Assessment of Control Technology 

Options for BART-Eligible 

Sources

Steam Electric Boilers, Industrial Boilers, 

Cement Plants and Paper and Pulp Facilities

Prepared by

Northeast States for Coordinated Air Use Management

In Partnership with

The Mid-Atlantic/Northeast Visibility Union

March 2005
ii

Members of Northeast States for Coordinated Air Use Management

Arthur N. Marin, Executive Director

Northeast States for Coordinated Air Use Management

Anne Gobin, Bureau Chief

Connecticut Department of Environmental Protection, Bureau of Air Management

James P. Brooks, Bureau Director

Maine Department of Environmental Protection, Bureau of Air Quality

Barbara Kwetz, Director

Massachusetts Department of Environmental Protection, Bureau of Waste Prevention

Robert Scott, Acting Director

New Hampshire Department of Environmental Services, Air Resources Division

William O’Sullivan, Director

New Jersey Department of Environmental Protection, Office of Air Quality Management

David Shaw, Director

New York Department of Environmental Conservation, Division of Air Recourses

Stephen Majkut, Chief

Rhode Island Department of Environmental Management, Office of Air Resources

Richard A. Valentinetti, Director

Vermont Department of Environmental Conservation, Air Pollution Control Division
iii

Assessment of Control Options for 

BART-Eligible Sources

Steam Electric Boilers, Industrial Boilers, 

Cement Plants and Paper and Pulp Facilities

Prepared by

Northeast States for Coordinated Air Use Management

In Partnership with

The Mid-Atlantic/Northeast Visibility Union

Submitted to the United States Environmental Protection Agency, Region III in partial 

fulfillment of requirements for USEPA grant XA-983799-01-2 to the 

Ozone Transport Commission

March 2005
iv
v

ASSESSMENT OF CONTROL OPTIONS FOR 

BART-ELIGIBLE SOURCES 

STEAM ELECTRIC BOILERS, INDUSTRIAL BOILERS, 

CEMENT PLANTS, AND PAPER AND PULP 

FACILITIES

Project Director 

Gary Kleiman, NESCAUM

Editors

Gary Kleiman, NESCAUM

Praveen Amar, NESCAUM

Principle Contributors

Praveen Amar, NESCAUM

Connie Senior, Reaction Engineering International

Rui Afonso, Energy and Environmental Strategies

Ingrid Ulbrich, NESCAUM
vi

Acknowledgments 

NESCAUM gratefully acknowledges the funding support provided by the United 

States Environmental Protection Agency under USEPA grant XA-983799-01-2 to the

Ozone Transport Commission. 

We also thank Glynn Rountree of the American Forest & Paper Association for 

making us aware of John Pinkerton’s work at NCASI and providing us with Tables V-2 

through V-5.

NESCAUM also thanks the following individuals for providing comments on this 

report: 

Doug Austin, Ozone Transport Commission

Mike Barden, Maine Paper and Pulp Association

John C. Buckley, NRG Energy

Bob Iwanchuck, ENSR on behalf of Dartmouth College

Wendy Jacobs, CT DEP

Roman Kramarchuk, U.S. EPA

Edward L. (Skip) Kropp, Jackson and Kelly on behalf of Midwest Ozone Group

Timothy Porter, Wheelabrator Technologies

Buzz Reynolds, CR Clean Air Technologies 

Luc Robitaille, St. Lawrence Cement

Glynn Rountree, American Forest and Paper Association

Cathy Waxman, KeySpan 
vii

Unit, Species, Acronyms

Acronyms

APCD – Air Pollution Control Device

BACT –Best Available Control Technology

BART – Best Available Retrofit Technology

CAA – Clean Air Act

CAAA – Clean Air Act Amendments

CKD – Cement Kiln Dust

CFBA – Circulating Fluidized-Bed Absorption

CFR – Code of Federal Regulations

DI – Dry Injection

DSI – Dry Sorbent Injection

EGU – Electricity Generating Unit

ESP – ElectroStatic Precipitator

ESFF – Electrostatic Stimulation of Fabric Filtration

FBC – Fluidized Bed Combustion

FF – Fabric Filters (also known as baghouses)

FGD – Flue Gas Desulfurization (also known as scrubbers)

FGR – Flue Gas Recirculation

FOM – Fixed Operating and Maintenance Costs

ICR – Information Collection Request

LAER – Lowest Achievable Emission Rate

LNB – Low NOX Burner

LSFO – Limestone Forced Oxidation

LSC – Low Sulfur Coal (also known as “compliance coal”)

MACT – Maximum Achievable Control Technology

MANE-VU – Mid-Atlantic/Northeast Visibility Union

MC – Mechanical Collector

NCG – Non Condensable Gases

NESCAUM – Northeast States for Coordinated Air Use Management

NSPS – New Source Performance Standard

NSR – New Source Review

OFA – Over Fire Air

PC – Pulverized Coal

PS – Particulate Scrubber

RACT – Reasonably Available Control Technology

RPO – Regional Planning Organization

SIP – State Implementation Plan

SCR – Selective Catalytic Reduction

SDA – Spray Dry Absorption

SNCR – Selective Non-Catalytic Reduction

SOG – Stripper Off Gases

TDF – Tire-Derived Fuel

US EPA – United States Environmental Protection Agency
viii

Chemical Species

EC – elemental carbon

HSO4 – bisulfate 

H2SO4 – sulfuric acid

HNO3 – nitric acid

NOX – oxides of nitrogen ( NO and NO2)

NO – nitric oxide

NO2 – nitrogen dioxide

NO3 – nitrate 

NH3 – ammonia

(NH4)3H(SO4)2 – letovicite

NH4HSO4 – ammonium bisulfate

(NH4)2SO4 – ammonium sulfate

NH4NO3 – ammonium nitrate

OC – organic carbon

PM2.5 – particle matter up to 2.5 μm in size

PM10 – particle matter up to 10?μm in size

PMcoarse – the difference: PM10 – PM2.5

S – sulfur

Se – selenium

SO2 – sulfur dioxide

SO4 – sulfate

VOC – volatile organic carbon

VOM – Variable Operating and Maintenance Costs

Units

Length

m – meter

μm – micrometer (0.000001m; 10-6m)

km – kilometer (1000 x m; 103 m)

Mm – Megameter (1000000 x m; 106 m)

Flow Rate

ACFM – Actual Cubic Feet per Minute

Volume

L – liter

m

3

– cubic meter 

Mass

lb – pound

g – gram

μg – micrograms (0.000001 x g; 10-6 g)

kg – kilograms (1000 x g; 103 g)
ix

Power

W – watt (Joules/sec)

kW – kilowatt (1000 x W; 103 W)

MW – megawatt (1000000 x W; 106 W)

Energy

Btu – British Thermal Unit (= 1055 Joules)

mmBtu – million Btu

MWh – megawatt hour

kWh – kilowatt hour

Concentration

μg/m3 – micrograms per cubic meter 

Visibility

dv – deciview

km – visual range in kilometers

Mm-1– extinction in inverse megameters
x

TABLE OF CONTENTS 

Acknowledgments.......................................................................................................... vi

Unit, Species, Acronyms...............................................................................................vii

Executive Summary ......................................................................................................xii

1. INTRODUCTION................................................................................................1-1

2. STEAM ELECTRIC PLANTS (EGUs)................................................................2-1

2.1. Description of generation process and typical technologies...........................2-1

2.2. Review of BART-Eligible EGUs in the MANE-VU Region .........................2-2

2.3. Available Control Technologies....................................................................2-2

2.3.1. Emission Characteristics of Regional Haze Precursors from Coal 

Combustion..........................................................................................................2-4

2.3.2. Control Technologies used for Coal-fired EGUs ......................................2-5

2.3.3. Emission Control Configurations for Coal-fired Electric Utility Boilers.2-20

2.4. Costs and Availability of Technology.........................................................2-22

2.4.1. Detailed Capital Costs, Operating and Maintenance Costs, and Cost 

Effectiveness......................................................................................................2-22

3. INDUSTRIAL BOILERS.....................................................................................3-1

3.1. Description of Boiler Process........................................................................3-1

3.2. Review of BART-Eligible Industrial Boilers in the MANE-VU Region........3-2

3.3. Available Control Technologies....................................................................3-2

3.3.1. Emission Characteristics of Regional Haze Precursors from Industrial 

Boilers ................................................................................................................3-3

3.3.2. Control Technologies used for Industrial Boilers......................................3-5

3.4. Costs of Technology...................................................................................3-12

3.4.1. NOX Technologies.................................................................................3-12

3.4.2. SO2 Technologies ..................................................................................3-13

3.4.3. PM Technologies...................................................................................3-14

4. PORTLAND CEMENT KILNS ...........................................................................4-1

4.1. Description of Cement-Making Processes.....................................................4-1

4.2. Review of BART-Eligible Cement Kilns in the MANE-VU Region .............4-2

4.3. Available Control Technologies....................................................................4-3

4.3.1. SO2 Controls............................................................................................4-3

4.3.2. NOX Controls...........................................................................................4-7

4.3.3. PM2.5 Controls .......................................................................................4-18

4.3.4. VOC Controls........................................................................................4-20

4.4. Costs and Availability.................................................................................4-20

4.4.1. Sulfur Dioxide Control...........................................................................4-20

4.4.2. Nitrogen Oxides Control........................................................................4-22

4.4.3. PM2.5 Control.........................................................................................4-24

5. KRAFT PULP MILLS .........................................................................................5-1

5.1. Description of pulp and paper processes .......................................................5-1

5.2. Review of BART-Eligible Pulp and Paper facilities in the MANE-VU Region ..

.....................................................................................................................5-2

5.3. Available Control Technologies....................................................................5-2
xi

5.3.1. SO2 Controls............................................................................................5-3

5.3.2. NOX Controls...........................................................................................5-4

5.3.3. PM2.5 Controls .........................................................................................5-5

5.3.4. VOC Controls..........................................................................................5-5

5.4. Costs and availability....................................................................................5-6

6. CONCLUSION....................................................................................................6-1

6.1. EGUs............................................................................................................6-1

6.2. Industrial Boilers..........................................................................................6-2

6.3. Cement Kilns................................................................................................6-2

6.4. Pulp Mills.....................................................................................................6-2
xii

Executive Summary

This report was prepared by the Northeast States for Coordinated Air Use 

Management (NESCAUM) as part of an effort to assist states and tribes as they prepare 

to comply with the Best Available Retrofit Technology Requirements (BART) of the 

Regional Haze Rule. The Haze Rule requires states to determine the most stringent 

technologically feasible system of controls that can reasonably be installed at each 

facility eligible for BART. Criteria that determine whether a specific control technology 

is deemed reasonable include: cost of the controls, other control technology in use at the 

source, energy and other non-air quality environmental impacts, remaining useful life of 

the source as well as the degree of visibility improvement anticipated to result from 

installation of the controls.

This assessment provides information on available technology options, control 

efficiency and typical installation costs for four important BART-eligible source 

categories in the MANE-VU region. These categories include Fossil-fuel fired steam 

electric plants of more than 250 million British thermal units per hour heat input, Fossilfuel boilers of more than 250 million British thermal units per hour heat input, Portland 

cement plants, and Kraft pulp mills. While there are 22 other source categories covered 

by the BART rule (with over 25 BART-Eligible facilities in at least 8 of these source 

categories in the MANE-VU region), we have chosen to focus on these four categories 

which include 75 of the 100 MANE-VU BART-Eligible sources identified at this time. 

[Editors note: The addition of NY and PA non-EGU facilities will change these numbers] 

These source sectors were chosen for a combination of factors including the number of 

facilities, the typical emission level for these type of facilities and the availability of a 

generic control technology characterizations for that sector. States will need to conduct 

an individual analysis for each facility prior to making a BART determination. This 

information is intended to facilitate that process by collecting available technology 

information in a single reference document.

The report finds that significant emissions reductions can be achieved through a 

variety of technologies that target different haze forming pollutants. While wet and dry 

scrubbing techniques may be cost-effective means of removing SO2 at EGUs and large 

industrial boilers, combustion modifications and process changes might be more effective 

at cement plants and paper and pulp facilities. Similarly for NOX control, SCR and 

SNCR are very efficient methods of post-combustion control that can be quite costeffective on large boilers, but combinations of combustion and post-controls as well as 

combustion modification and process changes are also viable means of reducing a 

facility’s total NOX emissions. These approaches need to be carefully considered on a 

unit-by-unit basis, taking into account fuel used (coal, natural gas, oil, wood, etc.) and 

capacity or use factors, to ensure that product quality and pollutant co-control issues are 

handled appropriately. Particulate controls include a variety of technologies, but 

electrostatic precipitators and fabric-filters (or baghouses) are viable options in different 

configurations for EGUs, industrial boilers and cement plants. Paper and pulp facilities 

may also consider demister pads, packed tower technologies and Venturi scrubbers.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 1-1

1-1

1. INTRODUCTION 

Under the U.S. Environmental Protection Agency’s (USEPA) 1999 “regional 

haze rule” [64 Fed. Reg. 35714 (July 1, 1999)], certain emission sources that “may 

reasonably be anticipated to cause or contribute” to visibility impairment in downwind 

Class I areas are required to install Best Available Retrofit Technology (BART).1 These 

requirements are intended to reduce emissions specifically from large sources that, due to 

age, were exempted from other control requirements of the Clean Air Act (CAA).

BART requirements pertain to 26 specified major point source categories, 

including power plants, industrial boilers, paper and pulp plants, cement kilns and other 

large stationary sources. To be considered BART-eligible, sources from these specified 

categories must have the potential to emit at least 250 tons per year of any haze forming 

pollutant and must have commenced operation or come into existence in the fifteen year 

period prior to August 7, 1977 (the date of passage of the 1977 Clean Air Act 

Amendments (CAAA), which first required new source performance standards). 

Because of the regional focus of the 1999 haze rule, it is likely that BART 

requirements will be applied to a much larger number of sources across a broader 

geographic region than has been the case historically (i.e. through reasonably attributable 

visibility impairment requirements in the 1980 haze regulations). In addition, USEPA 

has for the first time introduced the possibility that source-by-source, command and 

control type BART implementation may be replaced by more flexible, market-based 

approaches, provided such alternatives can be shown to achieve greater progress toward 

visibility objectives than the standard BART approach.

In developing future haze state implementation plans (SIPs), states and tribes will 

need to include an inventory of emissions from potentially BART-eligible facilities in 

their jurisdictions and specify the timetable and stringency of controls to be applied at 

those sources. In determining what level of control represents BART, states must address 

the following considerations for each eligible source or group of eligible sources:

• Compliance costs,

• Energy and non-air quality environmental impacts,

• Any existing pollution control technology in use at the source,

• The remaining useful life of the source, and 

• The degree of visibility improvement that may reasonably be anticipated 

to result from the imposition of BART.

In many respects, the strength of the BART program is dependent upon the 

interpretation of these factors and in January 2001 USEPA proposed guidelines for the 

interpretation and implementation of Best Available Retrofit Technology (BART) 

requirements, including these factors. While no explicit threshold was established for 

 

1

 There are seven designated Class I areas in the Northeast and Mid-Atlantic States. They include Acadia 

National Park and Moosehorn Wilderness Area in Maine; Roosevelt-Campobello International Park in New 

Brunswick and Maine; the Lye Brook Wilderness Area in Vermont; the Great Gulf and Presidential RangeDry River Wilderness Areas in New Hampshire; and the Brigantine Wilderness Area in New Jersey.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 1-2

1-2

any of these factors, the publication of the BART guidelines as a proposed rule in the 

Federal Register [66 Fed. Reg. 38108 (July 20, 2001)] initiated a formal rulemaking 

process to clarify BART requirements specifically. 

BART is the primary mechanism identified for regulating haze-forming pollutants 

from stationary sources for the first implementation period under the Haze Rule and the 

final BART regulations, anticipated to be published on April 15, 2005, gives urgency to 

understanding the implications of the final BART guidelines with respect to state 

planning efforts. Depending on a host of factors, BART may be the primary component 

of state haze plans or may be eliminated as a potential mechanism for state compliance.2 

Amid such uncertainty, states must continue to plan for the implementation of BART. 

To assist MANE-VU states and tribes with BART implementation efforts, MANE-VU 

has developed a list of BART-eligible sources in the region (NESCAUM, 2001; 

NESCAUM, 2003).3 The preliminary list developed in these documents has been 

refined by state permitting staff to verify identifications and determine eligibility for 

those sources for which incomplete information was available. The final, state-approved 

(i.e. each state has approved the list of sources within that state) list is available here as 

Appendix A. It should be noted that the review of the facilities for BART eligibility was 

performed prior to the release of the draft BART rule in 2004. Determinations were 

based upon the guidance provided in EPA draft rule released in 2001. It is anticipated 

that EPA will release a final BART rule in April 2005 and at that time final BARTeligibility determinations will be made. It is likely that there will be changes to the 

BART list based upon that final rule.

Once deemed BART-eligible, each source will undergo a BART engineering review to 

determine what system of controls constitutes BART for each facility. This review will 

examine impacts for all the BART pollutants. For example, if a facility triggeres BART 

because it has VOC emissions over 250 tons per year for date-eligible units, the facility 

will also have to examine the impacts of emissions of NOX, SO2, PM10 and ammonia, 

even if emissions of these pollutants are less than 250 tons per year. 

In addition, this review must take into account the statutory factors cited earlier including 

remaining useful life of a source and controls already in place at a source. After review 

of these criteria and control options, the level of required control will be established. It is 

anticipated that the final rule will also address the specific aspects relating to the 

completion of a BART engineering analysis. 

 

2

 A number of factors in the pending BART regulation may affect the strength of the program. Among 

these are (1) a final decision on whether USEPA’s Clean Air Interstate Rule (CAIR) could serve as BART 

for affected sources in states that choose this option, (2) final rules for how states may institute a source-bysource exemption test, (3) a decision on whether to aggregate emissions from multiple date-eligible boilers 

at a facility when comparing to the 250 ton/year emission threshold. An additional factor to consider is a 

provision contained in Senate Resolution 485 (the Clear Skies Act of 2003 which is expected to be reintroduced early in the 109th congress), which would act in place of the BART requirements of the regional 

haze rule.

3

 NESCAUM does not believe that there are any BART-eligible sources in the State of Vermont or any of 

the member Tribes in MANE-VU and thus we have not developed lists for these jurisdictions. In addition, 

Pennsylvania and the District of Columbia have developed BART-Eligible source lists following their own 

methodology and the identified sources are contained in the final list in Appendix A.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 1-3

1-3

As a next step in coordinating BART determinations for MANE-VU states and 

tribes, we present here (in Chapters 3 through 6 of this report) a preliminary assessment 

of available control technology options for states to consider as they undertake the 

specific BART determinations for each of the eligible facilities in four major source 

categories including EGUs, industrial boilers, cement plants and paper and pulp facilities. 

These four categories cover 76 of the 101 BART-eligible facilities in MANE-VU. 

While a facility specific review will need to be undertaken for each BARTeligibility (either to determine BART controls to be installed, or to determine the 

magnitude of emissions reductions that must be considered in a BART trading program), 

the information provided here will give states and tribes a foundation for conducting 

these reviews.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 2-1

2-1

2. STEAM ELECTRIC PLANTS (EGUs)

Electricity Generating Units or EGUs are the largest source category among the twenty -

six source categories covered by the Regional Haze Rule both in terms of total visibility 

impairing emissions and in terms of number of facilities. Estimates of national emissions for 

criteria air pollutants prepared by the USEPA show that electric utility power plants that burn 

coal are significant sources of sulfur dioxide (SO2), nitrogen oxides (NOX), and particulate 

matter (PM) (USEPA, 2000). Electric utility power plants are the nation’s largest source of SO2

emissions, contributing approximately 68 percent of the estimated total national SO2 emissions 

in 1998 (most recent year for which national estimates are available). Over 90 percent of these 

SO2 emissions are coal-fired electric utility boilers. Electric utilities contributed 25 percent of 

total national NOX emissions in 1998. Again coal combustion is the predominant source of NOX

emissions from the electric utilities (almost 90 percent of the estimated NOX emissions). Coalfired electric utility power plants also are one of the largest industrial sources of PM emissions. 

In general, the high combustion efficiencies achieved by coal-fired electric utility boilers result 

in low emissions of CO and volatile organic compounds (a precursor for the photochemical 

formation of ozone in the atmosphere). Although the emphasis of this Chapter is on coal-fired 

utility boilers, many technologies described here are also applicable to gas and oil-fired units (for 

example, SCR and SNCR technologies are equally applicable to coal and natural gas/oil units, 

generally at much lower capital and operating costs; same is true for wet scrubbers for SO2 

control and ESPs or baghouses for PM control for oil units).

All coal-fired electric utility power plants in the United States use control devices to 

reduce PM emissions. Many coal-fired electric utility boilers also are required to use controls for 

SO2 and NOX emissions depending on site-specific factors such as the properties of the coal 

burned, when the power plant was built, and the area where the power plant is located. Though 

there are other major stationary source sectors (for example, cement plants, paper and pulp 

plants, large industrial boilers, combustion turbines, iron and steel industry), coal-fired boilers 

are by far the largest contributor of all of these three precursors of regional haze. 

2.1. Description of generation process and typical technologies

The USEPA ICR (Information Collection Request) of 1999 (the most recent and quite 

detailed survey of coal-fired EGUs in the U.S. completed in connection with USEPA efforts to 

develop MACT regulations for mercury from EGUs) indicates that there were about 1,140 coalfired units in the U.S. (with a maximum capacity to generate in excess of 300,000 MW of 

power). This USEPA ICR data indicated that coal-fired steam electric generating units in the 

U.S. burned 786 million tons of coal of which, approximately 52 percent was bituminous and 37 

percent was sub-bituminous. Other fuels included lignite, anthracite coal, reclaimed waste coal, 

mixtures of coal and petroleum coke (pet-coke), and mixtures of coal and tire-derived fuel 

(TDF). Pulverized coal-fired (PC) boilers represent approximately 86 percent of the total 

number and 90 percent of total utility boiler capacity. Based on capacity, other types of boilers 

include cyclone-fired boilers (7.6 percent), fluidized-bed combustors (1.3 percent), and stokerfired boilers (1.0 percent).
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 2-2

2-2

2.2. Review of BART-Eligible EGUs in the MANE-VU Region

There are 53 BART-Eligible EGUs in the MANE-VU region. Table II-1 contains a 

summary list of these sources by state. A complete list is presented in Appendix A. Both lists 

are based on a previous NESCAUM report (2001) and follow-up review by state permitting 

authorities. 4 An estimated 1.2 million tons of SO2 and three-hundred thousand tons of NOX are 

emitted by these facilities and given the available control technology described in subsequent 

sections of this chapter, BART-Eligible EGUs represent a significant emissions reduction 

potential for consideration in the regional haze planning process.

Table II-1 BART-Eligible EGUs in the MANE-VU region. (NESCAUM, 2001).

State Total 

Number of 

BART EGUs

Total SO2

Emissions 

(1999 NEI)

Total NOX

Emissions 

(1999 NEI)

Connecticut 5 30,787 8,217

Delaware 3 10,490 4,465 

District of Columbia 1 1,432 447

Maryland 6 177,678 63,767

Massachusetts 7 97,854 27,350

Maine 1 6,406 879

New Hampshire 2 37,834 7,043

New Jersey 1 17,260 7,891

New York 13 73,164 31,392

Pennsylvania 14 744,165 151,992

Penobscot Tribe 0 N/A N/A

Rhode Island 0 N/A N/A

St. Regis Mohawk Tribe 0 N/A N/A

Vermont 0 N/A N/A

Region Total 53 1,197,070 303,443

2.3. Available Control Technologies

A variety of emission control technologies are employed to meet requirements for SO2, 

NOX, and primary PM emissions; the three major precursors of observed regional haze in the 

atmosphere (SO2 and NOX are mostly converted to ammonium sulfate and ammonium nitrate 

 

4

 NESCAUM does not believe that there are any BART-eligible sources in the State of Vermont or any of the 

member Tribes in MANE-VU and thus we have not developed lists for these jurisdictions. In addition, 

Pennsylvania and the District of Columbia have developed BART-Eligible source lists following their own 

methodology and any identified sources are contained here and in the final list in Appendix A.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 2-3

2-3

that are formed by the reactions of precursor gases with ammonia in the environment that is 

emitted mostly from agricultural and cattle related activities). Most utilities control SO2 by the 

use of either low-sulfur coal (generally less than 1 percent sulfur by weight) or by wet or dry 

scrubbing (known as flue gas desulphurization, or FGD). Generally, NOX emissions are 

controlled via combustion modification and, more recently, by more advanced post-combustion 

controls, which are required by the 1990 Clean Air Act and state regulations ( “NOX Transport 

SIP Call” and the Title IV of the 1990 CAAA are two major examples). Compared to these two 

precursors, PM emissions are almost universally controlled in the U.S. (almost 100% of units 

have either electrostatic precipitators (ESPs) or fabric filters (FF) (popularly known as “bag 

houses”). Based on the 1999 USEPA’s ICR (Information Collection Request) data, for postcombustion controls, 77.4 percent of the units have PM control only, 18.6 percent have both PM 

and SO2 controls, 2.5 percent have PM and NOX controls, and 1.3 percent have all three postcombustion control devices.

The different types of post-combustion control devices are briefly described below with 

detailed descriptions given later in this section:

SO2 post-combustion control technologies are systems that are classified as wet flue gas 

desulfurization (FGD) scrubbers, semi-dry scrubbers, or dry injection. Wet FGD scrubber 

controls remove SO2 by dissolving it in a solution. A PM control device is always located 

upstream of a wet scrubber. PM devices that may be used with wet FGD scrubbers include a 

Particulate Scrubber (PS), Cold Side (CS)-ESP, Hot Side (HS)-ESP, or a fabric filter (FF) or a 

baghouse. Semi-dry scrubbers include spray dryer absorption (SDA). Dry injection involves 

injecting dry powdered lime or other suitable sorbent directly into the flue gas. A PM control 

device (ESP or FF) is always installed downstream of a semi-dry scrubber or dry injection point 

to remove the sorbent from the flue gas.

NOX post-combustion control technologies include selective non-catalytic reduction 

(SNCR) and selective catalytic reduction (SCR) processes. With both of these methods, a 

reducing agent such as ammonia or urea is injected into the duct to reduce NOX to N2. SCR 

operates at lower temperatures than SNCR and is much more effective at reducing NOX, but it 

has higher capital costs for installation.

Particulate matter (PM) control technologies include electrostatic precipitators (ESPs), 

fabric filters (FFs) (also called “baghouses”), and particulate scrubbers (PS). ESPs and FFs may 

be classified as either cold-side (CS) devices [installed upstream of the air heater where flue gas 

temperatures range from 284 to 320 oF (140 to 160 °C)] or hot-side [installed downstream of the 

air heater and operate at temperatures ranging from 662 to 842 oF (350 to 450 °C)].

