Appendix J

BART Survey and Supplemental Information

November 11, 2004

Contact

Facility Name

Facility Street Address

Facility City, State, ZIP

Dear Contact:

I would like to request your assistance in gathering information needed about your facility

related to the federal regional haze program. In 1999, the Environmental Protection Agency

(EPA) issued regulations for the protection of visibility in our Natural Parks and Wilderness

Areas (See http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf). These regulations require

states to establish goals for improving visibility by developing long-term strategies for reducing

emissions of air pollutants that cause visibility impairment. The State of Missouri is working as

a member of the Central States Regional Air Planning Association (CENRAP) to meet these

requirements. CENRAP is an association of states, tribes, federal agencies, and other interested

parties organized for the purpose of studying visibility impairment and of assisting individual

states and tribes in preparing plans to address the problem. CENRAP includes the states and

tribal areas of Minnesota, Nebraska, Iowa, Kansas, Missouri, Oklahoma, Arkansas, Texas, and

Louisiana.

Missouri has been working jointly with these states and tribes to locate and operate air monitors,

to develop and share emission inventories, and to conduct regional computer modeling to help

identify potential strategies to reduce haze. Each state will use this information to develop

individual state implementation plans (SIPs) to meet each states’ obligation under the federal

regulations. Missouri is required to submit a SIP to EPA by December 31, 2007. While three

years seems like a long period of time, the state rulemaking timelines have grown to the point

that we need to begin now to consider potential regulations in place by then. One of the first

steps is to determine which air pollution units will be subject to the federal Best Available

Retrofit Technology (BART) regulations.
Page 2

BART applies to emission units in existence on August 7, 1977, that had begun operation after

August 7, 1962, and that, individually or in combination with other such units, have the potential

to emit 250 tons per year or more of any visibility-impairing pollutant. Having commenced

construction on or before August 7, 1977, BART-eligible sources were in existence prior to the

Prevention of Significant Deterioration (PSD) permitting requirements of the 1977 Clean Air Act

Amendments.

Visibility impairing pollutants include: ammonia (NH3), nitrogen oxides (NOx), particulate

matter less than ten microns (PM10), sulfur dioxide (SOx), and volatile organic compounds

(VOCs). Affected emission units must also fall into one of 26 source categories, including

electric generating units, industrial boilers, and other large industrial operations. Attachment A

is a list of the 26 source categories.

It is important that we ensure the accuracy of Missouri’s final list of BART-eligible sources. To

that end, we are asking for your participation in this process. We have queried our Emission

Inventory Questionnaire (EIQ) database using the Standard Industrial Classification and Source

Classification Codes to identify sources that correspond to the 26 BART source categories listed

in Attachment A. We then attempted to eliminate sources that we knew had been constructed

after August 7, 1977, and sources that have basic or intermediate Operating Permits (who

therefore have facility-wide emissions of less than 100 tons per year). Certain units at your

facility were not eliminated, so you are still on our list of potentially BART-eligible sources.

Your assistance is needed to confirm our finding and help us further determine if your facility

should remain on the list.

The enclosed questionnaire summarizes information related to your emission unit(s) and requests

additional data. The questionnaire lists information for each unit of interest at your facility and

includes blanks for you to insert the following information:

1) The “In existence date”, or indication (yes/no) that the unit was in existence on

August 7. 1977,

2) The “Began operation date”, or indication (yes/no) that the unit began operation

after August 7, 1962,

3&4) Confirmation of the industrial classification of your facility,

5) Potential emissions of the five pollutants (NH3, NOx, PM10, SOx, & VOCs),

6) Maximum heat input rate (million BTU/hr) if the unit is a fossil-fuel boiler,

7) Storage capacity (barrels) if the unit is a petroleum storage tank, and

8) Your conclusion summarizing your determination of whether your unit is BARTeligible or not.

