## Prepared for: Prepared by:

International Paper AECOM

Ticonderoga, NY Westford, MA

60156563

October 1, 2010 

# Environment



# Five Factor BART Analysis for

International Paper Ticonderoga Mill

September 2010

Document No.: 60156563

## Prepared for: Prepared by:

International Paper AECOM

Ticonderoga, NY Westford, MA

60156563

October 1, 2010 

# Environment



# Five Factor BART Analysis for

International Paper Ticonderoga Mill

_______________________________________________________________________________ Prepared By Robert Hall Seemantini Deshpande Adrienne Kieldsing

_________________________________ Reviewed By Robert M. Iwanchuk

September 2010

Document No.: 60156563

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# Contents

Executive Summary ............................................................................................................ ES-1

1.0 Introduction ...................................................................................................................... 1-1

1.1 Location of Source vs. Rele vant Class I Areas .................................................................. 1-2

1.2 Organization of Report ......................................................................................................... 1-2



# 2.0 Background Data ............................................................................................................ 2- 1

2.1 Overview of BART-Eligible Emission Units ......................................................................... 2-1

2.2 Description of BART-Eli gible Sour ces ................................................................................ 2-2

2.2.1 Power Boile r .......................................................................................................... 2-2

2.2.2 Recovery Bo iler ..................................................................................................... 2-2

2.2.3 Smelt Dissolvi ng Tank .......................................................................................... 2-2

2.2.4 Lime Kiln ................................................................................................................ 2-2

2.2.5 Miscellaneous S ources ......................................................................................... 2-3

2.3 Baseline Actual Emissions .................................................................................................. 2- 3

2.3.1 Power Boile r .......................................................................................................... 2-3

2.3.2 Recovery Bo iler ..................................................................................................... 2-4

2.3.3 Lime Kiln ................................................................................................................ 2-4

2.3.4 Smelt Dissolvi ng Tank .......................................................................................... 2-5

2.3.5 Miscellaneous S ources ......................................................................................... 2-5



# 3.0 Emission Control Alternatives fo r BART-Subject Sources ....................................... 3-1

3.1 Power Boiler Emission Cont rol Alternat ives ....................................................................... 3-1

3.1.1 SO 2 

# Emissions ...................................................................................................... 3-1

3.1.2 NOx Emissi ons ..................................................................................................... 3-3

3.1.3 Filterable PM E missions ....................................................................................... 3-5

3.2 Recovery Boiler ............................................................................................................... ..... 3-5

3.2.1 SO 2 

# Emission Cont rols ......................................................................................... 3-5

3.2.2 NO X 

# Emission C ontrols ......................................................................................... 3-6

3.2.3 PM Emission Control ............................................................................................ 3-7



# 4.0 Meteorological Data used in Visibility Improvement Modeling ................................. 4-1

5.0 CALPUFF Modeling Procedures ................................................................................... 5-1

5.1 CALPUFF Modeling Domain and Recept ors ...................................................................... 5-1

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# 5.2 Model Ve rsio n ................................................................................................................. ..... 5-1

5.3 Background Air Qual ity Data ............................................................................................... 5-1

5.4 Light Extinction and Haze Impact Calculat ions .................................................................. 5-1



# 6.0 CALPUFF Modeling and BART Determination Results .............................................. 6-1

6.1 Exemption Modeling ............................................................................................................ 6-1

6.2 Modeled Control Scenarios ................................................................................................. 6-2

6.3 Modeling Results for Ba seline Emissi ons ........................................................................... 6-2

6.4 Modeling Results for Power Boiler Guidel ine and Benchmark Emi ssion Rate s................ 6-4

6.5 Conclusions and BART Recommendatio n ......................................................................... 6-5



# 7.0 References .................................................................................................................... ... 7-1



# List of Appendices

Appendix A Response to N YSDEC Letter January 2010

Appendix B NCASI Emission Factors and Retr ofit Controls for Pulp Mill Sources

Appendix C NYSDEC BART Guidance Presentations

Appendix D Modeling Archive



# List of Tables

Table ES-1: Summary of BART Determ inations ................................................................................. ES-3

Table 2-1: Visibility Impacts of the BART -Exempt Sources at the Mill............................................... 2-1

Table 2-2: IP Ticonderoga Mill Ba seline Emissi ons ........................................................................... 2-6

Table 2-3: IP Ticonderoga Mill Baselin e Stack Parame ters ............................................................... 2-7

Table 3-1: Comparison of Power Boiler SO 2 

# Emissions to Guidelin es and Benchm arks ................. 3-3

Table 3-2: Comparison of Power Boiler NOx Emissions to Guidelines and Benchmarks ................ 3-5

Table 4-1: Comparison of the AECOM and VT DEC CALMET User-Defi ned Settings .................... 4-2

Table 5-1: References to the New IMPROVE Equation CALPOST Inputs ....................................... 5-2

Table 6-1: Exemption Modeling of BART-Eligib le Sources at the Mill ............................................... 6-1

Table 6-2: Regional Haze Impacts due to Baseline E missions ......................................................... 6-3

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# Table 6-3: Regional Haze Impacts for SO 2 

# Emission Guidelines and Benchmarks for IP's Power

Boiler ........................................................................................................................ ........... 6-4



# List of Figures

Figure 1-1: Location of the Class I Areas in Re lation to the Ti conderoga Mi ll .................................... 1-3

Figure 4-1: IP Ticonderoga CALMET Modeling Doma ins ................................................................... 4-3

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Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## ES-1



# Executive Summary

This report documents the key findings related to potential visibility im pacts and emission control

assessment for the BART-eligible emission units loca ted at the International Papers (IP) Ticonderoga

Mill. Six emission units at the Ticonderoga Mill began operation in the 15-year BART time window

and are “BART- Eligible” units.

Based on the visibility impairm ent criteria adopted by New York, modeling evaluations show that:

 None of IP’s Bart-Eligible units cause vi sibility impairment in any Class I area;

 Impacts from four units (Smelt Dissolving Tank , Lime Kiln, Starch S ilo and Chip cyclones) are

lower than de minimis levels and thereby det ermined to not contribute to degradation of

visibility in any Class I area.

 Impacts from IP’s Power Boiler and Recove ry Boiler exceed the 0.1 deciview contribution

criterion at the closest Class I area (Lye Brook Wilderness area) and therefore are subject to

BART control evaluations.

Conclusions from the Power Boiler and Recovery Bo iler BART control options evaluation are outlined

below:



# Power Boiler

Filterable PM

 PM controls currently in place achieve perfor mance levels required under federal New Source

Performance Standards for new boilers that were constructed prior to 2005.

 New Maximum Achievable Control Technology (MACT) standards will require additional

reduction of PM emissions.

 Existing PM controls, supplem ented by improvements required by Boiler MACT satisfy BART

PM control requirements for the boiler.

SO 2



#  SO 2 

# controls currently in place achieve perform ance levels consistent with most presumptive

BART benchmarks.

 New MACT standards will establish emission r equirements for acid gases. Operation and/or

control enhancements to comply with these provisions will further serve to reduce SO 2



# emissions.

 Existing SO 2 

# controls, supplemented by improvements required by Boiler MACT satisfy BART

control requirements for SO 2



# .

NOx

 NOx controls are currently in place to ensure compliance with CAIR NOx Budget

requirements.

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## ES-2



#  Future regulatory programs (such as RACT) ar e expected to periodically trigger requirements

to review NOx emissions levels which will serve to identify new and emerging technologies.

 Existing control systems and operational prac tices achieve NOx leve ls consistent with

presumptive BART benchmarks and satisf y BART requirements for NOx.



# Recovery Boiler

Filterable PM and SO 2



#  PM controls currently in place satisfy MACT standards for PM-HAPs and satisfy BART.

 SO 2 

# emissions from non-direct contact evaporatio n recovery furnaces are inherently low due

to operating practices.

 Existing design and operating practices satisfy BART for these pollutants.

 Revisions to Subpart MM MACT standards may imp act future emissions of these visibility

impairing pollutants.

NOx

 Good operating practices are currently us ed to comply with NYSDEC’s NOx RACT

requirements.

 No technically-feasible alternatives ha ve been identified for achieving additional NOx

emission reduction from recovery boilers.