For PM controls, ESPs are used on 84 percent of the existing electric utility coal-fired 

boiler units, and fabric filters or baghouses are used on 14 percent of the utility units. Postcombustion SO2 controls are less common. Wet flue gas desulfurization (FGD) systems are used 

on 15.1 percent of the units; and, dry scrubbers, predominantly spray dryer absorbers (SDA), are 

used on 4.6 percent of units that were surveyed. However, since it is generally more cost 

effective to install scrubbers on big units, the 20 percent of the units represent about 30% of the 

installed U.S. capacity. In response to the “Section 110 Transport SIP call” and the 

implementation of the Federal Title IV acid rain program, the application of post-combustion 

NOX controls is becoming more prevalent. For example, based on the current status of electric 

utility industry, it appears that one third of the coal-based capacity (about 100,000 MW out of the 
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 2-4

2-4

installed base of about 300,000 MW) has been or is currently being retrofitted with the advanced 

SCR technology .

2.3.1. Emission Characteristics of Regional Haze Precursors from Coal 

Combustion

Sulfur Dioxide 

SO2 emissions, mostly from the combustion of fossil fuels and by metallurgical 

processes, are the result of oxidation of sulfur in the coal during the combustion process. Coal 

deposits contain sulfur in amounts ranging from trace quantities to as high as eight percent or 

more. Most of this sulfur is present as either pyritic sulfur (sulfur combined with iron in the 

form of a mineral that occurs in the coal deposit) or organic sulfur (sulfur combined directly in 

the coal structure). During combustion, sulfur compounds in coal are oxidized to gaseous SO2 or 

SO3. When firing bituminous coal, almost all of the sulfur present in coal is emitted as gaseous 

sulfur oxides (on average, ninety eight percent). The more alkaline nature of ash in some 

subbituminous coals causes a portion of the sulfur in the coal to react to form various sulfate 

salts; these salts are emitted as fly ash or retained in the boiler bottom ash. Generally, the 

percentage of sulfur in the as-fired coal that is converted to sulfur oxides during combustion does 

not vary with the utility boiler design or operation. (USEPA, 1982; Buonicore and Davis, 1992).

Nitrogen Oxides 

The NOX formed during coal combustion by oxidation of molecular nitrogen (N2) in the 

combustion air is referred to as “thermal NOX.” The oxidation reactions converting N2 to NO 

and NO2 become very rapid once gas temperatures rise above 1,700°C (3,100°F). Formation of 

thermal NOX in a coal-fired electric utility boiler is dependent on two conditions occurring 

simultaneously in the combustion zone: high temperature and an excess of combustion air. A 

boiler design feature or operating practice that increases the gas temperature above 1,700 °C, the 

gas residence time at these temperatures and the quantity of excess combustion air affects 

thermal NOX formation. The formation of NOX by oxidation of nitrogen compounds contained 

in the coal is referred to as “fuel NOX.” The nitrogen content in most coals ranges from 

approximately 0.5 to 2 percent. The amount of nitrogen available in the coal is relatively small 

compared with the amount of nitrogen available in the combustion air. However, depending on 

the combustion conditions, significant quantities of fuel NOX can be formed during coal 

combustion. (USEPA, 1991; Buonicore and Davis, 1992).

Both NO and NO2 are formed during coal combustion by oxidation of molecular nitrogen 

that is present in the combustion air or nitrogen compounds contained in the coal. Overall, total 

NOX formed during combustion is composed predominantly of NO mixed with small quantities 

of NO2 (typically less than 10 percent of the total NOX formed). However, when NO is formed 

during coal combustion, the NO is oxidized to NO2 and is emitted to the atmosphere. 
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Particulate Matter

Primary PM emissions from coal-fired electric utility boilers consist primarily of fly ash. 

Ash is the unburned carbon char and the mineral portion of combusted coal. The amount of ash 

in the coal, which ultimately exits the boiler unit as fly ash, is a complex function of the coal 

properties, furnace-firing configuration, and boiler operation. For the dry-bottom, pulverizedcoal-fired boilers, approximately 80 percent of the total ash in the as-fired coal exits the boiler as 

fly ash. Wet-bottom, pulverized-coal-fired boilers emit significantly less fly ash: on the order of 

50 percent of the total ash exits the boiler as fly ash. In a cyclone furnace boiler, most of the ash 

is retained as liquid slag; thus, the quantity of fly ash exiting the boiler is typically 20 to 30 

percent of the total ash. However, the high operating temperatures unique to these designs may 

also promote ash vaporization and larger fractions of submicron fly ash compared to dry bottom 

designs. Fluidized-bed combustors emit high levels of fly ash since the coal is fired in 

suspension and the ash is present in dry form. Spreader-stoker-fired boilers can also emit high 

levels of fly ash. However, overfeed and underfeed stokers emit less fly ash than spreader 

stokers, since combustion takes place in a relatively quiescent fuel bed.

In addition to the fly ash, PM emissions from coal-fired EGUs result from reactions of 

the SO2 and NOX compounds as well as unburned carbon particles carried in the flue gas from 

the boiler. The SO2 and NOX compounds are initially in the vapor phase following coal 

combustion in the furnace chamber but can partially chemically transform in the stack, or near 

plume, to form fine PM in the form of nitrates, sulfur trioxide (SO3), and sulfates. Firing 

configuration and boiler operation can affect the fraction of carbon (from unburned coal) 

contained in the fly ash. In general, the high combustion efficiencies achieved by pulverizedcoal-fired boilers and cyclone-fired boilers result in relatively small amounts of unburned carbon 

particles in the exiting combustion gases. Those pulverized-coal-fired electric utility boilers that 

use special burners for NOX control tend to burn coal less completely; consequently, these 

furnaces tend to emit a higher fraction of unburned carbon in the combustion gases exiting the 

furnace.

Another potential source of PM from coal-fired EGUs can be found in the flue gas and 

the use of a dry sorbent-based control technology. Solid sorbent particles are injected into the 

combustion gases to react with the air pollutants and then recaptured by a downstream control 

device. Sorbent particles that escape capture by the control device are emitted as PM to the 

atmosphere. (USEPA, 1982; Buonicore and Davis, 1992).

2.3.2. Control Technologies used for Coal-fired EGUs

In addition to BART requirements, all EGUs in the U.S. must comply with applicable 

federal and state standards and programs that specifically regulate criteria air emissions from 

coal-fired electric utility boilers. The federal regulations and programs include New Source 

Performance Standards (NSPS), the CAA Title IV Acid Rain Program, the 1997 “Transport NOX

SIP call,” and the CAA Title V Operating Permits Program. The USEPA has delegated authority 

to individual state and local agencies for implementing many of these regulatory requirements 
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Additionally, some of the states in the Northeast, including Connecticut, Massachusetts, New 

Hampshire, New Jersey, and New York, have recently implemented new regulations or 

legislation that are more stringent than the federal requirements. Electric utility companies use 

one or a combination of the following three control strategies to comply with the specific set of 

requirements applicable to a given coal-fired boiler.

Pre-combustion Controls. Control measures in which fuel substitutions are made or fuel 

pre-processing is performed to reduce pollutant formation in the combustion unit.

Combustion Controls. Control measures in which operating and equipment 

modifications are made to reduce the amount of pollutants formed during the combustion 

process; or in which a material is introduced into the combustion unit along with the fuel 

to capture the pollutants formed before the combustion gases exit the unit.

Post-combustion Controls: Control measures in which one or more air pollution control 

devices are used at a point downstream of the furnace combustion zone to remove the 

pollutants from the post-combustion gases.

Table II-2 shows the national distribution of emissions control strategies for SO2, NOX, 

and PM used for coal-fired electric utility boilers in 1999 as reported in the Part II USEPA ICR 

data (USEPA, 2001). Approximately two-thirds of the total coal-fired electric utility boilers 

use either a low-sulfur fuel or a post-combustion technology (a wet or a dry scrubber) to control 

SO2 emissions. The methods used for controlling SO2 emissions from EGUs are discussed first. 

All coal-fired electric utility boilers in the United States are controlled for PM emissions by 

using some type of post-combustion controls. These particulate emission control types are 

discussed next. Although approximately two-thirds of the coal-fired electric utility boilers are 

controlled for NOX emissions, these units are not necessarily the same units controlled for SO2

emissions. The predominant strategy for controlling NOX emissions is to use combustion 

controls. Later in this section, the application of NOX emission controls to coal-fired electric 

utility boilers is described in detail.
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Table II-2 Criteria air pollutant emission control strategies as applied to coal-fired electric 

utility boilers in the United States for the year 1999 (USEPA, 2001).

Percentage of Coal-fired Electric Utility Boilers Using Control 

Strategy as Reported in Phase II USEPA ICR Data a,b

Criteria

Air Pollutant

Meet 

Applicable 

Standards 

Without 

Additional

Controls

Precombustion

Controls

Combustion

Controls

Postcombustion

Controls

Particulate

Matter

0 % 0 % 0 % 100 %

Sulfur

Dioxide 37 % 40 % 3 % 20 %

Nitrogen

Oxides 40 % 0 % 57 % 3 %

 (a) Approximately 1.5 % of the boilers use a combination of pre-combustion and post-combustion SO2

controls.

 (b) Approximately 1% of the boilers using post-combustion NOX controls also use some type of combustion 

controls.

SO2 Emission Controls 

Sulfur dioxide emissions from most coal-fired electric utility boilers are controlled using 

either of two basic approaches. The first approach is to use pre-combustion measures, namely, 

firing coal that contains lower amounts of sulfur. The low-sulfur coal may be naturally occurring 

or the result of coal cleaning. The other approach is to remove the sulfur compounds from the 

flue gas before the gas is discharged to the atmosphere. These post-combustion processes are 

collectively called “flue gas desulfurization” or “FGD” systems. All FGD systems can be further 

classified as wet or dry flue gas scrubbing systems. The SO2 control approaches include a 

number of different technology subcategories that are now commercially used in the United 

States, Europe, or Pacific Rim countries.

Table II-3 presents the 1999 nationwide distribution of SO2 controls used for coal-fired 

electric utility boilers by total number of units and by percentage of nationwide electricity 

generating capacity. For approximately one-third of the boilers, no SO2 controls were reported in 

the Part II USEPA ICR data. The other two-thirds of the units reported using some type of 

control to meet the SO2 emission standards applicable to the unit. Pre-combustion control by 

burning a low-sulfur content coal was reported for approximately 40 percent of the boilers. Postcombustion control devices for SO2 removal are used for approximately 20 percent (representing 

30% of the capacity in megawatts) of the boilers. Wet FGD systems are the most commonly used 

post-combustion control technique. The newer technologies of spray dryer systems or dry 
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injection are limited in their application to existing units. The remaining 3 percent of the boilers 

use fluidized-bed combustion (FBC) with limestone.

Low-sulfur Coal

Coal with low sulfur content can be burned and meet applicable SO2 emission standards 

without the use of additional controls is sometimes referred to as “compliance coal.” Coals 

naturally low in sulfur content may be mined directly from the ground. Alternatively, the sulfur 

content of coal fired in the boiler may be lowered first by cleaning the coal or blending coals 

obtained from several sources. However, burning low-sulfur coal may not be a technically 

feasible or economically practical SO2 control alternative for all boilers. In some cases, a coal 

with the required sulfur content to meet the applicable standard may not be available or cannot 

be fired satisfactorily in a given boiler unit design. Even if such a coal is available, use of the 

low-sulfur coal that must be transported long distances from the mine may not be costcompetitive with burning higher sulfur coal supplied by closer mines and using a postcombustion control device.
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Table II-3 Nationwide distribution of existing SO2 emissions controls used for coal-fired 

electric utility boilers for the year 1999 as reported in the Part II USEPA ICR data 

(USEPA, 2001).

Phase II USEPA ICR Data

SO2 Control Type Abbreviation

Code

Number

of Boilers

Percent of

Nationwide

Total 

Number of 

Units

Percent of

Nationwide

Electricity 

Generating

Capacity

Burn low-sulfur coal

(“compliance coal”)

LSC 455 39.9 % 38.2 %

Wet FGD system FGD 173 (a) 15.2 % 23.8 %

Spray dryer system SDA 52 (b) 4.6% 3.4 %

Fluidized-bed coal 

combustion with limestone FBC 37 (a,c) 3.2% 1.1 %

Dry injection DI 2 0.2 % < 0.1 %

No controls reported (d) 421 36.9 % 33.5 %

Nationwide Total 1,140 (e) 100 % 100 %

(a) Includes one FBC boiler unit using a wet FGD system.

(b) Includes three FBC boilers using spray dryer systems.

(c) FBC boilers using no downstream post-combustion SO2 controls.

(d) Entry in ICR response indicated none or was left blank.

(e) Does not include the three IGCC units.
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Various coal cleaning processes may be used to reduce the sulfur content of the coal. A 

significant portion of the pyritic sulfur minerals mixed with the mined coal can usually be 

removed by physical gravity separation or surface property (flotation) methods. However, 

physical coal cleaning methods are not effective for removing the organic sulfur bound in coal. 

Another method of reducing the overall sulfur content of the coal burned in a given boiler unit is 

to blend coals with different sulfur contents to meet a desired or target sulfur level.

Wet FGD Systems

The SO2 in flue gas can be removed by reacting the sulfur compounds with a solution of 

water and an alkaline chemical to form insoluble salts that are removed in the scrubber effluent. 

These processes are called “wet FGD systems” in this report. Most wet FGD systems for control 

of SO2 emissions from coal-fired electric utility boilers are based on using either limestone or 

lime as the alkaline source. At some of these facilities, fly ash is mixed with the limestone or 

lime. Several other scrubber system designs (e.g., sodium carbonate, magnesium oxide, dual 

alkali) are also used by a small percentage of the total number of boilers.

The basic wet limestone scrubbing process is simple and is the type most widely used for 

control of SO2 emissions from coal-fired electric utility boilers. Limestone sorbent is 

inexpensive and generally available throughout the United States. In a wet limestone scrubber, 

the flue gas containing SO2 is brought into contact with limestone/water slurry. The SO2 is 

absorbed into the slurry and reacts with limestone to form an insoluble sludge. The sludge, 

mostly calcium sulfite hemihydrate and gypsum, is disposed of in a pond specifically constructed 

for the purpose or is recovered as a salable byproduct.

The wet lime scrubber operates in a similar manner to the wet limestone scrubber. In a 

wet lime scrubber, flue gas containing SO2 is contacted with hydrated lime/water slurry; the SO2

is absorbed into the slurry and reacts with hydrated lime to form an insoluble sludge. The 

hydrated lime provides greater alkalinity (higher pH) and reactivity than limestone. However, 

lime-scrubbing processes require appropriate disposal of large quantities of waste sludge.

The SO2 removal efficiencies of existing wet limestone scrubbers range from 31 to 97 

percent, with an average of 78 percent. The SO2 removal efficiencies of existing wet lime 

scrubbers range from 30 to 95 percent. For both types of wet scrubbers, operating parameters 

affecting SO2 removal efficiency include liquid-to-gas ratio, pH of the scrubbing medium, and 

the ratio of calcium sorbent to SO2. Periodic maintenance is needed because of scaling, erosion, 

and plugging problems. Recent advancements include the use of additives or design changes to 

promote SO2 absorption or to reduce scaling and precipitation problems.

Spray Dryer Absorber

A spray dryer absorber (sometimes referred to as wet-dry or semi-dry scrubbers) operates 

by the same principle as wet lime scrubbing, except that the flue gas is contacted with a fine mist 

of lime slurry instead of a bulk liquid (as in wet scrubbing). For the spray dryer absorber 

process, the combustion gas containing SO2 is contacted with fine spray droplets of hydrated 

lime slurry in a spray dryer vessel. This vessel is located downstream of the air heater outlet 

where the gas temperatures are in the range of 120 to 180 °C (250 to 350 °F). The SO2 is 

absorbed in the slurry and reacts with the hydrated lime reagent to form solid calcium sulfite and 

calcium sulfate as in a wet lime scrubber. The water is evaporated by the hot flue gas and forms 

dry, solid particles containing the reacted sulfur. These particles are entrained in the flue gas, 
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along with fly ash, and are collected in a PM collection device. Most of the SO2 removal occurs 

in the spray dryer vessel itself, although some additional SO2 capture has also been observed in 

downstream particulate collection devices, especially fabric filters. This process produces dry 

reaction waste products for easy disposal.

The primary operating parameters affecting SO2 removal are the calcium-reagent-tosulfur stoichiometric ratio and the approach to saturation in the spray dryer. To increase overall 

sorbent use, the solids collected in the spray dryer and the PM collection device may be recycled. 

The SO2 removal efficiencies of existing lime spray dryer systems range from 60 to 95 percent.

Dry Injection

For the dry injection process, dry powdered lime (or another suitable sorbent) is directly 

injected into the ductwork upstream of a PM control device. Some systems use spray 

humidification followed by dry injection. This dry process eliminates the slurry production and 

handling equipment required for wet scrubbers and spray dryers, and produces dry reaction waste 

products for easier disposal. The SO2 is adsorbed and reacts with the powdered sorbent. The dry 

solids are entrained in the combustion gas stream, along with fly ash, and collected by the PM 

control device. The SO2 removal efficiencies of existing dry injection systems range from 40 to 

60 percent.

Circulating Fluidized-bed Absorber

In the circulating fluidized-bed absorber (CFBA), the flue gas flows upward through a 

bed of sorbent particles to produce a fluid-like condition in the bed. This condition is obtained 

by adjusting gas flow rate sufficiently to support the particles, but not carry them out of the 

system. Characteristics of the bed are high heat and mass transfer, because of high mixing rates, 

and particle-to-gas contact. These conditions allow the CFBA’s bed of sorbent particles to 

remove a sorbate from the gas stream with high effectiveness. In a CFBA, material is withdrawn 

from the bed for treatment (such as desorption) then re-injected into the bed. The SO2 removal 

efficiencies for CFBA technologies range from 80 to 98 percent, providing a very effective 

means of control.

NOX Emission Controls 

Control techniques used to reduce NOX formation include combustion and postcombustion control measures. Combustion measures consist of operating and equipment 

modifications that reduce the peak temperature and excess air in the furnace. Post-combustion 

control involves converting the NOX in the flue gas to molecular nitrogen and water using either 

a process that requires a catalyst (selective catalytic reduction) or a process that does not use a 

catalyst (selective noncatalytic reduction).

Table II-4 presents the 1999 nationwide distribution of NOX controls used for coal-fired 

electric utility boilers by total number of units and by percentage of nationwide electricity 

generating capacity. Approximately one-third of the boilers do not use additional NOX controls. 

The other two-thirds of the units use additional controls to meet the applicable NOX standards. 

The predominant control NOX strategy is to use one or more combustion control techniques. 

Post-combustion NOX reduction technologies (both catalytic and noncatalytic) accounted for 
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only a small percentage of the NOX emission controls used in 1999 (approximately three percent 

of the total units). However, a number of electric utilities have recently retrofitted are currently 

actively retrofitting a large number of units with advanced SCR technology to meet the 

requirements of the federal Title IV acid rain program or the Section 110 Transport SIP call.

Combustion Controls

A variety of combustion control practices can be used including low-NOX burners 

(LNBs), overfire air, off-stoichiometric firing, selective or biased burner firing, reburning, and 

burners-out-of-service. Control of NOX also can be achieved through staged combustion (also 

called air staging). With staged combustion, the primary combustion zone is fired with most of 

the air needed for complete combustion of the coal. The remaining air is introduced into the 

products of the partial combustion in a secondary combustion zone. Air staging lowers the peak 

flame temperature, thereby reducing thermal NOX, and lowering the production of fuel NOX by 

reducing the oxygen available for combination with the fuel nitrogen. Staged combustion may 

be achieved through methods that require modifying equipment or operating conditions so that a 

fuel-rich condition exists near the burners (e.g., using specially designed low- NOX burners, 

selectively removing burners from service, or diverting a portion of the combustion air). In 

cyclone boilers and some other wet bottom designs, combustion occurs with a molten ash layer 

and the combustion gases flow to the main furnace; this design precludes the use of low NOX

burners and air staging. Low-NOX burners may be used to lower NOX emissions by about 25 to 

55 percent. Use of overfire air (OFA) as a single NOX control technique reduces NOX by 15 to 

50 percent. When OFA is combined with low- NOX burners, reductions of up to 60 percent may 

result. The actual NOX reduction achieved with a given combustion control technique may vary 

from boiler to boiler.
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Table II-4 Nationwide distribution of existing NOX emissions controls used for coal-fired 

electric utility boilers for the year 1999 as reported in the Part II USEPA ICR data 

(USEPA, 2001).

Phase II USEPA ICR Data

NOX Control Type Abbreviation

Code Nationwide

Number

of 

Boilers

Nationwide

Percentage

 of

Boilers

Percent of

Nationwide

Electricity 

Generating

Capacity

Combustion controls -

low- NOX burners CC-LNB 404 35.4 % 43.0 %

Combustion controls -

low- NOX burners + 

overfire air

CC-LNB/OFA 84 7.4 % 10.4 %

Combustion controls -

overfire air CC-OFA 79 6.9 % 10.6 %

Other combustion 

controls (a) CC 83 7.3 % 5.6 %

Selective noncatalytic 

reduction SNCR 32 2.8 % 0.6 %

Selective catalytic 

reduction SCR 6 0.5 % 1.3 %

No controls reported (b) 452 39.7% 28.5 %

Nationwide Total 1,140 (c) 100 % 100 %

(a) Combustion controls other than low-NOX burners or overfire air. The controls include burners-out-of 

service, flue gas recirculation, off-stoichiometric firing, and fluidized-bed combustion.

(b) Entry in ICR response indicated “none,” “not applicable,” or was left blank.

(c) Does not include the three IGCC units.
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Just as the combustion air to the primary combustion zone can be reduced, part of the fuel 

may be diverted to create a secondary flame with fuel-rich conditions downstream of the primary 

combustion zone. This combustion technique is termed reburning and involves injecting 10 to 

20 percent of the fuel after the primary combustion zone and completing the combustion with 

overfire air. The fuel injected downstream may not necessarily be the same as that used in the 

primary combustion zone. In most applications of reburning, the primary fuel is coal and the 

reburn fuel is natural gas (methane), and the technology is known as “gas reburn.” 

Other ways to reduce NOX formation by reducing peak flame temperature include using 

flue gas recirculation (FGR), reducing boiler load, injecting steam or water into the primary 

combustion zone, and increasing spacing between burners. By using FGR to return part of the 

flue gas to the primary combustion zone, the flame temperature and the concentration of oxygen 

in the primary combustion zone are reduced. Increasing the space between burners provides 

greater heat transfer to heat-absorbing surfaces. Another combustion control technique involves 

reducing the boiler load. In this case, the formation of thermal NOX generally decreases directly 

with decreases in heat release rate; however, reducing the load may cause poor air and fuel 

mixing and increase CO and soot emissions.

Selective Catalytic Reduction

The selective catalytic reduction (SCR) process uses a catalyst with ammonia gas (NH3) 

to reduce the NO and NO2 in the flue gas to molecular nitrogen and water. The ammonia gas is 

diluted with air or steam, and this mixture is injected into the flue gas upstream of a metal 

catalyst bed (composed of vanadium, titanium, platinum, or zeolite). In the reactor, the reduction 

reactions occur at the catalyst surface. Typically some ammonia exits the catalyst, on the order 

of 1-5 ppm in the flue gas; this is called “ammonia slip”. The SCR catalyst bed reactor is usually 

located between the economizer outlet and air heater inlet, where temperatures range from 230 to 

400 °C (450 to 750 °F). The catalyst modules take up a considerable amount of space; in 

addition ductwork must be added for the ammonia injection section. There is not always room in 

an existing boiler to retrofit an SCR system. As a consequence, fan capacity may have to be 

increased, owing to the incremental pressure drop from the SCR and associated ductwork. In 

some cases, the boiler must be modified to increase the economizer exit temperature to the 

minimum and/or the air preheater must be modified. Installation of an SCR on a boiler is sitespecific and this results in a range of capital costs for SCR systems on boilers.

SCR catalysts in coal- and oil-fired boilers oxidize a small fraction of the SO2 in the flue 

gas to produce SO3. The SO3 in the flue gas from an SCR may only be on the order of 10 ppm 

(depending on the sulfur-content of the fuel), but it can have impacts on the downstream 

equipment and emissions. The combination of ammonia slip and increased SO3 can form 

deposits of ammonium bisulfate in the air preheater. SO can condense in the flue gas in the form 

of a fine aerosol of sulfuric acid, which can cause a visible plume, the so-called “blue plume”. 

Selective Noncatalytic Reduction

The selective noncatalytic reduction (SNCR) process is based on the same basic 

chemistry of reducing the NO and NO2 in the flue gas to molecular nitrogen and water but does 

not require the use of a catalyst to prompt these reactions. Instead, the reducing agent is injected 

into the flue gas stream at a point where the flue gas temperature is within a very specific 
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temperature range. Currently, two SNCR processes are commercially available: the THERMAL 

DeNOX and the NOXOUT (USEPA, 1998). The THERMAL DeNOX uses ammonia gas as the 

reagent and requires the gas be injected where the flue gas temperature is in the range of 870 to 

1090 °C (1,600 to 2,000 °F). Consequently, the ammonia gas is injected at a location upstream 

of the economizer. However, if the ammonia is injected above 1,090 °C (2,000 oF), the ammonia 

will oxidize and will result in the formation of excess NOX emissions. Once the flue gas 

temperature drops below the optimum temperature range, the effectiveness of the process drops 

significantly. By adding hydrogen gas or other chemical enhancers, the reduction reactions can 

be sustained to temperatures down to approximately 700 °C (1,300 °F). The NOXOUT is a 

similar process but uses an aqueous urea solution as the reagent in place of ammonia.

Using nitrogen-based reagents requires operators of SNCR systems to closely monitor 

and control the rate of reagent injection. If injection rates are too high, NOX emissions may 

increase, and stack emissions of ammonia in the range of 10 to 50 ppm may also result. A 

portion (usually around 5 percent) of the NO reduction by SNCR systems results from 

transformation of NO to N2O, which is a global warming gas. 

Particulate Matter Emission Controls 

Four types of control devices are used to collect PM emissions from coal-fired electric 

utility boilers: electrostatic precipitators, fabric filters, mechanical collectors, and particle 

scrubbers. Table II-5 presents the 1999 nationwide distribution of PM controls on coal-fired 

electric utility boilers by total number of units and by percentage of nationwide electricity 

generating capacity. Electrostatic precipitators are the predominant control type used on coalfired electric utility boilers both in terms of number of units (84 percent) and total generating 

capacity (87 percent). The second most common control device type used is a fabric filter. 