In completing the questionnaire I ask that you follow the enclosed “Instructions for BART

Information Request Form” for each unit, insert the requested information, and provide your own

evaluation of whether you believe the unit falls within the construction time span that would

identify your unit as a BART-eligible source. I also ask that you identify any additional
Page 3

emission units at your facility that we have failed to identify, but that you believe meet the

BART-eligible requirements.

Please complete the questionnaire and return it to the department at the following address:

Air Pollution Control Program

P.O. Box 176

Jefferson City, MO 65102

Attn: John Rustige, P.E.

To assist you in completing this questionnaire we have included definitions and guidance

material in a Frequently Asked Questions (FAQs) attachment to this letter. The Proposed

Guidelines for Best Available Retrofit Technology (BART) Determinations Under the Regional

Haze Regulations is also available at EPA’s website at

http://www.epa.gov/ttn/oarpg/t1/fr_notices/bart6-21.pdf

How will this data be used?

This is just the initial step in determining BART sources. After Missouri has compiled a list of

BART-eligible sources, there are several additional steps that have to be taken in the BART

process. The following is a brief summary of those steps:

1) Identification of sources subject to BART controls. Sources subject to BART controls

are those BART-eligible sources which “emit a pollutant which may reasonably be

anticipated to cause or contribute to any impairment in any Class I area.” This will

require air pollution modeling studies to determine each individual sources’

contribution to see what impact each source has on visibility in the Class I area.

2) Engineering analysis. For each source that is subject to BART controls an

engineering analysis of emission control alternatives will be required. This process

will be similar to the Best Available Control Technology (BACT) process that new

major sources undergo during construction permit review. This step requires the

identification of available, technically feasible, retrofit emission controls. For each

technology identified, an analysis must be made of the cost of compliance, and the

energy and non-air quality environmental impacts, taking into account the remaining

useful life and existing control technology operated at the source. For each source, a

“best system of continuous emission reduction” is selected based on this engineering

analysis.

3) Enforceable limits. Considering the engineering analysis, states must establish

enforceable emission limits, including a deadline for compliance, for each source

subject to BART.

We appreciate your assistance in completing the questionnaire to assist us in determining if your

facility is or is not subject to BART. Please respond even if you believe that your units do not
Page 4

meet the BART-eligible criteria so that we can eliminate them from our list. We request that you

return your questionnaire to us no later than December 17, 2004.

If you have any questions about the questionnaire, regional haze, or the BART process, please

contact John Rustige at P.O. Box 176, Jefferson City, MO 65102 or by phone at (573) 751-4817.

Thank you for your assistance.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Leanne Tippett Mosby

Director

LJT:jrl

Attachment
Attachment A

Source Categories Eligible for BART:

1. Fossil-fuel fired steam electric plants of more than 250 million Btu/hr heat input

2. Coal cleaning plants (with thermal dryers)

3. Kraft pulp mills

4. Portland cement plants

5. Primary zinc smelters

6. Iron and steel mill plants

7. Primary aluminum ore reduction plants

8. Primary copper smelters

9. Municipal incinerators capable of charging more than 250 tons of refuse per day

10. Hydrofluoric, sulfuric, and nitric acid plants

11. Petroleum refineries

12. Lime plants

13. Phosphate rock processing plants

14. Coke oven batteries

15. Sulfur recovery plants

16. Carbon black plants (furnace plants)

17. Primary lead smelters

18. Fuel conversion plants

19. Sintering plants

20. Secondary metal production plants

21. Chemical process plants

22. Fossil-fuel boilers (or combinations thereof) totaling more than 250 million Btu/hr heat

input

23. Petroleum storage and transfer facilities with a total storage capacity exceeding 300,000

barrels

24. Taconite ore processing facilities

25. Glass fiber processing plants

26. Charcoal production facilities.
Frequently Asked Questions (FAQ’s)

Q. What is regional haze?

Haze obscures the clarity, color, texture, and form of what we see. Some haze-causing

pollutants (mostly fine particles) are directly emitted to the atmosphere by a number of activities

(such as electric power generation, various industrial and manufacturing processes, truck and

auto emissions, burning related to forestry and agriculture, construction activities, etc.). Others

are formed when gases emitted to the air form particles as they are carried downwind. Examples

include sulfate, formed from sulfur dioxide, and nitrates, formed from nitrogen oxides. The

Regional Haze Rule was issued by the Environmental Protection Agency (EPA) to improve

visibility, or visual air quality, in 156 Class I areas across the country.