 BART for NOx emissions from IP’s Recovery Bo iler is use of three-level staged combustion

air system with ESPs.

The results of the case-by-case BART analysis fo r the BART-subject units are summarized in Table

ES-1.AECOM EnvironmentFive Factor BART Analysis for International Paper Ticonderoga MillSeptember 2010ES-3Table ES-1: Summary of BART DeterminationsParameter Power Boiler Recovery BoilerBaselineVisibilityImpacts(a)Days > 0.1 deciview(b)46 to 51 16-30Days > 0.5 deciview(b)2 to 5 0Days > 1.0 deciview(b)0 0Maximum Impact, deciview(b)0.64 (sulfates = 0.2, nitrates = 0.34) to 0.73 (sulfates =0.23, nitrates = 0.35)0.28 (sulfates = 0.11, nitrates = 0.13) to 0.38 (sulfates =0.18, nitrates = 0.13)Eighth Highest Impact, deciview(b)0.34 to 0.40 0.16-0.23PMEmissionsExisting Control Technology Multicyclone & wet scrubber ESPBaseline Filterable PM Emissions 48 lb PM/hr 8.1 lb PM/hrProposed BART Determination Currently permitted emissionsCompliance with the current MACT PM-HAP emissionlimitBasis and Other ConsiderationsFilterable PM-HAP control that will be required in 2014/15timeframe by Boiler MACT may decrease emissions.The maximum PM visibility impact is close to 0.1 deciviewand the eighth highest impact is less than 0.1 deciview.Filterable PM-HAP control that will be reviewed in2014/15 timeframe by 8-yr MACT review decreaseemissions.The maximum PM visibility impact is less than 0.1deciview.SO2EmissionsExisting Control Technology Wet scrubber with sodium hydroxide injectionLow odor non-direct contact evaporator inherentlyprovides very low emissions.Baseline SO2Emissions 274 lb/hr <1 lb/hrProposed BART Determination Currently permitted emissionsbased on wet scrubbing Continued good operating practicesBasis and Other ConsiderationsCurrently permitted emissions are less than MANE-VUpresumptive BART and within the range of otherbenchmark emission rates.Potential lower SO2emission rates show maximum visibilityimprovements less than 0.1 deciviewThe process results in inherently low emissions.Maximum SO2visibility impact is well below 0.1deciviewAECOM EnvironmentFive Factor BART Analysis for International Paper Ticonderoga MillSeptember 2010ES-4Parameter Power Boiler Recovery BoilerNOxEmissionsExisting Control TechnologyAdvanced combustion controls including TODD low NOxburnersStaged combustion with independently operatingprimary, secondary and tertiary air dampersBaseline NOx Emissions178 lb/hr (maximum daily average occurred on 12/26/05during the non-ozone season)65 lb/hrProposed BART Determination Currently permitted emissions Currently permitted emissionsBasis and Other ConsiderationsCurrently emissions are well controlled.Lower NOx emissions would decrease the maximumvisibility impact by no more than 0.18 deciviews and theeighth highest impact by no more than 0.07 deciviews.The Power Boiler will comply with the New York NOx RACTrule by July 1, 2014. In New York, compliance with theNOx RACT rule is the presumptive BART.Maximum visibility impacts due to NOx emissions areclose to 0.1 deciview and the eighth highest impact isless than 0.1 deciviewThere are no available additional controls.(a)At the Lye Brook Wilderness area which isthe closest Class I area and the location ofthe maximum predicted impacts. The rangereflects the different impactspredicted using two meteorological data basesrequired by NYSDEC for visibility modeling.(b)The reported impact is the change (delta deciview) compared to visibility presumed to occur on days under the best natural background conditions (20% best days)without influence from any man-made emission activity.

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# 1.0 Introduction

The Ticonderoga Mill, owned and operated by Internat ional Paper Company, has been identified by

NYSDEC as a source that is eligible for consider ation of BART controls for the visibility impairing

pollutants SO 2 

# , NOx, and PM 10 

# . This document describes the procedures by which a modeling

analysis and a BART engineering review have been co nducted for the units subject to BART at the

Ticonderoga Mill.

To protect visibility in national parks and wil derness areas, state and federal regulations require

evaluation of the existing level of emission controls and visibility im pacts associated with certain types

of emission sources that began operation between 1962 and 1977.

New York rules (6NYCRR § 249.1) require sources with BART-eligible units to evaluate emissions and

use modeling to determine if the emissions could reasonably cause or contribute to visibility

impairment at one or more of the seven Class I areas in the northeastern U.S.

“BART-Eligible” sources whose emissions are found to reasonably cause or contribute to visibility

impairment at Class I areas are designated as “BART- Subject” units that must satisfy best available

retrofit technology (BART) emissi on limitations. BART emission lim itations are to be established at

levels that reflect the degree of reduction achievable through app lication of the best system of

continuous emission reduction for each visibility impairing pollutant

Owners of BART-eligible units with modeled impacts below the NY “contribution” threshold of 0.1

deciviews are exempt from require ments to apply BART limitations . Owners of units exceeding the

impairment contribution threshold are required to submit BART control evaluations and control

recommendations to the permitting authorities no later than October 1, 2010.

International Paper secured the services of AECO M to conduct the required BART analyses for units

at the Ticonderoga Mill. Analyses were conducted in accordance with NY BART regulations and the

implementation guidelines (see Appendix C) and th e procedures contained in the Final BART

Guidelines published by the USEPA on July 6, 2005 (Federal Register Volume 70, No. 128).

Consistent with the BART Guidelines, the five steps for a case-by-case BART analysis were followed:

1. Step 1 – Identify all available control te chnologies for the affected units including

improvements to existing control equipment or installation of new add-on control equipment.

2. Step 2 – Eliminate technically infeasible options considering the commercial availability of the

technology, space constraints, operating problems and reliability, and adverse side effects on

the rest of the facility.

3. Step 3 – Evaluate the control effectiveness of the remaining technologies based on current

pollutant concentrations, flue gas properti es and composition, control technology

performance, and other factors.

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# 4. Step 4 – Evaluate the annual and incremental costs of each feasible option in accordance

with approved EPA methods, as well as the associated energy and non-air quality

environmental impacts.

5. Step 5 – Determine the visi bility impairment associated with baseline emissions and the

visibility improvements prov ided by the control technologies considered in the engineering

analysis (Steps 1 – 4).

The emission baseline period fo r this BART analysis is 2005-2009.



# 1.1 Location of Source vs . Relevant Class I Areas

Figure 1-1 shows the location of the Ticonderoga Mill relative to the seven Class I areas to be

considered for BART visibility assessments in New York. The seven Class I areas are:

1. Brigantine National Wildlife Refuge (NJ), located about 485 km from the Ticonderoga Mill;

2. Lye Brook Wilderness Area (VT), locate d about 87 km from the Ticonderoga Mill;

3. Presidential Range Dry River Wilderness (NH) , located about 164 km from the Ticonderoga

Mill;

4. Great Gulf Wilderness (NH), locate d about 171 km from the Ticonderoga Mill;

5. Dolly Sods Wilderness Area (WV), loca ted about 728 km from the Ticonderoga Mill;

6. Otter Creek Wilderness Area (WV), located about 746 km from the Ticonderoga Mill;

7. Acadia National Park (ME), locat ed about 378 km from the Ticonderoga Mill.



# 1.2 Organization of Report

This report documents the case-by- case BART analysis conducted for SO 2 

# , NOx and PM 10 

# emissions

from the BART-subject units at th e Ticonderoga Mill. Section 2 provides a description of Ticonderoga

Mill’s BART-eligible units and their baseline emissions. Section 3 provides a discussion of SO 2 

# , NOx

and PM control technologies. The available me teorological data and the CALPUFF modeling

procedures are described in Sections 4 and 5, respectively. The result s of the visibility modeling are

presented in Section 6 along with recommendations and conclusions. References are listed in

Section 7.

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Figure 1-1: Location of the Class I Areas in Relation to the Ticonderoga Mill

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# 2.0 Background Data

2.1 Overview of BART-Eligible Emission Units

BART-eligible emission units at the Ticonderoga Mil l were identified by NYSDEC as being the Power

Boiler, the Recovery Boiler, the Smelt Dissol ving Tank, the Lime Kiln and miscellaneous PM

emissions sources which include the Starch Silo and two Wood Chip Cyclones. Each of these

emission units began operation in the 15-year time frame targeted by the BART regulations (1962-

1977).