Fabric filters are used on about 14 percent of the coal-fired electric utility boilers. Particle 

scrubbers are used on approximately three percent of the boilers. The least used control device 

type is a mechanical collector. Less than one percent of the coal-fired electric utility boilers use 

this type of control device as the sole PM control. Other boilers equipped with a mechanical 

collector use this control device in combination with one of the other PM control device types.

Electrostatic Precipitators

Electrostatic precipitator (ESP) control devices have been used to control PM emissions 

for over 80 years. These devices can be designed to achieve high PM collection efficiencies 

(greater than 99 percent), but at the cost of increased unit size. An ESP operates by imparting an 

electrical charge to incoming particles, and then attracting the particles to oppositely charged 

metal plates for collection. Periodically, the particles collected on the plates are dislodged in 

sheets or agglomerates (by rapping the plates) and fall into a collection hopper. The dust 

collected in the ESP hopper is a solid waste that must be disposed of. 
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Table II-5 Nationwide distribution of existing PM emission controls used for coal-fired 

electric utility boilers for the year 1999 (USEPA, 2001).

Phase II USEPA ICR Data

PM

Control Type

Abbreviation

Code

Number

 of Boilers

Percent of

Nationwide

Total 

Number of 

Units

Percent of

Nationwide

Electricity 

Generating

Capacity

Electrostatic precipitator

(Cold-side) CS- ESP 822 (a) 72.1 % 74.7 %

Electrostatic precipitator

(Hot-side) HS-ESP 122 10.8 % 11.3 %

Fabric filter FF 155 (b) 13.6 % 9.4 %

Particle scrubber PS 23 (c) 2.0% 3.0 %

Mechanical collector (d) MC 5 0.4 % 0.2 %

Multiple control device

combinations (e) 13 1.1 % 1.4 %

Nationwide Total 1,140 (f) 100 % 100 %

(a) Includes 10 boilers with cold-side ESP in combination with upstream mechanical collector.

(b) Includes eight boilers with baghouse in combination with upstream mechanical collector.

(c) Includes two boilers with particle scrubber in combination with upstream mechanical collector.

(d) Boilers using mechanical collector as only PM control device.

(e) Boilers using a combination of two or more different control device types other than mechanical 

collectors. Includes two boilers that use a hot-side ESP in series with a cold-side ESP.

(f) Does not include the three IGCC units.
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The effectiveness of particle capture in an ESP depends largely on the electrical 

resistance of the particles being collected. An optimum value exists for a given ash. Above and 

below this value, particles become less effectively charged and collected. Table II-6 presents the 

PM collection efficiency of an ESP compared with the other control device types. Coal that 

contains a moderate to high amount of sulfur (more than approximately three percent) produces 

an easily collected fly ash. Low-sulfur coal produces a high-resistivity fly ash that is more 

difficult to collect. Resistivity of the fly ash can be changed by operating the boiler at a different 

temperature or by conditioning the particles upstream of the ESP with sulfur trioxide, sulfuric 

acid, water, sodium, or ammonia. In addition, collection efficiency is not uniform for all particle 

sizes. For coal fly ash, particles larger than about 1 to 8 μm and smaller than about 0.3 μm (as 

opposed to total PM) are typically collected with efficiencies from 95 to 99.9 percent. Particles 

near the 0.3 μm size are in a poor charging region that reduces collection efficiency to 80 to 95 

percent.

An ESP can be used at one of two locations in a coal-fired electric utility boiler system. 

For many years, every ESP was installed downstream of the air heater where the temperature of 

the flue gas is between 130 and 180 °C (270 and 350 °F). An ESP installed at this location is 

referred is as a "cold-side" ESP. However, to meet SO2 emission requirements, many electric 

utilities switched to burning low-sulfur coal (discussed in Section 2.3.2 under SO2 controls). 

These coals have higher electrical ash resistivities, making the fly ash more difficult to capture 

downstream of the air heater. Therefore, to take advantage of the lower fly-ash resistivities at 

higher temperatures, some ESPs are installed upstream of the air heater, where the temperature 

of the flue gas is in the range of 315 to 400 °C (600 to 750 °F). An ESP installed upstream of the 

air heater is referred to as a "hot-side" ESP. (Buonicore and Davis, 1992; USEPA, 1998).

Fabric Filters

Fabric filters (FF) have been used for fly ash control from coal-fired electric utility 

boilers for about 30 years. This type of control device collects fly ash in the combustion gas 

stream by passing the gases through a porous fabric material. The buildup of solid particles on 

the fabric surface forms a thin, porous layer of solids or a filter, which further acts as a filtration 

medium. Gases pass through this cake/fabric filter, but the fly ash is trapped on the cake surface. 

The fabric material used is typically fabricated in the shape of long, cylindrical bags. Hence, 

fabric filters also are frequently referred to as "baghouses."
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Table II-6 Comparison of PM collection efficiencies for different 

PM control device types (Buonicore and Davis, 1992).

Representative PM

PM Mass Collection Efficiency Range

Control Type

Total

PM

PM

less than 0.3 μm

Electrostatic 

precipitator

(Cold-side)

99 to 99.7 % 80 to 95 %

Electrostatic 

precipitator

(Hot-side)

99 to 99.7 % 80 to 95 %

Fabric filter 99 to 99.9 % 99 to 99.8%

Particle scrubber 95 to 99 % 30 to 85 %

Mechanical collector 70 to 90 % 0 to 15 %
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Gas flow through a FF becomes excessively restricted if the filter cake on the bags 

becomes too thick. Therefore, the dust collected on the bags must be removed periodically. The 

type of mechanism used to remove the filter cake classifies FF design types. Depending on the 

FF design type, the dust particles will be collected either on the inside or outside of the bag. For 

designs in which the dust is collected on the inside of the bags, the dust is removed by either 

mechanically shaking the bag (called a "shaker type" FF) or by blowing air through the bag from 

the opposite side (called a "reverse-air" FF). An alternate design mounts the bags over internal 

frame structures, called "cages" to allow collection of the dust on the outside of the bags. A 

pulsed jet of compressed air is used to cause a sudden stretching then contraction of the bag 

fabric dislodging the filter cake from the bag. This design is referred to as a "pulse-jet" FF. The 

dislodged dust particles fall into a hopper at the bottom of the baghouse. The dust collected in 

the hopper is a solid waste that must be disposed of.

An FF must be designed and operated carefully to ensure that the bags inside the 

collector are not damaged or destroyed by adverse operating conditions. The fabric material 

must be compatible with the gas stream temperatures and chemical composition. Because of the 

temperature limitations of the available bag fabrics, location of an FF for use in a coal-fired 

electric utility boiler is restricted to downstream of the air heater. In general, fabric filtration is 

the best commercially available PM control technology for high-efficiency collection of small 

particles.

Electrostatic stimulation of fabric filtration (ESFF) involves a modified fabric filter that 

uses electrostatic charging of incoming dust particles to increase collection efficiency and reduce 

pressure drop compared to fabric filters without charging. Filter bags are specially made to 

include wires or conductive threads, which produce an electrical field parallel to the fabric 

surface. Conductors can also be placed as a single wire in the center of the bag. When the bags 

are mounted in the baghouse, the conductors are attached to a wiring harness that supplies 

electricity. As particles enter the field and are charged, they form a porous mass or cake of 

agglomerates at the fabric surface. Greater porosity of the cake reduces pressure drop, while the 

agglomeration increases efficiency of small particle collection. Cleaning is required less 

frequently, resulting in longer bag life. For felted or nonwoven bags, the field promotes 

collection on the outer surface of the fabric, which also promotes longer bag life. Filtration 

velocity can be increased so that less fabric area is required in the baghouse. The amount of 

reduction is based on an economic balance among desired performance, capital cost, and 

operating costs. A number of variations exist on the ESFF idea of combining particle charging 

with fabric filtration. (Buonicore and Davis, 1992; Turner and McKenna, 1989).

Particle Scrubbers and Mechanical Collectors

Particle scrubbers are generally much less efficient than ESPs and baghouses (especially 

in collecting finer fraction of PM). For this reason and because they entail higher operating costs 

associated with achieving high collection efficiency, they are not widely used in the industry. 

Similarly, mechanical collectors have the least collection efficiency and are hardly used in the 

industry. These two methods are not discussed further in this report. (Buonicore and Davis, 

1992).
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2.3.3. Emission Control Configurations for Coal-fired Electric Utility Boilers

Table II-7 presents the 1999 nationwide distribution of post-combustion control device 

configurations used for coal-fired electric utility boilers. For approximately 70 percent of the 

boilers, the only control device used downstream of the furnace is an ESP. If the unit is subject 

to SO2 and/or NOX emission limit standards, these units do burn low-sulfur coals to meet the SO2

emission limit and use some type of NOX combustion controls to meet the NOX emission limit. 

Approximately 25 percent of the boilers use some combination of post-combustion control 

devices. The most common configuration used is an ESP with a downstream wet scrubber for 

SO2 control. Less than 2 percent of the units used a combination of PM, SO2, and NOX postcombustion control devices.

It is important to note that, for the case of PM, the data on PM control as shown for the 

year 1999 should not have changed in any significant way. However, for SO2, the requirements 

of Phase II ( starting in the Year 2000) of the Title IV (acid rain provisions) of the 1990 CAAA, 

should have resulted in some boilers either switching to low -sulfur coal or the application of wet 

or dry scrubbers. It appears that the SO2 scrubber retrofit activity in the U.S. has been rather 

insignificant since 1999. The most active retrofits have involved the application of SCR, SNCR, 

and gas reburn (in conjunction with low-NOX burners where appropriate) to significantly reduce 

NOX emissions in the eastern U.S. These reductions, however, are only for ozone season (May 1 

to September 30) since the NOX Transport SIP call applies to ozone season. As of 2003, more 

than 50 applications of SCRs, SNCRs, or gas reburn have either been completed or are under 

construction.
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Table II-7 Nationwide distribution of post-combustion emission control configurations 

used for coal fired electric utility boilers for the year 1999 as reported in the Part II 

USEPA ICR data (USEPA, 2001).

Post-Combustion Emission Control Device Configuration

PM control SO2 control NOX control

Phase II USEPA ICR Data

Post-combustion 

Control Strategy

E

S

P

F

F

P

S

M

C

W

S

S

D

A

D

I

S

C

R

S

N

C

R

Number

of boilers

Percent of

nationwide

total number

? 791 69.4%

? 80 7.0%

? ? 6 0.5 %

? 5 0.4 %

? ? 4 0.4 %

? 2 0.2 %

Post-combustion

PM controls

only

? 2 (a) 0.2 %

? ? 133 11.7 %

? ? 38 3.3%

? ? 18 1.6 %

? ? 13 1.1 %

? ? 4 0.4 %

? ? 3 0.2 %

? ? 2 0.2 %

Post-combustion

PM controls

and

SO2 controls

? ? ? 1 0.1 %

? ? 12 1.0 %

? ? 11 0.9 %

Post-combustion

PM controls

and

NOX controls ? ? 1 0.1 %

? ? ? 6 0.5 %

? ? ? 4 0.4 %

? ? ? 2 0.2% 

? ? ? 1 0.1 %

Post-combustion

PM controls,

SO2 controls,

and

NOX controls

? ? ? 1 0.1 %

Total 1,140 (b) 100 %

(a) Units using hot-side ESP in series with a cold-side ESP. Counted as a “multiple control device combination" in Table II-5

(b) Does not include the three IGCC units.
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2.4. Costs and Availability of Technology 

The technologies to control three of the precursors of regional haze are commercially 

available. Since EGUs are the most significant stationary source of SO2, NOX, and PM, they 

have been subject to extensive federal and state regulations to control all three pollutants. The 

technical feasibility of control technologies has been successfully proven for a large number of 

small (say, 100 MW) to very large boilers (over 1,000 MW) using different types of coal used. 

Over the last few years, a large amount of cost data have also become available that clearly 

indicate that many technologies provide substantial and extremely cost effective reductions. 

2.4.1. Detailed Capital Costs, Operating and Maintenance Costs, and Cost 

Effectiveness

 Cost of Controlling SO2 Emissions

Both wet and dry scrubbers are in wide commercial use in the U.S. The capital costs for 

new or retrofit wet or dry scrubbers are high when compared to the capital costs for NOX and PM 

controls. The recent capital costs range from $180/kW for large units (larger than 600 MW) to 

as high as $350 for small units (200 to 300 MW). However, the last few years has seen a general 

trend of declining capital costs due to vendor competition and technology maturation. The cost 

effectiveness (in dollars per ton) is very attractive, since these devices remove a very large 

amount of SO2 (driven by high sulfur content of coal burned). The typical cost effectiveness is in 

the range of 200 to 500 dollars per ton of SO2 removed though higher values are obtained for 

small units operating at low capacity factors and burning low-sulfur coal. The cost effectiveness 

is determined mostly by the baseline pre-controlled SO2 emisison rate (or sulfur content of fuel), 

size and capacity factor of the unit, as well as the capital cost of FGDs (that generally ranges 

from $150 to $200/kW). 

Cost of Controlling NOX

A representative summary of range of costs associated with various technologies for NOX

control is provided below.

Gas Reburn

 In general, the capital costs range from $15/kW to $30/kW for gas reburn and $30/kW to 

$60/kW when using coal as the reburn fuel. Operating costs are mainly driven by fuel cost 

differential (certainly gas vs. coal). For other fuels (e.g. coal/orimulsion reburning), fuel 

preparation costs become more important (micronization, atomization) as there is little or no fuel 

cost differential. The cost in dollars per ton of NOX removed is in the range of 500 to 2000 

dollars.

Retrofit schedules are directly related to the scope of the retrofit requirements. In most 

cases, 3-6 weeks are adequate for a reburn retrofit.

Low-NOX Burners
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In general, the capital costs for burners range from $10,000 to 50,000 per burner plus 

installation. The lower end of this range applies when existing burners are modified instead of 

replaced to achieve lower NOX. Operating costs are negligible unless increased unburned carbon 

results in lost revenues from ash sales. An outage is generally required when implementing this 

technology, but coal-flow sensors and adjustable orifices are best installed when a mill is out of 

service. Low-NOX Burners provide moderate NOX reductions in the range of 30 to 60% at 

moderate cost ($200 to 500 per ton of NOX removed).

Overfire Air (OFA)

OFA technologies have little or no impact on operating costs (other than the potential for 

an increase in unburned carbon - efficiency loss -, and the resulting impact on ash disposal 

options). Retrofit costs are site-specific. As such, the economics of these technologies are 

driven by capital/retrofit costs which typically range from $5-$10/kW, with the lower range 

reflecting easier application whereas the higher costs are typically associated with more difficult 

and involved retrofits. The cost effectiveness is in the range of $250 to 600 per ton of NOX

removed. 

From a schedule standpoint, OFA retrofit projects can require outages of 3 – 6 weeks, 

depending on factors such as scope of work, integration with other plant outage requirements, 

etc.

SCR 

Capital costs for retrofit SCR systems to coal-fired power generation sources are specific 

to the individual site, but have been documented to be within the range of $70/kW to about 

$190/kW. The lower end of this range applies to retrofits with nominal difficulty. The high end 

of the range would typically be associated with retrofits having significantly impeded 

construction access, extensive relocations, and difficult ductwork transitions. 

Capital costs for retrofit SCR systems on oil and gas-fired boilers are substantially lower 

(about half to one third) than costs of coal-fired boiler retrofits. Lower volumes of catalyst are 

required for gas-fired boilers because of the lack of ash and catalysts poisons like arsenic in the 

flue gas. Capital costs for oil-fired retrofits are intermediate between coal- and gas-fired 

retrofits. Oil combustion produces some particulate matter, which necessitates larger SCR 

catalyst volume as compared to that for natural gas.

Operating costs are mainly driven by cost of reagent, energy penalty (pressure loss, 

ammonia vaporization), catalyst replacement and dedicated O and M costs. SCR technology 

offers very high NOX reductions (from 90 to 95%) and cost effectiveness (in the range of $1,000 

to 1500 per ton of NOX removed). 

 SNCR

The capital costs for SNCR application are low making it an attractive option for 

moderate NOX reductions (25 to 50%). Capital cots range from $10 to $20/kW for power 

generation boilers. 
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Operating costs are driven primarily by the consumption of the chemical reagent –

usually urea for SNCR - which in turn is dependent upon the efficiency of the control equipment

as well as the initial NOX level and the desired percent reduction. These are typically in the 

range of $500-$700/ton of NOX.

An additional consideration important in the overall operating costs is the potential 

contamination of fly ash by ammonia making it potentially unsalable.

Cost of Controlling PM

The costs associated with controlling PM from EGUs generally do not scale on the size 

of the unit but on the volume of flue gases processed by the control devices (ESPs or fabric 

filters). The representative costs are provided below. 

ESPs 

The following values represent typical costs for application of ESPs to units handling a 

range of flue gas rates (these numbers reflect unit sizes ranging from utility-size units up to about 

2,000,000 ACFM to smaller process down to about 10,000 ACFM):

• Capital: $15 - $40/ACFM

• Fixed O&M: Dry ESP’s - $0.25 - $0.65/yr-ACFM

 Wet ESP’s - $0.15- $0.50/yr-ACFM 

• Variable O&M: Dry ESP’s - $0.45 - $0.60/yr-ACFM

 Wet ESP’s - $0.25 - $0.50/yr-ACFM

Fabric Filters 

Baghouses have been used extensively for many years in different industries. The EGU 

sector, while predominantly dominated by ESP’s, has started to utilize FF’s in the last 20 years.

• Capital: Reverse Air Fabric Filter - $17 - $40/ACFM

 Pulse Jet Fabric Filter - $12 - $40/ACFM

• Fixed O&M: Reverse Air Fabric Filter - $0.35 - $0.75/yr-ACFM

 Pulse Jet Fabric Filter - $0.50 - $0.90/yr-ACFM

• Variable O&M: Reverse Air Fabric Filter - $0.70 - $0.80/yr-ACFM

 Pulse Jet Fabric Filter - $.90 - $1.1/yr-ACFM
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References

Buonicore, A.J., and W.T. Davis (eds.). Air Pollution Engineering Manual. Air & Waste 

Management Association. Van Nostrand Reinhold, New York, NY. 1992.

NESCAUM, A Basis for Control of BART Eligible Sources, Northeast States for Coordinated Air 

Use Management, Boston, MA, July, 2001. 

Turner, J.H., and J.D. McKenna. Fabric Filter Baghouses I - Theory, Design, and Selection. 

ETS, Inc., Roanoke, VA. 1989.

U.S. Environmental Protection Agency. Air Quality Criteria for Particulate Matter and Sulfur 

Oxides, Volumes 1-3, EPA/600/8-82/029a-c. (NTIS PB84-156777). Office of Health and 

Environmental Assessment, Environmental Criteria and Assessment Office, Research Triangle 

Park, NC. 1982.

U.S. Environmental Protection Agency. Air Quality Criteria for Oxides of Nitrogen, Volumes 1-

3, EPA/600/8-91/049a-c (NTIS PB92-176361; 95-124525; 95-124517), Office of Health and 

Environment Assessment, Environmental Criteria and Assessment Office, Research Triangle 

Park, NC. 1991.

U.S. Environmental Protection Agency, Stationary Source Control Techniques Document for 

Fine Particulate Matter, Woodward, K., EPA/425/R-97-001 (NTIS PB99-116493). Office of 

Air Quality Planning and Standards, Research Triangle Park, NC. October 1998.

U.S Environmental Protection Agency, National Air Pollutant Emissions Trends, 1900-1998, 

U.S. EPA and the States: Working Together for Cleaner Air, Nizich, S.V., A.A. Pope, and L.M. 

Driver. EPA-454/R-00-002 (NTIS PB2000-108054). Office of Air Quality Planning and 

Standards, Research Triangle Park, NC. March 2000.

U.S. Environmental Protection Agency. Database of information collected in the Electric Utility 

Steam Generating Unit Mercury Emissions Information Collection Effort. OMB Control No. 

2060-0396. Office of Air Quality Planning and Standards. Research Triangle Park, NC. April 

2001. Available at: <http://www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html>.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 3-1

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3. INDUSTRIAL BOILERS

Industrial boilers are a significant source of emissions among the twenty-six 

source categories covered under the Regional Haze Rule. Estimates of national emissions 

for criteria air pollutants prepared by the USEPA (2000) show that industrial boilers 

contributed approximately 12 percent of the estimated total national SO2 emissions and 

23 percent of total national NOX emissions in 1998 (the most recent year for which 

national estimates are available). Industrial boilers also are one of the largest industrial 

sources of PM emissions, with 16 percent of the national PM10 emissions and 20 percent 

of the national PM2.5 in 1998. Contrast this with the emissions of EGUs for which PM10

and PM2.5 emissions were 25 percent and 23 percent of national totals in 1998, 

respectively. In general, the combustion efficiencies achieved by industrial boilers are 

lower than those of EGUs, resulting in significant emissions of CO (18 percent of the 

1998 emissions) and volatile organic compounds (6 percent of the 1998 emissions) from 

industrial boilers. Industrial boilers also produced 16 percent of the ammonia emissions 

in 1998. Ammonia is precursor of secondary PM in the atmosphere.

About 46 percent of the SO2 emissions from industrial boilers are from coal-fired 

boilers (see Table III-1). The predominant sources of NOX emissions from industrial 

boilers are gas-fired boilers (30 percent) and internal combustion boilers (34 percent); 

coal-fired boilers were only responsible for 17 percent of NOX emissions from industrial 

boilers. Although the emphasis of this Chapter is on coal-fired utility boilers, many 

technologies described here are also applicable to gas and oil-fired units (for example, 

SCR and SNCR technologies are equally applicable to coal and natural gas/oil units, 

generally at much lower capital and operating costs; same is true for wet scrubbers for 

SO2 control and ESPs or baghouses for PM control for oil units).

Table III-1 Distribution of emissions from industrial fuel boilers from 1998 

National Emissions Inventory (USEPA, 2000)

Fuel/Source NOX SO2 PM10 PM2.5

Coal 17% 46% 31% 16%

Oil 7% 27% 18% 16%

Gas 39% 21% 18% 26%

Other 4% 5% 25% 32%

Internal Combustion34% 1% 7% 10%

3.1. Description of Boiler Process

Typically, industrial boilers generate steam used for process heating or on-site 

generation of electricity. Industrial boilers burn a wider variety of fuels than EGUs and 

there are a larger number of boiler designs in use than in the electric power sector. 

According to information contained in USEPA’s Docket on “National Emission 

Standards for Hazardous Air Pollutants for Industrial/ Commercial/Institutional Boilers 
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and Process Heaters” (USEPA, 2004) in 1998 there were 63,767 fossil fuel-fired boilers, 

1,100 wood-fired boilers and 998 boilers classified as non-fossil-fuel-fired. The fossil 

fuels fired were natural gas, distillate oil, residual oil, coal and petroleum coke. The 

majority (75 to 95 percent) of the boilers firing natural gas, residual oil and distillate oil 

are fire tube boilers; the rest are water tube boilers. Coal-fired boilers include fluidized 

bed boilers, stokers, cyclone boilers, and pulverized coal-fired boilers (wall-fired or 

tangentially fired). Wood-fired boilers include fluidized bed boilers, cyclones, stokers 

and dutch ovens. 

3.2. Review of BART-Eligible Industrial Boilers in the MANE-VU 

Region

There are 10 facilities with BART-Eligible industrial boilers in the MANE-VU 

region. Table III-2 contains a list of these sources based on a previous NESCAUM report 

(2003) and follow-up review by state permitting authorities. 5

Table III-2 BART-Eligible Facilities in the Industrial Boiler Category

State Company/Facility City/Town Category

Connecticut SPRAGUE PAPERBOARD INC Versailles boilers

Massachusetts GENERAL ELECTRIC AIR (GE Aircraft Engines) Lynn boilers

Massachusetts

TRIGEN BOSTON ENERGY-KNEELAND 

STATION Boston boilers

Massachusetts SOLUTIA INC. (MONSANTO CO.) Springfield boilers

Massachusetts HARVARD UNIVERSITY CAMBRIDGE Cambridge boilers

Maine International Paper - Bucksport Bucksport boilers

Maine Katadhin - Mill W. Millinocket boilers

New Hampshire Annheuser-Busch Merrimack boilers

New Hampshire Dartmouth College Hanover boilers

Rhode Island BROWN UNIVERSITY Providence boilers

3.3. Available Control Technologies

A variety of emission control technologies are employed to meet requirements for 

sulfur dioxide (SO2), nitrogen oxides (NOX), and primary PM emissions, the three major 

precursors of observed regional haze in the atmosphere. SO2 and NOX are mostly 

converted to ammonium sulfate and ammonium nitrate that are formed by the reactions 

of precursor gases with ammonia, which is emitted mostly from agricultural and cattlerelated activities. 

Pollutant emission controls are generally divided into three major types:

 

5

 NESCAUM does not believe that there are any BART-eligible sources in the State of Vermont or any of 

the member Tribes in MANE-VU and thus we have not developed lists for these jurisdictions. In addition, 

Pennsylvania and the District of Columbia have developed BART-Eligible source lists following their own 

methodology and any identified sources are contained here and in the final list in Appendix A.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 3-3

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• Pre-combustion Controls. Control measures in which fuel substitutions are made 

or fuel pre-processing is performed to reduce pollutant formation in the 

combustion unit.

• Combustion Controls. Control measures in which operating and equipment 

modifications are made to reduce the amount of pollutants formed during the 

combustion process; or in which a material is introduced into the combustion unit 

along with the fuel to capture the pollutants formed before the combustion gases 

exit the unit.

• Post-combustion Controls: Control measures in which one or more air pollution 

control devices are used at a point downstream of the furnace combustion zone to 

remove the pollutants from the post-combustion gases.

3.3.1. Emission Characteristics of Regional Haze Precursors from 

Industrial Boilers

Nitrogen Oxides 

The formation of NOX is an unfortunate byproduct of the combustion of fossil 

fuels. Both NO and NO2 (collectively called NOX) are formed during fossil fuel 

combustion by oxidation of molecular nitrogen that is present in the combustion air or 

nitrogen compounds contained in the fuel. The degree to which this conversion occurs is 

dependent on many factors including both the combustion process itself and the 

properties of the particular fuel being burned. This explains why similar boilers firing 

different fuels or similar fuels burned in different boilers will yield different NOX

emissions. Overall, total NOX formed during combustion is composed predominantly of 

NO mixed with small quantities of NO2 (typically less than 10 percent of the total NOX

formed). However, once NO formed during coal combustion is emitted to the 

atmosphere, the NO is oxidized to NO2.

