Preston Br:vanl 

Secretary ofNntural Resources 

• • 

COMMQNWEALTH of VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

. VALLEY REGIONAL OFFICE 

441'1 Early Road, P.O. Box 3000. Harrisonburg, Virginia 12801 

(540) 574-7800 Fax (540) 574-7878 

\1'11'11' .deq. \·irginia.gov 

January 15, 2009 

VRO-AIR-017-09 

David K. Paylor 

Director 

R. Bradley Chewning. P.E. 

Regional Dir~c(or 

Mr. Chas Cartwright 

Superintendent 

Shenandoah National Park 

3655 U.S. Highway 211 East 

Luray, Virginia 22835-9036 

Facility: O-N Minerals (Chemstone) Company 

Location: Shenandoah County 

Re: Draft Best Available Retrofit Technology (BART) Pemlit and Engineering Analysis 

Dear Mr. Cartwright: 

Enclosed for your review are the draft permit and engineering analysis for the Best. 

Available Retrofit Technology (BART) determination for the O-N Minerals (Chemstone) 

Company lime manufacturing plant in Strasburg, Shenandoah County, Virginia: During the 

BART application analysis and draft permit development, copies of the following documents 

~ave been provided to Don Shepherd of the National Park Service (document dates provided): 

• September 2006: CALPUFF modeling results for Chemstone's plant 

• February 23, 2007: Chemstone's initial BART application 

• March 27, 2007: DEQ-VRO's.application completeness review letter 

• Letters from Chemstone dated April 27,2007 and May 31,2007 

• Letter from Chemstone dated March 17,2008, responding to DEQ & NPS 

comments on Chemstone's revised modeling analysis (copy of letter provided· to 

Bruce Polkowsky ofNPS) 

• Letters from DEQ-VRO dated March 27, 2007, August 14, 2007, September 10; 

2008, November 21,2008, and ,.lanuar), 6, 2009 
.i • • 

Mr. Chas Cartwright 

January 15, 2009 

Page 2 

Electronic files for the draft permit and accompanying engineering analysis have-been 

sent today to Don Shepherd of the National Park Service. 

Please note that, due to their size, the attachments to the engineering analysis have not 

_ been enclosed. Please let me know if you would like (0 review any or all of the attaclmlents 

and we'll gladly send them to you via electronic mail. 

This letter provides written notification of commencement of the 60-day review period 

provided to Federal' Land Managers for consultation on implementation plans related to 

regional haze, according to 40 CFR 51.3080)(2). -A public hearing is anticipated at the earliest 

on March 16,2009. 

If you have any questions regarding this matter, please conta~t me at (540) 574-7821 or 

sgfoleyCCUdeq. virginia.gov . -

Enclosures 

cc: Walter K. Wilkie, EPA Region III 

Chris Pilla, EPA Region III 

Don Shepherd, NPS (via electronic mail) 

-S~ncerely, . 

~/J~ Sharon O. Foley, P.E. 

Air Permit Manager 

David St. Clair, O-N Minerals (Chemstone) Company (via electronic mail) 

Mike Kiss, DEQ (via electronic mail) . 
• • 

VRO-AIR-O 18-09 

COMMONWEALTH of VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

VALLEY REGIONAL OFFICE 

L. Preston Bryant. Jr. . 

Secretary of Natural ResollTl:es 

Ms. Cindy M. Huber 

Air Reso.urce Specialist 

USDA Forest Service 

4411 Early Road, P.O. Box 3000, Harrisonburg, Virginia 22801 

(540) 574-7800 Fax (540) 574-7878 

WII'W .dt'tj. virginia.gel" 

January 15, 2009 

5162 Valleypointe Parkv.'ay 

Roanoke, VA 24019 

Facility: O-N Minerals (Chemstone) Company 

Location: Shenandoah County 

Re: Draft Best Available Retrofit Technology (BART) Permit and Engineering Analysis 

Dear Ms. Huber: 

Dal'id K. Paylor 

Director 

Amy Thatcher Owens 

Regional Director 

Enclosed for your review are the draft permit and engineering analysis' for the Best Available 

Retrofit Technology (BART) determination for the O-N Minerals (Chemstone) Company lime 

manufacturing plant in Strasburg, Shenandoah County, Virginia. Ptease note that, due to their size, the 

attachments to the engirieering analysis haVe not been enclosed. Please let me know ifyoll wouJd like to 

review any or all of the attachments and we'll gladly send them to you via electronic mail. 