Q. What is a Class I area?

The Clean Air Act defines mandatory Class I Federal areas as certain national parks (over

6000 acres), wilderness areas (over 5000 acres), national memorial parks (over 5000 acres), and

international parks that were in existence as of August 1977. There are currently 156 Class I

areas listed in the United States. These areas include many of our best known and most treasured

natural areas, such as the Grand Canyon, Mt. Rushmore, Yosemite, Yellowstone, Mount Rainier,

Shenandoah, the Great Smokies, Acadia, and the Everglades. Two class I areas are located in

Missouri. Hercules Glade Wilderness Area (12,300 acres) is located approximately 35 miles

southeast of Springfield, Missouri and the Mingo Wilderness Area (7,700 acres) is located

approximately 20 miles southwest of Poplar Bluff, Missouri.

Q. Why is Missouri actively participating with other Midwestern states in the regional

haze planning efforts of the Central Regional Air Planning Association

Recent research has clearly shown that particulate matter and other haze producing

precursors can generally span broad geographic areas and can be transported great distances,

sometimes hundreds or thousands of miles. Consequently, haze occurs regionally throughout the

nation. Pollutants produced in other states may affect Missouri’s Class I areas, and Missouri

sources may affect Class I areas located outside our borders. Also, by joining with other states,

Missouri is able to share the planning and the rigorous and intensive computer modeling

necessary to understand haze formation and its causes.

Q. What does BART stand for?

Best Available Retrofit Technology.

Q. What are the steps in identifying BART-eligible sources?

Step 1: Evaluate emission unit’s construction/reconstruction dates.

Step 2: Verify BART category.
Step 3: Determine potential emissions.

Step 4: Provide additional information (boilers & storage tanks only).

Q. What does “in existence on August 7, 1977" mean?

The regulation defines “in existence” to mean that:

The owner or operator has obtained all necessary preconstruction approvals or permits

required by Federal, State, or local air pollution emissions and air quality laws or regulations

and either has (1) begun, or caused to begin, a continuous program of physical on-site

construction of the facility or (2) entered into binding agreements or contractual obligations,

which cannot be canceled or modified without substantial lose to the owner or operator, to

undertake a program of construction of the facility to be completed in a reasonable time. See 40

CFR 51.301.

Example: The owner or operator obtained necessary permits in early 1977 and entered

into binding construction agreements in June 1977. Actual on-site construction began in late

1978, and construction was completed in mid-1979. The source began operating in September of

1979. The emission unit was “in existence” as of August 7, 1977.

Q. What does “in operation before August 7, 1962" mean?

An emissions unit that meets the August 7, 1977 “in existence” test is not BART-eligible

if it was in operation before August 7, 1962. “In operation” is defined as “engaged in activity

related to the primary design function of the source.” This means that a source must have begun

actual operations by August 7, 1962 to satisfy this test.

Example: The owner or operator entered into binding agreements in 1960. Actual on-site

construction began in 1961, and construction was completed in mid-1962. The source began

operating in September of 1962. The emissions unit was not “in operation” before August 7,

1962 and is therefore subject to BART.

Q. What is a “reconstructed source?”

Under a number of CAA programs, an existing source which is completely or

substantially rebuilt is treated as a new source. Such “reconstructed” sources are treated as new

sources as of the time of the reconstruction. Consistent with this overall approach to

reconstructions, the definition of BART-eligible facility (reflected in detail in the definition of

“existing stationary facility”) includes consideration of sources that were in operation before

August 7, 1962, but were reconstructed during the August 7, 1962 to August 7, 1977 time period.