The Smelt Dissolving Tank, the Lime Kiln and the miscellaneous PM emission sources were

determined through modeling to be exempt from any further BART analysis or control evaluation

requirements based on modeling results showing that these units have less than 0.1 deciview impact

(see Table 2-1) at any Class I area.

Table 2-1: Visib ility Impacts of the BART-Exempt Sources at the Mill



# Source Class I area Maximum dv B

ext (1) 

# 8 th 

# Highest dv B ext (1)



# Lime Kiln Lye Brook

Wilderness (2) 

# 0.001 0.000

Smelt Dissolving Tank 0.017 0.007

Starch Silo/Chip

Cyclones Great Gulf

Wilderness (3) 

# 0.008 0.003

1. Deciview. A measurement of visibility impairment. A deciview is a haze index derived from calculated light extinction,

such that uniform changes in haziness correspond to uniform incremental changes in perception across the entire

range of conditions, from pristine to highly impaired. The deciview haze index is calculated based on the following

equation (for the purposes of calculating deciview, the atmospheric light extinction coefficient must be calculated

from aerosol measurements):

HI = 10 ln (b/10);

where b = the atmospheric light extincti on coefficient, expressed in inverse megameters (Mm -1 

## )”.

These values represent the changes in visibility from the 20% best natural backgr ound conditions.

2. Results are presented for the Lye Brook Wilderness since th e highest visibility impacts fr om the Lime Kiln and the

Smelt Dissolving Tank occur at this Class I area.

3. Results are presented for the Great Gu lf Wilderness since the highest visib ility impacts from t he miscellaneous PM

sources occur at this Class I area.



# The Power Boiler is currently permitted to burn No. 6 fuel oil, bark/wood, reje cted digester wood knots,

primary clarifier fiber, dried secondary biomass and wa ste fuel types “A” for the production of steam

and electricity via a turbine generator. The Power Boiler also combusts the non-condensable gases

(NCG) produced by the pulping and chemical recovery process. The fuel mix for the Power Boiler is

typically approximately 20% wood/bark and ~80% re sidual oil on a heating value basis. The other

fuels listed in the permit have not been fired or have been fired on a very limited basis over the last

five years.

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# The Recovery Boiler is used to recover chemical s from spent pulping liquor and to produce steam for

the mill. It consists of a low odor non-direct contac t Kraft recovery furnace and a smelt dissolving tank.

The Recovery Boiler at the mill processes black liquor solids (BLS) and fires No. 6 oil as an auxiliary

fuel.



# 2.2 Description of B ART-Eligible Sources

2.2.1 Power Boiler

The Power Boiler is rated at 855 MMBtu/hr and is permitted to fire up to 450 wet tons per day of

wood/bark with the remaining heat input from firing of low sulfur No.6 oil. It is equipped with advanced

combustion controls including low NOx burners. Emissions of SO 2 

# from the Power Boiler are currently

controlled by an Entoleter wet-alkaline scrubber that was installed in 1996. Sodium hydroxide is

injected into the scrubber recycle line to control SO 2 

# . The current permit limits for SO 2 

# are 309 lb/hr as

a 24-hr rolling average and 435 lb/hr as a 3- hour rolling average. Emissions of PM/PM 10 

# from the

Power Boiler are controlled by multicyclones and the dual purpose wet scrubber system. Filterable

particulate emissions are limited by permit conditions to no more than 0.10 lb/MMBtu. NOx emissions

from oil combustion are controlled using TODD Variflame Series 38 low NOx burners. Advanced

combustion techniques are also employed to contro l NOx generated from the combustion of all fuel

types. NOx emissions are limited by the permit to no more than 0.25 lb/MMBtu as a block daily

average from May 1 through September 30 and 0.25 lb/MMBtu as a 30-day rolling average from

October 1 through April 30.



# 2.2.2 Recovery Boiler

The Recovery Boiler is a Babcock and Wilcox strai ght fired, low odor, non-direct contact evaporation

boiler that processes black liquor and may burn No. 6 oil (with a sulfur content of 1.5%) as an auxiliary

fuel. No. 6 fuel oil use is restricted to less than 10% of the total fuel burned in the recovery boiler

based on heat input. This unit is equipped with a three level staged combustion air supply system that

reduces both NOx and total reduced sulfur (TRS) em issions and an electrostatic precipitator for

control of PM emissions. Filterable particulate emissi ons from the Recovery Boiler are limited by the

Subpart MM MACT standard to not more than 0.03 gr ains per dry standard cubic feet (gr/dscf) of

exhaust gas at 8% O 2



# .



# 2.2.3 Smelt Dissolving Tank

The sulfur and sodium chemicals recycled in the kraft process (smelt) flow from the bottom of the

recovery boiler into the Smelt Dissolving Tank to fo rm green liquor. The smelt is dissolved in water to

form green liquor. It is then transferred to a re caustisizing tank where calcium oxide is added to

convert the solution back to white liquor for return to the digester. Emissions from this unit are routed

through a wet scrubber ( ∆ P 6 – 9” water) with a demister. Filt erable particulate emissions from the

Smelt Dissolving Tank are limited by the Subpart MM MACT standard to not more than 0.15 gr/dscf at

8% O 2



# .



# 2.2.4 Lime Kiln

The Lime Kiln converts the lime mud to calcium oxide through a process called “calcining”. This unit is

equipped with a venturi scrubber for control of PM emissions and total reduced sulfur emissions. NOx

emissions from the Lime Kiln are permitted at 120 ppmv, wet, at 10% O 2 

# based on NYSDEC’s NOx

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# RACT requirements. Filterable PM emissions from this unit are limited by the Subpart MM MACT

standard to no more than 0.15 gr/dscf at 10% O 2



# .



# 2.2.5 Miscellaneous Sources

The miscellaneous BART-eligible PM sources at t he mill consist of a starch silo and two chip

cyclones. The starch silo’s actual PM emissi ons are 6,832 lb/year whereas the two wood chip

cyclones emit 19,803 lb PM/year. These PM emissions were obtained from the mill’s annual emission

statements and are based on the material throughput rates for each miscellaneous source.



# 2.3 Baseline Actual Emissions

The highest daily emission rate, for each source, of SO 2 

# , NOx, and filterable PM emissions occurring

between 2005 and the end of 2009 was identified from production records, monitoring data, and stack

test reports, and used as the basis for the baseline modeling case for BART-eligible sources. This

determination was made independently for each BART-e ligible unit based on processing emissions

records of only that unit. Maximum emissions ar e not necessarily expected to occur from all BARTeligible sources on the same day, and in fact downtim e of one source may be the very reason for high

production or emissions from another. This approach prov ides a conservative basis for determining if

a BART-eligible unit, by itself caus es or contributes to visibility degradation but does not necessarily

allow informed decisions regarding the cumulative impac t from all BART-eligible sources at the facility.

Table 2-1 provides a summary of the SO 2 

# , NOx, and filterable PM emissi on rates used in the visibility

modeling analysis of BART-eligible units. Table 2-2 provides the corresponding stack parameters that

were used in the modeling anal ysis for baseline conditions.



# 2.3.1 Power Boiler

Baseline SO 2 

# and NOx emissions from the Power Boiler were based on the maximum actual daily

SO 2 

# and NOx emission rates recorded by the CEMS during the period 2005-2009. The maximum

daily NOx emission rate was found to occur on 12/26/2005 (during the non-ozone season). The

baseline filterable PM emission rate was based on the maximum actual daily hea t input rate of 16,762

MMBtu/day (equivalent to daily average of 698.4 MMBtu/hr) and 0.068 lb/MMBtu (measured during a

October 19, 2007 stack test).

Since 80% or more of the heat input comes from No. 6 oil when the boiler is operated at the maximum

baseline rates identified above, PM 10 

# speciation was based on profiles for 100% oil firing. This

assumption is conservative since oil firing results in higher visibility impacts, due to sulfate emissions,

as compared to wood firing. Hence, speciation of the particulate matter emissions from the Power

Boiler into filterable and condensable PM 10 

# components was conducted using the following approach:

 The total filterable PM emission rate was obtained from stack tests.

