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u.s. Environmental

EPA

Protec1ion Agency

Region 5 - Air and Radiation Division

Correspondence

============~!~============

March 20, 1998

Robert Hodanbosi, Chief

Division of Air Pollution Control

Ohio Environmental Protection Agency

1600 WaterMark Drive

Columbus, Ohio 43215

Dear Mr. Hodanbosi:

The purpose of this letter is to provide comments on the Best

Available Control Technology (BACT) analysis provided in the

permit application and draft Permit to Install (PTI) of ProTec Coating Company in Leipsic, Ohio.

The BACT analysis as represented in the application currently

considers three control technology options: 1) selective

catalytic reduction (SCR), 2) standard recuperative burners

with staged air nozzles, and 3) standard recuperative burners

without staged air nozzles (no control). The application and

draft permit refer to the second control option as "low-NOx

burners with staged air nozzles." However, this control

option would utilize the Bloom 2320 recuperative radiant-tube

burner, which lacks the features of a true low-NOx burner

such as air staging, fuel staging, or ceramic/refractory

baffles. Based on information provided in discussions with

vendors, the United States Environmental Protection Agency

(USEPA) advises that the BACT analysis refer to the second

control option as "standard recuperative burners" rather than

low-NOx burners.· Subsequently, since this pollution control

option is not equivalent to low-NOx burners, and~all

available control options must be considered, Pro-Tec should

include a true low-NOx burner, such as the Bloom 2370 Type F,

in its BACT analysis. Because this technology has been

developed, patented, and available for sale, it is considered

"available" as BACT. (USEPA is mentioning the Bloom 2370

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Type F only to provide an example of a true low-NOx burner,

and not to endorse the product.)

Since the State operates a delegated Prevention of

Significant Deterioration program, the State is obligated to

follow the Federal regulations in 40 CFR 52.21 and the

supporting policy. A summary of this policy with respect to

BACT is described in the October 1990 "New Source Review

Workshop Manual." The Federal policy indicates that before a

BACT control option that has been demonstrated successful in

practice can be rejected from consideration, the applicant

must demonstrate in the public record that, "circumstances

exist at the source which distinguish it from other sources

where the control alternative may have been required

previously . "The policy continues by saying that any

such unique characteristics must focus on the application of

control technology. The statements conclude by stating, "In

the absence of unusual circumstances, the presumption is that

sources within the same category are similar in nature and

that cost and other impacts that have been borne by one

source of a given source category may be borne by another

source of the same source category." This means that, in the

absence of a unique technical demonstration, if nitrogen

dioxide from an annealing furnace is controlled by SCR at

another source, then Pro-Tee should be expected to use that

technology at their annealing furnace.

In our review of all the material including the draft permit

and the application that was submitted by the State, we have

not found a demonstration of any unusual circumstances that

warrant the rejection of SCR as a control option. At this

point we have identified at least three annealing furnaces

that are controlling NOx emissions with SCR.

We believe that Ohio should also consider an additional

comment on the cost analysis. Pro-Tee's basis for their

rejection of SCR is the cost effectiveness calculation of

$5,727 per ton. First, a simple rejection of that cost

level because it is too high is not an accepted basis for

such rejection. Second, it appears that the cost figures mayhave been based upon old data which does not take into

account the steady reduction of SCR costs. Third, the

question arises as to whether the cost figures are based on

irrelevant factors such as costs incurred by the construction

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currently underway at the Pro-Tee site and any retrofitting

that may be required to accommodate SCR. For these reasons,

it is the po~ition of USEPA that SCRneeds to be reevaluated

in the Pro-Tee BACT analysis.

Finally, as mentioned in the February 27, 1998, letter from

our qffice to you, BACT must be determined for each emission

unit with respect to NOx for the proposed construction. It

is unclear from the draft permit whether BACT has been

selected for the NOx-emitting units other than the annealing

furnace. We are particularly interested in the proposed

control strategy for the two hot water boilers. While the

draft permit lists the use of low-NOx burners as Best

Available Technology (BAT) for these boilers, if the term

IIlow-NOx burnersll as it is used here is not consistent with

the accepted definition of this technolo~y, then the analysis

would be insufficient to conclude that the State's BAT

selection would be equivalent to BACT.

I hope this information is useful. We look forward to

continuing our cooperative effort to fully address the

permitting requirements of the Clean Air Act for this source.

If you have any questions regarding this letter, please

contact Kaushal Gupta at (312) 886-6803 or Kushal Som at

(312) 353-5792.

Sincerely yours,

/s/

Cheryl Newton, Chief

Permits and Grants Section

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Ant AND RADiATION DaVIS10N

77 WEST .JACKSON BOULEVARD (A·t8.J)

CHJeA~O. 1l.l.lHOIS 60604

(8001 621"1'I43t OR (312) 3S3-2.2.12.

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