Under the regulation, a reconstruction has taken place if “the fixed capital cost of the new

component exceeds 50 percent of the fixed capital cost of a comparable entirely new source.”

The rule also states that “Any final decision as to whether reconstruction has occurred must be

made in accordance with the provisions of Secs. 60.15 (f)(1) through (3) of this title.” [40 CFR

51.301] “Secs. 60.15(f)(1) through (3)” refer to the general provisions for New Source

Performance Standards (NSPS). Thus, the same policies and procedures for identifying

reconstructed “affected facilities” under the NSPS program must also be used to identify
reconstructed “stationary sources” for purposes of the BART requirement. You should identify

reconstructions on an emissions unit basis, rather than on a plantwide basis. That is, you need to

identify only the reconstructed emission units meeting the 50 percent cost criterion. You should

include reconstructed emission units in the list of emission units you identified in Step 1. The

“in operation” and “in existence” tests apply to reconstructed sources. If an emissions unit was

reconstructed and began actual operation before August 7, 1962, it is not BART-eligible.

Similarly, any emissions unit for which a reconstruction “commenced” after August 7, 1977, is

not BART-eligible.

Q. How are modifications treated under the BART provision?

In general, the term “modification” refers to any physical change or change in the method

of operation of an emissions unit that leads to an increase in emissions. The EPA believes that

the best interpretation for purposes of the visibility provisions is that modified emissions units

are still “existing”. The BART requirements in the CAA do not appear to provide any

exemption for sources which were modified since 1977. Accordingly, if an emissions unit began

operation before 1962, it is not BART-eligible if it is modified at a later date, so long as the

modification is not also a “reconstruction.” Similarly, an emissions unit which began operation

within the 1962-1977 time window, but was modified after August 7, 1977, is BART-eligible.

Q. What pollutants should I address?

Visibility-impairing pollutants include the following:

1. Sulfur oxides (SOx),

2. Nitrogen oxides (NOX),

3. Particulate matter. (Please use PM10 as the indicator for particulate matter. PM10 emissions

include the components of PM2.5 as a subset. There is no need to have separate 250 ton

thresholds for PM10 and PM2.5, because 250 tons of PM10 represents at most 250 tons of PM2.5,

and at most 250 tons of any individual particulate species such as elemental carbon, crystal

material, etc).

4. Volatile organic compounds (VOC), and

5. Ammonia (NH3).

Q. What does the term “potential” emissions mean?

The regional haze rule defines potential to emit as follows:

“Potential to emit” means the maximum capacity of a stationary source to emit a pollutant

under its physical and operational design. Any physical or operational limitation on the

capacity of the source to emit a pollutant including air pollution control equipment and

restrictions on hours of operation or on the type or amount of material combusted, stored, or

processed, shall be treated as part of its design if the limitation or the effect it would have on

emissions is federally enforceable. Secondary emissions do not count in determining the

potential to emit of a stationary source.

Q. How do I calculate “potential emissions?”
Your facility may have already gone through the potential to emit calculations when

applying for your operating permit. Please refer to the potential to emit calculations performed

for your operating permit. Potential emissions are the emission rates of any pollutant at

maximum design capacity. Annual potential shall be based on the maximum annual rated

capacity of the installation assuming continuous year-round, around-the-clock operation.

Federally enforceable permit conditions on the type of material combusted or processed,

operating rates, hours of operation or the application of air pollution control equipment shall be

used in determining the annual potential. Secondary emissions (emissions which occur or would

occur as a result of the construction or operation of the installation or major modification but do

not come from the installation or modification itself) do not count in determining annual

potential.

Q. How do I determine the BART category status of steam electric plants?

“Steam electric plants of more than 250 million BTU/hr heat input.” Because the category refers

to “plants,” boiler capacities must be aggregated to determine whether the 250 million BTU/hr

threshold is reached.