The NOX formed during combustion by oxidation of molecular nitrogen (N2) in 

the combustion air is referred to as “thermal NOX.” The oxidation reactions converting 

N2 to NO and NO2 become very rapid once gas temperatures rise above 1,700°C 

(3,100°F). Formation of thermal NOX in a boiler is dependent on two conditions 

occurring simultaneously in the combustion zone: high temperature and an excess of 

combustion air. A boiler design feature or operating practice that increases the gas 

temperature above 1,700 °C, the gas residence time at these temperatures, or the quantity 

of excess combustion air affects thermal NOX formation. The formation of NOX by 

oxidation of nitrogen compounds contained in the coal is referred to as “fuel NOX.” The 

nitrogen content in coal and petcoke ranges from approximately 0.5 to 2 percent; in 

wood, the nitrogen content is typically 0.1 to 0.2 percent. The amount of nitrogen 

available in the fuel is relatively small compared with the amount of nitrogen available in 

the combustion air. However, a significant portion of the fuel nitrogen can be converted 

to NO in the flame. Local temperature, oxygen concentration and NO concentration 

affect the conversion of fuel nitrogen to NO and this is exploited in low-NOX firing 

systems.
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Sulfur Dioxide

SO2, like NOX, is a precursor to acid rain and fine particulate matter (PM2.5) and is 

also an undesirable byproduct of the combustion of sulfur-containing fuels. Coal 

deposits contain sulfur in amounts ranging from trace quantities to as high as 8 percent or 

more. Natural gas contains virtually no sulfur. Residual oil can have 1 to 2 percent 

sulfur by weight, while petroleum coke can have as much as 6 percent sulfur. During 

combustion, sulfur compounds in the fuel are oxidized to gaseous SO2 or SO3. When 

firing bituminous coal, almost all of the sulfur present in coal is emitted as gaseous sulfur 

oxides (on average, 98 percent). The more alkaline nature of ash in some sub bituminous 

coals causes a portion of the sulfur in the coal to react to form various sulfate salts; these 

salts are emitted as fly ash or retained in the boiler bottom ash. When firing petcoke or 

residual oil, more of the SO2 is converted to SO3 because of the oxidation that is 

catalyzed by vanadium in the ash. In coal-fired boilers, SO3 levels are typically 10 ppm 

or less. With petcoke firing, however, SO3 levels as high as several hundred ppm have 

been reported (Fernando,2001). Formation of SO3 is a concern because the temperature 

of the particulate control device or scrubber is often below the acid dew point, resulting 

in nucleation and condensation of ultrafine sulfuric acid particles from the SO3 present in 

the gas. These particles can contribute to the fine PM emissions from the stack.

Unlike nitrogen in fossil fuels and wood, almost all of the sulfur in fuel is 

oxidized to form SO2. This means that the relationship between sulfur content in the fuel 

and SO2 production is much more direct than that between fuel nitrogen and NOX, and as 

such, it makes fuel switching (for example higher to lower sulfur coal) directly 

proportional to reductions in SO2. Generally, the percentage of sulfur in the fuel that is 

converted to sulfur oxides during combustion does not vary with the boiler design or 

operation. The exception to this is the fluidized bed boiler in which limestone is added to 

the bed. The bed is operated at a sufficiently low temperature (compared to other 

combustion systems) that sulfur is captured effectively in the bed as calcium sulfate.

Particulate Matter

Primary PM emissions from boilers consist primarily of fly ash. Ash is the 

unburned carbon and the mineral portion of the fuel. Coals contain 4 to 12 percent ash 

typically. Other liquid or solid fuels (oil, petroleum coke, wood) contain less than one 

percent ash. The amount of ash that ultimately exits the boiler unit as fly ash is a 

complex function of the fuel properties, furnace-firing configuration, and boiler 

operation. For the dry-bottom, pulverized-coal-fired boilers, approximately 80 percent of 

the total ash in the as-fired coal exits the boiler as fly ash. Wet-bottom, pulverized-coalfired boilers emit significantly less fly ash: on the order of 50 percent of the total ash 

exits the boiler as fly ash. In a cyclone-fired boiler, most of the ash is retained as liquid 

slag; thus, the quantity of fly ash exiting the boiler is typically 20 to 30 percent of the 

total ash. However, the high operating temperatures unique to these designs promote ash 

vaporization and this results in larger fractions of submicron fly ash compared to dry 

bottom designs. Fluidized-bed combustors emit high levels of fly ash since the coal is 
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fired in suspension and the ash is present in dry form. Spreader-stoker-fired boilers can 

also emit high levels of fly ash. However, overfeed and underfeed stokers emit less fly 

ash than spreader stokers, since combustion takes place in a relatively quiescent fuel bed.

In addition to the fly ash, PM emissions from boilers result from reactions of the 

SO2 and NOX compounds as well as unburned carbon particles carried in the flue gas 

from the boiler. The SO2 and NOX compounds are initially in the vapor phase following 

coal combustion in the furnace chamber but can partially chemically transform in the 

stack, or near plume, to form fine PM in the form of nitrates, sulfur trioxide (SO3), and 

sulfates. Firing configuration and boiler operation can affect the fraction of carbon (from 

unburned fuel) contained in the fly ash. Combustion efficiencies tend to be lower in 

industrial boilers than in EGUs. Oil or petcoke combustion results in high amounts of 

sulfur trioxide as compared to coal combustion because of the high vanadium content of 

residual oil and petcoke. 

NOX control technologies that inject ammonia or amine-based reagents (like 

Selective Catalytic Reduction or Selective Non-Catalytic Reduction) produce ammonia, 

generally with concentrations less than 10 ppm. This ammonia can also form fine 

particulate in the stack, if it persists through the air pollution control devices.

3.3.2. Control Technologies used for Industrial Boilers

Application Status

According to the 1998 survey of industrial boilers by USEPA (2004), only 2 

percent of gas-fired boilers and 3 percent of oil-fired boilers had any kind of air pollution 

control device. More coal-fired boilers had air pollution control devices: 47 percent had 

some control device and these were largely PM controls.

For PM controls, ESPs were used on 12 percent of the coal-fired boiler units in 

1998, fabric filters or baghouses were used on 10 percent of the boiler units, mechanical 

collectors were used on 21 percent of the units, and particulate scrubbers were only used 

on 2 percent of the units. 66 percent of wood-fired boilers used mechanical collectors for 

PM control, while 10 percent used PM scrubbers and another 10 percent used ESPs. 

Post-combustion SO2 control was used by less than one percent of industrial 

boilers in 1998, with the exception of boilers firing petcoke: 2 percent of boilers firing 

petroleum coke had acid scrubbers. A small percentage of industrial boilers had 

combustion controls in place in 1998, although since 1998, additional low-NOX firing 

systems may have been installed.

SO2 Reduction Overview

Almost all SO2 emission control technologies fall in the category of reducing SO2

after its formation, as opposed to minimizing its formation during combustion. The 

exception to the nearly universal use of post-combustion controls is found in fluidized 

bed boilers, in which limestone is added to the fluidized bed combustion. Typically 90 
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percent of the sulfur can be captured in a coal-fired fluidized bed using limestone with 

Ca/S molar ratios of 2 to 2.5, depending on the sulfur content of the fuel, the reactivity of 

the limestone and the operation of the combustor.

Post-combustion SO2 control is accomplished by reacting the SO2 in the gas with 

a reagent (usually calcium- or sodium-based) and removing the resulting product (a 

sulfate/sulfite) for disposal or commercial use depending on the technology used. SO2

reduction technologies are commonly referred to as Flue Gas Desulfurization (FGD) 

and/or "Scrubbers" and are usually described in terms of the process conditions (wet 

versus dry), byproduct utilization (throwaway versus saleable) and reagent utilization 

(once-through versus regenerable).

Within each technology category, multiple variations are possible and typically 

involve the type and preparation of the reagent, the temperature of the reaction (for dry 

processes), the use of enhancing additives, etc. Because these variations mostly involve 

complex process chemistry, but are fundamentally similar, this summary focuses on the 

major categories of SO2 control technologies, their applicability, performance and cost.

Pre-Combustion Control

A coal with sufficiently low sulfur content that when burned in the boiler meets 

the applicable SO2 emission standards without the use of additional controls is sometimes 

referred to as “compliance coal.” Coals naturally low in sulfur content may be mined 

directly from the ground. Alternatively, the sulfur content of coal fired in the boiler may 

be lowered first by cleaning the coal or blending coals obtained from several sources. 

However, burning low-sulfur coal may not be a technically feasible or economically 

practical SO2 control alternative for all boilers. In some cases, a coal with the required 

sulfur content to meet the applicable standard may not be available or cannot be fired 

satisfactorily in a given boiler unit design. Even if such a coal is available, use of the 

low-sulfur coal that must be transported long distances from the mine may not be costcompetitive with burning higher sulfur coal supplied by closer mines and using a postcombustion control device.

Various coal cleaning processes may be used to reduce the sulfur content of the 

coal. A significant portion of the pyritic sulfur minerals mixed with the mined coal can 

usually be removed by physical gravity separation or surface property (flotation) 

methods. However, physical coal cleaning methods are not effective for removing the 

organic sulfur bound in coal. Another method of reducing the overall sulfur content of 

the coal burned in a given boiler unit is to blend coals with different sulfur contents to 

meet a desired or target sulfur level.

In-Process Controls

Fluidized bed boilers generally operate at lower temperatures than other 

combustion systems, 800 to 870oC (1500 to 1600oF). The lower temperatures allow the 

use of limestone or dolomite to be added to the bed to capture sulfur. Limestone 

(CaCO3) is converted to CaO at approximately 800oC (1500oF). SO2 released from the 
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fuel reacts with CaO to form CaSO4, which is thermodynamically stable at bed 

temperatures. By recycling some of the solids leaving the bed, which contain unsulfated 

calcium, 90 percent removal of SO2 can be achieved with Ca/S molar ratios of 2 to 2.5 in 

circulating fluidized beds. Higher Ca/S ratios are required in bubbling beds. In either 

case, the sorbent is removed with the ash from the bed and sent to disposal.

Post-Combustion Controls 

Wet Processes

Wet FGD "scrubbers" date back to the 1960s with commercial applications in 

Japan and the U.S. in the early 1970s. They represent the predominant SO2 control 

technology in use today with over 80% of the controlled capacity in the world and the 

U.S.

In a wet scrubber, the SO2-containing flue gas passes through a vessel or tower 

where it contacts an alkaline slurry, usually in a counterflow arrangement. The intensive 

contact between the gas and the liquid droplets ensures rapid and effective reactions that 

can yield greater than 90 percent SO2 capture. Currently, advanced scrubber designs 

have eliminated many of the early problems, primarily related to reliability, but have also 

demonstrated very high SO2 reduction capabilities with some units providing over 95 

percent control.

Variations of the basic technology, in addition to equipment improvements made 

over the years, include reagent and byproduct differences. Limestone, lime, sodium 

carbonate and even seawater-based processes are commercial. Limestone is by far the 

most widely used with commercial-grade gypsum (wallboard quality) being produced in 

the so-called Limestone Forced Oxidation (LSFO) process. The use of other reagents, as 

mentioned, is driven by site-specific criteria, such as local reagent availability, 

economics, efficiency targets, etc.

Dry Processes

Dry processes include spray dryer absorbers (SDA) and Dry Sorbent Injection 

(DSI) technologies. SDA refers to a configuration where the reaction between SO2 and 

the sorbent takes place in a dedicated reactor or scrubber hence the common reference to 

"dry scrubber"; conversely, DSI uses the existing boiler/duct system as the "reactor" and 

several configurations are possible based on the temperature window desired. This can 

occur at furnace (~2200oF), economizer (800-900oF) or duct temperatures (~250oF). Dry 

processes are more compatible with low to medium sulfur coals due to limitations in 

reaction rates and sorbent handling (e.g., atomization). Therefore, high-sulfur 

applications are not likely. In addition, another common feature among them is the need 

for particulate control downstream of the sorbent injection. Usually this is accomplished 

through the use of fabric filters (baghouses) which are, not only efficient collectors of 

particulates, but also provide additional SO2 removal as the flue gas passes through 

unreacted sorbent collected on the filters. 
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Dry SO2 controls vary significantly in performance, with SDAs being able to 

achieve about 80 percent removal rates, whereas the various forms of DSI are capable of 

40 to 75 percent efficiencies. 

NOX Reduction Overview 

As a result of the complex interactions in the formation of NOX, an equally large 

number of approaches to minimize or reduce its emissions into the atmosphere have been 

and continue to be developed. A relatively simple way of understanding the many 

technologies available for NOX emission control is to divide them into two major 

categories: (1) those that minimize the formation of NOX during the combustion process 

(e.g., smaller quantities of NOX are formed); and (2) those that reduce the amount of NOX

formed during combustion prior to exiting the stack into the atmosphere. In industry 

"language" it is common to refer to the first approach under the "umbrella" of 

Combustion Modifications whereas technologies in the second category are termed PostCombustion Controls. 

Within each of these categories, several technologies and variations of the same 

technology exist. Finally, combinations of some of these technologies are not only 

possible but often desirable as they may produce more effective NOX control than the 

application of a stand-alone technology.

The following summaries describe the major technologies in each category.

Combustion Modifications

Combustion modifications can vary from simple "tuning" or optimization efforts 

(similar to a "tune-up" in a car) to the deployment of dedicated technologies such as 

Low-NOX Burners (LNB), Overfire Air (OFA) or gas recirculation (GR).

Boiler Tuning or Optimization

Combustion optimization efforts can lead to improvements in NOX emissions of 5 

to 15 percent or even higher in cases where a unit may be badly "de-tuned." It is 

important to remember that optimization results are truly a function of the "preoptimization" condition of the power plant or unit (just as the improvement in a car from 

a "tune-up" depends on how "bad" it was running prior to it), and as such have limited 

opportunity for drastic emission reductions.

Recent development of "intelligent controls" - software-based systems that "learn" 

to operate a unit and then maintain its performance during normal operation, are expected 

help in keeping plants well-tuned, as they gain acceptance and become common features 

in combustion control systems.
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Low-NOX Burners and Overfire Air

LNBs and OFA represent practical approaches to minimizing the formation of 

NOX during combustion. Simply, this is accomplished by "controlling" the quantities and 

the way in which fuel and air are introduced and mixed in the boiler (usually referred to 

as "fuel or air staging").

These technologies are the most prevalent in the power industry at present. For 

example, plants that have had to comply with Title IV of the CAAA of 1992 have largely 

used these technologies for compliance. Competing manufacturers have proprietary 

designs, geared towards application in different boiler types, as well as reflecting their 

own design philosophies. LNBs and OFA, which can be used separately or as a system, 

are capable of NOX reductions of 40 to 60 percent from uncontrolled levels. Again, the 

type of boiler (e.g., dry versus wet-bottom, wall- versus tangential-fired, NSPS versus 

pre-NSPS) and the type of fuel (e.g., bituminous versus sub-bituminous) will influence 

the actual performance achieved.

Furthermore, all combustion modification approaches face a common challenge: 

that of "striking a balance" between NOX reduction and fuel efficiency. The concern is 

exemplified by the typically higher carbon levels in the fly ash, which reflect lower 

efficiency (more fuel needed for the same electrical output), but also the contamination of 

the fly ash itself possibly making it unsuitable for reutilization (e.g., cement industry).

LNBs/OFA have little or no impact on operating costs (other than by the potential 

for the above-mentioned efficiency loss). 

From a schedule standpoint, LNB/OFA retrofit projects have "lead" times of 10 to 

14 weeks and can require outages of 6 to 10 weeks, depending on factors such as scope of 

work, integration with other plant outage requirements, etc.

Post-Combustion Controls

Readily available post-combustion NOX controls are limited to Selective NonCatalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR). They are 

fundamentally similar, in that both use an ammonia-containing reagent to react with the 

NOX produced in the boiler, and convert it to harmless nitrogen and water, SNCR 

accomplishes this at higher temperatures (1700oF-2000oF) in the upper furnace region of 

the boiler, while SCR operates at lower temperatures (about 700oF) and hence needs a 

catalyst to produce the desired reaction between ammonia and NOX. 

While this difference between the two technologies may seem minor, it yields 

significant difference in performance and costs. This is because in the case of SNCR, the 

reaction occurs in a somewhat uncontrolled fashion (e.g., the existing upper furnace 

becomes the "makeshift" reactor which is not what it was originally designed to be), 

while in the SCR case, a dedicated reactor and the reaction-promoting catalyst ensure a 

highly controlled, efficient reaction. In practice, this means that SNCR has lower capital 

costs (no need for a reactor/catalyst); higher operating costs (lower efficiency means that 

more reagent is needed to accomplish a given reduction in NOX); and finally, has limited 

NOX reduction capability (typically 30 to 40 percent with some cases achieving 
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reductions in the 50 percent range). SCR, on the other hand, offers lower operating costs 

and the opportunity for very high NOX reductions (up to 90 percent and higher).

Operating costs are driven primarily by the consumption of the chemical reagent –

usually urea for SNCR and ammonia for SCR, - which in turn is dependent upon the 

efficiency of the process (usually referred to in terms of reagent utilization) as well as the 

initial NOX level and the desired percent reduction. Two additional parameters important 

in the overall operating costs are: (1) the potential contamination of coal fly ash by 

ammonia making it unsaleable; and (2) the life cycle of the catalyst due to premature 

“poisoning.” 

Selective Catalytic Reduction

The selective catalytic reduction (SCR) process uses a catalyst with ammonia gas 

(NH3) to reduce the NO and NO2 in the flue gas to molecular nitrogen and water. The 

ammonia gas is diluted with air or steam, and this mixture is injected into the flue gas 

upstream of a metal catalyst bed (composed of vanadium, titanium, platinum, or zeolite). 

In the reactor, the reduction reactions occur at the catalyst surface. The SCR catalyst bed 

reactor is usually located between the economizer outlet and air heater inlet. The catalyst 

modules take up a considerable amount of space; in addition ductwork must be added for 

the ammonia injection section. There is not always room in an existing boiler to retrofit 

an SCR system. As a consequence, fan capacity may have to be increased, owing to the 

incremental pressure drop from the SCR and associated ductwork. In some cases, the 

boiler must be modified to increase the economizer exit temperature to the minimum 

and/or the air preheater must be modified. Installation of an SCR on a boiler is sitespecific and this results in a range of capital costs for SCR systems on boilers.

Selective Noncatalytic Reduction

The selective noncatalytic reduction (SNCR) process is based on the same basic 

chemistry of reducing the NO and NO2 in the flue gas to molecular nitrogen and water 

but does not require the use of a catalyst to prompt these reactions. Instead, the reducing 

agent is injected into the flue gas stream at a point where the flue gas temperature is 

within a very specific temperature range. A minimum of 0.5 seconds of residence time is 

required at a temperature of about 1800oF to achieve high (50 to 60 percent) NOX

removal with SNCR. Good dispersion of the reagent in the flue gas is also needed to get 

good utilization of the reagent and to avoid excessive ammonia slip from the process. 

The need for a sufficient volume in the boiler at the right temperature window precludes 

the application of SNCR in all types of industrial boilers.

PM Reduction Overview

Particulate matter is generated by a variety of physical and chemical processes. It 

is emitted to the atmosphere through combustion, industrial processes, fugitive emissions 

and natural sources. In combustion processes, the mineral matter (inorganic impurities) is 
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converted to ash. The particles suspended in the flue gas are known as fly ash. Fly ash 

constitutes the primary particulate matter, which enters the particulate control device. 

Particulate matter is in general referred to as "PM", " PM10", " PM2.5" (particulate matter 

(PM) with an aerodynamic equivalent diameter of 10 microns or less and 2.5 microns or 

less, respectively).

Quantity and characteristics of the fly ash and particle size distribution depend on 

the mineral matter content of the fuel, combustion system, and operating conditions. 

Combustion technique mainly determines the particle size distribution in the fly ash and 

hence the final particulate emissions. Common combustion systems in pulverized coal 

firing include dry bottom, wall (front, opposed) and corner (tangential) burners and wet 

bottom furnaces. In dry bottom boilers, 10 to 20 percent of the ash is discharged as dry, 

bottom ash. In wet bottom boilers, 50 to 60 percent of the ash is discharged at the bottom 

of the boiler as slag. Stokers or grate-fired boilers are used to burn coal, wood and waste. 

The majority of the ash falls through the grate and is discharged as bottom ash. Mineral 

composition of the coal and the amount of carbon in the fly ash determine the quantity, 

resistivity and cohesivity of the fly ash. 

PM emissions from other point source processes involve similar phenomena 

where particulate matter is carried with the flue gas, in suspension to the stack. Hence, 

the general technologies applicable to one source are typically suitable for the others as 

well. Factors such as type and quantity of PM, characteristics of the process gas 

(temperature, moisture, other contaminants) have a major influence on the selection and 

design of the PM control technology.

PM Control Technologies 

The following four major types of particulate controls technologies are common 

for a variety of applications:

Wet scrubbers

Scrubbers work on the principle of rapid mixing and impingement of the 

particulate with the liquid droplets and subsequent removal with the liquid waste. For 

particulate controls the “venturi scrubber” is an effective technology whose performance 

is directly related to the pressure loss across the venturi section of the scrubber. Venturi 

scrubbers are effective devices for particulate control. However, for higher collecting 

efficiencies and a wider range of particulate sizes, higher pressures are required. Highenergy scrubbers refer to designs operating at pressure losses of 50 to 70 inches of water. 

Of course, higher pressure translates to higher energy consumption. Performance of 

scrubbers varies significantly across particle size range with as little as 50 percent capture 

for small (<2 microns) sizes to 99 percent for larger (>5 microns) sizes, on a mass basis.

Electrostatic Precipitators (ESP)
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ESP’s operate on the principle of electrophoresis, by imparting a charge to the 

particulates and collecting them on opposed charged plates. Dry vs. wet refers to whether 

the gas is water cooled and saturated prior to entering the charged plate area, or is 

collected dry on the plates. In gases with high moisture content, dry ESPs are not suitable 

because the wet gas would severely limit the ability to collect the “sticky” particulates 

from the plates. The wet ESP technology is capable of very high removal efficiencies 

and is well suited for the wet gas environments. Both types of ESPs are capable of 

greater than 99 percent removal of particle sizes above 1 micron on a mass basis. 

Fabric Filters

These are essentially “giant” vacuum cleaners. As in the case of the dry ESP, 

Fabric Filters (FFs, sometimes called baghouses) are not well suited for wet gas 

applications. However FFs are extremely efficient in collecting PM including fine 

(submicron) size fractions. 

Cyclones 

Cyclones are devices that separate particulates from the gas stream through 

aerodynamic/centrifugal forces. However, the technology is only effective in removing 

larger size particles (greater than about five microns).

3.4. Costs of Technology 

3.4.1. NOX Technologies

A representative summary of range of costs associated with various technologies 

for NOX control in industrial boilers is provided in Table III-4, taken from Reference 4. 

Capital costs and pollutant removal costs (in $/ton of pollutant removed) are given for 

three different boiler sizes: 1000, 500, and 100 MMBtu/hr. For each boiler size, the 

range of costs corresponds to a range of capacities from about low (5 to 14 percent of 

capacity) to high (86 to 93 percent of capacity). Industrial boilers have a wider range of 

sizes than EGUs and often operate over a wider range of capacities.

Low-NOX Burners (LNBs)

The capital costs for coal burners range from $2,500 to $5,100 per MMBtu/hr of 

boiler size. The lower end of this range applies when existing burners are modified 

instead of replaced to achieve lower NOX. Operating costs are negligible unless 

increased unburned carbon results in lost revenues from ash sales. An outage is generally 

required when implementing this technology, but coal-flow sensors and adjustable 

orifices are best installed when a mill is out of service. Low-NOX Burners provide 

moderate NOX reductions in the range of 30 to 50 percent at moderate to high cost ($200 

to $3,000 per ton of NOX removed). The size of the boiler affects both the capital cost 
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and the cost per ton. The combination of LNBs and overfire air (OFA), with or without 

flue gas recirculation (FGR), is more expensive but NOX reduction is higher, as high as 

80 percent for gas-fired boilers. From a schedule standpoint, LBB/OFA retrofit projects 

can require outages of 3 to 6 weeks, depending on factors such as scope of work, 

integration with other plant outage requirements, etc.

SNCR

The capital costs for SNCR application are low making it an attractive option for 

moderate NOX reductions (about 40 percent). As discussed above, the NOX reduction 

that can be achieved will vary from one boiler to another, and depend on the residence 

time available in the boiler in which the temperatures fall within the window for the 

SNCR chemistry to take place. Capital costs range from $2,000 to $4,000 per MMBtu/hr 

for industrial boilers. Operating costs are driven primarily by the consumption of the 

chemical reagent – usually urea for SNCR - which in turn is dependent upon the 

efficiency of the control equipment as well as the initial NOX level and the desired 

percent reduction. These are typically in the range of $1,300 to $10,000/ton of NOX.

An additional consideration important in the overall operating costs for coal-fired 

boilers is the potential contamination of fly ash by ammonia, making it potentially 

unsalable.

SCR

Capital costs for retrofit SCR systems to industrial boilers are mostly within the 

range of $4,000 to $15,000 per MMBtu/hr. Installation of an SCR on a boiler is sitespecific and this results in a range of capital costs for SCR systems on boilers. Coal-fired 

boilers have higher capital costs. The systems must be larger to allow for flow of fly ash 

through the catalyst without plugging. Catalyst activity deteriorates faster in coal-fired 

boilers because of the higher levels of contaminants in the flue gas (like arsenic) and the 

deposition of ash on the catalyst. Catalysts must be replaced more frequently in coalfired systems, which increases the operating cost. The lower end of this range applies to 

retrofits with nominal difficulty. The high end of the range would typically be associated 

with retrofits having significantly impeded construction access, extensive relocations, and 

difficult ductwork transitions.

In addition to catalyst replacement costs, operating costs are mainly driven by 

cost of reagent, energy penalty (pressure loss, ammonia vaporization) and dedicated O 

and M costs. SCR technology offers very high NOX reductions (80 percent or better); the 

cost per ton of NOX removed is considerably higher than SNCR, although the overall 

NOX reduction is higher. 

3.4.2. SO2 Technologies 

Both wet and dry scrubbers are in wide commercial use in the U.S. The capital 

costs for new or retrofit wet or dry scrubbers are high when compared to the capital costs 
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for NOX and PM controls (Khan, 2004b). Dry sorbent injection (DSI) has lower capital 

costs than a spray dryer absorber (SDA), although DSI can only achieve about 40 percent 

SO2 reduction. SDA systems can achieve 90 percent reduction. Capital costs for DSI are 

in the range of $8,600 to $26,000 per MMBtu/hr, depending on the size of the system and 

on the sulfur content of the fuel. Capital costs for SDA systems are about double that for 

DSI systems, but the cost per ton of SO2 removed is similar: $400 to $4,000 per ton of 

SO2 removed. These costs are higher than the costs for scrubbers on EGUs, which are 

only $100 to $200 per ton of SO2 removed. 