This letter provides written notification of commencement of the 60-day review period provided 

to Federal Land Managers for consultation on implementation plans related to regional haze, according to 

40 CFR 51.308(i)(2). A public hearing is anticipated at the earliest on March 16; 2009. 

If you' have any questions regarding this matter, please contact me at (540) 574-7821 or at 

s!Zfolev(Ci)deq.virl!inia,gov. 

Enclosures 

cc; Walter K. Wilkie, EPA Region III 

Chris Pilla, EPA Region Iff 

Don Shepherd, NPS (via electronic mail) 

Sincerely, 

~I:J~ Sharon G. Foley, P.E. 

Air Permit Manager . ~ 

David St. Clair, O-N Minerals (Chemstone) Company (via electronic mail) 

Mike Kiss, DEQ (via electronic mail) . 
Justin.Laura 

From: 

Sent: 

To: 

Cc: 

Subject: 

Laura, 

Oon_ Shepherd@nps.gov 

Monday, March 02, 2009 4:08 PM 

Justin,Laura 

Andrea_ Stacy@nps.gov; Gordon_ Olson@nps.gov; Holly-Salazer@nps.gov; 

Jim_Schaberl@nps.gov; John_Notar@nps.gov; Julie_ Thomas_McNamee@nps.gov; 

Keith_Newlln@nps.gov; Bruce_Polkowsky@nps.gov; McLeod,Ooris; Kiss,Michael 

Re: O~N Minerals draft BART permit 

Sorry to be so late with my response, but i am very pleased with the work that your office produced on O-N and the proposed result. 

The thoroughness ofthe review and the diligence shown by DEQ are excellent examples of how the BART process should work, and i 

hope that YOll will allow me to share your analysis with others. 

I do suggest that you take another look at your detennination that SCR is technically infeasible. I suspect that SCR may be infeasible, 

but for reasons different from those cited. For example, the statement, "To avoi.d fouling the catalyst bed with· the particulate matter in 

the exhaust stream, a SCR unit must be located downstream of the particulate matter control device." may be correct in the context of a 

lime kiln, but that needs to be explained. I suggest that a comparison be presented between a typical "high-dust" SCR installation on a 

PC boiler versus a hypothetical high-dust installation 011 a lime kiln. It may be that the sheer concentration of dust in the kiln exhaust 

may render SCR infeasible, or its high alkaline content, or both, but that should be demonstrated. (A statement fi.-om an SCR vendor 

that application in the high dust location is infeasible could be an adequate alternative.) 

And, since it is technically feasible to install an SCR downstream of the dust collector and reheat the gas to the necessaly operating 

temperature tor the SCR, an analysis of the economic feasibility of that option should be included. I looked back at the analysis that ON submitted in May 2007 and a few issues seemed to indicate that reheating may not be as expensive as O~N had proposed then. First, 

if the exhaust gas temperature is about 190 F pel' the 10/30/07 stack test, and the optimum SCR temperature is about 690 F, then it 

would only be necessaty to raise the gas temperature by 500 F instead of the 1100 F implied in the O-N example calculation for 

SNCR. In that example, O~N assumed a natural gas price of $9.66I1vlcf; to day's price is about $4I1vlcf. And, if SCR can remove 90% 

of the NOx, then the $/ton for the reheat costs fot' SCR should be substantially lower than presented by O-N for SNCR. Of course, this 

does not include the Total Annual Costs for installing and operating the SCR. If the SCRreheat costs seem reasonable, then O-N 

should be asked to evaluate the total cost of the "SCR with reheat" option. 