Example: A stationary source includes a steam electric plant with three 100 million BTU/hr

boilers. Because the aggregate capacity exceeds 250 million BTU/hr for the “plant,” these

boilers would be identified as BART-eligible.

Q. How do I determine the BART category status of fossil-fuel boilers?

“Fossil-fuel boilers of more than 250 million BTU/hr heat input.” The EPA has proposed

two options for interpreting this source category title. The first option would be to aggregate all

boiler capacities to determine whether the 250 million BTU/hr threshold is reached. Under the

second option, this category would be interpreted to cover only those boilers that are individually

greater than 250 million BTU/hr. Until the rule and guidance is finalized, Missouri is collecting

information assuming that all boiler capacities will need to be aggregated. If EPA decides to

make BART applicable to boilers that are individually greater than 250 million BTU/hr, the

surveys collected will provide the information needed to exempt the appropriate units.

Q. How do I determine the BART category status of petroleum storage and transfer

facilities with a capacity exceeding 300,000 barrels?

The 300,000 barrel cutoff refers to the total facility wide tank capacity for tanks that were

put in place within the 1962-1977 time period, and includes gasoline and other petroleum

derived liquids.
Additional Definitions and Guidance

Stationary source means all of the pollutant emitting activities which belong to the same

industrial grouping (i.e., have the same two-digit SIC code), are located on one or more

contiguous or adjacent properties, and are under the control of the same person (or persons under

common control). [40CFR51.301].

In existence means that the owner or operator has obtained all necessary preconstruction

approvals or permits required by Federal, State, or local air pollution emissions and air quality

laws or regulations and either has (1) begun, or caused to begin, a continuous program of

physical on-site construction of the facility or (2) entered into binding agreements or contractual

obligations, which cannot be cancelled or modified without substantial loss to the owner or

operator, to undertake a program of construction of the facility to be completed in a reasonable

time [40CFR51.301]. The potential emissions of all emission units falling within the 15-year

BART window and within any of the 26 source categories (they don’t all have to be in the same

category) must be aggregated for comparison to the 250-ton/year threshold. For the two source

categories, fossil fuel fired steam electric plants of 250 million Btu/hr heat input and fossil fuel

boilers (or combinations thereof) totaling more than 250 million Btu/hr heat input, the proposed

rule (subject to change) requires that the maximum heat input rates of all individual emission

units falling within the BART window first be aggregated for comparison to the 250-million

Btu/hr threshold. For petroleum storage and transfer facilities, the capacities of all storage tanks

falling within the BART window must first be aggregated for comparison to the 300,000-barrel

threshold. The total potential emissions of these such units or tanks, along with all other

emission units falling within the BART window and within any of the 26 source categories, must

then be compared to the 250-ton/year threshold to determine BART eligibility. Note, in the final

rule EPA may choose not to aggregate boilers on the basis of heat input rate but, instead, apply

the 250-million Btu/hr threshold to individual fossil-fuel boilers. Therefore, all boilers should be

listed individually for purposes of this preliminary assessment.

Note: The BART requirements are a core component of the federal regional haze program and

are likely to provide the primary basis for implementing substantial pollution reductions to

advance visibility goals over the next decade. The BART requirements were outlined in the

Clean Air Act Amendments of 1977 and subsequently updated in the regional haze rule of 1999

and in more recent guidance published on July 20, 2001 (Federal Register [66 Fed. Reg., 38108

(July20,2001)] as a proposed rule.
INSTRUCTIONS FOR BART INFORMATION REQUEST FORM

Work through these steps sequentially for each emissions unit (EU) listed on each form. If we

have missed any EUs that meet the BART criteria, please add them to the blank form. Make

copies of the blank form as needed.

STEP A. “Dates”: Evaluate EU construction/reconstruction dates.

1. Enter “yes” if EU was in existence on August 7, 1977; otherwise enter “no.”

2. Enter “yes” if EU began operation after August 7, 1962; otherwise enter “no.”

If 1. and 2. are both “yes”, move to Step B.