 The filterable PM 10 

# portion of the total filterable PM was calculated using the cumulative size

distributions given in AP-42 Table 1.3-4 (uncont rolled size fractions). The total filterable PM 10



# is 71% of the filterable PM. The fine PM 10 

# (i.e., PM 2.5 

# ) was calculated as the 52% of total

filterable PM. The coarse PM 10 

# (particles with aerodynamic diameters between 10  m and

2.5  m) was calculated as 19% of PM based on the difference between the total filterable

PM 10 

# and the fine PM 10 

# (filterable PM 2.5 

# ).

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#  Elemental carbon or black carbon was estimated to be 7.4% of fine PM 10 

# (PM 2.5 

# ) based on

the best estimates for industrial petroleum in Table 6 of “Catalog of Global Emissions

Inventories and Emission Inventory Tools for Bl ack Carbon”, William Battye and Kathy Boyer,

EPA Contract No. 68-D-98-046, January 2002. Fine soil is the difference between fine total

and fine EC.

 The condensable PM emission factor was based on AP-42 Table 1.3-2 (1.5 lb/1000 gal) for

No.6 oil-fired boilers. All inorganic condensable PM 10 

# was assumed to be sulfates (i.e. no soil

component).



# 2.3.2 Recovery Boiler

The Recovery Boiler is equipped with two stacks ( an old stack and a new stack). Baseline PM, SO 2



# and NOx emissions from this unit were based on the results of the stack tests conducted during the

period 2005-2009. The total emissions from the Recovery Boiler were apportioned to each stack

based on the flow measurements made during stack tests.

Speciation of the particulate matter emissions fr om the non-direct contact Recovery Boiler into

filterable and condensable PM 10 

# components was conducted using the following approach:

 The total filterable PM emission rate was obtained from stack tests.

 For a non-direct contact evaporation furnace, as per AP-42 Table 10.2-3, 74.8% of filterable

PM is PM 10 

# for a recovery boiler. Coarse PM 10 

# is 7.5% of total filterable PM 10 

# and 67.3% of

total filterable PM 10 

# is fine PM 10 

# (filterable PM 2.5 

# )

.

 Elemental carbon or black carbon was estimated to be 7.4% of fine PM 10 

# (PM 2.5 

# ) based on

the best estimates for industrial petroleum in Table 6 of “Catalog of Global Emissions

Inventories and Emission Inventory Tools for Bl ack Carbon”, William Battye and Kathy Boyer,

EPA Contract No. 68-D-98-046, January 2002. Fine soil is the difference between fine total

PM 10 

# and fine EC.

 Condensable PM 10 

# emission rates are based on NCASI emission factors (Particulate

Emissions for Pulp and Paper Industry Specific Sources, February 9, 2006). This is a nondirect contact evaporation recovery furnace. T he emissions factors are 0.53 lb/ton of BLS for

CPM IOR and 0.104 lb/ton of BLS for CPM OR. Sulfates, based on ion chromatography, are

34% of the CPM.



# 2.3.3 Lime Kiln

Baseline filterable PM, SO 2 

# and NOx emissions from the Lime Kiln were based on the results of the

stack tests conducted during the period 2005-2009.

Speciation of the particulate matter emissions fr om the Lime Kiln into filterable and condensable PM 10 

# components was conducted using the following approach:

 The total filterable PM emission rate of the Lime Kiln was obtained from stack tests.

 Total filterable PM is assumed to be equal to filterable PM 10 

# . Coarse PM 10 

# emissions from the

Lime Kiln are calculated as 98.3% of filterable PM 10 

# based on AP-42 Table 10.2-4. Coarse

PM 10 

# is 2.3% of filterable PM and 96% of filterable PM is fine PM 10 

# (filterable PM 2.5 

# ).

 There are no data on EC for this source type. PM 10 

# emissions from smelt tanks and lime kilns

are assumed to be all inorganic given the nat ure of the processes. Therefore, as a

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 2-5



# conservative estimate, it is assumed that 2.5% of fine PM 10 

# (1/3 of the percentage assumed

for the recovery boilers) is EC.

 Condensable PM 10 

# emissions from Lime Kilns are based on NCASI emission factors

(Particulate Emissions for Pulp and Paper Industr y Specific Sources, February 9, 2006). The

emissions factors are 0.0060 gr/dscf @10% O 2 

# for inorganic CPM and 0.00030 gr/dscf @10%

O 2 

# for organic CPM. Sulfates, based on ion ch romatography, are 21% of the inorganic CPM.

Stack gas flow is calculated from the st ack parameters assuming saturation and 10% O 2 

# on a

dry basis.



# 2.3.4 Smelt Dissolving Tank

Baseline PM and SO 2 

# emissions from the Smelt Dissolving Tank were based on the results of the

stack tests conducted during the period 2005-2009. Due to the nature of the process, this unit does

not result in any NOx emissions.

Speciation of the particulate matter emissions fr om the Smelt Dissolving T ank into filterable and

condensable PM 10 

# components was conducted using the following approach:

 The total filterable PM emission rate of the Smelt Dissolving Tank was obtained from stack

tests.

 For a smelt dissolving tank, based on AP-42, Table 10.2-6, 88.5% of filterable PM is PM 10 

# , 15.5% of filterable PM is coarse PM 10 

# , and 73.0% of filterable PM is fine PM 10 

# .There are no

data on EC for this source type. PM 10 

# emissions from smelt tanks and lime kilns are assumed

to be all inorganic given the nature of the proce sses. Therefore, as a conservative estimate,

it is assumed that 2.5% of fine PM 10 

# (1/3 of the percentage assumed for the recovery boilers)

is EC.

 Condensable PM 10 

# emissions from this unit are based on NCASI emission factors (Particulate

Emissions for Pulp and Paper Industry Specific Sources, February 9, 2006). The emissions

factors are 0.0192 lb/ton of BLS for inorganic CP M and 0.0044 lb/ton of BLS for organic CPM.

Sulfates, based on ion chromatography, are 29% of the inorganic CPM.



# 2.3.5 Miscellaneous Sources

Miscellaneous material handling sources (starch silo and the two chip cyclones) are expected to have

PM emissions only. The baseline PM emissions for these sources were based on the PM emission

rates reported by the mill in its annual emission st atement. Further, all PM is assumed to be PM 10 

# and

all PM 10 

# is conservatively assumed to be fine PM 10 

# (fine soil) for these sources. Based on their

nature, these sources are not expected to emit EC or condensable PM 10



# .AECOM EnvironmentFive Factor BART Analysis for International Paper Ticonderoga MIllSeptember 20102-6Table 2-2: IP Ticonderoga Mill Baseline EmissionsAECOM EnvironmentFive Factor BART Analysis for International Paper Ticonderoga MillSeptember 20102-7Table 2-3: IP Ticonderoga Mill Baseline StackParametersEMISSIONUNIT IDEMISSION UNIT DESCRIPTIONLocation in Lat/Long andGround Elevation(ft)StackHeightfromGround(ft)Stack ExitTemperature(F)StackExitVelocity(ft/sec)StackDiameter(ft)00044 POWER BOILER43.8893 Lat., -73.3973LongMSL=171 ft205 142 25.69 12.9200001RECOVERY BOILER, NON-DIRECTCONTACT EVAPORATION, OLDSTACK43.8892 Lat., -73.3972LongMSL=170 ft205 407 67.66 6.1700103RECOVERY BOILER, NON-DIRECTCONTACT EVAPORATION, NEWSTACK43.8895 Lat., -73.3970LongMSL=171 ft200 381 24.48 9.0000003 SMELT DISSOLVING TANK43.8891 Lat., -73.3975LongMSL=171 ft169 136 28.73 3.3800005 LIME KILN43.8879 Lat., -73.3963LongMSL=171 ft80 159 22.78 4.33---OTHER MISCELLANEOUS SOURCES(Starch Silo and two Chip Cyclones)43.8874 Lat., -73.3963LongMSL=171 ft20 Ambient 0 3.67

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-1



# 3.0 Emission Control Alte rnatives for BART-Subject Sources

As discussed previously, the Lime Kiln, the Smel t Dissolving Tank and the miscellaneous PM sources

at the Ticonderoga Mill were found to have insi gnificant modeled impacts and were hence deemed to

be exempt from BART requirements. This section discusses emission control alternatives for the two

emission units determined to be subject to BART, the Power Boiler and the Recovery Boiler.