Wet FGD systems also remove 90 percent and higher of the SO2, but the capital 

cost is about 50% higher than the cost for an SDA system. The costs per ton of SO2

removed are similar to the costs for SDA for coal-fired boilers. Costs per ton of SO2 are 

estimated to be about twice as high for oil-fired boilers as compared to coal-fired boilers.

3.4.3. PM Technologies

As with most control technologies, the costs of PM controls involve both capital 

and operating costs. A cost-effectiveness indicator, such as $/ton as is typically used for 

other technologies (e.g. NOX and SO2), is very difficult to address for generic PM 

control costs, as the range of PM reductions for different fuels and processes is so wide 

that cost ranges become useless. An attempt to summarize costs in terms of capital and 

O&M components is presented below. 

Capital

While it is customary to indicate capital costs on a $/kW basis for power 

generation applications, this is not relevant for non-power applications since no 

electricity is generated. However, one of the main parameters dictating the “sizing” and 

hence, the costs of a PM control device, is the quantity of flue gas it must handle. As a 

result, it is more appropriate to generalize capital costs per actual cubic feet per minute 

(ACFM) of gas flow and is given on a “$/ACFM” basis. The following values represent 

typical costs for several of these technologies (these numbers reflect unit sizes ranging 

from utility-size units up to about 2,000,000 ACFM to smaller process down to about 

10,000 ACFM)) 

• Dry ESPs - $15 - $40/ACFM

• Wet ESPs - $15 - $40/ACFM

• Reverse Air Fabric Filter - $17 - $40/ACFM

• Pulse Jet Fabric Filter - $12 - $40/ACFM

• Venturi Scrubber - $5 - $20/ACFM

• Cyclone - $1 - $5/ACFM

O&M

O&M costs are difficult to generalize for such a variety of technologies and 

applications, as they are affected by many parameters that include type of fuel, type of 
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process, local ash disposal options, local cost of power, etc. O&M costs include fixed 

costs (FOM) and variable costs (VOM). The costs provided below are presented in 

$/year-ACFM and reflect costs for coal-based fuels but should reasonably apply to other 

sources as well.

Fixed O&M

• Dry ESPs - $0.25 - $0.65/yr-ACFM

• Wet ESPs - $0.15- $0.50/yr-ACFM 

• Reverse Air Fabric Filter - $0.35 - $0.75/yr-ACFM

• Pulse Jet Fabric Filter - $0.50 - $0.90/yr-ACFM

• Venturi Scrubber - $0.25 - $0.65/yr-ACFM

• Cyclone – Not applicable

Variable O&M

• Dry ESPs - $0.45 - $0.60/yr-ACFM

• Wet ESPs - $0.25 - $0.50/yr-ACFM 

• Reverse Air Fabric Filter - $0.70 - $0.80/yr-ACFM

• Pulse Jet Fabric Filter - $.90 - $1.1/yr-ACFM

• Venturi Scrubber - $1.2 - $1.8/yr-ACFM

• Cyclone – Not applicable
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References

Fernando, R., The use of petroleum coke in coal-fired plant. IEA Coal Research: 

London, 2001.

Khan, S. Methodology, Assumptions, and References Preliminary NOX Controls Cost 

Estimates for Industrial Boilers. 

http://cascade.epa.gov/RightSite/dk_public_collection_item_detail.htm?ObjectType=dk_

docket_item&cid=OAR-2003-0053-0170&ShowList=xreferences&Action=view 

(Accessed February 19, 2004a).

Khan, S. Methodology, Assumptions, and References Preliminary SO2 Controls Cost 

Estimates For Industrial Boilers. 

http://cascade.epa.gov/RightSite/dk_public_collection_item_detail.htm?ObjectType=dk_

docket_item&cid=OAR-2003-0053-0166&ShowList=xreferences&Action=view 

(Accessed February 14, 2004b).

U.S. Environmental Protection Agency, National Air Pollutant Emissions Trends, 1900-

1998, U.S. EPA and the States: Working Together for Cleaner Air; Nizich, S. V.; Pope, 

A. A.; Driver, L. M., EPA-454/R-00-002 (NTIS PB2000-108054); Office of Air Quality 

Planning and Standards: Research Triangle Park, NC, March 2000.

U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air 

Pollutants for Industrial/ Commercial/Institutional Boilers and Process Heaters, 

http://cascade.epa.gov/RightSite/dk_public_collection_detail.htm?ObjectType=dk_docke

t_collection&cid=OAR-2002-0058&ShowList=items&Action=view (Accessed February 

25, 2004).
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Table III-4. NOX reduction and control costs for industrial boilers (Khan, 2004a).

Fuel Technology

NOX

Reduction $/Ton of Pollutant vs. Boiler Size

Capital Costs $/ MMBtu/hr vs. Boiler 

Size

%

1000 

MMBtu/hr

250 

MMBtu/hr

100 

MMBtu/hr

1000 

MMBtu/hr

250 

MMBtu/hr

100 

MMBtu/hr

Gas LNB/OFA 60 280 - 5260 424 - 7973 559 - 10521 1280 1940 2554

Gas LNB/OFA/GR 80 368 - 6204 543 - 9415 700 - 12374 2000 3031 3991

Oil LNB/OFA(1) 30 306 - 2630 464 - 3986 612 - 5260 1280 1940 2554

Oil LNB/OFA/GR (1) 50 326 - 2505 477 - 3790 615 - 4973 2000 3031 3991

Oil LNB/OFA/GR (2) 30 741 - 5694 1085 - 8613 1399 - 11303 2000 3031 3991

Coal LNB (subbit.) 51 256 - 1520 389 - 2305 512 - 3033 2554 3872 5097

Coal LNB/OFA (subbit.) 65 306 - 1727 454 - 2608 593 - 3428 3649 5531 7281

Coal LNB/OFA (bit) 51 392 - 2197 581 - 3317 757 - 4358 3649 5531 7281

Gas SNCR 40 1842 - 14165 2193 - 20870 2521 - 27105 2111 3200 4212

Oil SNCR (1) 40 1485 - 4271 1670 - 5892 1840 - 7399 2045 3100 4081

Oil SNCR (2) 40 1628 - 5497 1889 - 7753 2123 - 9842 2045 3100 4081

Coal SNCR 40 1285 - 2962 1473 - 4015 1625 - 4970 2639 4000 5266

Gas SCR 80 986 - 14815 1354 - 21095 1689 - 26859 4014 6084 8009

Oil SCR (1) 80 760 - 10458 997 - 14443 1245 - 18544 5547 8407 11067

Oil SCR (2) 80 1017 - 14601 1343 - 20113 1694 - 25838 5547 8407 11067

Coal SCR 80 876 - 4481 1123 - 5924 1349 - 7262 7298 11062 14562

Notes

(1) 0.5 lb/MMBtu inlet NOX

(2) 0.36 lb/MMBtu inlet NOX
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3-18

Table III-5. SO2 reduction and control costs for industrial boilers (Khan, 2004b).

Fuel Technology

SO2

Reduction $/Ton of Pollutant vs. Boiler Size

Capital Costs $/ MMBtu/hr vs. Boiler 

Size

%

1000 

MMBtu/hr

250 

MMBtu/hr

100 

MMBtu/hr

1000 

MMBtu/hr

250 

MMBtu/hr

100 

MMBtu/hr

Coal DSI high S coal 40 633 - 1703 763 - 2471 943 - 3543 12508 18838 26835

Coal DSI lower S coal 40 697 - 1986 849 - 2952 1075 - 4283 8648 12987 17995

Coal SDA 90 381 - 1500 569 - 2611 790 - 3920 20275 36226 54679

Coal Wet FGD high S coal 90 373 - 1789 528 - 2708 664 - 3513 32313 48857 64240

Coal Wet FGD lower S coal 90 461 - 2273 661 - 3460 836 - 4495 29888 45283 59598

Oil Wet FGD 90 693 - 5082 1011 - 7801 1285 - 10160 27455 41604 54761
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 4-1

4-1

4. PORTLAND CEMENT KILNS

Portland cement is a main ingredient for concrete and other common building 

materials. Portland cement is mainly composed of clinker, a material formed by heating 

limestone and other ingredients to temperatures over 2,650oF. High combustion 

temperatures require significant amounts of fuel and can result in significant emissions of 

NOX and SO2. Crushing of ingredients and finished clinker can release dust and 

particles. Ammonia is sometimes produced during the heating of limestone.

The cement industry has seen significant growth in capacity and technology over 

the last 30 years. In 2000, the U.S. had 201 cement kilns with the annual capacity to 

produce 84 million metrics tons of concrete, with production projected to grow to 109 

million metric tons in 2004 (Portland Cement Association, 2000).

4.1. Description of Cement-Making Processes

Concrete is a combination of Portland cement, sand, and gravel. The key 

component of Portland cement is clinker, a material produced by heating limestone and 

other raw materials to temperatures over 2,650oF, requiring combustion temperatures of 

about 3,000oF. These high temperatures are normally achieved in a rotary kiln, as shown 

in Figure IV-1. Feed material is added at the elevated end of the rotating, refractorylined, cylindrical kiln and the feed gradually tumbles to the high-temperature end of the 

kiln and the main combustion zone, sometimes referred to as the "Burn Zone." The tilted 

design of the cement kiln allows gravity to assist the motion of the clinker material while 

hot exhaust gases move upward and exit at the elevated end of the kiln. 

Figure IV-1. Simplified Sketch of a Rotary Kiln.

Raw material, or 

material from 

precalciner 

Clinker 

Out

Flame –

the "Burn Zone"

Exhaust Gases 

to Precalciner 

and Gas 

Cleaning

Fuel and 

Air In
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4-2

Cement kilns fall into four general process categories. Preheater kilns preheat and 

partially calcine feed material in a series of cyclones or grates prior to admitting the feed 

to the rotary kiln. This additional heat supplements the heat in the exhaust from the kiln. 

The calcined feed then enters the rotary kiln at about 1,500oF to 1,650oF. Precalciner 

kilns, on the other hand, utilize a burner in a separate vessel along with a series of 

cyclones or grates to preheat and calcine the feed. In long kiln systems, the raw feed 

material is added to the rotary kiln itself as either a powder (“dry”) or a slurry (“wet”). 

Long wet and long dry kilns do not have preheaters and have much longer rotary kilns, 

with wet process kilns being the longest - normally several hundred feet long. Preheater 

and precalciner kilns are more energy efficient than long wet or long dry kilns and 

typically have greater capacity. A preheater kiln is similar, but fuel is not added and 

there is no burner on the cyclonic preheater portion. Preheaters could also be replaced 

with suspension preheaters, but these are less common. If past trends continue, many of 

the existing long wet kilns and dry kilns are expected to be replaced with precalciner and 

preheater kilns since precalciner and preheater kilns are more energy efficient and also 

typically have greater capacity. 

Coal is the fuel of choice in cement kilns, primarily because of its low cost, but 

also because the coal ash contributes somewhat to the product. The current fuel use in 

cement kilns is about 82% coal; 4% natural gas; and 14% other fuels, mainly combustible 

waste (industrial waste, tires, sewage sludge, etc.). Fuel nitrogen therefore contributes a 

small but significant amount to the total NOX for nearly all cement applications (see the 

section on NOX controls included later). 

Recent years have seen Portland cement plant capacity stretched by high demand, 

making technologies that can increase capacity without increased capital expenditures 

very attractive. The industry is therefore developing technologies that improve facility’s 

outputs or reduce their operating costs. Incidentally, some of these technologies also 

offer the potential to reduce NOX and other emissions.

4.2. Review of BART-Eligible Cement Kilns in the MANE-VU Region

NESCAUM’s analysis of BART-eligible sources in the MANE-VU Region6

(NESCAUM, 2004) identified two Portland cement facilities as being eligible for BART. 

The facilities are shown in Table IV-1. [Editor’s note: Additional facilities are likely to 

be added when PA and NY inventories are complete]

 

6

 NESCAUM does not believe that there are any BART-eligible sources in the State of Vermont or any of 

the member Tribes in MANE-VU and thus we have not developed lists for these jurisdictions. In addition, 

Pennsylvania and the District of Columbia have developed BART-Eligible source lists following their own 

methodology and any identified sources are contained here and in the final list in Appendix A.
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4-3

Table IV-1 BART-Eligible Portland Cement facilities in MANE-VU Region 

Facility Kiln type

Capacity, 

thousands 

tons/yr

Primary 

Fuel(s)

St. Lawrence Cement (Hagerstown, MD) Dry 550 Coal

Dragon Products (Thomaston, ME) Wet 392

Coal, 

petcoke

4.3. Available Control Technologies

A number of technologies exist for controlling emissions from cement kilns. 

Secondary (post-combustion) control devices can be helpful in reducing emissions, and a 

variety of these are available. Many technologies and techniques have been developed in 

response to a specific environmental need and target a specific pollutant, sometimes 

achieving reduction in other pollutants at the same time. Both secondary controls and 

process changes are discussed below, grouped by their targeted pollutant. When 

additional emissions reductions are possible, they are noted with the targeted pollutant. 

Controls are examined for SO2, NOX, PM, and VOCs.

4.3.1. SO2 Controls

In contrast with electric utility boilers, SO2 emissions from rotary kilns producing 

cement clinker under oxidizing conditions are nearly independent of fuel sulfur input, 

but, rather, are closely related to the amount of sulfide (e.g. pyrite) in kiln feed and to the 

molar ratio of total sulfur to total alkali input to the system. In cement kilns SO2

emissions generally depend on:

• Inherent SO2 removal efficiency of kiln system,

• Form of sulfur (e.g. pyritic) and sulfur concentrations in raw material,

• Molecular ratio between sulfur and alkalis,

• Prevailing conditions (oxidizing or reducing) and their location within

kiln, and

• Temperature profile in the kiln system.

Depending upon the level of sulfur in a plant’s limestone compared to the sulfur 

content of its heating fuel, fuel switching may not be sufficient to reduce SO2 emissions 

(Tanna and Schipholt, 2004). However, when fuel sulfur levels are high, fuel switching 

may have a significant benefit of reducing SO2 levels. 

In addition to the control techniques used in the electric utility boilers, cement 

plants may also resort to other basic reductions techniques involving reduction of sulfur 

input to the kiln, by switching fuels or changing the limestone, or reduction of SO2

emissions from reducing both the sulfur in the sources and using a secondary control 

device. It is common to achieve some level of SO2 reductions when seeking to reduce 

another pollutant, usually NOX (technologies targeting another pollutant, but also 
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reducing SO2, are described in the NOX and PM sections below). In addition to 

considering a change in the primary fuel for the kiln, staged combustion with mid-kiln 

injection of a low-sulfur fuel may be considered for reducing SO2. Including highpressure air injection at a mid-kiln firing site can limit oxygen in the kiln and suppress 

SO2 formation (Hansen, 2002). Since these techniques are primarily used to reduce NOX, 

more information about mid-kiln fuel injection can be found in the section on NOX

emissions, but other specific SO2 control technologies applicable to cement kilns are 

listed below.

Fuel Switching 

Selecting a fuel with lower sulfur content, a strategy commonly adopted in the 

utility boilers, is less effective in cement-making systems, where SO2 emissions are not 

strongly dependent on fuel sulfur content. Depending upon the level of sulfur in a plant’s 

limestone compared to the sulfur content of its heating fuel, fuel switching may not be 

sufficient to reduce SO2 emissions (Tanna and Schipholt, 2004). However, when fuel 

sulfur levels are high, fuel switching may have a significant benefit in SO2 levels. 

Inherent Removal 

Raw materials, primarily limestone, are preheated in the cement-making process 

either in the preheater tower or in the rotary kiln. In either case, the limestone comes in 

contact with hot combustion exhaust gases. The calcium in the lime reacts with SO2 in 

the gas, providing in-process removal of sulfur in the kiln system. Removal efficiencies 

in rotary kiln systems range between 38% and 99% of sulfur input, and 50% to 70% of 

the remaining SO2 is removed from exhaust gases when passing through an in-line raw 

mill system (Miller et al., 2001).

Process Alterations 

The following methods to remove and prevent formation of SO2 by modifying or 

controlling conditions in the system are available due to the nature of the Portland cement 

manufacturing process:

• The oxygen concentration of the exhaust gases can be controlled to ensure 

sufficient oxygen exists to stabilize alkali and calcium sulfate compounds 

formed in the process. Concentrations of O2 and, more importantly CO, 

have a strong influence on the stability of alkali and calcium sulfates in the 

burning zone. Control of burning- zone O2 and CO concentrations is a 

widely used industrial practice, and a control technique applicable to all 

rotary kilns producing cement clinker. The downside of this technique is 

the more favorable conditions created for generation of NOX in the rotary 

kiln.

• Burning-zone flame shape can be modified to minimize localized reducing 

conditions. It has been observed (Hansen, 1986) that flame impingement 

in the hot zone had a major effect on SO2 emissions from the kiln, even if 

total oxygen is sufficient to fully combust all fuel. Avoiding flame 

impingement in the burning zone minimizes SO2 formation. Avoiding 

flame impingement on the clinker, a technique applicable to all rotary 
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4-5

kilns producing cement clinker, requires proper solid fuel preparation and 

proper flame shaping and control.

• Raw materials can be altered to affect the alkali/sulfur molar ratio. SO2

concentrations in kiln exit gases vary with the molar ratio of alkali to 

sulfur; when alkalis are in excess of sulfur, SO2 emissions are typically 

low, due to more sulfur being retained in clinker as alkali sulfates. Also, 

kiln feed containing carbon seems to directly cause SO2 emissions. 

Changing raw materials may reduce SO2 emissions. Substituting a raw 

material containing pyritic sulfur or organic sulfur with one containing 

lesser amounts of these compounds reduces SO2 emissions. Replacement 

of raw materials, however, is often constrained by economic 

considerations, while alkali input increase may also be limited by cement 

product quality specifications on total alkali in cement. 

• Alterations to system can influence SO2 emissions. It has been found that 

an improved distribution of kiln feed may equalize temperatures in bottom 

stage cyclones and reduce SO2 emission by as much as 20% (Miller, 

2001).

Scrubbers

Dry Reagent Injection

Steuch and Johansen (1991) found that Ca (OH)2 (hydrated lime) was the most 

effective scrubbing agent, particularly when added to the kiln feed and when the exhaust 

gases were near the dew point. Adding quicklime or hydrated lime into the upper 

preheater cyclones demonstrated up to 70% removal efficiency (Nielse, 1991). 

Several dry reagent systems are available:

• The RMC Pacific process (Sheth, 1991) injects dry Ca(OH)2, and with 

different stoichiometric ratios (40:1 to 50:1), has obtained efficiencies 

ranging from 55% to 65%. SO2 removal of 80% was obtained with 

injection into the roller mill.

• Krupp Polysius Polydesox process uses hydrated lime where SO2 in the 

raw feed tends to form from pyrites and obtains removal efficiencies of up 

to 85% (Miller, 2001).

• De-SoX Cyclone, by Fuller Company (Miller, 2001), reduces SO2

emissions in a precalciner kiln by removing a portion of the gases from the 

precalciner outlet to a cyclone, and from there to the Stage II cyclone 

where pyritic sulfur in kiln feed is decomposed into SO2. The feed (or 

“raw meal”), containing freshly produced lime, is discharged into the 

outlet duct of the second stage (this process is known as hot meal 

injection). Removal efficiencies of 5 to 30% are claimed.

Lime/Limestone Spray Dryer Absorber 
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4-6

Design stoichiometric ratios of calcium to sulfur for spray dryer systems in utility 

boilers are typically between 0.9 and 1.5, with most below 1.0. These SO2 scrubbers are 

designed for removal efficiencies in excess of 80%.

SO2 reacts with CaCO3, to form CaSO4, a reaction that becomes more complete as 

the temperature and the fineness of CaCO3 increase. The presence of water vapor also 

increases conversion.

Most of the spray dryer type SO2 control technologies in the cement industry are 

applied to preheater or preheater/precalciner kilns. Exhaust gases from long dry kilns are 

cooled by either spray water introduced into the feed end of the kiln or by dilution aircooling after the gases leave the kiln. Adding a conditioning tower to replace water 

sprays or dilution air enables the alkaline slurry system to be used to reduce SO2

emissions (the equivalent of a spray dryer). The range of temperatures for exit gases from 

long wet kilns does not allow the use of an alkaline slurry spray dryer type scrubber 

because the addition of the lime slurry may drop the exhaust gases temperature below the 

acid dew point, creating significant plugging and corrosion problems in the downstream 

Particulate Control Device (PCD), duct work, and induced draft (ID) fan.

RMC Pacific's Alkaline Slurry Injection System (Sheth, 1991)

RMC Pacific uses a hydrated lime, spray dryer absorber to reduce SO2 emissions. 

The captured sulfur compounds are returned as a portion of the raw material feedstock to 

the roller mill, which results in no scrubber effluent or sludge disposal. When SO2

emissions are high and preheater exit gas temperatures are low, sufficient lime slurry 

cannot be added to reduce SO2 to acceptable levels. With different stoichiometric ratios 

(40:1 to 50:1), the process has obtained efficiencies ranging from 55% to 65%. SO2

removal of 80% was obtained with injection into the roller mill.

EnviroCare Microfine Lime System (Miller, 2001)

This system uses the existing gas conditioning tower to introduce the scrubbing 

reagent (water suspension of finely pulverized calcium hydroxide, Ca (OH)2). The small 

size of the lime particles (3-10 microns) allows the particles to dissolve in water droplets 

quickly and react with SO2 as it is absorbed into the water droplet. The dried lime 

continues to react with any remaining SO2 in the downstream kiln system and PCD. Lime 

injection rate can be optimized through a feedback control loop from an SO2 monitor. 

EnviroCare claims an SO2 removal efficiency of greater than 90%.

Wet SO2 Scrubbers

Wet scrubbers have been used successfully in the utility industry. Calcium sulfate 

scaling and cementitious buildup when a wet scrubber is used for acid gas control applied 

to the exhaust gas from a cement kiln can be avoided if these systems are installed 

downstream of a high efficiency PCD (e.g., fabric filter). Failure of the PCD can pose 

difficult problems for a downstream wet scrubber.
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4-7

Fuller Company (FLS Miljø) (Miller, 2001)

The Monsanto Dyna Wave wet SO2 scrubber has been installed by the Fuller 

Company and used on several cement kilns in the U.S. This wet scrubber is designed to 

remove SO2, halide gases, and some particulate matter. 

The scrubber, typically located downstream from the kiln PCD and operated 

under positive pressure, uses limestone as the absorbent. A slurry (approximately 20% 

limestone and 80% water) produced in the mixing tank is sprayed countercurrent to the 

gas flow to cool the gases and react with SO2 forming calcium sulfite (CaSO3) and 

calcium sulfate (CaSO4), which precipitates. Air is sparged into the sump at the bottom of 

the tower to oxidize CaSO3 to CaSO4+2H2O (gypsum).

Monsanto EnviroChem DynaWave (Miller, 2001)

DynaWave is a "Reverse Jet" scrubber that can simultaneously accomplish 

several gas cleaning/process needs: hot gas quenching, particulate removal, and acid gas 

absorption. The reverse jet is an annular orifice scrubber having one to three large-bore 

nozzles through which a relatively large volume of scrubbing liquid is injected counter to 

the gas flow to create a froth zone. The gas collides with the liquid, forcing the liquid 

radialy outward toward the wall. A standing wave, created at the point the liquid is 

reversed by the gas, is an extremely turbulent region where the gas absorption and 

particulate collection occurs. 

The system is a tailpipe system generally installed downstream of the PCD, and 

operates with a saturated gas stream. Therefore, it would likely be applicable to most if 

not all the cement kilns. A single-stage DynaWave scrubber in full-scale operation has a 

reported SO2 removal efficiency of about 90%. Monsanto EnviroChem claims that 

multiple units may be installed in series to achieve whatever removal efficiency is 

required (e.g., 99.9%).

4.3.2. NOX Controls

The following sections discuss the formation of NOX in cement kilns, potential 

NOX control techniques, NOX control in the cement industry, and the cost effectiveness 

of applicable controls. 

 NOX Formation in Kiln Systems 

Nitrogen oxides (NOX) are formed during the combustion of fuels in the cementmaking process. In kiln exhaust gases, more than 90% of NOX is NO, with NO2 generally 

making up the remainder from rotary kilns producing cement clinkers (Gardeik, 1984). 

There are three different NOX formation mechanisms - thermal, fuel, and feed NOX -

typically contributing to NOX emissions. 
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4-8

Thermal NOX

Thermal NOX is formed by oxidation of atmospheric molecular nitrogen at high 

temperatures (>1,200 °C). Most NOX formed in the high-temperature environment of the 

main combustion zone (burning zone) of a kiln is "thermal NOX". Since the flame 

temperature in a kiln is significantly above that threshold, a considerable amount of 

thermal NO is generated in the burning zone. 

While conditions in the burning zone of a cement kiln favor formation of thermal 

NOX, those prevalent in secondary combustion zones (e.g. calciners, preheater riser ducts 

and mid-kiln firing in long wet or dry kilns) with temperatures below 1200°C, are less 

conducive to significant thermal NOX formation. In that zone, formation of fuel NOX and 

feed NOx is more prevalent.

The amount of thermal NOX produced is related to fuel type, burning zone 

temperature, and oxygen content. Therefore, raw materials that are hard to burn (i.e., 

materials that require more heat input per ton of clinker produced) generate more NOX.

Fuel NOX

Fuel NOX is the result of oxidation of nitrogen compounds in fuel. Fuel nitrogen 

is only partially converted into NOX during combustion. The amount formed depends on 

fuel type, precalciner type and precalciner temperature. NOX formed in the secondary 

combustion zone, primarily fuel NOX (Gardeik, 1984), depends on: 

• Nitrogen concentration in the fuel,

• Oxygen concentration in the combustion zone,

• Initial NO concentration in the combustion gas,

• Volatile concentration in the (solid) fuel, and

• Temperature in the secondary combustion zone.

As opposed to the burning zone of the kiln, where higher temperatures result in 

much higher NOX formation, higher temperatures (up to 1100°C) in the precalciner may 

actually reduce NOX emissions when a fuel containing nitrogen is used (Nielsen, 1990). 

 In the design of modern low-NOX calciners, high temperatures and reducing 

conditions are proven methods for suppressing the formation of fuel NOX generated in 

the precalciner, and for destroying thermal NOX generated in the burning zone of the 

rotary kiln (Keefe and Shenk, 2002).

