Attachment H2 

BART Facility Letters 
Date 

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 evaluate certain older, large emission units and 

determine whether these units require the installation 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 built 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 visibility-impairing pollutant. The applicable 

pollutants are: ammonia, nitrogen oxides (NOx), particulate matter (PM10), sulfur 

dioxide (SO2) and volatile organic compounds (VOCs). Affected emission 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 stationary sources having 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/tribes are required to set periodic goals for 

improving visibility in the nation’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 SIPs/TIPs” to the EPA in the 2004-2006 time 

period (i.e., no later than one year after the PM2.5 attainment/nonattainment 

designations are made). In their planning SIPs/TIPs, states/tribes must identify all 

BART-eligible sources. 

The current regulatory schedule requires that states/tribes, by December 31, 2008, 

or earlier, submit regional haze SIPs/TIPs to the EPA containing, among other things, 

emission limitations representing BART and compliance schedules for all BARTeligible sources that reasonably may be anticipated 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 decisions 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 source1 consisting of those 

emission units or processes that individually or in aggregate: 

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

• were in existence2 on August 7, 1977, and began operation after August 7, 

1962, and 

• have the potential to emit 250 tons per year or more of any visibilityimpairing pollutant3 [ammonia, nitrogen oxides (NOx), particulate matter 

(PM10), sulfur dioxide (SO2) 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 requirement and we are asking for your assistance with this 

information. Attached to this letter you will 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 facility 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 obtained all necessary preconstruction approvals or 

permits required by Federal, State, or local air pollution 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 contractual 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 threshold. 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 the BART window first be aggregated for comparison to 

the 250-million Btu/hr threshold. For petroleum storage 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 determine 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 request 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, please 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 capable 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 processing plants 

26. Charcoal production facilities