and the two horizontal wet kilns which will be replaced by a vertical dry kiln roughly 530 feet high.
Other new features include a second crusher, a new raw mill, a new coal mill, scrubbers, SNCR equipment, Baghouse dust collectors and continuous emissions monitors.
Reagan also listed the main areas Lafarge examined in their DEIS application including air quality, land use zoning, solid waste, noise, traffic, natural resources, socioeconomic impact and energy resources.
“The new plant will be more energy efficient, using 42 percent less fuel per ton of product produced,” he said. “It will also produce 40 percent less kiln waste and eliminate the use of water resources in the cement making process.”
DEC staff spoke of the improved wastewater management as highly beneficial to the SPEDES application.
“The new design will eliminate processed waste waters,” DEC’s Shane Mitchell said. “That simplifies the permit.”
While Reagan said greenhouse gases would rise because of the increased production the amount discharged would still be well within DEC and EPA regulations.
DEC Regional Air Pollution Control Engineer Don Spencer agreed with Reagan’s statement, saying that emissions would be less than 1 percent of the highest levels permitted.
Reagan also spoke about the project timeline, saying 2011-2014 would involve design, buying of equipment and the start of construction.
The first full year of production would be 2015.
“The new plant will allow the Ravena facility to remain globally competitive, improve the air quality and retain 180 jobs,” he said.
Spencer said the DEIS covers the old and new EPA regulations for the existing plant as well as the proposed plant.
Some of DEC’s findings thus far are the new plant will reduce filterable emissions from 195 tons in 2006 to 28 tons per year with an accompanying 75 percent reduction in condensable emissions.
Sulfur dioxide will decrease from 11,635 tons to 562 and nitrogen oxides will go from 5058 tons to 2107.
New EPA regulations for mercury reduce the total allowed from 95 pounds per year in 2013 to roughly 60 pounds by 2015.
The DEC recently limited mercury production to 176 pounds a year for the existing plant, roughly half of the 398 Lafarge reported in 2006.
There are no national carbon monoxide standards but EPA has issued recommendations in its BACT (Best attainable control technology) papers.
“Lafarge is proposing to set up many of the recommendations listed in those papers,” Spencer said.
Following the presentations, some in the audience asked questions.
Friends of Hudson Director Susan Falzon thanked the DEC for extending the usual thirty day comment period to ninety days.
“The Friends of Hudson are encouraged by what we can see in the DEIS,” she said. “We have pushed for a long time to clean up this plant. We are pleased Lafarge appears to be doing what they are required to do.”
She then inquired about how the DEC determined which agencies to involve and what relationship the DEC DEIS had with the parallel DOH (Department of Health) study.
Clarke said Falzon should direct those questions to the DOH but she pointed out that public health issues had been part of the original scoping document.
“Are there any formal channels for handling public health issue questions?"’ she asked.
Elyse Griffin of CASE also pointed out there was little in the DEIS about the effect of the new plant’s emissions on public health.
“There are only two pages devoted to public health in the entire 1000-page document,” she said.
But Spencer said the air dispersion standards discussed in the DEIS conform with state and national health standards and there ares far more than two pages of data in the document.
Elyse Kunz of CASE asked about fugitive dust provisions in the DEIS and whether Lafarge could enclose the new tower. She also asked about plans for the plant’s visual appearance.
In response to questions about the new power plant proposed for the modernized plant, Reagan said it was 100 percent based on waste heat and no new fuel would be required to run it. He also said it was for on-site use only.
At least one in the audience was solidly behind Lafarge’s proposal.
Ravena resident Mary Driscoll said “Lafarge has been a good neighbor. My children went to school here. I’m tired of hearing we are wallowing in cement dust. We can’t all be lawyers and teachers. Some of us have to be blue collar workers.”
Others questioned how Lafarge would dispose of contaminated equipment, who would conduct continuous monitoring and whether the company intended to use burning tires as a fuel source.
DEC and Lafarge countered all questions with reasonable explanations and continuously pointed out the company’s intent to comply with all regulations.
One DEC staffer pointed out if Lafarge didn’t comply with adequate data requirements the repercussions would be onerous.
In response to questions of why other heavy metals besides mercury such as lead and cadmium didn’t have individual limits the DEC said only mercury is volatile and can be emitted as a gas.
According to their data, only 8 percent of mercury enters the landfills while 92 percent is released in the air.
The DEC further pointed out that new EPA regulations require a decrease of 90 percent of all other heavy metals.
Falzon asked about clarity in conditions for start-up and shut-down emissions and was referred to specific sections in the DEIS.
She stressed that compliance and enforcement had to be more rigorously monitored.
“We think the DEC must ensure the safety and health of people in the community,” she said. “We are reviewing the DEIS with our engineers and our attorneys.”
Falzon also criticized the length and format of the DEIS document, calling it hard to read, poorly organized and too long.
Clarke responded: “It’s probably just as complicated for us as it is for you.”