Feed NOX

NOX emissions can also result from the oxidation of nitrogen compounds in the 

raw material feed to the kiln (feed NOX). The range of nitrogen concentrations in various 
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4-9

kiln feeds is 20-1000 ppm (Gartner, 1983) and the potential contribution of feed NOX to 

total NOX emissions is 0.2-10 lbs of NOX per ton of clinker.

Up to 50% of feed nitrogen may be converted to NOX, if raw materials are heated 

slowly: with rapid heating, the conversion rate is much lower.

The following conclusions can be made for rotary kiln systems (Young and von 

Seebach, 1999):

• Formation of thermal NOX in the burning zone is the major contributor to 

NOX emissions from the kiln

• Fuel NOX is the major contributor in the secondary combustion zone of 

precalciner and riser duct fired preheater kilns

• Feed NOX is usually a minor contributor to the total NOX generated in 

rotary kiln systems.

It should be further noted that, due to the dynamic nature of kiln operations, NOX

formation can be highly variable so each kiln will tend to have unique NOX emission 

characteristics, inherent to the variability in cement manufacturing process. Figure IV-2 

illustrates the wide range of NOX emissions from different types of kilns.

NOX emissions rates are also site- and kiln-specific, and may be quite dissimilar 

between two apparently identical kilns, for causes not fully understood, but, probably 

connected to the raw materials used. Other causes for NOX emissions rate differences 

may result from different types or classes of cement products being produced; chemical 

variations between these different products can influence cement kiln operating 

parameters and thus NOX emissions. Short-term process transients such as kiln feed rates 

and fuel quality also affect NOX emissions. All of these factors can influence the 

applicability and costs of incorporating NOX controls.
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Figure IV-2. NOX emissions for various cement kiln types (USEPA, 1994). 

(SP: Suspension Preheater kilns)

NOX Control Techniques

There are two broad categories of NOX reduction techniques for cement kilns: 

1) process controls, including combustion modifications, that rely on reducing or 

inhibiting the formation of NOX in the manufacturing process (modifications for cement 

kilns include low-NOX Burners (LNB), secondary combustion, and staged combustion); 

and 2) post-combustion (secondary) controls, where flue gases are treated to remove 

NOX that has already been formed.

It should be noted that the quality of clinker produced in a kiln varies with 

characteristics of the combustion, so primary controls need to be selected carefully. Dry 

low-NOX (DLN) operation, for example, has seen varied levels of success. The main 

firing zone of the kiln requires very high temperatures and is not compatible with the 

lower flame temperature used by DLN to reduce NOX. Low excess air and air-staging 

are problematic control options for kilns because the kilns need an oxidizing environment 

not provided by those techniques. Despite these problems, indirect firing in combination 

with a LNB has been successfully used in some facilities, including California Portland 

Cement. Low-NOX combustion methods can be used in the precalciner because high 

temperatures are not required in that part of the process.

Indirect firing is a method that permits use of LNBs in the primary kiln burning 

zone. When indirect firing is used, pulverized coal is fed to and collected in a particulate 

matter collection system (a cyclone separator that exhausts gas through a fabric filter). 
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 4-11

4-11

The pulverized coal is then temporarily stored in a bin or hopper, where it is fed to the 

burner. This method allows less primary air to be used in the burner than with a directfired coal mill, resulting in less thermal NOX.

LNBs can be used when indirect firing is employed. When implementing indirect 

firing with LNBs, other process improvements are often implemented, such as better 

process controls. According to Portland Cement Association (1998), 20%-30% NOX

reductions can be achieved from the use of indirect firing with LNBs and associated 

process modifications. 

Combustion modifications are less successful at reducing NOX emissions in 

thermal processing applications (like cement kilns) than in boilers for steam and/or power 

production. Chemical reactions producing cement clinker require high material and gas 

temperatures, and product quality also requires an oxidizing atmosphere in the 

combustion zone of a cement kiln. Excessively high temperatures in the burning zone 

pose equipment damage risk, while temperatures too low will no longer produce a salable

product.

NOX emissions can also be affected by kiln feed chemical characteristics, feed 

chemical uniformity, and specific fuel consumption. As stated by EPA’s NOX Alternative 

Control Technique Document for the Cement Manufacturing Industry (USEPA, 1994), 

"For any given type of kiln, the amount of NOX formed is directly related to the amount 

of energy consumed in the cement-making process. Thus, measures that improve the 

energy efficiency of this process should reduce NOX emissions in terms of lb of NOX / 

ton of product." 

Following are some of the more common process modifications that have been 

made to reduce NOX emissions from cement kilns (NESCAUM, 2001):

• Changing fuel (e.g. natural gas to coal firing).

• Improving kiln feed chemical uniformity, for more stable kiln operations:

o Modifications to quarry operations,

o Raw material blending facilities, and

o On-line analytical control systems for raw material proportioning 

(e.g. kiln feed blending systems).

• Modifications to improve thermal efficiency, including:

o Reducing excess air infiltration,

o Increasing efficiency of cyclones in preheater kilns,

o Reducing the amount of moisture in slurry (wet process kilns 

only),

o Revising kiln chain systems in long wet or long dry kilns,

o Modifying or replacing clinker coolers to improve heat recovery 

and cooler efficiency,

o Initiating operator training programs, and
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o Returning as much cement kiln dust (CKD) as possible to the kiln 

system (without adversely affecting product quality).

• Installing or upgrading kiln system sensors and instrumentation.

• Installing or upgrading computer controls of kiln systems to stabilize kiln 

operation and avoid burning zone temperature variations.

According to Young and von Seebach (1999), industry data and experience show 

that control of burning zone temperature is the primary process control method applicable 

to lowering thermal NOX formation. Process modifications that allow better control of the 

kiln burning zone temperature will result in reducing thermal NOX formation and 

minimizing NOX spikes. Stable kiln operation, through feed chemical uniformity, results 

in overall NOX reductions of 10% - 15%, while poor kiln feed chemical uniformity 

results in overfiring the kiln, and higher NOX emissions.

Fuel Switching

Switching to a lower-nitrogen fuel in a precalciner may reduce NOX emissions, 

but the nitrogen content of the fuel burned in the burning zone has little or no effect on 

NOX generation. Generally, no relationship has been found between fuel nitrogen content 

and the NOX emissions from a cement kiln (Miller and Egelov, 1980).

Process Optimization and Automated Control

Process optimization is a common method for reducing NOX emissions from 

cement kilns. In principle, any effort that reduces the amount of fuel being fired to 

produce clinker will result in a reduction in NOX generation. In practice, process 

optimization often entails the use of advanced computer controls and instrumentation. 

Many of the primary NOX control technologies described are implemented along with 

process optimization to take advantage of their combined effects and to improve overall 

facility operation. NOX reductions reported in this Chapter are generally attributed to the 

changed combustion process (for example, mid-kiln firing). Combined reductions 

reported in a case study (NESCAUM, 2001) equivalent to 55% reduction in average NOX

emissions - from 845 lb/hr to 383 lb/hr – were achieved largely by reducing the 

variability of the process with a computer-automated optimization system. Mid-kiln 

firing provided additional NOX reduction for an overall NOX emission reduction of 59% 

from controls.

Flue Gas Recirculation

Flue gas recirculation (FGR) or water/steam injection into the main flame to 

reduce flame temperatures and NOX formation is not a viable method of reducing NOX in 

a cement kiln burning zone. FGR's effectiveness relies on cooling the flame and 

generating an oxygen deficient (reducing) atmosphere for combustion to reduce NOX

formation, conditions that are not compatible with cement kiln operation. High flame 
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temperature and an oxidizing atmosphere are process requirements to produce a quality 

clinker product.

Indirect Firing

Conversion from a direct coal firing system to an indirect firing system kiln with a 

low NOX burner may result in NOX reductions ranging from 0% to about 20% (Kupper et 

al., 1990; Schrsemli, 1990). Incorrect use of multi-channel (low NOX) burners can 

increase NOX rather than reduce NOX, and it has been found (Hansen, 1985) that less 

excess air in the kiln combustion gases results in less NO formation at the same burning 

zone temperature. NOX reductions of 15% were reported.

Low-NOX Burners 

LNBs have been successfully used in the primary burn zone and especially in the 

precalciner kilns. 

Secondary combustion zones have proven effective at reducing NOX emissions in 

cement kilns. In long kilns, secondary combustion can be partly accomplished by midkiln injection of fuel (less than 20% of kiln fuel). NOX emissions are reduced because 

less fuel is burned in the high temperature environment of the burning zone. Another 

NOX reducing technique is the use of fuel in the riser duct of preheater kilns, although, 

because of high prevailing temperatures, such reductions do not always occur. With 

precalciner kilns, which employ a secondary combustion zone at a much lower 

temperature than the burning zone, typically 60% of the fuel is burned in the precalciner, 

with the combustion air coming directly from the clinker cooler, and NOX emissions for 

these kilns are less than from long wet, long dry, or preheater kiln systems because 60% 

of the total fuel requirement is burned under lower temperature conditions where 

negligible amounts of thermal NOX are formed. Furthermore, precalciner kilns have the 

potential for staged combustion as a NOX control technique. All major equipment 

suppliers offer "low-NOX” precalciner designs. Fuel burned in a sub-stoichiometric O2 

environment creates a strongly reducing atmosphere (relatively high concentrations of 

CO) that inhibits formation of fuel NOX and destroys a portion of the NOX formed in the 

kiln burning zone. Additional tertiary combustion air is added later to complete 

combustion of the fuel.

Staged combustion has become a well-known method for reducing NOX

emissions from cement plants, but as NOX and CO emissions limits become more 

stringent, control via fuel and air staging are coming under reconsideration. Low- NOX

calciners combine high temperature combustion and firing under reducing conditions 

without staging fuel/air.

Low-NOX Precalciners

Precalciner kilns can employ LNBs because the temperature in the precalciner can 

be low enough to reduce thermal NOX but still be effective in heating the limestone. 
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 4-14

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Since roughly 60% of the fuel burned in a precalciner kiln is fired in the precalciner, NOX

reductions can be substantial. All new precalciner kilns are equipped with low-NOX

burners in the precalciner. Low-NOX precalciners have been shown to reduce NOX by 

30%-40% compared to conventional precalciners (Young and von Seebach, 1998). This 

reduction is from the precalciner-generated NOX, not for the entire kiln.

Several precalciner kilns in the U.S. have recently been retrofitted with these 

"two-NOX" calciners, and several new kiln lines have been installed using low-NOX

precalciner technology. Operating experience indicates a noticeable reduction in NOX per 

ton of clinker. Industry reports place the NOX reduction potential of staged combustion 

with a low-NOX precalciner at 30% - 40% when compared to a conventional precalciner 

kiln system.

Low-NOX precalciner is a proven way to reduce NOX emissions in a cementmaking system, and all new cement-making systems are expected to be built with it. They 

come in two types, “in-line”, commonly used with “normal” fuels (e.g. coal, oil, gas), or 

“separate-line”, selected for difficult-to-burn fuels (e.g. petroleum coke and anthracite) 

because its high oxygen atmosphere ensures improved fuel burnout. In-line calciners 

have lower specific NOX emissions than separate-line ones, but both are capable of 

meeting current CO/NOX emission standards for any combination of fuel and feed, and 

both are dependent on the presence of strong reduction and oxidation zones.

CemStar

Another approach that has been proven effective in reducing NOX is the patented 

CemStar process, originally developed and sold as a method to increase production of 

clinker from existing kilns while minimizing capital expenditures (Young, 1995; Young, 

1996). In the CemStar process, steel or blast furnace slag is introduced as feed material 

into the kiln. The slag is generally added at the inlet to the rotary kiln (typically after the 

precalciner or preheater), regardless of kiln type. Unlike normal cement materials, which 

require significant processing to achieve adequate grain size, the slag need only be 

crushed to 3/4 to 1-1/2 inch pieces. Minimal processing is necessary because the slag has 

a low melting temperature and its chemical nature is very similar to the desired clinker. 

Minimal slag processing permits the equipment for the CemStar to be inexpensive and 

also reduces energy consumption per unit of clinker produced. Moreover, the CemStar 

process can be implemented on a kiln quickly with minimal impact to facility operations. 

The equipment needed is mostly material handling equipment. 

The CemStar approach has many advantages: energy input can be reduced, NOX

emissions (both lbs/hr and lbs/ton of clinker) can be reduced, and kiln capacity can be 

increased. Since the steel slag more closely resembles the desired kiln product than do 

the normal raw materials, kilns with CemStar require less intense firing and allow for a 

significant reduction of peak burn-zone temperature. The lower burn zone temperature 

results in less thermal NOX generation. NOX reduction may be expected to be in the 

range of 20% or more for most kilns. If initial, uncontrolled NOX is high due to thermal 

NOX, CemStar is likely to provide reductions on the order of 40%-50%. Results of 

controlled testing of CemStar with baseline conditions resulted in 20% reduction in NOX, 
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 4-15

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corresponding with a reduction in average burn-zone temperature of over 200°F. Kiln 

capacity is increased because each ton of steel slag added to the kiln results in about a ton 

of additional production, though the precise amount of additional kiln production is 

dependent on the mineral characteristics of the local raw material. This capacity increase 

is the reason that many facility owners may initially choose to use CemStar. 

TXI, the developer of CemStar, reports that more than 10 plants are currently 

equipped with the technology. NESCAUM (2001) discusses one application of CemStar 

on a long-wet process kiln.

Mid-Kiln Firing 

Mid-kiln firing entails injecting a fuel, usually tires, mid-way through long dry 

and long wet kilns. This method has been shown to reduce NOX by about 30% with midkiln heat input comprising about 20% of the total heat input (Portland Cement 

Association, 1998). Results of tests of mid-kiln firing on several kilns are summarized in 

Table 2 (NESCAUM,2001). The average NOX reduction for these kilns is about 27%. 

Mid-kiln firing reduces the heat needed, and therefore the thermal NOX produced in the 

primary burn zone. Fuel NOX will also be reduced because tires and other mid-kiln fuels 

have low nitrogen contents. Nitrogen content in tires is roughly one fifth that of coal on a 

mass basis, while heating value on a mass basis is similar (Schrama et al., 1995; 

Stillwater and Wahlquist, 1998). Coal can be used as a mid-kiln firing fuel, but tires are 

preferable because they provide a revenue source when kiln operators are paid a tipping 

fee for taking whole tires. Other revenue-generating fuels could potentially be used as 

well. 

Table IV-2 NOX Reduction at Cement Kilns Using Mid-Kiln Technology 

(NESCAUM,2001)

Initial NOX (ppm) 936 1372 1342 1359 565 513

Final NOX (ppm) 790 994 600 883 488 456

% Reduction 16% 28% 55% 35% 14% 11%

High-pressure air injection, mentioned in the previous section as a potential 

control for SO2 emissions, was primarily developed as a NOX reduction strategy (Hansen, 

2002). The technique was designed for use with staged fuel combustion (mid-kiln firing) 

and mixing air. Mid-kiln firing with mixing air creates stratified thermal layers in the 

kiln, preventing immediate combustion of the mid-kiln fuel and lowering exit oxygen 

levels enough that additional CO is produced. Injecting high-pressure air into the kiln 

provides energy to mix the layers, lowering the main flame temperature and creating a 

reducing area between the fuel and air injection points, which encourages the destruction 

of NOX. The technique has been shown to reduce NOX by about 50%, while also 

reducing CO by 47% and SO2 by 97%.
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Biosolids Injection

Biosolids Injection (BSI) is a technology that was developed in the 1990's by the 

cement industry for NOX reduction in precalciner and preheater kilns (Biggs, 1995). BSI 

adds dewatered sewage sludge to the mixing chamber of the precalciner. The dewatered 

biosolids provide a source of ammonia, producing an SNCR reaction to reduce NOX. At 

a Mitsubishi Cement Kiln in California, BSI provided about 50% reduction in NOX from

about 250 ppm (at 12% oxygen) to 120-125 ppm (at 12% oxygen). BSI has the 

additional benefit of offering a potential revenue stream because many communities are 

willing to pay a tipping fee for accepting biosolids. BSI technology may require 

significant capital equipment expenditures, however. The material handling equipment 

needed and the moisture in the dewatered biosolids is sufficient to strain the capacity of 

the fans of many existing facilities. It appears that biosolids injection may be an effective 

approach for NOX reduction, but it will depend on the specifics of the kiln.

Selective Non-catalytic Reduction

Selective Non-catalytic Reduction (SNCR) of NOX is based on the injection of a 

reagent, typically NH3 or urea, into the kiln system at a location with an appropriate 

temperature window 1140 – 2010oF (870 - 1100°C). Some researchers have found that 

the most effective temperature range is narrower, about 1650 – 2000°F (900 - 1000°C). 

Temperature is critical because no catalyst is used. At temperatures too high, the reagents 

will form additional NOX, and, at low temperatures, the reactions proceed slowly and 

promote the escape of substantial amounts of unreacted ammonia. Under optimum 

conditions about one mole of NH3 is required to reduce one mole of NOX, but the 

amount of NH3 is always critically dependent on the reaction temperature. Ammonia 

slip, which increases rapidly when the molar ratio of NH3 to NO is above one, causes a 

detached plume and can increase opacity of the stack gases.

Preheater and precalciner kilns operate with kiln gas exit temperatures in the 

appropriate temperature range. SNCR systems have been used on some preheater kilns in 

Europe. For wet and long dry kilns, these temperatures exist midway through the kiln. 

Access to this area is possible only through ports in the kiln shell as used in mid-kiln 

firing or with scoops used to return cement kiln dust. Ammonia must be added 

continuously in a fixed molar ratio to NOX in order to be effective and to minimize 

ammonia slip. Therefore, SNCR is not technically feasible at this time on long wet 

process or long dry process kilns.

SNCR has been tested in the U.S. on precalciner kilns and is planned for 

commercial use in other countries (Steuch et al., 1994; Sun et al., 1994). Experience is 

limited to only a few units worldwide, but some tests have reported significant 

reductions. Table 3 lists commercial installations of urea SNCR on precalciner kilns and 

the results of some demonstration programs. Effective operation of SNCR requires 

availability of a section of kiln with the proper temperature and residence time 

characteristics for good reduction. The specifics of the installation will determine the 

level of reduction that is possible. It is unlikely that SNCR can be used effectively on 

many long kilns (wet or dry) because of the need for access to the proper temperature 
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region for injecting urea or ammonia reagent. However on some precalciner kilns the 

access to the proper temperature zone is good. 

Although SNCR technology has the potential to offer significant reductions on 

some precalciner kilns and it is being used in numerous cement kilns in Europe, it has 

been tested in only one facility in the U.S. 

Table IV-3 NOX Reduction Performance of Urea SNCR on Precalciner Cement 

Kilns (NESCAUM, 2001)

Company /

Location

Unit Type Size

(MMBtu/hr)

NOX Baseline Reduction

(%)

NH3

SLIP, 

(ppm)

Ash Grove Cement

Seattle, WA 

(Demo)

Cement 

Kiln/

Precalciner

160 tons

solids/hr

350-600 lb/hr >80 < 10

Korean Cement 

Dong Yang Cement, 

Korea (Demo)

New 

Suspension

Precalciner

na 1.27 lb/MMBtu 45 na

Taiwan Cement

Units #3, #5, & #6

Cement 

Kiln/

Precalciner

260

697

658

1.29 lb/MMBtu

1.58 lb/MMBtu

0.92 lb/MMBtu

50

45

25

15

15

15

Wulfrath Cement

Germany (Demo)

Cement 

Kiln

140 1000 mg/Nm3

500 ppm

90 na

Selective Catalytic Reduction 

Selective Catalytic Reduction (SCR) uses ammonia, in the presence of a catalyst 

(e.g. titanium dioxide; vanadium pentoxide), to selectively reduce NOX emissions from 

exhaust gases. SCR has been extensively and quite successfully used in a very cost 

effective manner on coal- and gas-fired utility boilers, industrial boilers, gas turbines and 

internal combustion diesel engines in the U.S. Typically, anhydrous ammonia, usually 

diluted with air or steam is injected into hot flue gases, which then pass through a catalyst 

bed where NOX is reduced to N2 gas and water. The optimum temperature for SCR 

depends on the catalyst but is usually between 570 and 840oF (300 and 450°C).

Exit gas temperatures from dust collectors on wet kilns, for long dry kilns, and for 

dust collectors in preheater kilns that use in-line raw mills for grinding and drying raw 

materials are relatively low and flue gases would have to be reheated before employing 

SCR. This technology so far has not been applied to the cement kilns but is being 
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evaluated by some of the state air permitting agencies as Best Available Control 

Technology (BACT) for some of the new cement kilns being proposed in the U.S.

Combination of Technologies

It is not uncommon to combine combustion technologies with post-combustion 

technologies for other source types, and this could be done for cement kilns in some 

cases. It is also possible to combine multiple combustion technologies on cement kilns. 

For example, one of the case studies in Status Report on NOx Controls for Gas Turbines, 

Cement Kilns, Industrial Boilers, Internal Combustion Engines; Technologies and Cost 

Effectiveness (NESCAUM, 2001) combines indirect firing and mid-kiln firing to reduce 

NOX by a combined amount approaching 50%. It is also reasonable to expect that 

technologies such as CemStar might be combined with a combustion technology such as 

mid-kiln firing to provide combined benefits, and it may be feasible to use SNCR or SCR 

in combination with other controls for cement kilns. The exact amount of reduction will 

depend upon the regulatory requirements and technical limitations. In some cases the 

NOX reductions may not be additive.

4.3.3. PM2.5 Controls

The particulate matter exiting the kiln system with the exhaust gases is relatively 

coarse, with most of the particuate matter having diameters greater than 10 microns, but 

the concentrations of particles in the exhaust can be several times higher than in a coalfired power plant. Particulate control devices for cement plants must be able to clean 

gases with fairly high dust loading.

As is the case for many other industrial sectors, the main control options for fine 

particles are baghouses (more formally known as Fabric Filters) and electrostatic 

precipitators (ESPs), described in Section 2.3.2 (EGUs). The following section describes 

some issues specifically related to cement kilns and the use of these devices, including a 

new filter system combining a baghouse and an ESP.

Cement kilns primarily utilize baghouses of the reverse-air and pulse-jet types. 

Both types are usually configured so that the bags can be cleaned during an “off-line” 

cycle, in which a section of the baghouse is closed off from the main exhaust flow for 

cleaning. This tends to reduce the need for a high-pressure pulse that causes additional 

wear on the filtration fabric, allows less time for particles to be collected in the hopper 

during its brief and frequent use, and requires additional power for operation. The choice 

between a reverse-air and pulse-jet system is generally made on the basis of the volume 

of exhaust and production from the kiln. In general, kilns producing less than 1650 stpd 

(with exhaust volumes below 128,000 acfm) are most efficiently served by a jet-pulse 

system (D’Lima and Pirwitz, 2000). The decision is more complex for kilns up to 6600 

stpd (with exhaust volumes up to 853,000 acfm), for which initial equipment costs are 

similar but lifetime operation costs are more complicated. D’Lima and Pirwitz (2000) 

concluded that jet-pulse systems are appropriate for the smallest kilns and reverse-air 
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systems are preferred for all larger kilns, even though they may have higher installation 

costs for kilns of more modest size.

Corrosion in baghouses has been an important topic in the cement kiln control 

literature (Jansen and Mazeika, 2003; Biege and Shenk, 2001). A 2002 EPA rule [40 

CFR Part 63 Subpart LLL (2002)] requires gas temperatures entering the control device 

not to exceed 400°F (205°C) in order to control dioxin emissions. Water sprays are 

usually utilized to control exhaust temperature, but adding water vapor to the exhaust 

stream while lowering exhaust temperature brings the gas near the dew point of some 

corrosive components. Corrosion issues can be addressed in a number of ways, but all 

add cost to the use of the control system.

The three components of corrosion are corrosive gases, condensation, and a 

corrodible surface; reducing any component will reduce corrosion. Corrosive gases can 

be reduced in a roller mill; this may be one of the most effective methods to reduce 

corrosion. Many of the gases are absorbed by the feed during the milling process and are 

therefore not available to form acids in the exhaust. Changing the feed may also reduce 

some of the acidic gases. Condensation is prevented most easily by keeping the exhaust 

temperature hot; however, when this is not allowed, it is best to maintain the exhaust 

temperature as high as possible, preventing drops which may allow acidic condensation. 

Insulating surfaces and carefully sealing unused sections of the control device can 

prevent exhaust from leaking into cool areas where it can condense and cause corrosion. 

Finally, corrosive-resistant materials and acid-resistant coatings can help reduce 

corrosion in control equipment.

Instead of a baghouse or an ESP, a combined system has become available, 

utilizing components of both systems. Whereas an in-series, hybrid system has the ESP 

and baghouse systems in independent compartments, this technology is described as “an 

ESP in which every other row of discharge electrodes is replaced by a single row of filter 

bags” (Gebert et al., 2003). In this new system, where the filter bags are directly adjacent 

or parallel to the ESP electrical field, ESP zones alternate with filter zones, allowing 

primary collection by the ESP and pre-ionization of the remaining dust for collection on 

the filter bags. A highly efficient expanded polytetrafluoroethylene (ePTFE) membrane is 

used as the filter fabric, which can remove an order of magnitude more of fine particulate 

than ordinary bags. During a pilot system test of a 225 m3/min (9000 acfm) slipstream 

from a coal-fired power plant in South Dakota, greater than 99.99% removal efficiency 

was shown. With the ESP fully engaged, bag cleaning was required only every 300 

minutes, compared to every fifteen minutes when the ESP was not used. This system has 

been utilized in full-scale commercial operation at a cement kiln in Italy since September 

2002, capturing dust from the cement kiln, raw mill and clicker cooler. Another similar 

filter is in operation since October 2002 at the coal-fired power plant in South Dakota 

mentioned above.

The synergy between the two technologies enables operation of the filter bags at 

high air-to-cloth (A/C) ratios, and, combined with the new compact size for filters, 

provides the following benefits for a cement plant:

• Ability to reach high control efficiencies in all operation modes,

• Continuous stable operation, and
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• Lower operating costs, due to reduced number of system components.

4.3.4. VOC Controls

No controls which specifically targeted VOCs were identified for cement kilns.

4.4. Costs and Availability 

4.4.1. Sulfur Dioxide Control 

The SOx control techniques applicable to the cement industry and the assumed 

SOx reductions that the various control technologies can achieve are summarized in Table 

IV-4. 

The achievable SOx reductions vary greatly. Even when the same control 

technology is applied to kilns of the same type, the removal efficiency will depend on 

kiln operating parameters, uncontrolled SOx emissions rate, and many other site-specific 

factors.