As discussed in greater detail below, emissions of both SO 2 

# and NOx from the Power Boiler are

currently well controlled with performance leve ls comparable to various benchmarks that have been

previously used to define BART. Filterable PM e missions are also currently well controlled and

expected to be reduced even further when the new In dustrial Commercial Institutional (ICI) Boilers

and Process Heaters MACT standard (40 CFR 63 Subpart DDDDD) becomes effective.

For the Recovery Boiler, emission controls and operat ing practices currently in place satisfy BART

requirements. As discussed in more detail below, there are no additional SO 2 

# or NOx emission

control technologies available to significantly imp rove performance levels currently being achieved.

Filterable PM emissions from the Recovery Boiler currently meet BART requirements through

compliance with the applicable MACT standard (40 CFR 63 Subpart MM). Section 3.1 presents

emission control alternatives for the Power Boiler. Th e Recovery Boiler is discussed in Section 3.2.



# 3.1 Power Boiler Emission Control Alternatives

3.1.1 SO 2 

# Emissions

The fuel mix for the Power Boiler is typically 20% wo od/bark and 80% residual oil (No. 6 fuel oil) on a

heating value basis. Fuel sulfur for residual oil used at the IP Ticonder oga Mill is limited to a

maximum concentration of 1.5%. Over the most recent 5 years, the actual fuel oil sulfur content has

ranged from 0.81% to 1.48%. Before cont rol, approximately 85% to 90% of the SO 2 

# emissions are

attributable to fuel oil combustion.

Emissions of SO 2 

# are controlled by an Entoleter wet-alkaline scrubber that was installed in 1996.

Sodium hydroxide is injected into the scrubber recycle line to control SO 2 

# . The current permit limits for

SO 2 

# are 309 lb/hr as a 24-hr rolling average and 435 lb/hr as a 3-hour rolling average. The 24-hour

average emission limit of 309 lb/hr is equivalent to 0.36 lb/MMBtu at the maximum rated capacity of

855 MMBtu/hr and higher lb/MMBtu rates at lower ope rating loads. During the 2005 to 2009 period,

the actual maximum 24-hr emission rate was 274 lb/hr.

In general, the emission controls that might be availa ble for this type of source are the combustion of

natural gas or possibly lower sulfur fuel oil and/or wet or dry scrubbing. However, natural gas is not

available for the IP Ticonderoga Mill because the distance to the nearest natural gas pipeline is

approximately 70 miles. With regard to lower sulf ur fuel oil and/or wet or dry scrubbing, the Power

Boiler emissions and emission controls are already consistent with BART guidelines and policies as

well as other available benchmarks as discussed below . In addition, as shown in Section 6, even if

SO 2 

# emissions were reduced, the resulting visibi lity improvements would not be significant.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-2



# NYSDEC policy is that the pres umptive BART for residual oil fire d utility boilers, with no add-on

emission controls, is the use of fuel with no more than 1% S. For typical residual fuel oil, 1% S results

in an SO 2 

# emission rate of 1.05 lb/MMBtu. This policy w ould define BART for an oil fired utility boiler

operating at 855 MMBtu/hr as an SO 2 

# emission rate of 900 lb/hr as a 24-hr average. The current

maximum permitted emission rate for IP’s Power Bo iler is currently 309 lb/hr as a 24-hr average,

which is well below NYSDEC’s pr esumptive BART emission rate for a similarly sized residual oil-fired

utility boiler. Even at low loads, the SO 2 

# emissions from IP’s Power Boiler are at or below the

emission rate that would be achieved if 1% S oil was burned without emission controls.

MANE-VU’s BART Workgroup Recomm endations for presumptive SO 2 

# control levels for industrial

boilers list 90% control, compliance with the ICI Boil er MACT acid gas control level, or 0.55 lb/MMBtu

(0.5% fuel sulfur limit). 1 

# IP will meet these presumptive BART requirements by complying with the ICI

Boiler MACT acid gas control requirements when t hese are finalized. The 0.55 lb/MMBtu emission

rate would result in SO 2 

# emissions of 470 lb/hr at the Power Boiler’s maximum rating of 855

MMBtu/hr. IP’s current permit limi t of 309 lb/hr as a 24-hr average is well below the 470 lb/hr MANEVU presumptive BART guidance.

The most stringent, relevant SO 2 

# emission requirements in current NYSDEC rules is the Subpart 225-

1 limitations for residual fuel oil in New York Ci ty (0.3% S) and Nassau, Rockland, and Westchester

Counties (0.37%S). These fuel sulfur limits ar e equivalent to 0.314 lb /MMBtu and 0.387 lb/MMBtu,

respectively. At IP’s Power Boiler’s maximum rating of 855 MMBtu/hr these emission rates would

result in SO 2 

# emissions of 268 lb/hr to 331 lb/hr. The higher emission rate is above IP’s currently

permitted emissions while lower emission rate is slight ly below IP’s current permi t limit. However, as

shown in Section 6 of this report, the lower emi ssion rate would result in an insignificant modeled

visibility improvement of only 0.02 deciviews.

The Federal New Source Performance Standard for indus trial oil fired boilers built after February 28,

2005 is 0.20 lb/MMBtu (40 CFR 60 Subpart Db). At IP’s Power Boiler’s maximum rating of 855

MMBtu/hr this emission rate would result in SO 2 

# emissions of 171 lb/hr which is lower than IP’s

currently permitted emission rate (which is 309 lb /hr as a 24-hr average). However, as shown in

Section 6 of this report, the lower emission rate would result in an insignificant modeled visibility

improvement of only 0.07 deciviews.

Table 3-1 summarizes the above guidance and benchmarks for SO 2 

# emissions. The Power Boiler

SO 2 

# emissions are already well controlled and are wi thin the range of the guidelines and benchmarks

shown in Table 3-1. In addition, as shown in Section 6, the visibi lity benefits associated with reducing

SO 2 

# emissions to the lower benchmark levels are not significant. Therefore, the current SO 2 

# emission

limit of 309 lb/hr as a 24-hr rolling average and future compliance with the ICI Boiler MACT acid gas

standard represent BART for IP’s Power Boiler.

1 

## Five-Factor Analysis of BART-Eligible Sources, prepared by NESCAUM for the MANE-VU Regional Planning

Organization, June 1, 2007.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-3

Table 3-1: Comparison of Power Boiler SO 2 

## Emissions to Guide lines and Benchmarks



# Case Basis for SO 2 

# Emissions SO 2 

# Emissions

No. Description lb/hr as 24-hr average

Base Case

Base Baseline Actual with Wet Scrubbing Wet Scrubbing 274

SO 2 

# Benchmark Cases at Maximum Design Capacity, 855 MMBtu/hr

1 Current Allowable SO 2 

# Case with Wet

Scrubbing Wet Scrubbing 309

2 MANE-VU Presumptive BART for

Industrial Boilers, 0.55 lb/MMBtu 0.55 lb/MMBtu 470

3 NYSDEC limit for Nassau, Rockland

and Westchester counties, 0.37 % S 0.387 lb/MMBtu 331

4* NYSDEC limit for New York City, 0.30

% S 0.314 lb/MMBtu 257

5* NSPS (40 CFR 60 Subpart Db) for

industrial oil-fired boilers built after

February 2005 0.20 lb/MMBtu 171

*Visibility modeling showed that SO 2 

# benchmark cases 4 and 5 resulted in insignificant visibility

improvements.



# 3.1.2 NOx Emissions

The fuel mix for the Power Boiler is typically 20 % wood/bark and 80% residual oil on a heating value

basis. NOx emissions are controlled using advanc ed combustion controls including TODD Variflame

Series 38 low NOx burners for firing oil. The TODD burners limit NOx emissions by reducing the

flame temperature and lowering the ef fective oxygen concentration.

Primary and secondary air enters the burner from the windbox through an annular air gap. The air

gap is designed to accelerate the primary and secondar y air without flow disturbances from the lower

velocity in the windbox. The air then turns 90 degrees and is further accelerated through a venturi.

