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# &EPA

u.s.EnvironmentalProtec1ionAgency Region5 -AirandRadiationDivision 

## Correspondence**============~!~============** March 20, 1998
Robert Hodanbosi, Chief Division ofAir Pollution Control Ohio Environmental ProtectionAgency 1600 WaterMark Drive Columbus, Ohio 43215
DearMr. 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 airnozzles (no control). The application and draft permit refer to the second control option as "low-NOx burners with staged air nozzles." However, this control optionwouldutilize 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 informationprovided in discussions with vendors, the United States Environmental ProtectionAgency (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-NOxburners,**and~all** available control options must be considered, Pro-Tec should include a true low-NOxburner, 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-NOxburner, andnot to endorse the product.)
Since the State operates a delegated Prevention of Significant Deteriorationprogram, the State is obligated to follow the Federal regulations in 40 CFR 52.21 and the supporting policy. Asummary of this policywith 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 canbe 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 suchunique characteristics must focus on the application of control technology. The statements conclude by stating, "In the absence ofunusual circumstances, the presumption is that
sources within the same category are similar innature and that cost and other impacts that have beenborne by one source ofa given source categorymaybe borne by another
source of the same source category." This means that, in the absence of a unique technical demonstration, ifnitrogen dioxide from an annealing furnace is controlledby SCR at another source, then Pro-Tee shouldbe 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 submittedby the State, we have not found a demonstration of anyunusual 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 acceptedbasis for such rejection. Second, it appears that the cost figures mayhave beenbasedupon 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 incurredby the construction

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currentlyunderway at the Pro-Tee site and any retrofitting that maybe required to accommodate SCR. For these reasons, it is the**po~ition** ofUSEPA 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, BACTmust be determined for each emission unit with respect to NOx for the proposed construction. It is unclear from the draft permit whether BACThas 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 waterboilers. While the draft permit lists the use of low-NOxburners as Best Available Technology (BAT) for these boilers, if the term IIlow-NOxburners ll as it is usedhere is not consistent with the accepted definition of this**technolo~y,** then the analysis wouldbe insufficient to conclude that the State's BAT selectionwouldbe 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 CleanAirAct for this source.

Ifyou have any questions regarding this letter, please contact Kaushal Gupta at (312) 886-6803 or Kushal Som at (312) 353-5792. Sincerelyyours,
/s/ Cheryl Newton, Chief Permits and Grants Section 

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AntAND RADiATION DaVIS10N
77 WEST.JACKSON BOULEVARD(A·t8.J)**CHJeA~O.** 1l.l.lHOIS60604 (8001 621"1'I43t OR (312) 3S3-2.2.12.

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