I realize that we are asking a lot of this pal1icular lime manufacturing facility, and i really appreciate the progress you have made. But, 

to my knowledge, it is located closer to a Class I area than any other similar facility, and even with the excellent reduction in S02 

emissions that you have proposed, it would continue to contribute to visibility impairment in Shenandoah National Park. With that 

"cloudlt hanging over our heads, i really want to feel confident that we have exhausted every potentially feasible remedy before we 

conclude that this is the best that w~ can do for now. Because NOx is the pollutant emitted ill the largest quantity by O-N, it seems that 

one last look at reducing that pollutant may be worthwhile. 

Based upon YOUl' repOlt, a 330 tpy reduction n S02 yields a 0.11 dv improvement at Shenandoah; that indicates that we get about 

0.00033 dv improvement per ton of S02 reduced. Do we have any modeling results that could provide some insight on how effective 

NOx reductions at O~N would be with respect to improving visibility at Shenandoah? 

thanks again ... 

Don Shepherd 

National Park Service 

Air Resources Division 

12795 W. Alameda Pkwy. 

Lakewood, CO 80228 

Phone: 303-969~2075 

Fax: 303-969-2822 

E-Mail: dOIl_ shepherd@nps.gov 

"Justin,Laura" 

<lrjustin@deq.vir 

1 
ginia.gov> To 

<Don _ Shepherd@nps.gov> 

0211112009 02:28 cc 

PM EST 

Subject 

O-N Minerals draft BART permit 

Hi, Don, 

We'd like to start preparing the public notice for the O-N Minerals 

(Chemstone) draft BART permit (next week will be 30 days since providing the draft documents to the FLMs). Before we move 

forward with the notice, I wanted to see if you believe there are any issues we need to discuss before we commence public comment. 

I'd appreciate any feedback you can offer. 

Thanks, 

Laura 

Laura R. Justin 

Environmental Engineer Sr 

Virginia DEQ - Valley Regional Office 

(540) 574-7857 

2 
VRO-AIRw272-09 

I,. l'roslOll Br),ont, Jr. 

Sc~rClary QfNnluml ROSOlirces 

COMMONWEALTH of VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALl1Y 

VALLEY REGfONALOFFICE 

4411 Eorly Rond, P.O. Box 3000, Hnl'risonblll'g, Virginin 22801 

(540) 574-7800 FI1X (540) 574-7878 \I'\\·w.d~q. virginIR.go\' 

September 22, 2009 

Ms. Martha Bogle 

Superintendent 

Shenandoah National Pm'k 

3655 Hwy 21 J East 

Luray, VA 22835 

Re: Response to FLM comments on draft BART permit fol' O-N Minerals (Chemstone) 

Company, Registration 80252 

Deal' Ms. Bogle: 

DavJd K. Paylor 

Dlreclor 

Amy Thn(ch~r OWells 

Regionnl Di~c(or 

On January 15,2009, the Valley Regional Office (VRO) of the Department of 

Environmental Qllality provided the Fedet'al Land Managers copies of our draft Best Available 

Retrofit Technology (BART) permit and analysis for O~N Min.orals (Chemstone) Company, Inc. 

(Chemstone). The submittal of the draft permit marked the beginning of the 60 M day review 

period provided to Federal Land Managers (FLMs) fol' cOlls\lltatloll on implementation plans 

related to l'egional haze, according to 40 CFR 51.308(i)(2), On March 2, 2009, VRO staff 

received comments via electronic mail from Don Shepherd of the National Park Service's Ail' 

Resollrces Division In Colorado. A copy ofMt'. Shepherd's comments is attached, 

The commetlts foc'lsed on our BART determination for NOx from Chemsfone's rotary 

kiln. Specifically, NPS suggested that highwdust Selective Catalytic Reduction (SCR) may be 

technically feasible and requested fUl'ther demonstration that postMbaghouse SCR 1S economically 

infeasible, In response to NPS' comments, VRO staff asked Chemstone to address (he technical 

feasibility of high-dust SCR and to provide a cost analysis for usc of SCR following the 

haghOllse, Chemstone's l'esponses arc attached and ou!' evahmtioll oftheh'l'csponse is 

smll111arized below. 