Wet-limestone scrubbers and spray dryers can be used as secondary control 

devices to reduce SO2 emissions from a cement kiln. 

Capital and operating costs for spray dryers and wet scrubbers as applied to 

cement kilns were computed by Young (2002). Both technologies were assumed to be 

installed after the existing APCD, which would allow the CKD to be recycled back to the 

kiln. If CKD is not recycled, there is a negative impact on the operating cost of the plant. 

Table IV-5 summarizes the capital and operating costs in terms of $ per ton of clinker 

produced for different types of kilns. The capital and operating costs of the spray dryer 

include a baghouse, new stack and new ID (induced draft) fan. The capital and operating 

costs for the wet scrubber include new fans and a new stack as well as a new wastewater 

treatment facility. 

Another installation was made in 1998 at Castle Cement’s Ribblesdale (UK) 

facility (Castle Cement, 2004). Scrubber installation cost £5 million and operational 

costs are about £750,000 annually. Emissions from one unit were reduced by 90%.
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Table IV-4 SO2 Control Techniques Applicable to Cement Kilns (Miller, 2001)

SO2 reduction 

technique Applicable to kiln type

Range of 

removal 

efficiency

Long wet Long dry Preheater Precalciner

Process alterations x x x x 0-100%

Dry reagent injection x x 25-85%

Hot meal injection x x 0-30%

Spray dryer absorber x x x 50-90%

Wet SO2 scrubber x x x x 80-95%

Table IV-5 Capital and operating costs of spray dryers and wet scrubbers applied 

to cement kilns (Young, 2002)

Spray Dryer Wet Scrubber

Clinker 

capacity, 

tpy

Capital 

Cost, $/ton

clinker

Annual 

Operating 

Cost, $/ton 

clinker

Capital 

Cost, $/ton 

clinker

Annual 

Operating 

Cost, $/ton 

clinker

Small wet kiln 300,000 $54.67 $20.02 $47.00 $22.59

Medium wet kiln 600,000 $38.17 $14.09 $32.67 $17.58

Medium dry kiln 600,000 $39.75 $14.79 $31.83 $17.21

Large dry kiln 1,200,000 $23.17 $9.43 $20.42 $13.05

Medium preheater kiln 600,000 $17.92 $7.51 $15.83 $9.85

Medium precalciner kiln w/ bypass 600,000 $25.17 $10.20 $19.33 $11.42

Large preheater kiln 1,200,000 $10.96 $5.41 $10.83 $8.14

An alternative secondary control device for SO2 was designed and applied as part 

of U.S. Department of Energy’s Clean Coal Technology program. A co-project of 

Passamaquoddy Technology and Dragon Products Company in Thomaston, ME, the 

Passamaquoddy Technology Recovery ScrubberTM (Recovery ScrubberTM) utilizes 

cement-kiln dust as a reagent for removing SO2 from kiln exhaust gases (USDOE, 2001). 

Waste heat from the kiln is used to crystallize K2SO4, a saleable, fertilizer-grade byproduct. The remaining cement kiln dust is returned to the kiln, significantly reducing 

particulate emissions, eliminating the need for removal of the dust to a landfill, and 
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reducing the requirement for raw materials by about 10 percent. Sulfur dioxide was 

reduced by 82 to 98.5%, depending on scrubber inlet SO2 rates. In addition, NOX was 

reduced by about 25% and VOCs by 70%. Capital costs for a Recovery ScrubberTM were 

estimated at about $10.5 million in 1996 dollars, with operating and maintenance costs of 

$150,000 per year and electricity costs of $350,000 per year (787 kW at $0.06/kW). 

4.4.2. Nitrogen Oxides Control

Table 6 presents a summary of NOX controls that are feasible for cement kilns, the 

range of potential NOX reductions from applying these controls, the cost effectiveness of 

the controls, and effects on other emissions when using these controls. 
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Table IV-6 Summary of the Feasibility of NOX Controls for Cement Kilns

NOX Reduction Technique

Technical 

Feasibility

NOX Reduction Potential 

(%)1

Cost Effectiveness 

($/ton NOX

removed)

Effect on Other 

Emissions Reference

Process Modifications In full-scale 

use

0 - 30 [15] 3,100 - 8,800 Unknown 16

Low NOX Burners w/ 

Indirect Firing

In full-scale 

use

0 – 20 [10] 5,800 - 8,100 Unknown 16

Low NOX Burners w/ 

Indirect Firing and Midkiln Tire Injection

In full-scale 

use

[49] 1 - 1,800 Unknown

17

Mid-Kiln Injection of 

Fuel, Riser Duct Firing 

Calciners

In full-scale 

use

0 – 30 [15] 5,100 -11,500

May increase CO, 

SO; hydrocarbon 

emission

16

CemStar Wet kilns 20 - 50 [20] 0-600 Unknown 17

Low NOX Precalciner

Have been 

installed on 

several fullscale kilns -

Offered by 

several 

different 

vendors.

30 – 40 [30] 2,700 - 3,600

May Increase 

emissions CO, 

S02, and/ or 

hydrocarbons

16

SNCR

May be 

applicable 

only on 

preheater or 

precalciner 

kilns - limited 

data

15 – 65 [45] 900 - 1,200

May Increase 

emissions CO, 

NH3, and 

NH4+salts 

(detached plume)

17

Biosolids Injection

May be 

applicable 

only on 

preheater or 

precalciner 

kilns - limited 

data

[50] 100-1,800

May Increase 

emissions CO, 

NH3, and 

NH4+salts 

(detached plume

17

1Values in brackets are the assumed NOX reductions used to calculate the estimated cost effectiveness of each 

 Technology.
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4.4.3. PM2.5 Control

As discussed above, control of particulate matter in cement kilns is accomplished 

using baghouses and electrostatic precipitators. These processes are also used in electric 

utility generating units and industrial boilers. Capital and operating costs for fabric filters 

and ESPs as applied to cement kilns were computed by Young (2002) and are 

summarized in Table IV-7. The costs include the addition of a new fan.

Table IV-7 Capital and operating costs of baghouses and ESPs applied to cement 

kilns (Young, 2002)

New ESP New baghouse

Clinker 

capacity, 

tpy

Capital 

Cost, $/ton 

clinker

Annual 

Operating 

Cost, $/ton 

clinker

Capital 

Cost, $/ton 

clinker

Annual 

Operating 

Cost, $/ton 

clinker

Small wet kiln 300,000 $14.00 $3.35 $16.67 $3.81

Medium wet kiln 600,000 $11.00 $2.49 $13.00 $2.92

Medium dry kiln 600,000 $10.50 $2.54 $12.00 $2.78

Large dry kiln 1,200,000 $7.33 $1.51 $8.67 $1.96

Medium preheater kiln 600,000 $4.33 $1.03 $5.17 $1.17

Medium precalciner kiln w/ bypass 600,000 $5.33 $1.42 $6.33 $1.53

Large preheater kiln 1,200,000 $3.33 $0.74 $4.00 $0.90
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References

Biege, NW and RE Shenk. “Strategies for Reducing Cement Kiln Baghouse Corrosion 

Problems.” IEEE/PCA Cement Industry Technical Conference, Vancouver, British 

Columbia; May 2001. 

Biggs, H.O. "BioSolids Injection Technology: an Innovation in Cement Kiln NOX

Control." Proceedings of the 31st International Cement Seminar. TP 881 .I5, 1995.

Castle Cement. “http://www.castlecement.co.uk/env_emm.htm” 5 May 2004.

D’Lima, Hector and W. Pirwitz. “Cement Kiln Baghouse: 20 Year Life Cycle 

Comparison, Jet Pulse vs. Reverse Air.” IEEE-IAS/PCA Cement Industry Technical 

Conference; Salt Lake City, UT: May 2000.

Gardeik. H.O. et.al., Research Institute of the Cement Industry, Dusseldorf; Behavior of 

nitrogen oxides in rotary kiln plants of the cement industry; Trans of ZKG No.10/84

Gartner, E.M.; Nitrogenous Emissions from Cement Kiln Feeds; Interim Report on 

Project HM7140-4330; For presentation at Rule 1112 Ad Hoc Committee Meeting South 

Coast Air Quality Management District, El Monte, CA; June 7, 1983 

Jansen, A. and L. Mazeika. “Alternative Solutions for Corrosion Problems in Cement 

Plant Pollution Control Equipment.” IEEE-IAS/PCA 44th Cement Industry Technical 

Conference; Dallas, TX: May 2003. 

Gebert, R., et al. “A New Filter System, Combining a Fabric Filter and Electrostatic 

Precipitator for Effective Pollution Control Be hind Cement Kilns.” IEEE-IAS/PCA 44th 

Cement Industry Technical Conference; Dallas, TX: May 2003. 

Hansen, E.R., The Use of Carbon Monoxide and Other Gases for Process Control; 27th 

I.E.E.E. Cement Industry Technical Conference Proceedings, May 1985

Hansen, E.R., “Panel Discussion: Reduction of Clinker Alkali and SO2, NOX Emissions 

from Preheater Kilns,” Portland Cement Association, GTC Fall Meeting, September, 

1986.

Hansen, Eric R. “Staged Combustion for NOX Reduction Using High Pressure Air 

Injection” IEEE-IAS/PCA 43rd Cement Industry Technical Conference; Jacksonville, 

FL: May 2002. 

Keefe, B.P. and R.E.Shenk, “Staged Combustion for Low-NOX Calciners; Sept, 2002 

Kupper, D., et. al.; Trends on Desulfurization and Denitification Techniques in the 

Cement Industry; Proceeding of Emerging Technologies in Resource Recovery and 

Emission Reduction in the Cement Industry; Sponsored by the Portland Cement 

Association, Dallas, TX; September, 1990
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 4-26

4-26

Miller, F.M. and A.H. Egelov; Relationship between cement kiln operation and content 

of NOX is kiln gases; Zement-Kalk-Gips International; Weisbaden, Germany, 1980.

Miller, F.M. et. al. “Formation and Techniques of Control of Sulfur Dioxide and Other 

Sulfur Compounds in Portland Cement Kiln Systems. Portland Cement Association R&D 

Serial No. 2460, 2001.

NESCAUM, Status Report on NOX Controls for Gas Turbines, Cement Kilns, Industrial 

Boilers, Internal Combustion Engines; Technologies and Cost Effectiveness, Amar, P., 

Staudt, J., Northeast States for Coordinated Air Use Management, Boston, MA, January, 

2001.

NESCAUM, Technical Memorandum #6: Development of a List of BART-Eligible 

Sources in the MANE-VU Region. Boston, MA; May, 2004.

Nielse, P.B., “Die SO2 – und NOX-Emissionen bei modernen Zementdrehofen_Anlagen 

mit Blick auk=f zukünftige Verordnungen (SO2 and NOX Emissions from Modern 

Cement Kilns with a View of Future Regulations),” Zement-Kalk-Gips, Vol. 44, No.9, 

1991 pp. 449-456

Nielsen, P.B., and O.L.Jepsen; An Overview of the Formation of SOx and NOX in 

Various Pyroprocessing Systems; Presented at: IEEE Cement Industry Technical 

Conference, XXXII; Tarpon Springs, FL, May, 1990

Portland Cement Association. "Report on NOX Formation and Variability in Portland 

Cement Kiln Systems Potential Control Techniques and Their Feasibility and Cost 

Effectiveness." PCA R&D Serial No. 2227, December, 1998.

Portland Cement Association, U.S and Canadian Portland Cement Industry: Plant 

Information Summary, Data as of December 31, 2000.

Schrsemli, Dr. W.; Experience with Measures to Reduce SO2 and NOX Emissions from 

Cement Kilns In; Proceeding of Emerging Technologies in Resource Recovery and 

Emissions Reduction in the Cement Industry; Sponsored by the Portland Cement 

Association, Dallas, TX; September, 1990

Schrama, H., Blumenthal, M., and Weatherhead, E. C. "A Survey of Tire Burning 

Technology for the Cement Industry." IEEE Cement Industry Technical Conference. 

San Juan, Puerto Rico: June 4-9, 1995.

Sheth, S.H., “SO2 Emissions History and Scrubbing System—Santa Cruz Plant, 

California, RMC Limestone,” 33rd IEEE Cement Industry Conference, Mexico City, 

Mexico, May, 1991.

Steuch, H.E., and Johansen, V., “Some Facts on SO2 Emissions”, Rock Products, Vol. 94, 

No.6, 1991, pp.65-71
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 4-27

4-27

Steuch, H.E., Hille, J., Sun, W.H., Bisnett, M.J, and Kirk, D.W. "Reduction of NOX

Emissions from a Dry Process Preheater Kiln with Calciner Through the Use of the 

NOXOUT Process." Portland Cement Association Meeting of the General Technical 

Committee. Seattle, WA: September 18-21, 1994.

Stillwater, M.A. and Wahlquist, C.J. "Building a Successful Tire Derived Fuel 

Program." Proceedings of the 34th International Cement Seminar. December 6-9, 1998, 

Salt Lake City, UT. 

Sun, W.H., Bisnett, M.J., et al. "Reduction of NOX Emissions from Cement 

Kiln/Calciner through the Use of the NOXOUT Process." International Specialty 

Conference on Waste Combustion in Boilers and Industrial Furnaces. Air and Waste 

Management Association. Kansas City, MO: April 21, 1994.

Tanna, B. and B. Schipholt. “Waste-Derived Fuel Use in Cement Kilns” ERAtech 

Group, LLC http://www.eratech.com/papers/wdf.htm, accessed September, 2004. 

U.S. Department of Energy, NETL. Cement Kiln Flue Gas Recovery Scrubber Project: 

A DOE Assessment. DOE/NETL-2002/1163, November 2001. 

U.S. Environmental Protection Agency. “Alternative Control Techniques Document --

NOX Emissions from Cement Manufacturing.” EPA453/R-94-004, March, 1994.

Young, R.D. "Method and Apparatus for Using Steel Slag in Cement Clinker 

Production." U.S. Patent No. 5,421,880. Issued June 6, 1995.

Young, R.D. "Method and Apparatus for Using Blast-Furnace Slag in Cement Clinker 

Production." U.S. Patent No. 5,494,515. Issued February 27, 1996.

Young, G.L. Review of Model Kiln Scenarios and Cost Estimates for Control of

Hazardous Air Pollutants. Portland Cement Association, Report SP127, 2002.

Young, G. L. and von Seebach, M. " NOX Variability Emission and Control from 

Portland Cement Kilns." Proceedings of the 34th International Cement Seminar, 

December 6-9, 1998

Young, G.L. and von Seebach, Michael; NOX Abatement in Kiln Plants in the Cement 

Industry, Zement-Kalk-Gips, Volume 52, Number 6, 1999
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 5-1

5-1

5. KRAFT PULP MILLS

5.1. Description of pulp and paper processes

Kraft pulping processes consists of wood preparation, pulping, pulp washing, 

oxygen delignification and/or bleaching of pulp and chemical recovery as illustrated in 

Figure V-1. Beginning with wood preparation, logs are debarked, ground into wood 

chips, and then screened to remove chips of unacceptable sizes. During the pulping 

process, the wood chips enter the digester where they are cooked with liquor and broken 

down into a pulp slurry. The pulp slurry is transferred to a blow tank while the spent 

liquor is sent to a flash tank. The pulp slurry then enters the pulp washing process where 

knots, shives, and short fibers are removed, spent cooking chemicals are recovered from 

the pulp slurry, and the pulp slurry is thickened for later processes. Next, the pulp 

enters the oxygen delignification process where the lignin content of the pulp is reduced 

to increase brightness of the pulp. The brightness of the pulp is further enhanced by 

bleaching, a multi step process that removes residual lignin by using chemicals to oxidize 

and dissolve the lignin compounds. Lastly, the chemical recovery process recovers the 

spent cooking liquor using the following methods: evaporation to reduce water content 

in spent liquor, combustion of concentrated spent liquor, and recovery of chemicals from 

Figure 1. Schematic of the Kraft Pulping and Recovery Process (Someshwar and 

Pinkerton, 2000).
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5-2

combustion products. The regeneration of lime, which is used for recovering sodium, is 

an additional step of the kraft chemical recovery process not found in the acid sulfite, 

mechanical, or semi chemical processes. 

Acid Sulfite and semi chemical processes are very similar to the kraft process, 

however, the acid sulfite process differs from the kraft process in the type of cooking 

liquor used and the semi chemical process differs from the kraft process in the use of 

lower temperatures, more dilute cooking liquor or shorter cooking time, and mechanical 

disintegration. Mechanical pulping uses high-energy refining systems to produce pulp 

from chips and bleaching agents are used to decolorize lignin instead of removing lignin. 

(Someshwar and Pinkerton, 2000; Pinkerton, 2000).

5.2. Review of BART-Eligible Pulp and Paper facilities in the MANEVU Region

There are 10 facilities with BART-Eligible industrial boilers in the MANE-VU 

region. Table III-2 contains a list of these sources based on a previous NESCAUM report 

(2003) and follow-up review by state permitting authorities. 7[Editor’s note: additional 

facilities may be added after NY and PA have completed their inventory].

Table V-1 BART-eligible pulp and paper facilities.

State Company/Facility City/Town Category

Maryland WESTVACO FINE PAPERS Luke kraft pulp

Maine Domtar - Pulp & Paper Baileyville kraft pulp

Maine Fort James - OldTown Old Town kraft pulp

Maine IP Androscoggin Jay kraft pulp

Maine Lincoln Pulp and Paper Lincoln kraft pulp

Maine Madison Paper Madison kraft pulp

Maine Mead WestVaco Rumford kraft pulp

Maine SD Warren - Somerset Skowhegan kraft pulp

Maine SD Warren Co. Westbrook kraft pulp

New Hampshire Pulp & Paper Mills (33007-00001-11) Berlin kraft pulp

5.3. Available Control Technologies

The pulp and paper production, consisting of chemical, mechanical, and semi 

chemical processes, has a number of potential sources of SOx, NOX, particulates, and 

VOC emissions (Pinkerton, 2000). The major chemical wood pulping processes are 

kraft, acid sulfite, and semi chemical pulping. Kraft pulping accounts for 80% of the 

 

7

 NESCAUM does not believe that there are any BART-eligible sources in the State of Vermont or any of 

the member Tribes in MANE-VU and thus we have not developed lists for these jurisdictions. In addition, 

Pennsylvania and the District of Columbia have developed BART-Eligible source lists following their own 

methodology and any identified sources are contained here and in the final list in Appendix A.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 5-3

5-3

pulp produced in the U.S, mechanical and semi chemical pulping, for 10% and 6%, 

respectively and sulfite or soda chemical process accounts for the remaining pulping 

capacity (Someshwar and Pinkerton, 2000). 

A variety of technologies exist for controlling emissions from pulp and paper 

facilities. Secondary control devices can be helpful in reducing emissions, and a number 

of them are available. Many facilities have found that significant emissions reductions 

can be achieved through process changes at the facility. Both secondary controls and 

process changes are discussed below, grouped by their targeted pollutant. When 

additional emissions reductions are possible, they are noted with the main (or targeted) 

pollutant. The sections below will describe the potential sources of significant SOx, 

NOX, particulates, and VOC emissions in the major pulping processes and the measures 

used to control them. 

5.3.1. SO2 Controls

In a kraft mill, SO2 is a product of the incineration of black liquor in the recovery 

furnace; black liquor is made up of 3-5% sulfur by weight of dissolved solids. The 

majority of the sulfur exits the furnace in the smelt; however, typically less than 1% can 

be emitted as a gas or particulate, resulting in average SO2 concentrations of 0-500 ppm 

in stack gases. Recovery furnace SO2 emissions are a function of liquor properties such 

as sulfidity (sulfur-to-sodium ratio), heating value, and solids content; combustion air and 

liquor firing patterns; furnace design features; furnace load; auxiliary fuel use; and stack 

gas oxygen content. To reduce SO2 emissions from the recovery furnace, the 

temperature in the lower furnace must be uniform. This has been achieved by optimizing 

liquor and combustion air properties and firing patterns. Reducing liquor sulfidity has 

also been used as a control strategy for SO2 emissions. Flue gas desulfurization as an 

effective control strategy is uncertain due to the mostly low and unpredictable levels of 

SO2 emitted. 

In a lime kiln, SO2 is produced from the combustion of fuel oil or non 

condensable gases (NCG). On average, lime kiln SO2 emissions are very low due to the 

capture of SO2 from the alkaline material inside the kiln and the venturi scrubber usually 

installed immediately after the kiln. 

In semi chemical processes, only neutral sulfite semi chemical (NSSC) pulping

emits SO2 emissions as a result of the combustion of sulfur-containing semi chemical 

spent liquor in a fluidized bed combustor. Limited data shows an SO2 emission factor for 

a fluidized bed combustor burning NSSC liquor as 1 lb SO2/a.d. ton of pulp. 

A major source of SO2 in acid sulfite processes is from the digester and blow tank 

areas. During a hot blow, significant quantities of SO2 can be released into the blow 

gases ranging from 10 to 70 pounds per ton of pulp. Using an alkaline solution to scrub 

the blow gases, 97% of SO2 can be recovered and returned to the acid-preparation 

system. While this approach is possible using sodium and NH3 bases, magnesium and 

calcium bases need slurry scrubbers deemed less practical. Scrubbing becomes 
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 5-4

5-4

impractical when during a cold blow, only 4 to 20 pounds SO2 per pulp are released into 

the blow gases. 

SO2 can also escape from acid bisulfite washers and screens which can result in 

uncontrolled emissions generally ranging from 1 to 4 lb SO2/ton pulp but can get up to as 

much as 16 lb SO2/ton pulp. The gases emitted from the washers and screens are hooded 

and then directed to a direct-contact scrubber where the SO2 is scrubbed from the gases. 

(Someshwar and Pinkerton, 2000; Pinkerton, 2000).

5.3.2. NOX Controls

NOX is produced from the incineration of black liquor in the kraft recovery 

furnace with black liquor containing 0.05% to 0.25% nitrogen by weight of liquor solids 

content. Normal NOX emissions from kraft recovery furnaces are less than 100 ppm. 

NOX emissions are mainly a result of fuel NOX since the maximum temperature in the 

recovery furnace is approximately 2400oF and the temperature required for formation of 

significant amounts of thermal NOX is greater than 2800oF. NCASI studied the origins of 

NOX emissions from kraft recovery furnaces and concluded that the two most important 

factors affecting NOX emissions, in order of importance, were the black liquor nitrogen 

content and excess oxygen in the zone where most of the liquor combustion occurs. 

Since it is difficult to alter the liquor N content, the best approach to minimizing NOX in 

recovery furnaces is staged-air combustion. Currently, most recovery furnaces already 

optimally use staged combustion and emit less than 100ppm NOX. 

NOX is produced in the kraft lime kiln from the combustion of fossil fuels, such as 

natural gas and residual fuel oil. Due to the design of the lime kiln, SNCRs and SCRs 

are not viable NOX reduction techniques. Installing Low-NOX Burners (LNBs) is also 

not a practical NOX reduction technique according to a BACT analysis conducted on a 

new lime kiln in 1997. The installation of LNBs had a negative influence on the 

efficiency, energy usage, and calcining capacity of the lime kiln. Hence, like the 

recovery furnace, combustion modification such as decreasing excess air is the best way 

to reduce NOX emissions. However, since the mechanisms of NOX formation and NOX

emission reduction are not completely known, NOX reduction strategies should be 

considered on a case-by-case basis. 

Some NOX emissions result from the burning of stripper off gases (SOGs) with 

significant ammonia and methanol content and combustion of NCG in the kiln, thermal 

oxidizer, or boiler. When SOGs containing methanol and ammonia are incinerated, the 

ammonia could potentially oxidize to produce NOX. NH3 will oxidize to NOX when 

injected into gases above 2000oF to 2200oF, reduce NOX to N2 when gas temperatures 

range from about 1600oF to 2200oF, and remain as NH3 in temperatures below 1600oF. 

However, the degree of NH3 conversion to NOX and the expected baseline level of NOX

emissions from pulp process units burning NCG and SOGs are not known. 

NOX emissions are expected during combustion of liquor in recovery furnaces for both 

semi chemical and acid sulfite processes. (Pinkerton, 2000; Someshwar, 1999).
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5-5

5.3.3. PM2.5 Controls

Measurable particulate emissions sources in a kraft mill are recovery furnaces, 

smelt-dissolving tanks, and lime kilns while fugitive particulate emissions sources are 

coal piles, paved and unpaved roads, bulk material handling such as lime, limestone, or 

starch, and wood handling. Particulate emissions from recovery furnaces are controlled 

by ESPs with particulate removal efficiencies of 90% in older units and 99% in newer 

units. Demister pads, packed towers or venturi scrubbers are used to achieve particulate 

emissions control in smelt-dissolving tanks, and venturi scrubbers and ESPs are used for 

control in lime kilns. Controlled mean particulate emission factors from smelt dissolving 

tank vents and kraft lime kilns are 0.13 lb/ton black liquor solids and 1.82 lb/ton of 

reburned lime product, respectively. Fugitive emissions are controlled by wetting; using 

chemical agents, building enclosures, and windscreens; paving or wetting roads; and 

modifying handling equipment. 

In semi chemical processes, particulate emissions only become a concern when 

recovery furnaces are used. These emissions are controlled by using ESPs, wet ESPs or 

venturi scrubbers. In acid sulfite processes, the burning of both ammonium and 

magnesium base liquors will result in the release of particulate matter in the form of 

ammonium salts and magnesium oxide, respectively. The ammonium salts are removed 

when the flue gas exiting the absorption unit enters a series of fabric mesh pads called 

“candles.” The magnesium oxide particulates are removed using multiple cyclones, a 

series of 3 or 4 packed tower absorbers, and in addition, some mills use venturi scrubbers 

and/or a SO2 scrubber. Controlled particulate emissions of ammonia salt particles are 

<0.5 gr/dscf @ 8% O2 and for magnesium oxide, 0.05 to 0.1 gr/dscf correct to 8% O2. 

(Someshwar and Pinkerton, 2000).

5.3.4. VOC Controls

VOC emissions sources in a kraft mill are recovery furnaces and lime kilns. In a 

recovery furnace, VOC emissions are produced from incomplete combustion or from the 

contact between the black liquor and flue gas where volatile material from the liquor can 

transfer to the flue gas. Factors that affect recovery-furnace VOC emissions are the level 

of excess air used and the degree of mixing achieved within the furnace. To lower 

recovery-furnace VOC emissions, the residence time, oxygen content, temperature, and 

level of turbulence in the furnace combustion zone must be increased. However, 

increasing these parameters will increase NOX emissions. 

VOC emissions from lime kilns are also produced from incomplete combustion. 

