Preston Br:vanl Secretary ofNntural Resources 

# • •

COMMQNWEALTH 

# ofVIRGINIA

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-NMinerals (Chemstone) Company Location: Shenandoah County


### Re: Draft 

### BestAvailable 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 ofthe following documents**~ave** been provided to Don Shepherd ofthe 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 ofletter 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 ofthe National Park Service. Please note that, due to their size, the attachments to the engineering analysis have not

_been enclosed. Please let me know ifyou would 

### like (0 review any or all ofthe attaclmlents

and we'll gladly send them to you via electronic mail. This letter provides written notification ofcommencement ofthe 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. Ifyou 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 

# COMMONWEALTHof

# VIRGINIA

DEPARTMENT

### OF ENVIRONMENTAL QUALITY VALLEY REGIONAL OFFICE L. Preston Bryant. Jr.

. Secretary ofNatural 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

5162Valleypointe 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 ofthe attachments and we'll gladly send them to you via electronic mail. This letter provides written notification ofcommencement ofthe 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. Ifyou' 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 iam 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 ofhow 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 ofthe particulate matter control device." may be correct inthe context ofa 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. Itmay be that the sheer concentration ofdust in the kiln exhaust may render SCR infeasible, or its high alkaline content, orboth, butthat should be demonstrated. (A statement fi.-om an SCR vendor that application inthe high dust location is infeasible could be an adequate alternative.) And, since it is technically feasible to install an SCRdownstream ofthe dust collector and reheat the gas to the necessaly operating temperature tor the SCR, an analysis ofthe economic feasibility ofthat 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 maynot be as expensive as**O~N**had proposed then. First, ifthe exhaust gas temperature is about 190 F pel' the 10/30/07 stack test, and the optimum SCRtemperature is about 690 F, then it would only be necessaty to raise the gas temperature by 500 F instead ofthe 1100 F implied in the O-N example calculation for SNCR. In that example,**O~N** assumed a natural gas price of$9.66I1vlcf; today's price is about $4I1vlcf. And, ifSCRcanremove 90% ofthe NOx, then the $/ton for the reheat costs fot' SCR should be substantially lower than presented by O-N for SNCR. Ofcourse, this does not include the Total Annual Costs for installing and operating the SCR. Ifthe SCRreheat costs seemreasonable, then O-N should be asked to evaluate the total cost ofthe "SCR with reheat" option. Irealize that we are asking alot ofthis 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 ShenandoahNational Park. With that "cloudlt hanging over our heads, ireally want to feel confidentthat 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 ofS02reduced. 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 1ginia.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 ifyou 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. MarthaBogle Superintendent Shenandoah National Pm'k 3655 Hwy 21 J 

### East Luray, VA 22835 Re: Response to FLM comments on draft BARTpermitfol' 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) ofthe Department of Environmental Qllality provided the Fedet'al Land Managers copies ofour draftBest Available RetrofitTechnology (BART) permit and analysis for**O~N** 

### Min.orals (Chemstone) Company, Inc. (Chemstone). The submittal ofthe draft permit marked the beginning ofthe 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 oftheNational Park Service's Ail' Resollrces Division In Colorado. Acopy ofMt'. Shepherd's comments is attached, The commetlts foc'lsed on our BARTdetermination 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 staffasked Chemstone to address (he technical feasibility ofhigh-dust SCR and to provide acost 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'

### ofNPScomments: NPS questioned that SCR )'vas technically infeasible and suggested that the analysis demonstrate specifically why ahigh-dust SCR is infeasible 011 

### alime kiln ''''hen such control has been used successfully onptllverized 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' aPC 

### boiler 1S 

### approximately 10 g/Nm3
, 

### whereas the dust loading fOl' 

### alime kiln prior to abaghouse is typicaUy several times highet', in excess of80 

### glNmJ

, 

### The relatively high dust loading fo1' lime kiln exhaust streams 

### poses achallenge to a catalyst-based control devjce positioned before a

### dustcollector. Furthermore, the fact thut the 

### limekiln'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 atypical PCB 

### application, Additionally, SCR has not beenused to cOllteollime kilns and, unlike SNCR, has had extremely limited application to cementkilns. We have found no examples ofSCR use on a cement kiln in the U.S. Vle are aware ofthree full-scale cement kiln applications ofSCRin the B.U: (one in Gel'many and two inItaly), ollly two ofwhich 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 inabilityto achieve the required reduction efficiency, Because SCR has never beenused to control alime kiln, it is likely that extended pilotscale trials would be required prior to its application 

