"Air Quality Permit Issuance and Varying Interpretations of BACT in the Flat Glass Industry"
"Air Quality Permit Issuance and Varying Interpretations of BACT in the Flat Glass Industry"
ABSTRACT
During the past several years, six flat glass
manufacturing
facilities have received air quality construction permits under the
Prevention
of Significant Deterioration air quality regulations in the states of
Wisconsin,
Iowa, New York, Kentucky and North Carolina. While production
methods
and emissions were similar, interpretation of the Best Available
Control
Technology (BACT) requirement varied significantly depending on the
state
and the supervising office of the USEPA. Beginning in 1991 with
facilities
in Wisconsin, BACT had required the installation of a spray drier -
electrostatic
precipitator emission control system for the control of PM10 and SO2
emissions,
with no provision to control NOx emissions. Subsequent BACT
determinations by other states no longer required the spray drier -
electrostatic
precipitator system, based on the premise that this equipment was not
cost
effective. These same determinations did require use of the “3R
Process”,
an innovative control method, to reduce NOx emissions by approximately
50%. Litigation over the most recent BACT determination continues
due to a petition filed under 40 CFR Part 70.8 of the Title V operation
permit regulations. Evaluation of this petition by USEPA suggests
the agency does not agree with the cost effectiveness criteria used in
recent state determinations to establish BACT for flat glass
plants.
Consideration of the BACT determination history for flat glass plants
will
assist with future plant design and air pollution control
determinations.