In addition, VOC emissions can be a result of VOCs entering the kiln with the liquid part 

of the lime mud and VOCs being present in the scrubber makeup water. These 

additional VOCs are then emitted into the flue gas when the lime mud is heated and the 

flue gas exiting the kiln strips the VOCs from the scrubber makeup water. VOC 

emissions from lime kilns tend to be small with the majority being methanol. 

In semi chemical and acid sulfite pulping processes, VOC emissions are a product 

of incomplete combustion in the fluidized bed combustor or in a specialized recovery 

furnace. Semi chemical VOCs can also be introduced into the flue gas if flue gas comes 
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5-6

in contact with pulping liquor. VOCs from both semi chemical and acid sulfite pulping 

processes can enter the flue gas if the flue gas is able to strip organic compounds such as 

methanol from the scrubber makeup water. According to limited data, VOC emissions 

can significantly be reduced by improving combustion conditions and controlling liquor 

firing. 

Mechanical pulping processes only emit VOCs and steam into the atmosphere. 

The VOCs in wood are emitted with the steam when wood undergoes cooking and 

refining processes. A study conducted by NCASI showed that VOC emission rates were 

proportional to steam emission rates. This data suggests that in order to decrease VOC 

emissions, the temperature in the exhaust gas must be reduced below the boiling point of 

water. (Someshwar and Pinkerton, 2000; Pinkerton, 2000).

5.4. Costs and availability 

According to John Pinkerton at the National Council of the Paper Industry for Air and 

Stream Improvement (NCASI) (Pinkerton, 2004), pulp and paper industry representatives 

have been working with several engineering firms to evaluate to assess the costs and 

emission reduction potential of SO2 and NOX control technologies. Many of the 

technologies are candidates for evaluation as part of a BART site-specific engineering 

analysis. Particulate matter (PM) control strategies were also evaluated by NASCI. 

Information on applicability and cost is summarized in Tables V-2 through V-5 for Kraft 

Recovery Furnaces, Lime Kilns, Wood and Wood/Gas boilers and Wood/Coal and 

Wood/Oil boilers. 

Information on the technologies referenced in the tables was collected by NASCI 

based on installation of processes or evaluation of these processes as part of New Source 

Review (NSR) Best Available Control Technology (BACT) or Lowest Achievable 

Emission Rate (LAER) analyses, state Reasonably Available Control Technology 

(RACT) evaluations in ozone non-attainment areas, the USEPA NOX SIP Call, or for 

other reasons. 

The range in costs and emission reductions reflects the fact that site-specific 

factors play a critical role in determining how cost-effective various technologies will be 

in practice. Existing facilities do not always adequate or appropriate space for new 

equipment, which adds uncertainty to the capital and operating cost, as well at to the 

achievable emissions reductions. Hence the range of costs cited in the tables.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 5-7

5-7

Table V-2 Reduction of NOX, SO2 and PM in Kraft Recovery Furnaces (Pinkerton, 

2004).

SO2 NOX PM

Factors affecting 

emissions

Type of furnace, operating 

practices, black liquor 

solids concentration.

Type of furnace, operating 

practices, nitrogen content 

of black liquor, black 

liquor solids 

concentration.

Type of furnace, ESP 

efficiency

Current 

Emission Levels

~0 to 300 ppm 40 to 130 ppm 0.01 – 0.1 gr/dscf

National 

Emission 

Standards

none none 1978 NSPS, 2001 

MACT Existing Source 

– 0.044 gr/dscf. New 

source MACT is 0.015 

gr/dscf

Recent BACT 

Determinations

50 to 300 ppm 75 to 150 ppm 0.021 to 0.044 gr/dscf

Current Installed 

End of Pipe 

Control 

Technologies

none none ESPs 

 Control Options Optimize, on site-specific 

basis, liquor solids and 

operating practices; install 

SO2 scrubber 

Staged combustion 

practices (very sitespecific)

Larger ESPs 

Applicability of 

Control Option 

and Potential 

Emission 

Reductions

Scrubbing possible on 

some units to reduce SO2

to as low as 10 ppm. 

Some units have emissions 

this low or lower at 

present.

SNCR and SCR not 

demonstrated as 

technically feasible. 

Larger ESP possible on 

some units, although 

retrofit costs highly sitespecific. Depending on 

current ESP design and 

condition, replacement 

or expansion of existing 

ESP can be considered

Cost of Option Capital $8 million (1.7 

MMlb/day BLS DCE unit; 

$12.8 million (3.7 

MMlb/day BLS NDCE 

unit); Operating costs of 

$1.1 to $1.3 million (1.7 

MMlb/day unit), or $1.6 to 

1.8 million/yr (3.7 

MMlb/day unit). Lower 

operating costs are for 

achieving 50 ppm; higher 

for achieving 10 ppm. 

Costs are very sitespecific.

Replacement of ESP to 

achieve 0.015 gr/dscf 

PM emissions: for a 3.7 

MMlb BLS/day NDCE 

furnace - Capital $29.3 

million; operating $1.9 

million/yr; for a 1.7 

MMlb BLS/day DCE 

unit: $18.4 million 

capital; $1.2 million/yr 

operating. Costs are very 

site-specific.
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Table V-3 Reduction of NOX, SO2 and PM in Lime Kilns (Pinkerton, 2004).

SO2 NOX PM

Factors affecting 

emissions

Emissions are minimal 

due to alkaline nature of 

lime in kiln

Type of fuel (gas vs. oil), 

operating temperatures, 

nitrogen content of oil 

and oxygen availability 

in flame zone, burning 

NCGs

Type of control device 

and control device 

efficiency

Current Emission 

Levels

~0 to 20 ppm 0.05 to 0.4 lb/106 Btu 

heat input

0.01 – 0.2 gr/dscf

National 

Emission 

Standards

none none 1978 NSPS – 0.067/0.13 

gr/dscf (gas/oil); 2001 

MACT Existing Source 

– 0.064 gr/dscf. New 

source MACT is 0.01 

gr/dscf

Recent BACT 

Determinations

30 to 80 ppm 100 to 220 ppm 0.015 to 0.13 gr/dscf

Current Installed 

Control 

Technologies

none none Wet scrubbers, ESPs 

Control Options Wet scrubber with 

supplemental caustic 

control

none Replace wet scrubber 

with ESP 

Applicability of 

Control Option 

and Potential 

Emission 

Reductions

ESPs have higher 

removal efficiencies than 

wet scrubbers; all lime 

kilns installed in last ten 

years have ESPs rather 

than scrubbers. Average 

ESP emissions are on the 

order of 0.01 gr/dscf.

Cost of Option Replacement of scrubber 

with ESP to achieve 0.01 

gr/dscf PM emissions: 

for a 270 ton CaO/day 

kiln - $3.4 million; 

operating $0.2 

million/yr. 
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5-9

Table V-4 Reduction of NOX, SO2 and PM in Wood and Wood/Gas-Fired Boilers 

(Pinkerton, 2004).

SO2 NOX PM

Factors affecting 

emissions

Sulfur content of wood 

minimal

Type of boiler, wood nitrogen and 

moisture content, operating 

practices

Wood ash content, control 

device efficiency, 

operating practices

Current Emission 

Levels

0.025 lb/106 Btu is AP42 emission factor 0.15 to 0.3 lb/106 Btu 0.05 to 0.6 lb/106 Btu 

National 

Emission 

Standards

none Subpart Db NSPS- none if gas 

capacity factor limited to 10% or 

less; gas capacity factor over 10% 

- 0.3 lb/106 BTU except 0.2 lb/106

BTU for new/reconstructed units 

after 1997 

Subpart D, Db, Dc NSPS –

0.1 lb/106 Btu; final boiler 

MACT limit – 0.07 lb/106

Btu for existing, 0.025 

lb/106 Btu for new solid 

fuel boilers

Recent BACT 

Determinations

0.01 to 0.045 lb/106 Btu 0.25 to 0.3 lb/106 Btu 0.02 to 0.1 lb/106 Btu 

Current Installed 

Control 

Technologies

none SNCR for base loaded boilers Mechanical collectors, wet 

scrubbers, gravel bed 

filters, ESPs, fabric filters

Control Options none SNCR for base loaded boilers Replace wet scrubber with 

an ESP 

Applicability of 

Control Option 

and Potential 

Emission 

Reductions

SNCR has been installed on a few 

new wood boilers to achieve NOX

reductions in the 20 to 50% range. 

SNCR not appropriate for boilers 

with high load swings. SCR has 

not been applied. 

ESPs in use on many wood 

boilers. Emission levels as 

low as 0.02 lb/106 Btu 

possible. Retrofit costs 

highly site-specific. 

Cost of Option Installing SNCR to achieve 0.15 

lb/106 Btu NOX emissions on a 

300,000 pph wood boiler: Capital 

$1.5 million; operating $0.1 

million/yr

Installing ESP to achieve 

0.04 lb/106 Btu PM 

emissions on a 300,000 

pph wood boiler: Capital 

$21.3 million; operating 

$1.4 million/yr. Costs to 

achieve a 0.065 lb/106

standard range from $18.7 

million to $5.1 capital, 

$900,000 to $77,000 

operating—highly sitespecific

Control Option Methane de-NOX Reburn

Applicability of 

Control Option 

and Potential 

Emission 

Reductions

Has been applied to one boiler 

burning wood, gas, and sludge. 

Involves natural gas injection and 

flue gas recirculation in stokertype boilers only. NOX reduction 

reported to be 40 to 50% in 

boilers burning high nitrogen 

content fuels.

Cost of Option Capital costs unavailable. Lower 

operating costs claimed due to 

increased boiler efficiency.
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5-10

Table V-5 Reduction of NOX, SO2 and PM in Wood/Coal and Wood/Oil-Fired 

Boilers (Pinkerton, 2004).

SO2 NOX PM

Factors 

affecting 

emissions

Coal/oil sulfur content, 

ratio of wood to coal/oil

Type of boiler, coal/oil nitrogen 

content, wood nitrogen and 

moisture content, ratio of wood to 

coal/oil

Wood/coal/oil ash content, 

oil S level, control device 

efficiency

Current 

Emission Levels

Depends on fuel mix and 

coal/oil S content

0.25 to 0.7 lb/106 Btu 0.03 to 0.3 lb/106 Btu 

National 

Emission 

Standards

Subpart D NSPS limits 

SO2 to 1.2/0.8 lb/106 Btu 

(coal/oil); Subparts Db 

and Dc require percent 

reduction (except for 

very small boilers or 

those with low coal 

capacity factors) or use 

of very low S oil 

Revised 1998 NSPS has 0.2 

lb/106 Btu limit for boilers over 

100 x 106 Btu/hr for all fossil 

fuels, limit applies if annual fossil 

fuel capacity factor exceeds 10%. 

Prior NOX limits were fuel-type 

dependent and ranged from 0.3 to 

0.7 lb/106 Btu for oil and coal.

Subpart D, Db, Dc NSPS –

0.1 lb/106 Btu unless 

annual wood capacity 

factor is less than 10%; 

final boiler MACT limit –

0.07 lb/106 Btu for existing, 

0.025 lb/106 Btu for new 

solid fuel boilers

Recent BACT 

Determinations

0.3 to 0.5 lb/106 Btu 0.3 to 0.7 lb/106 Btu 0.03 to 0.1 lb/106 Btu 

Current 

Installed 

Control 

Technologies

Alkaline scrubbing SNCR for base loaded boilers, 

FGR, Low NOX burners

Mechanical collectors, wet 

scrubbers, gravel bed 

filters, ESPs, fabric filters

Control Options Alkaline scrubbing Low NOX burners Replace wet scrubber with 

an ESP 

Applicability of 

Control Option 

and Potential 

Emission 

Reductions

Generally applicable; 

reductions up to 90% 

possible

This option only available to 

pulverized coal/stoker boilers or 

oil/wood units. NOX reductions in 

the 20 to 50% range can be 

achieved for the coal or wood 

contribution to total NOX. 

ESPs in use on many 

wood/coal and wood/oil 

boilers. Emission levels as 

low as 0.02 lb/106 Btu 

possible. Retrofit costs 

highly site-specific. 

Cost of Option Capital cost for scrubber 

installation following 

and ESP on a 300,000 

pph wood/coal boiler -

$7.4 to 8.2 million. 

Annual operating cost 

for 50% removal $1.0 

million, $1.5 to 2.0 

million for 90% removal. 

Installing low NOX burners to 

achieve a 0.3 lb/106 Btu level on 

a 300,000 pph wood/pulverized 

coal boiler: Capital $2.9 million; 

operating $0.15 million/yr. 

Retrofit costs site-specific.

Remove existing control 

device and install ESP to 

achieve 0.04 lb/106 Btu PM 

emissions on a 300,000 pph 

wood/coal boiler: Capital 

$5.1 to 20.5 million; 

operating $70,000 to 1.2 

million/yr. Retrofit costs 

site-specific.

Control Option Lower S content coal/oil; 

gas

SNCR for base loaded boilers

Applicability of 

Control Option 

and Potential 

Emission 

Reductions

Generally applicable Limited NOX reductions possible, 

in the 20 to 40% range. SNCR 

not appropriate for boilers with 

high load swings.

Cost of Option Dependent on fuel prices Capital cost of $1.5 million for a 

300,000 pph wood boiler with 

limited coal or oil use; operating 

cost of $0.15 million/yr. Retrofit 

costs site-specific.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 5-11

5-11

References

Someshwar, A. V.; Pinkerton, J. E., “Wood Processing Industry” in Air Pollution 

Engineering Manual, 2nd ed.; Davis, W. T., John Wiley & Sons, Inc.: New York City, 

2000; 780-801.

Pinkerton, J. E., “Pulp and Paper Air Pollution Problems” in Industrial Environmental 

Control Pulp and Paper Industry, 3rd ed.; Springer, A. M., Tappi Press: Atlanta, 2000; 

501-526.

Someshwar, A. V. A., Review of NOX Emission Control Strategies for Industrial Boilers, 

Kraft Recovery Furnaces, and Lime Kilns; NACSI: Research Triangle Park, 1999; 22-27.

Pinkerton, J.E., National Council of the Paper Industry for Air and Stream Improvement 

(NCASI), jpinkerton@ncasi.org, 2004.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 6-1

6-1

6. CONCLUSION

As states prepare to conduct BART determinations for their eligible facilities, 

preliminary information has been collected on the availability, costs and efficiencies of a 

variety of technology options. Depending on the requirements contained in the final 

BART regulations, anticipated for April 2005, states will have to decide what level of 

cost and what degree of visibility improvement is considered reasonable before 

completing BART determinations. MANE-VU has reviewed technology options for four 

of the 26 BART-eligible source categories. For EGUs, industrial boilers, cement plants 

and paper and pulp facilities, we present typical control options and costs. Facility 

specific reviews will be needed to determine specific controls and costs for each BARTEligible source in the region.

6.1. EGUs

The presumptive level of control for previously uncontrolled EGU boilers as 

included in the proposed BART regulations include FGD (Scrubber) technology with an 

SO2 control efficiency of approximately 95 percent. Chapter 2 points out that the average 

scrubber operating today does not achieve this level of control (existing scrubbers have a 

range of efficiencies between 30 and 97 percent); however, new installations are 

achieving rates even higher than 95 percent removal. Additional measures which can be 

considered for SO2 control include the use of low-sulfur coal (compliance coal) (typically 

XX percent SO2 reduction), spray dry adsorption (60-95 percent removal), dry scrubbing 

(40-60 percent removal) or circular fluidized-bed adsorption technology (80-98 percent 

removal). SO2 control is highly cost effective with operational costs in the $100-200 per 

ton range.

NOX control technologies can be grouped into combustion controls (including 

low-NOX burners (LNBs), overfire air, off-stoichiometric firing, selective or biased 

burner firing, reburning, burners-out-of-service, and air staging) and post-combustion 

controls (include selective non-catalytic reduction (SNCR) and selective catalytic 

reduction (SCR) processes). Combustion controls result in typical NOX reductions of 15 to 

60 percent, depending on the specific boiler and combination of controls. SCR achieves a 

90-95 percent reduction whereas SNCR achieves 25-50 percent reduction in NOX. Costs 

for NOX removal range from $200-500/ton for some of the low yield techniques to $1000 

to $1500/ton for SCR with 90-95 percent removal efficiency.

Particulate matter (PM) control technologies include electrostatic precipitators 

(ESPs), fabric filters (FFs) (also called “baghouses”), and particulate scrubbers (PS). 

These technologies typically achieve greater than 95 percent removal of total particulate 

mass with over 80 percent removal of PM smaller than 0.3 um (with the exception of 

particulate scrubbers which achieve only 30-85 percent removal for this smaller size 

fraction). Mechanical collectors have even lower trapping efficiencies. PM controls are 

in place on virtually all EGUs already, hence the issue that will be faced in conducting

BART determinations is how these existing controls will interface with proposed controls 

for other pollutants.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 6-2

6-2

6.2. Industrial Boilers

For industrial boilers, many of the same control technologies for EGUs are 

applicable to this source category including: low sulfur coal, wet and dry FGD (or 

scrubber) technology for SO2, combustion modifications and SCR and SNCR technology 

for NOX, and ESP, fabric filter and wet scrubbing techniques for PM. However, 

industrial boilers have a wider range of sizes than EGUs and often operate over a wider 

range of capacities. Thus cost estimates for the same technologies will generally range, 

depending on the capacity of the boiler and typical operating conditions. High end cost 

estimates for NOX removal can be over $10,000/ton. 

6.3. Cement Kilns

Designing a system of emission controls for cement kilns are somewhat more 

complicated given that the quality of clinker produced in a kiln varies with characteristics 

of the combustion, it is possible to combine combustion technologies with postcombustion technologies for cement kilns in some cases and it is also possible to combine 

multiple combustion technologies on cement kilns. As a result, primary controls need to 

be selected carefully taking engineering and cost decisions into account for each specific 

kiln. 

Control options for SO2 include in-process removal, process changes (e.g. 

combustion optimization, flame shape adjustment or raw material changes), and the use 

of wet or dry scrubbers. For NOX, both process modifications (e.g. combustion 

modifications, low-NOX burners, secondary combustion or staged combustion) as well as 

post combustion controls need to be selected carefully. Particulate control devices for 

cement plants must be able to clean gases with fairly high dust loading given that the 

concentrations of particles in the exhaust can be several times higher than in a coal-fired 

power plant. In addition, PM technologies are affected by the presence of corrosive gases 

which can be reduced most effectively in a roller mill. While fabric filters (baghouses) 

and electrostatic precipitators are still the most common means of PM control at cement 

plants, a number of novel techniques and procedures are used to deal with the unique 

issues face by cement kilns. 

Costs for SO2 controls at cement kilns will vary widely depending on control 

options selected and process variables (e.g. whether material is recycled in the control 

process). Capital cost for typical wet/dry scrubbing post-combustion controls have been 

estimated in the $10-50/ton of clinker produced with operating costs in the $5-20/ton of 

clinker range. PM controls are similarly estimated in the $3-15/ton of clinker range for 

capital costs and $0-30/ton clinker for operating costs on an annual basis. NOX has not 

been estimated on a per ton of clinker basis, but estimates vary between 0 and 

$10,000/ton of NOX reduced. 

6.4. Pulp Mills

Paper and pulp facilities have perhaps the widest range of operational 

configurations and thus possibilities for reducing pollutant emissions. A variety of 
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 6-3

6-3

technologies exist for controlling emissions from pulp and paper facilities. Secondary 

control devices can be helpful in reducing emissions for some processes, and a number of 

them are available. Many facilities have found that significant emissions reductions can 

be achieved through process changes at the facility. Both secondary controls and process 

changes are presented as options.

For Kraft mill recovery furnaces, combustion modifications can be effective at 

reducing SO2, NOX, and VOCs. Reducing the liquor sulfidity can also help reduce SO2

emissions. PM control for recovery furnaces is typically achieved through the use of 

ESPs or wet ESPs.

Lime kilns are also a significant source of visibility impairing pollutants; 

however, there are fewer options for effectively reducing SO2 emissions. Combustion 

modifications can reduce NOX and VOC emissions and Venturi scrubbers and ESPs are 

commonly used for PM control.

Demister pads, packed towers and Venturi scrubbers are used to reduce PM 

emissions from smelt dissolving tanks.

The range in costs and emission reductions reflects the fact that site-specific 

factors play a critical role in determining how cost-effective various technologies will be 

in practice. Existing facilities do not always adequate or appropriate space for new 

equipment, which adds uncertainty to the capital and operating cost, as well at to the 

achievable emissions reductions. Hence a wide range of costs have been cited.
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 1

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Appendix A: BART-Eligible Facilities in the 

MANE-VU Region

NESCAUM has conducted two previous studies to identify a comprehensive list 

of BART-eligible sources in the MANE-VU region (NESCAUM, 2001; NESCAUM, 

2003). These studies have been carefully reviewed by permitting authorities in each of 

the MANE-VU jurisdictions and the sources listed in Table A-1 represent the list of 

sources identified through that process. Non-EGU sources for Pennsylvania and New 

York are still pending and should be available for inclusion in the Final Report.

Table A-1 BART-Eligible Facilities in the MANE-VU Region

State Facility Town/City BART Category

Connecticut Middletown EGU

Connecticut Montville EGU

Connecticut Norwalk Harbor EGU

Connecticut

PSEG Power Connecticut LLCBridgeport Harbor EGU

Connecticut

PSEG Power Connecticut LLC-New 

Haven Harbor EGU

Connecticut SPRAGUE PAPERBOARD INC Versailles boilers

Connecticut PFIZER INC Groton chemical plant

Delaware Edge Moor EGU

Delaware Indian River EGU

Delaware Mckee Run EGU

Delaware Citisteel Claymont iron and steel

Delaware DuPont Edge Moor Edge Moor chemical plant

Delaware Reichhold Cheswold chemical plant

Delaware Motiva Delaware City petrol. storage

District of 

Columbia Benning (PEPCO)

District of 

Columbia EGU

Massachusetts Brayton Point EGU

Massachusetts Canal EGU

Massachusetts Cleary Flood EGU

Massachusetts Braintree Electric EGU

Massachusetts Mystic EGU

Massachusetts New Boston EGU

Massachusetts Salem Harbor EGU

Massachusetts EASTMAN GELATINE CORP Peabody chemical plant

Massachusetts

GENERAL ELECTRIC AIR (GE 

Aircraft Engines) Lynn boilers

Massachusetts

TRIGEN BOSTON ENERGYKNEELAND STATION Boston boilers
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 2

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Massachusetts GULF OIL LP CHELSEA Chelsea petrol. storage

Massachusetts

REFUSE ENERGY SYSTEM 

COMPANY Saugus incinerator

Massachusetts SOLUTIA INC. (MONSANTO CO.) Springfield boilers

Massachusetts

EXXON EVERETT TERMIN 

(EXXON EVERETT MARKETING 

TERMINAL #240 Everett petrol. storage

Massachusetts GLOBAL PETROLEUM CORP. Revere petrol. storage

Massachusetts

HARVARD UNIVERSITY 

CAMBRIDGE Cambridge boilers

Maryland C P Crane EGU

Maryland Chalk Point EGU

Maryland Dickerson EGU

Maryland Herbert A Wagner EGU

Maryland Morgantown EGU

Maryland Vienna EGU

Maryland EASTALCO ALUMINUM Frederick aluminum ore

Maryland

ST. LAWERENCE CEMENT(formerly 

Independent Cement) Hagerstown portland cement

Maryland WESTVACO FINE PAPERS Luke kraft pulp

Maryland METTIKI COAL CORPORATION Oakland coal cleaning

Maine William F Wyman EGU

Maine Domtar - Pulp & Paper Baileyville kraft pulp

Maine Dragon Products Thomaston portland cement

Maine Fort James - OldTown Old Town kraft pulp

Maine International Paper - Bucksport Bucksport boilers

Maine IP Androscoggin Jay kraft pulp

Maine Katadhin - Mill W. Millinocket boilers

Maine Lincoln Pulp and Paper Lincoln kraft pulp

Maine Madison Paper Madison kraft pulp

Maine Mead WestVaco Rumford kraft pulp

Maine SD Warren - Somerset Skowhegan kraft pulp

Maine SD Warren Co. Westbrook kraft pulp

Maine Gulf Oil - S Portland South Portland petrol. storage

New Hampshire Merrimack EGU

New Hampshire Newington EGU

New Hampshire Annheuser-Busch Merrimack boilers

New Hampshire

Pulp & Paper Mills (33007-00001-

11) Berlin kraft pulp

New Hampshire Dartmouth College Hanover boilers

New Jersey Hudson EGU

New Jersey CHEVRON PRODUCTS CO 18058 Perth Amboy petrol. refinery

New Jersey

AMERADA HESS CORP PORT 

READING 17996 Woodbridge petrol. refinery

New Jersey BAYWAY REFINING CO 41805 Linden petrol. refinery

New Jersey

COASTAL EAGLE POINT OIL 

COMPANY 55781 Westville petrol. refinery

New Jersey

COLORITE SPECIALTY RESINS 

45940 Burlington chemical plant
DRAFT – Assessment of Control Options for BART-Eligible Sources Page 3

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New Jersey

GATX TERMINALS CORP 

CARTERET FACILITY 18010 Carteret petrol. storage

New Jersey GENERAL CHEMICAL CORP 07369 Newark acid, sulfur, charcoal

New Jersey

GREEN TREE CHEMICAL 

TECHNOLOGIES INC 18185 Parlin chemical plant

New Jersey Griffin Pipe Products (45954) Florence iron and steel

New Jersey

Infineum USA LP- Bayway Chemical 

Plant (41767) Linden chemical plant

New Jersey

SHELL OIL PRODUCTS CO 

SEWAREN PLANT 18051 Sewaren petrol. storage

New York Arthur Kill EGU

New York Astoria EGU

New York Bowline Point EGU

New York Charles Poletti EGU

New York Danskammer EGU

New York E F Barrett EGU

New York Lovett EGU

New York Northport EGU

New York Oswego EGU

New York Ravenswood EGU

New York Roseton EGU

New York Samuel A Carlson Generating Station EGU

New York Consolidated Edison's 59th St Station EGU

Pennsylvania Bruce Mansfield EGU

Pennsylvania Brunner Island EGU

Pennsylvania Cheswick EGU

Pennsylvania Conemaugh EGU

Pennsylvania Eddystone EGU

Pennsylvania Hatfield's Ferry EGU

Pennsylvania Homer City EGU

Pennsylvania Keystone EGU

Pennsylvania Martins Creek EGU

Pennsylvania Mitchell EGU

Pennsylvania Montour EGU

Pennsylvania New Castle EGU

Pennsylvania Portland EGU

Pennsylvania Warren EGU

Rhode Island BROWN UNIVERSITY Providence boilers

Rhode Island Clariant Corp. Coventry chemical plant