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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

34) II-B-19 

Docket Number: 

A-90-37 

Printed 11/4/2008 10:22:19 AM Sheet 34 of 147 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

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FEB 3 1989 

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OFFICE OF 

AIR ANO RAOIATION 

MEMORANDUM 

SUBJECT: BACT Determination for Davidson Exterior Trim/Textron 

John S. Seitz , Director K^Jy^fC^ 

Stationary Source Compli^a^ce 'Bivi 

Office of Air Quality Planning and Standards 

FROM: 

TO: Winston A. Smith, Director 

Air, Pesticides and Toxics Management Division 

Region IV 

On October 14, 1988 you forwarded to this division a request 

regarding the BACT determination for the Davidson Exterior 

Trim/Textron facility in Georgia. We have coordinated a response 

to your request with the New Source Review Section in AQMD, 

the Chemical Application Section in ESD, and the Air Enforcement 

Division in OECM. The following responses to your questions 

are provided: 

1. Does Davidson Exterior present "unique and convincing" 

arguments which would justify elimination of add-on spray 

booth and/or over controls as BACT? 

While Davidson has supplied data on the control cost, 

cost effectiveness, and percent increase in the cost per 

unit of product, they have not presented an argument as t o 

why the control cost is unreasonable. It also appears tha t 

there are control alternative s available which Davidson has 

not explored (see response to question 2 & 3 below). 

Therefore, we agree tha t Davidson Exterior has failed to 

make a case for rejecting as BACT the add-on controls in 

question. 

2. Are there other fascia plants which have been required to 

instal l both spray booth and oven controls? 

We know of no other fascia plants which have been required 

to instal l both spray booth and oven controls. The General 
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Motors parts plant in Oshawa, Ontario, Canada has recently 

installe d an exhaust air recirculation and VOC control 

(incineration) system on the clear coat portion of the 

fascia spray booths. 

3. Has EPA established spray booth and/or oven controls as BACT 

at fascia painting operations? 

Bake oven exhaust controls have been required in several 

3ACT/IAER permi ts for fascia painting (Subaru-Isuzu, DuPont, 

Saturn, etc.). Spray booth exhaust controls have not been 

required in BACT/LAER permi ts for fascia painting. The 

number of controlled spray booths is growing (e.g.,. automobiles,, 

aerospace, metal parts), and the cost of control is becoming 

lower with experience and the development and demonstration of 

new technologies (e.g. , recirculation, control equipment for 

low VOC concentration exhaust streams). Spray booth exhaust 

controls, therefore, must receive serious consideration in 

current and future permitting of fascia painting operations. 

4. Were the oven controls installed on the fascia operations at 

the Subaru/lsuzu facility , located in Lafayette, Indiana, the 

result of a BACT evaluation or necessitated for some other 

reason? 

The bake oven exhaust controls a t Subaru-Isuzu were part of 

the BACT demonstration. 

5. If the arguments presented by Davidson Exterior do not 

constitut e a "unique and convincing" basis for rejection of 

controls, what would EPA consider to be valid criteri a for 

rejection of the controls? 

Three criteri a which should be asked when reviewing permits 

in which more stringent levels of control have been rejected 

as BACT are discussed below: 

i) If another similar source has adopted certain emission 

controls, why can't this applicant? Where similia r units 

have adopted a particula r level of emission control or 

control technology, the applicant should justify on technical, 

environmental, or economic ground why they cannot also adopt 

that particula r control system or otherwise meet tha t level 

of control. This analysis should focus on the differences 

(if any) between the two sources (e.g. , differences in raw 

material costs or control costs). 
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i i) Why is the economic impact of a level of control 

unreasonable? Where a permit applicant claims that emission 

control costs are unreasonable, the burden of showing why 

the cost are unreasonable is on the applicant. Some 

possible parameters for judging the reasonableness of a 

control level could be the percent of the tota l cost of a 

construction or modification project, cost effectiveness 

($ per ton), or percent cost increase per unit of product. 

Again, other similar sources that have adopted a particula r 

level of control may provide a useful benchmark against which 

to compare the claimed economic impact of emission controls. 

However, control cost data and cost effectiveness calculations 

• likely do not, standing alone, provide a convincing argument 

against adopting a potentia l BACT level. For example, simply 

stating that it is infeasible to meet a particula r cost 

per ton of pollutant controlled is not adequate; the 

reason must be explicity explained to EPA, the permitting 

agency, and the public. The applicant should lock at this 

cost in terms of typical control cost for other sources of 

this pollutant. The costs of control for similar sources 

is addressed in #i above. 

iii ) Based on the reviewer's experience in reviewing control 

cost estimates and cost effectiveness calculations for a 

particula r pollutant and source category, do the cost data 

provided by the applicant seem credible ? In other words, 

ar e the cost estimates within the range of costs you would 

expect to see for tha t particula r type of source or pollutant ? 

If a cost or cost effectiveness estimate strike s you as being 

too high, you should ask the applicant to explain why their 

emission control costs would be higher than those documented 

for a similar source. 

6. Would Headquarter's support a §167 order, issued by Region 

IV, if i t is determined tha t Davidson Exterior has not 

installe d or proposed to instal l BACT? 

Consistent with the July 15, 1988 guidance on procedures to 

follow when EPA finds a Deficient New Source Permit, a deficient 

BACT analysis is cause for expeditious (within 30 days of 

permit receipt) issuance of a §167 order in SIP-approved programs. 

However, the ultiirate decision vfoether to proceed with enforcement 

action in this or any other case depends, in large part, upon 

a ll the specifics of the particula r cases. These include, among 

others : 
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1) The "time and manner i n which EPA has informed th e 

applican t and th e permittin g authorit y of allege d 

defects in the permit, and of the consequences of a 

failur e t o correc t thos e defects. 

2) The amount of time between permit issuanc e and th e 

commencement of enforcement action . 

3) Whether the applican t ha s entere d int o constructio n 

contracts, begun actua l construction , or otherwis e 

acted in relianc e on th e State-issue d permit. 

4) Plus., for SIP approved States, ..the content of the 

Stat e regulation s and relevan t Federa l Registe r 

notices. 

I apologiz e for the delay in providing thi s response . If 

you have any questions, pleas e contac t Gary McCutchen i n AQMD 

(FTS-629-5592) regarding responses #1 & 5, Dave Salman in ESD 

(FTS-629-5417) regarding response s #2-4, and Sall y Farrel l of 

my staff (FTS-382-2875) regarding response #6. 

c c : Wayne Aronson, Region IV 

Mark Armentrout, Region IV 

Gary McCutchen, AQMD 

Sam Duletsky, AQMD 

Jim Berry, ESD 

Dave Salman, ESD 

Judy Katz, OECM 

NSR Contacts, Region I-X 

Greg Foote , OGC