Near the exit of the venturi, the air splits into tw o distinct concentric streams. The primary air passes

through a swirler while the secondary air passes outside the periphery of the swirler.

The outward spin provided to the primary air, and to any combustion products formed in the vortex

region, results in a low pressure region immediately in front of the swirler. Consequently, a portion of

the combustion gases spinning outward from the sw irler, along with a portion of the gases in the

secondary air region, are drawn from a region several f eet in front of the swirler. The gases are then

recirculated back into this low pressure region. This “recirculation” of flue gases back into the area in

front of the swirler provides flame stabilization and helps to reduce NOx emissions in the primary

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-4



# combustion zone by reducing the flame temperat ure and lowering the “effective” oxygen

concentration.

The currently installed NOx emission controls lim it NOx emissions to 0.25 lb/MMBtu. Maximum

baseline emissions during the 2005 to 2009 period we re 178 lb/hr as a 24-hr average. At the

maximum design heat input of 855 MMBtu/hr, ma ximum permitted NOx emissions are 214 lb/hr.

EPA’s study regarding the cost-effectiveness of NOx retr ofit controls to oil-fire d units was inconclusive.

While advanced combustion controls were cost-effecti ve for some units, there were several facilities

for which NOx retrofit controls proved to be to o expensive. Therefore, EPA decided not to issue a

presumptive BART limit for oil-fired boilers (Federal Register, Vol. 70, No. 128, Page 39136, July 6,

2005). EPA’s analysis indicates that they anticipat ed that BART emission control options for oil fired

boilers would be limited to com bustion controls. The IP Power Boiler currently uses modern

combustion controls to limit NOx emissions.

The Federal New Source Performance Standard for indus trial oil fired boilers built after February 28,

2005 is 0.20 lb/MMBtu (40 CFR 60 Subpart Db). At IP’s Power Boiler’s maximum rating of 855

MMBtu/hr this emission rate would result in NOx emissions of 171 lb/hr which is lower than IP’s

current maximum emission rate which is 214 lb/hr as a 24-hr average. However, as shown in Section

6 of this report, if this lower emission rate could be achieved, it would result in insignificant modeled

maximum and eighth highest visibili ty improvements of only 0.08 to 0.09 deciviews and 0.03 to 0.04

deciviews, respectively.

In lieu of site specific, case-by-case RACT analysis, new (2010) NYSDEC presumptive RACT

requirement for oil fired industrial power boilers is a NOx emission rate of 0.15 lb/MMBtu. At IP’s

Power Boiler’s maximum rating of 855 MMBtu/hr this emission rate would result in NOx emissions of

128 lb/hr which is lower than IP’s current maximum permitted emission rate (which is 0.25 lbs/MMBtu

as a 24-hr block daily average, equivalent to 214 lb/hr). As shown in Section 6 of this report, if this

lower emission rate could be achieved, it woul d result in small modeled maximum and eighth highest

visibility improvements of only 0.17 to 0.18 deciviews and 0. 07deciviews, respectively. The NYSDEC

NOx RACT rule allows emissions higher than the pr esumptive RACT requirement if the presumptive

limit cannot be achieved or if it cannot be achieved in a cost effective manner. IP will be submitting a

NOx RACT compliance plan, in accordance with the state regulation, by January 1, 2012.

Table 3-2 summarizes the guidance and benchmarks for NOx emissions. The Power Boiler NOx

emissions are already well controlled using advanced combustion controls including low NOx burners.

In addition, as shown in Section 6, the visibility benefits associat ed with reducing NOx emissions are

very small. Therefore, the current maximum NOx emission rate of 0.25 lb/MMBtu and future

compliance with NYSDEC’s NOx RACT rule are proposed as BART for NOx emissions from the

Power Boiler.

## AECOM Environment

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## 3-5

Table 3-2: Comparison of Power Boiler NOx Emissions to Guide lines and Benchmarks



# Case

Basis for NOx

Emissions NOx Emissions

No. Description lb/hr as 24-hr

average

Base Case

Base Current Baseline NOx Case with advanced

combustion controls including TODD low NOx

burners Maximum actual

daily emissions 178

NOx Benchmark Cases at Maximum Design Capacity, 855 MMBtu/hr

1 Current Allowable NOx Case with advanced

combustion controls including TODD low NOx

burners, 0.25 lb/MMBtu 0.25 lb/MMBtu 214

2* NSPS (40 CFR 60 Subpart Db) for industrial

oil-fired boilers built after February 2005, 0.20

lb/MMBtu 0.20 lb/MMBtu 171

3* Future NYSDEC Presumptive RACT, 0.15

lb/MMBtu 0.15 lb/MMBtu 128

*Visibility modeling showed that NOx benchmark ca ses 2 and 3 resulted in only small visibility

improvements.



# 3.1.3 Filterable PM Emissions

Filterable PM emissions from the Power Boiler are controlled by a multicyclone and an Entoleter wetalkaline scrubber that was installed in 1996. Filter able PM emissions are limited to 0.10 lb/MMBtu.

Additional PM reductions are ex pected to be required to meet new MACT standards. The proposed

Industrial Commercial Institutional Boilers and Process Heaters MACT standard (40 CFR 63 Subpart

DDDDD) that would apply to the Power Boiler is 0.02 lb/MMBtu. EPA’s analysis in the Federal EPA

BART Guidelines states that “....you may rely upon MACT standards for purposes of BART.” (Federal

Register, Vol. 70, No. 128, Page 39164, July 6, 2005). For compliance with the BART rule, IP will

comply with the ICI Boiler MACT standard for PM emissions when it is finalized.



# 3.2 Recovery Boiler

A recovery boiler is used to recover pulping che micals, evaporate residual moisture from the black

liquor solids, and burn the organic constituents to pr oduce steam. The IP Recovery Boiler processes

black liquor and uses No. 6 oil as an auxiliary fuel . This unit is currently equipped with a three level

staged combustion air control system with ESPs.



# 3.2.1 SO 2 

# Emission Controls

In general, black liquor contains a si gnificant amount of sulfur, nominally 3% to 5% by weight of the

dissolved solids. SO 2 

# emissions from recovery boilers occu r due to the volatilization and subsequent

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-6



# oxidation of sulfur compounds present in black liquor and the occasional use of auxiliary fuel (in this

case No. 6 oil). Unlike conventional steam boilers, the vast majority of sulfur that is present in the

liquor is not converted to SO 2 

# , since the primary objective is to recover and re-use the sulfur. Proper

operation of the recovery boiler maximizes the conv ersion of sulfur compounds in the liquor to the

principal constituents of pulping chemicals through capture of t hese compounds in the combustion

zone of the boiler by sodium fume released from the smelt bed. Consequently proper operation of the

recovery boiler itself results in inherent control of SO 2 

# emissions. Moreover, the Recovery Boiler at

the Ticonderoga Mill is a non-direct evaporatio n recovery furnace which, due to its design

characteristics, inherently results in low SO 2 

# emissions.

The available retrofit technologies for control of SO 2 

# from Kraft mill Recovery Boilers are:

 Staged Combustion Systems

 Wet Scrubbers

The IP Recovery Boiler is currently equipped with a two-level staged combustion air control system

which provides control over the boile r operating parameters that minimize SO 2 

# emissions.

The only available alternative to proper recovery boiler operation with a staged combustion air system

for SO 2 

# control is the addition of a wet scrubbing devi ce downstream of the existing ESP. Dry

scrubbing techniques, which seek to remove SO 2 

# via direct injection of solid lime or limestone directly

into the recovery boiler flue gas, are not technically feasible for recovery boilers. The reaction

products from dry scrubbing (calcium sulfate and ot her calcium-based salts) would necessarily need

to be collected in the PM control system (ESP), and thereby would contaminate the sodium sulfate

(salt cake) that the ESP collects and recycles back to the pulping process.

Only three recovery boilers in the U.S. are equipped with wet scrubbers in addition to ESPs.

However, none of these scrubbers were installed to achieve SO 2 

# removal: two of the units were

installed for heat recovery reasons, and the third wa s installed on a unit that is equipped with a direct

contact evaporator to prevent liquid droplets from being entrained and discharged to the atmosphere.