High.Dust SCR 

SUI1111W1J' ofNPS comments: NPS questioned that SCR )'vas technically infeasible and suggested 

that the analysis demonstrate specifically why a high-dust SCR is infeasible 011 a lime kiln ''''hen 

such control has been used successfully on ptllverized coal (PC) boilers, 
Ms. Martha Bogle 

Sel)tembel' 22, 2009 

Page 2 

Response: As reported in Chemstone's May 8, 2009 submittal (attached), the particulate matter 

control device loading typical fol' a PC boiler 1S approximately 10 g/Nm3, whereas the dust 

loading fOl' a lime kiln prior to a baghouse is typicaUy several times highet', in excess of80 

glNmJ, The relatively high dust loading fo1' lime kiln exhaust streams poses a challenge to a 

catalyst-based control devjce positioned before a dust collector. Furthermore, the fact thut the 

lime kiln's dust loading is prlmal'lIy calciulll oxide (CaD), known to deactivate COlwolltiollal 

catalysts by its cOllversion to calcium sulfate, further distinguishes the process from a typical 

PCB application, 

Additionally, SCR has not been used to cOllteollime kilns and, unlike SNCR, has had 

extremely limited application to cement kilns. We have found no examples of SCR use on a 

cement kiln in the U.S. Vle are aware of three full-scale cement kiln applications of SCR in the 

B.U: (one in Gel'many and two in Italy), ollly two of which are CUlTelltJy openlting the SCR (and 

these have been operational less than (\VO years). Reportedly SCR 'use has been discontinued 

(and replaced by SNCR) at the Gel'man facility due to various technical issues~ including 

inability to achieve the required reduction efficiency, 

Because SCR has never been used to control a lime kiln, it is likely that extended pilotscale trials would be required prior to its application on a Hme kiln. Accordingly> SCR may not 

meet the definition of "available" teclmology for a lime kiln given in the BART g\lidelines. As 

stated in EP Ns final BART gllidelines (at 70 FR 39164): IITechllologies which have not yet 

been applied to (01' pel'mitted for) full scale operations need not be considered as available; we do 

not expect the source owner to purchase oi' construct a process 01' conti'o) device that has not 

already been demonstmted in practice. It Due to its lack of successful demonstt'ation on the few 

cement kilns to which it has been applied and given EPA's guidance, SCR is 110t an appl'opl'iate 

cmldidate at this point foJ' technology h'ansfcl' consideration fol' BART control of a lime kiln, 

Based on the high dust concentration in the lime kiln's exhaust stream, the content of the 

dust, and the lack of commercial demonstmtion Oil lime kilns, we continue to believe that SCR 

lIse pl'ior to the baghOl,lse is not a technically feasible control option fol' Chemstone's t'ota!'y kiln. 

SCR with reheat 

SummCIIJI q{ NPS comments: NPS I'eqm~sted that we revi,ew the economic feasibility of using a 

SCR positioned after tho baghouse, 

Response: In response to NPS' comments, we asked Chemstone to evaluate the cost pel' tOll of 

contl'olling NO;, from the rotary kiln 1..1sing SCR after the baghouse. As indicated in the attached 

submittals ft'om Chemstone, the cost pel' tOll is calculated to be $7AOO, We believe this to be 

cost prohibitive for BART contl'o1. Note that the I'eduction efficiency \lsed in the cost analysis 

(80%) is lower than that referenced in NPSI comments (90%) all SCR with l'eheat. OUt' research 

indicates that 80% is a l'easonable control basis for SCR fol' a kiln application. Although SCR 

technology is capable of achieving 90% reduction on boilel's \lI1del' optimal conditions, this level 

of control is not necessarily achievable on other industrial processes that lwYe different exha~lst 
Ms. Martha Bogle 

September 22, 2009 

Page 3 

stream characteristics. SCR has not been demonstrated on a lime kiln. Tempel'ahll'e fluctuations 

inherent to lime kiln operation would be expected to reduce the reduction efficiency of the 

catalyst. It Sh0111d be noled that the only cement kiln SCR fOl' which operating data are available 

(the German facility referenced above) reportedly achie,ied an approximate 50% reduction 

during the time that it was operating the control device. 