If 1a and 1b are “yes” and “no” or “no and “yes,”respectively, skip Steps B through D for this

EU, move to Step E and complete the form by answering “no, outside date range” to question 8.

STEP B. “BART Category”: Verify BART category.

3. This question contains a number corresponding to the list of BART categories from

Attachment A. Review this number and determine whether it is appropriate for this EU,

and enter “yes” or “no” as appropriate. If you answered “yes”, continue to Step C.

4. If you answered “no” in number 3, please enter the correct number corresponding to the

BART categories listed on Attachment A and continue to Step C. If this EU doesn’t fall

within one of the 26 BART categories, enter “none”. If you entered “none” skip Steps C

and D for this EU, move to Step E and complete the form by answering “no, source is not

a BART category” to question 8.

STEP C. “Emissions”: Enter potential emissions.

5. The actual emissions that you reported to us for calendar year 2002 for each emission

unit are summed and provided in table form. Ammonia (NH4) emissions have not been

included because Missouri facilities were not required to report ammonia emissions in

2002. If you see any errors, please bring them to our attention, by noting this on the

form.

Enter the current potential emissions for each pollutant for this unit in tons/year. Enter

“0” if your potential emissions for that pollutant is “0”. You may have conducted this

calculation when preparing your operating permit, and it is suggested that you use these

figures when or if they are available.

Potential emissions for this unit shall be calculated in a manner similar to how actual

emissions are calculated for your annual EIQ, except that your emissions must be

calculated based on the maximum annual-rated capacity of the installation, assuming
continuous year-round around-the-clock operation. Federally enforceable permit

conditions limiting the type of materials combusted, or processed, operating rates, hours

of operation or the application of air pollution control equipment shall be used in

determining the annual potential.

A federally enforceable condition is any limitation or condition that is enforceable by the

EPA Administrator. It includes all New Source Performance Standards (NSPS), National

Emission Standards for Hazardous Air Pollutants (NESHAPs), and Hazardous Air

Pollutant (HAP) requirements, requirements within the state implementation plan (SIP),

any Prevention of Significant Deterioration (PSD) or non-attainment review permits, and

any existing construction or operating permits.

Since the construction permit rule is approved by the EPA as part of the Missouri SIP,

construction or operating permit limitations are federally enforceable and should be

considered in your calculations. These limits can take the form of limits on emissions,

production, or even other operational limitations.

In calculating potential emissions, the installation may also consider “inherent physical

limitations” in potential to emit calculations. In other words, emissions which are

constrained by process limitations external to the unit rather than “maximum capacity” of

the unit are process bottlenecks and are considered as a “physical limitations” when

calculating potential to emit.

If this EU includes fossil-fuel boilers or petroleum storage tanks, move on to Step D.

Otherwise, skip Step D and move to Step E.

STEP D. Additional information (boilers & storage tanks only):

6. Enter the maximum heat input capacity of the boiler in million British thermal units per

hour (MMBtu/hr). If there are multiple boilers within this EU, enter the sum of the heat

input capacities for all boilers put in place within the 1962-1977 time period. Continue to

Step E.

7. Enter the capacity of the petroleum storage tank in barrels. If there are multiple tanks

within this EU, enter the sum of the capacities for all tanks put in place within the 1962-

1977. Continue to Step E.

STEP E. “Conclusion”: Provide conclusion or notes about this EU.

8. If you have already entered a “no” answer to this question already, then continue with

Step A on the next form for your facility (if any).

If your potential emissions is below 250 tons per year for each individual pollutant enter

“No. PTE<250 for each individual pollutant for this EU”, then continue with Step A on

the next form for your facility (if any).
If your potential emissions is above 250 tons per year for any one or more pollutants

enter “yes”. By entering yes you are determining that this unit will be preliminarily

classified as “BART-eligible” and staff will be further reviewing this preliminary

determination. Please continue with Step A on the next form for your facility (if any).