Furthermore, the inherent SO 2 

# control provided via proper operation of a recovery boiler results in a

much lower SO 2 

# concentration in recovery boiler flue gas t han in the flue gas of emission units to

which wet scrubbers are routinely applied (such as fossil fuel-fired steam generating units). The

NCASI retrofit control technology assessm ent in Appendix B provides further details.

Therefore, BART for SO 2 

# emissions from the Recovery Boiler is the currently installed three-level

staged combustion air control system with ESPs.



# 3.2.2 NO X 

# Emission Controls

NO X 

# emissions generally result from fuel NO X 

# and thermal NO X 

# . However, NO X 

# formation in recovery

boilers is believed to be primarily from fuel NO X 

# because the temperatures in the combustion zone of

the boiler are not high enough for significant thermal NO X 

# formation. Fuel NO X 

# emissions from

recovery furnaces are typically low due to the low ni trogen content of black liquor solids. In addition,

the Recovery Boiler operates as a staged combustion boiler with independently operating primary,

secondary and tertiary air dampers. Total air and the distribution between the air stages can be

adjusted to control the Kraft recovery sodium sulf ite reactions, to assure complete combustion of

organic compounds, and to control TRS, CO and NO X



# .

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-7



# The available retrofit technologies for control of NO X 

# from combustion sources are generally

considered to be:

 Staged Combustion Systems

 SNCR

 SCR

 Low NO X 

# burners

 Flue Gas Recirculation

Recovery boilers are complex systems, specifically designed for chemical recovery, that can not apply

the types of NO X 

# emission controls used on typical coal, oil, and natural gas fired boilers such as low

NO X 

# burner, flue gas recirculation, selective non-catalyti c reduction, and selective catalytic reduction.

Low NO X 

# burners, which use staged combustion, have not been demonstrated on recovery boilers.

Black liquor has a large percentage of water that requires specifically designed black liquor burner

guns that provide long droplet trajectories for drying (see the NCASI retrofit control technology

assessment in Appendix B).

Flue gas recirculation is a technology used to control thermal NO X 

# by reducing combustion

temperatures. However, NO X 

# emissions from recovery fur naces are a result of fuel NO X 

# oxidation.

Therefore, flue gas recirculation is not te chnically feasible for recovery furnaces.

Selective non-catalytic reduction has not been demonstr ated on recovery boilers. There are concerns

that long term injection of ammonia or urea in a recovery furnace may adversely affect the chemical

recovery process. In addition, la rge variations in gas temperatures due to fluctuating loads and black

liquor quality would adversely affe ct the performance of selective n on-catalytic reduction. Ammonia

slip and increased plume opacity are also issues.

Selective catalytic reduction is not technically feasib le due to high particulate concentrations in the

economizer region and catalyst poisoning by alkali metals such as sodium.

In summary, there are no technically-feasible alternatives for control of NO X 

# emissions from recovery

boilers other than the controls that are currently in place. In particular, emission controls which have

been demonstrated on conventional st eam boilers (including low NO X 

# burner, flue gas recirculation,

selective non-catalytic reduction, and selective cata lytic reduction) cannot be applied to or have not

been demonstrated to be feasible on a recovery boiler.

Therefore, BART for NO X 

# emissions from IP’s Recovery Boiler is the currently installed three-level

staged combustion air control system with ESPs.



# 3.2.3 PM Emission Control

Particulate matter emissions from the Recovery Boil er are currently controlled using a three-chamber

electrostatic precipitator.

The available retrofit technologies for control of parti culate matter from Kraft mill Recovery Boilers are:

 Electrostatic Precipitators

 Wet Scrubbers

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 3-8



#  Fabric Filters

Recovery boilers are designed and operated so that sodium fume released from the smelt bed is

present in the combustion cham ber in order to capture the SO 2 

# that is generated as a result of

oxidation of the reduced sulfur compounds in black liquor. As a consequence, recovery boilers emit

relatively low levels of SO 2 

# emissions, but have higher levels of uncontrolled PM emissions.

Nonetheless, economical operation of the chemical recovery cycle in the Kraft pulping process

requires that the vast majority of this uncontro lled PM be captured in a control device and the

collected sodium salts (primarily sodium sulfate) be returned to the process.

Electrostatic precipitation is the only type of PM control technology used on modern recovery boilers

at Kraft pulp mills. At one time prior to the promul gation of New Source Performance Standards for

Kraft pulp mills, recovery boilers utilized vent uri scrubbers for PM emissions control. However

because ESPs are capable of a greater degree of emis sions control at a lower operating cost, venturi

scrubbers are no longer utilized.

Fabric filters have been utilized on conventional coal-fired steam generatin g units and are generally

considered to be equivalent to ESPs on these types of sources in te rms of PM control efficiency.

However, they have not been applied to recovery boilers at Kraft pulp mills and are thus not

considered to be an available BART alternative.

EPA’s analysis in the Federal EPA BART Guideli nes states that “....you may rely upon MACT

standards for purposes of BART.” (Federal Register, Vol. 70, No. 128, Page 39164, July 6, 2005).

The IP Recovery Boiler currently complies with Chemical Recovery MACT standard (40 CFR 63,

Subpart MM). Therefore, current PM emissions m eet BART requirements and no additional controls

are required.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 4-1



# 4.0 Meteorological Data used in Visibility Improvement

Modeling

NYDEC requires that the meteorol ogical data used for the BART visibility modeling be for calendar

year 2002. The agency also requires that two diff erent meteorological CALMET databases be used in

the analysis, one developed by AECOM and the ot her developed by the Vermont Department of

Environmental Conservation (VT DEC). The AECOM CALMET database is fully described in a

separate document titled “Updated CALMET Modeling Procedures for BART Visibility Improvement

Assessments in the MANE-VU RPO” . The VT DEC CALMET database is described in Appendix D of

the document titled “Development of Parallel CALPUFF Dispersion Modeling Platforms for Sulfate

Source Attribution Studies in the Northeast U.)” , available on the web at

http://www.nescaum.org/documents/contributions-t o-regional-haze-in-the-northeast-and-mid-atlantic--

united-states/

.

This section discusses the two meteorological CALMET databases for year 2002 and the basic

differences between the two. A primary difference between the two is the grid size resolution as

shown in Figure 4-1. The VT DEC has a domain that covers approximately a 2,664 km (east-west) by

2,160 km (north-south) area with a 36-km grid reso lution. In contrast, the AECOM domain covers an

area approximately 1,052 km (east-we st) by 1,300 km (north-south), has a grid resolution of 4 km and

contains 11 vertical levels. The similarities and differences in t he two databases are summarized in

Table 4-1.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 4-2

Table 4-1: Comparison of the AECOM and VT DEC CALMET User-Defined Settings



# Variable Description AECOM

CALMET Critical

Settings VT DEC

CALMET Critical

Settings

Version No. CALMET model version number Version 5.8, Level

070623 Version 5.53 , Level

030709

MREG Technical options must conform to

USEPA guidance 1 no

DGRIDKM Domain grid spacing 4 36

NX Number of X grid cells 263 74

NY Number of Y grid cells 325 60

NZ Number of vertical layers 11 8

IPROG Use MM5 data as an input to diagnostic

wind field 14 (MM5 used) 0 (MM5 not used)

RMAX1 Max surface over-land extrapolation

radius (km) 40 1000

RMAX2 Max aloft over-land extrapolation radius

(km) 40 1000

RMAX3 Maximum over-water extrapolation

radius (km) 100 1000

TERRAD Radius of influence of terrain features

(km) 15 100

R1 Relative weight at surface of Step 1 field

and obs 5 1000

R2 Relative weight aloft of Step 1 field and

obs 5 1000

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 4-3

Figure 4-1: IP Ticonderoga CALMET Modeling Domains

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 5-1



# 5.0 CALPUFF Modeling Procedures

This section provides a summary of the modeling procedures that were used for the refined CALPUFF

analysis conducted for IP’s Ticonderoga Mill.



# 5.1 CALPUFF Modeling Domain and Receptors

AECOM used the latest EPA-approved version of CALPUFF (Version 5.8, Level 070623) with both

meteorological databases as discussed in Section 4.

The extent of the AECOM and VT DEC modeling do mains are shown in Figure 4-1. The CALPUFF

modeling domains were made equal in size to the CALMET domain (as described in Section 4.1) and

they have sufficient buffer around the source and Cla ss I areas to account for puff re-circulations.