We find that SCR with reheat is not an economically feasible cOlltrol option fol' the rotary 

kiJn. As noted above, commercial use of SCR on cement kilns is extremely limited and we are 

mlaWftl'e of~lIlY SCR use on a lime kiln. It should be noted that the cost effectiveness calculation 

did not incJude pilot testing that would likely be l'equil'ed in any proposed application of SCR to 

a lime kiln. 

In its comments, NPS also· cited the effectiveness of SOzl'cductions in improving 

visibility at Shenandoah National Part (SNP) (0.00033 dv pel' ton S02 reduced) ~U1d questioned 

whether any modeling had been cOndtlcted which could be \lsed to determine the effectiveness of 

NOx reductions in improving visibility at SNP. Modeling has not been conducted to determine 

the visibility improvement resulting from application of NO x contt'ols, because no NOx control 

was found to be both technically and economically feasible. FOl'the same reason, we do not 

beHeve that the I'elative effectiveness of S02 and NOx reductions in visibility improvement is a 

pel'tinent measure in Chemstone's case. Nonetheless, to respond to the inquiry and in the 

absence of modeling results I'eflecting NOx control, a consel'vative estimate may be made by 

assuming that the enti1'e modeled visibility impairment (1,1 dv) would be mitigated by I'educing 

NOx by 80% (305 tOlll'eduction» resulting in an effectiveness of 0,0036 dv/ton NOx reduced. If 

802 and NOx control were eqtlfllly feasible both technically and economically, this metl'ic m.ight 

be instrllctiye in choosing the more effective visibility improvement stl·nfegy. Given that the 

BART determination includes the application of S02 control and that NOx contl'Ol is cost 

prohibitive, this then appeal'S to be an·cxtl'aneOtlS me!lSUl'e. 

Please note that we have made changes, described below, to the dl"aft permit that was 

provided to theFLMs in January. 

(l) The effective date of the SOz1imits (and the l'eqtlil'ement to operate a CEMS) 

in the permit have been changed from August 1,2012 to September 10, 2010. 

The change was made for consistency with the terlllS of a pending EP A 

enforcement settlement. 

(2) Condition 23 (S02 emission limits) has been clmnged to indicate that the 

pl'oduetioll·based limit (lbs/tsf) does not appJ)' during stal'tllp of the kiln. We 

did not intend that that prod\lction~based limit would apply during times when 

there is no product made, and the revised condition clarifies this intent. The 

lbs/hl' limit applies at all times, including stm1up. 

(3) Condition 26 (Recordkeeping) has been amended to remove the l'cq\.lil'ement 

to keep records of limestone fced sulfur cOlltent~ as this is no longer needed for 

enforceability of the limits. 
Ms, Mattha Bogle 

September 22, 2009 

Page 4 

In summary, DEQ has addl'essed the concerns raised by NPS dming its l'evie\" period. 

We would be glad to discllss any quostiOllS OJ' l'omaining concerns you may have. A dl'aft permit 

is enclosed; it includes minol' rovisions made at Chemstone's request (revisions are highlighted). 

We plan to commence the 30·day public comment period for the draft BART determination 

within the next few weeks. NPS' March 2,2009 comments and our response will be reforenced 

in the public notice and available for p\lbHc review alld comment. 

Enclosl11'es 

cc: Walter K. Wilkie, EPA Region III 

Sincerely, 

/JJWI-I71 hV~ Sharon G. Foley, P,E. 

Ail' Permit ManageI' 

MUlll'een Hyzel', USFS (via electronic mail) 

Don Shepherd, NPS (via electl'onic mail) 

Jim Schubert, NPS (via electronic mail) 

Andrea Stacy, NPS (via electronic mail) 

Cindy H1.lhel', USFS (via electronic mail) 

David St. Clair) OHN Minen\ls (Chemstone) Company (via electronic mail) 

Dods McLeod, DEQ (via electronic mail)