This question also provides a few lines for you to add any comments or a brief

explanation that might help staff understand your conclusion about whether this unit is or

is not “BART-eligible”.

NOTE: The 250 ton per year threshold applies to the sum of emissions from all units at

the facility that meet the construction/reconstruction date test and the BART category

test. If you have multiple units at your facility that meet these tests, staff will use the

figures reported on this questionnaire and sum each pollutant to determine the overall

potential of each pollutant at your facility.

Please sign and date the forms and return to the following address no later than December 17,

2004.

Missouri Department of Natural Resources

Air Pollution Control Program

P.O. Box 176

Jefferson City, MO 65102

Attn: John Rustige, P.E.
MattBlunt, Governor ~ D'&.Yle_Childers, Dfrectol' 

OFNATU 

www.dnr.mo.gov 

NOV 1 22007 

Mr. Aaron Miller 

Doe Run Company 

881 Main Street 

Herculaneum, MO 63048 

SOtJRCES 

RE: Control Requirements and Permit Status 


Doe Run ..:.. Glover Plant 


Dear Mr. Miller: 

As we understand, your facility is in care/maintenance status and it is unlikely yOu will operate 

anytime in the near future. Currently no smelter operations or production ofrefined lead is 

occurring and the only activity at the facility is rail transfer that occurs about twice per week. 

The facility has been allowed to suspend all State Implementation Plans (SIP) and Maximum 

Achievable Control Technology (MACT) required compliance testing and reporting 

requirements until the facility resumes operations. Doe Run ....: Glover is still required to conduct 

air monitoring at several locations and maintains those records electronically. In addition, your 

operating permit application has been on hold for an extended period of time. Our goal is to 

better understand the plans for your operation at Glover and detail' those in the operating pennit 

for this facility. 

If operations commence to produce refined lead, Doe Run - Glover will be subject to additional 

federal requirements beyond the current lead SIP. These include a detailed Best Available 

Retrofit Technology (BART) evaluation and potential additional control under the federal 

regional haze rule. Also, Doe Run Glover might be subject to control requirements for the 

St. Louis PM2.5 SIP that is currently under development. 

According to the U.S. Environmental Protection Agency's (EPA)flnal rule published on 

July 6, 2005, BART applies only to a major stationary source which "was in existence on 

August 7, ·1977, but which has not been in operation for more than 15 years as ofsuch date.". 

Based on survey data submitted by Doe Run and a cursory review ofEmission Inventory 

Questionnaire/construction permit data, the blast furnace and sinter plant were designated as 

BART-eligible. . 

o 

Recycled raper 
Mr. Aaron Miller 

Page Two 

According to 10 CSR 10-6.060(1 )(C), no owner or operator shall begin operation of any 

installation~ which has been shut down for longer than five years without obtaining a pennit from 

the permitting authority. Therefore, if ea,ch individual emission unit is not operated within five 

years ofits last operation (currently understood to be in 2003) without clear indication ofintent 

to operate by having an operating permit, new construction permits must be acquired from the 

Missouri Department ofNatural Resources' Air Pollution Control Program before you 

commence operation. 

We intend to issue your operating permit or terminate your application. To' accomplish this, 

please confirm the last operating date of each major process unit and the future plans for each 

unit at Glover. Please provide this information within 30 days ofreceipt ofthis letter. If you 

request termination, or we do not hear from you at the end ofthat time, we will terminate your 

operating pennit application. 

If you have any questions regarding permit issues, please contact me. Questions regarding 

BART~ regional haze, or the st. Louis PM2.5 SIP should be directed to Mr. JeffBennett or 

Mr. John Rustige. All contacts may be reached at (573) 751-4817. Thank you for your time and 

attention. 

Sincerely, 

AIR POLLUTION CONIROL PROGRAM 

Michael 

/Y2dJ~ J. Stansfi~~ Operating Permits Unit Chief 

MJS:jdn 

c: P AMS File: 2200-0008-020