### on aHmekiln. Accordingly> SCR

### may not meet the definition of"available" teclmology for alime kiln given in the BARTg\lidelines. As stated in EPNsfinal BART gllidelines (at70 FR 39164): IITechllologies whichhave notyet been applied to (01'

### pel'mitted for) full scale operations need notbe considered as available; we do notexpect the source ownerto purchase oi' construct aprocess 01' 

### conti'o) device thathas not already been demonstmted inpractice. It 

### Due to its lack ofsuccessful demonstt'ation on the few cement kilns to which it has been applied and given EPA's guidance, SCRis 110t

### an appl'opl'iate cmldidate at this point foJ' technology h'ansfcl' consideration fol' BART control ofalime 

### kiln, Based on 

### the high dust concentration 

### in the lime kiln's exhaust 

### stream, the contentofthe dust, and the lack ofcommercial demonstmtion Oil 

### lime kilns, we continue to believethat 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 ofusing a SCRpositioned aftertho baghouse, 

### Response: In response to NPS' comments, we asked Chemstone to evaluate the costpel' 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 believethis to be costprohibitivefor 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 SCRwith l'eheat. 

### OUt'research indicates that 80% is al'easonable control basis for 

### SCR fol' akiln application. Although SCR technology is capable ofachieving 90% reduction on boilel's \lI1del' optimal conditions, this level ofcontrol is not necessarily achievable on otherindustrial processes that lwYe different**exha~lst**

### Ms. Martha 

### Bogle September22, 2009 Page 3 

### stream characteristics. SCR has not been demonstrated on alime kiln. Tempel'ahll'e fluctuations inherentto lime kiln operation would be expected to reduce the reduction efficiency ofthe 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 

### reheatis not an 

### economically feasible 

### cOlltrol optionfol' the 

### rotary kiJn. As 

### noted above, commercial use ofSCR 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 ofSCR to alime 

### kiln. In its comments, NPS also·cited the effectiveness ofSOzl'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\lsedto determine the effectiveness of NOx

### reductions in improving visibility at SNP. Modeling has 

### not been conducted to determine the visibility 

### improvement resulting from 

### application ofNOx

### 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 ofS02 and NOx

### reductions in visibility 

### improvementis a pel'tinent measure in Chemstone's case. Nonetheless, to respond to 

### the inquiry and in the absence of

### modeling results I'eflectingNOx

### control, a

### consel'vative estimate may be made by 

### assuming thatthe enti1'e modeled 

### visibility impairment (1,1 

### dv) would be mitigated by 

### I'educing 

### NOx

### by 80% (305 

### tOlll'eduction» resulting in an 

### effectiveness of0,0036 

### 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 thatthe BART determination 

### includes the application ofS02 

### 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 permitthatwas provided to theFLMs in 

### January. (l) 

### The effective date ofthe SOz1imits (and the l'eqtlil'ement 

### to operate aCEMS) in the permit have 

### beenchanged from August 1,2012 to September 10, 2010. The change was made for consistency with the terlllS ofa 

### pending EPA 

### 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 

### ofthe 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 oflimestone fced sulfur**cOlltent~** 

### as this is no 

### longerneeded 

### for enforceability ofthe limits.

### Ms, Mattha Bogle September22, 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. Adl'aftpermit is enclosed; it includes minol' rovisions made at Chemstone's request 

### (revisions are highlighted). We plan to commence the 30·day 

### public commentperiod for the draft BART determination within the 

### nextfew weeks. NPS' March 2,2009 

### comments and ourresponse will be reforenced in the public notice and available for p\lbHc 

### review alld 

### comment.

Enclosl11'es
cc: WalterK. 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 (viaelectronic 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)