# Attachment H2

BART Facility LettersDate

Mr Bill Klutz Degussa-Huls Corporation

4201 Degussa Road
Theodore, AL 36582

Re: BART Information Request Facility Number 503-5011

Dear Mr Klutz:

Under the Clean Air Act, states must evalua te certain older, larg e emission units and determine whether these units require the inst allation of the best emission controls available as part of strategies for meeting the goals of the regional haze program. This requirement, known as the Best Available Retrofit Technology (BART) requirement, applies to emission units bu ilt between August 7, 1962 and August 7, 1977 that, individually or in combination with other such units, have the potential to emit 250 tons per year or more of any visi bility-impairing pollutan t. The applicable pollutants are: ammonia, nitrogen oxides (NO

x ), particulate matter (PM 10 ), sulfur dioxide (SO 2 ) and volatile organic compounds (VOC s). Affected emi ssion units must fall into one of 26 source categories, including steam electric plants and industrial boilers, and large industrial plants such as pulp mills, refineries and smelters. (See attached list.)

Alabama has compiled a preliminary list of st ationary sources havi ng emission units

that fall into one of the 26 named source categories and that collectively have the potential to emit 250 tons per year or more of any visibility-impairing pollutant. Your facility has been identified as a potential BART-eligible source.

Background

Under the 1999 regional haze rule, states/tri bes are required to set periodic goals for improving visibility in the nati on’s 156 Class I natural areas. As they work to reach these goals, states/tribes must develop state or tribal implementation plans (SIPs/TIPs) that contain enforceable measures and control strategies for reducing visibility-impairing pollution. States/tribes participating in a regional planning process must submit initial “planning SI Ps/TIPs” to the EP A in the 2004-2006 time period (i.e., no later than one year after the PM 2.5 attainment/nonattainment designations are made). In their planning SIPs/TIPs, stat es/tribes must identify all BART-eligible sources.

The current regulatory schedule requires th at states/tribes, by December 31, 2008, or earlier, submit regional haze SIPs/TIP s to the EPA containing, among other things, emission limitations representing BART and compliance schedules for all BARTeligible sources that reasonably may be antici pated to cause or contribute to visibility impairment in any mandatory Class I area . In their regional haze SIPs/TIPs, states/tribes must support their BART decisi ons or any alternative emission reduction programs that they may have developed as part of the regional planning process.A BART-eligible source is that portion of a stationary source 1 consisting of those emission units or processes that individually or in aggregate:

• fall into any of the 26 source categori es as listed in the attached table,

• were in existence 2 on August 7, 1977, and bega n operation after August 7,
1962, and

• have the potential to emit 250 tons pe r year or more of any visibilityimpairing pollutant 3 [ammonia, nitrogen oxides (NO

x ), particulate matter (PM 10 ), sulfur dioxide (SO 2 ) and volatile organic compounds (VOCs)].

Conclusion

BART-eligible source identification is a mandatory requirement under the Clean Air Act and the EPA Regional Haze rule. This preliminary assessment is an important step in meeting the requirem ent and we are asking for your assistance with this information. Attached to this letter you wi ll find a report that contains a list of possible BART-eligible units at your facility. This report was compiled from the Department’s emission inventory database and information in the facility file. We are asking that you review the data provided for your facility in this report and provide comments on the accuracy of our information. The following items are of particular

concern:

• potential ammonia emissions,

• installation dates of units,

• reconstruction dates of units, and

• identification of other units at your fa cility that are BART-eligible that ADEM.

1 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]

2 In existence means that the owner or operator has obtain ed all necessary preconstruction approvals or permits required by Federal, State, or local air pollu tion 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 co ntractual 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]

3 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 thresh old. 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 th e BART window first be aggregated for comparison to the 250-million Btu/hr threshold. For petroleum storag e 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 determin e 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. (See proposed rule for more detail.)Information collected will be shared with the other states/tribes within the

Southeast.

We request that you respond to this re quest no later than September 1, 2002. A self-addressed envelope has been provided to facilitate your submittal of this information to the Department. Thank you in advance for your assistance. If you have questions concerning this request, plea se do not hesitate to contact Doug Carr, Cala Obenauf, or me at 334/271-7861.

Sincerely,

Timothy S. Owen, Chief Engineering Services Branch

Air Division

TSO/WAB:co

Attachments

1. Source Categories Eligible for BART

2. Emission Units Identified as Potential BART Sources

### 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 capa ble 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 proc essing plants

26. Charcoal production facilities