The receptors used for each of the Class I areas ar e based on the National Park Service database of

Class I receptors, available at http://www.nature.nps.gov/air /maps/Receptors/index.cfm

.



# 5.2 Model Version

The EPA-approved version of CALPUFF was used to model the IP BART sources, POSTUTIL was

used to combine impacts from all three units and CALPOST was used to process the regional haze

impacts with Method 8 (New IMPROVE equation). CALPUFF Version 5.8, Level 070623; POSTUTIL

Version 1.56, Level 070627; and CALPOST Version 6.221, Level 080724 were used.

These programs are available for download from TRC website

http://www.src.com/calpuff/calpuff1.htm

.



# 5.3 Background Air Quality Data

CALPUFF modeling was conducted with the hourly background ozone data that was developed for

MANE-VU BART modeling. Ozone data collection and processing is described in Appendix D,

Section D.3.3.1 of the NESCAUM document titled “Development of Parallel CALPUFF Dispersion

Modeling Platforms for Sulfate Source At tribution Studies in the Northeast U.S”

.

As for ammonia, AECOM followed the IWAQM Phas e 2 report, where it is suggested to use a

background ammonia concentration of 0.5 ppb in fore sted areas. Since most Class I areas and the

surrounding region are mainly covered by forest, an ammonia concentration of 0.5 ppb was used in

accordance with the recommendations in IWAQM Phase 2.



# 5.4 Light Extinction and Ha ze Impact Calculations

The FLAG 2008 document (dated June 26, 2008) provides guidance on the recommended new

IMPROVE equation application. CALPOST Version 6. 221 defines this application as Method 8, Mode

5. The assessment of visibility impacts at the Class I areas used CALPOST Method 8.

The CALPOST postprocessor was used for the calculation of the impact of the modeled source’s

primary and secondary particulate matter concentrati ons on light extinction. In the new IMPROVE

equation, the total sulfate, nitrate, and organic carbon compound concentrations are each split into

two fractions, representing small and large size dist ributions of those components. New terms, such

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 5-2



# as sea salt (important for coas tal locations), absorption by NO 2 

# (only used where NO 2 

# data are

available), and site-specific Rayleigh scatt ering have been added to the equation. The new

IMPROVE equation for calculating light extinction is shown below.

The FLAG 2008 document provides inputs to the new IMPROVE equation that are based on either

the 20% best or annual average natural conditions. Per NYSDEC guidance, AECOM elected to use

inputs that are based on the 20% best natural conditions. Inputs to the CALPOST Method 8

calculations for each Class I area were obtained from the FLAG 2008 document tables referenced

below.

Table 5-1: References to the Ne w IMPROVE Equation CALPOST Inputs



# Sea salt concentration FLAG 2008 Table V.1-1

Raleigh scattering FLAG 2008 Table V.1-1

Monthly f L 

# (RH) FLAG 2008 Table V.1-3

Monthly f S 

# (RH) FLAG 2008 Table V.1-4

Monthly f SS 

# (RH) FLAG 2008 Table V.1-5

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 6-1



# 6.0 CALPUFF Modeling and BART Determination Results

This section provides a summary of the modeled visibility impacts due to the current baseline

emissions as well as visibility improve ments that might result from lower SO 2 

# and NOx emissions from

the Power Boiler. This section also pr esents the recommended BART determination.



# 6.1 Exemption Modeling

Baseline emissions of the haze-causing pollutants were modeled using CALPUFF to determine if

emissions from a given source at the Mill coul d reasonably be anticipated to cause or contribute to

visibility impairment at one or mo re of the seven Class I areas in northeastern U.S.A. Table 6-1

presents the results of this exemption modeling. As shown in Table 6-1, the visibility impacts from the

Lime Kiln, the Smelt Dissolving Tank and the miscellaneous PM sources are less than 0.1 dv.

Therefore, these sources are exempt from BART analysis.

Table 6-1: Exemption Modeling of BART-Eligible Sources at the Mill



# Reasonably

Anticipated to Cause

or Contribute to Modeled Impact

Compared to Natural

Back g round Visibilit y

BARTEligible

Emission

Unit Cause

(>1.0 dv) Contribute

(>0.1 dv) 8 th 

# highest

impact (dv) Maximum

single day

impact (dv) Impacted

Class I

Areas (1) 

# Subject

to

BART

Power

Boiler No Yes 0.341 0.635 ANP, GGW,

PRDRW,

LBW Yes

Recovery

Boiler No Yes 0.163 0.282 LBW Yes

Lime Kiln (2) 

# No No 0.000 0.001 None No

Smelt

Dissolving

Tank (2) 

# No No 0.007 0.017 None No

Starch Silo,

Chip Bin

C y clones (2) 

# No No 0.003 0.008 None No

(1) Class I areas: ANP – Acadia National Park, GGW – Great Gulf Wilderness, PRDRW – Presidential Range Dry

River Wilderness, LBW – Lye Brook Wilderness

(2) Impacts presented for the Lye Brook Wilderness (most heavily affected Class I area)

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 6-2



# 6.2 Modeled Control Scenarios

Baseline emissions from the Power Boiler and alternative SO 2 

# and NOx guideline and benchmark

emission rates outlined in Tables 2-2, Table 3- 1 and Table 3-2 were modeled using CALPUFF.

Visibility impacts at each of the seven Class I ar eas are presented in Table 6-2 from each of the

BART-eligible emission units at the Ticonderoga Mill. Reported impac ts are the changes in visibility

attributed to the Ticonderoga Mi ll emission sources as compared to natural background conditions on

the days with most favorable visibility conditions (i.e., 20% best days for visibility ). Table 6-2 also lists

the number of days that the modeled impact from a source is predicted to be above 0.1, 0.5 and 1.0

deciview.

The following factors should be considered when eval uating CALPUFF visibility modeling results.

Baseline modeling analysis always uses the worst-ca se emission rate from each BART-eligible unit

and assumes it occurs every day of the simulated y ear. Actual emissions are always lower which

means that the degree of visibility improvement pr edicted from any control action will always be

overestimated. The manner in which the daily haze predictions are accounted for in the CALPOST

output overstates the impact for even a perfect m odel. The only information saved in CALPOST for

each day is the peak 24-hour prediction anywhere in a Class I area. The predicted impact for each

day is effectively assumed to be a) always in the sa me place and b) in all portions of the Class I area

simultaneously. In reality, for each individual receptor , there could be many days of very low or even

zero concentrations that are not proper ly accounted for. Therefore, the 98 th 

# percentile day’s prediction

is often comprised of impacts in 8 different places that are all a ssumed to be co-located. CALPUFF

does not account for the full cycl e of diurnal influences that affe ct plume transport and dispersion.

Finally, the visibility impact associated with nitr ates is generally believed to be overstated by

CALPUFF, especially in winter.

NYSDEC recommends that the max imum visibility impact from each source should be compared to

the threshold of 0.1 deciviews to determine if a source significantly contributes to visibility impairment.

NYSDEC also recommends using the maximum and 98 th 

# -percentile statistic fo r comparing visibility

improvements due to BART control options. On an annual basis, the 98 th 

# percentile value implies the

8 th 

# highest day at each modeled Class I area.



# 6.3 Modeling Results fo r Baseline Emissions

CALPUFF modeling results of the baseline emissions at the seven Class I areas are presented in

Table 6-2. Modeling was conducted with the two CALMET databases for the year 2002. The highest

visibility impacts from the Mill’s sources occur at the Lye Brook Wilderness due to its close proximity to

the Mill.

The results of the baseline emissions analysis indi cate that only the Power Boiler and Recovery Boiler

have predicted visibility changes relative to natur al background exceeding 0.1 deciviews in at least

one Class I area. Therefore, all other sources at the IP Ticonderoga Mill are exempt from BART, in

accordance with NYSDEC policy (see Appendix C), be cause emissions from these other sources may

reasonably be anticipated to not cause or contribute to visibility impairment at a nearby Class I area.

The results of the visibility improvement mode ling for the benchmark emission levels, which were

discussed in Section 3, are discu ssed in the next section.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 6-3

Table 6-2: Regional Haze Impacts due to Baseline Emissions

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 6-4



# 6.4 Modeling Results for Power Boiler Guideline and Benchmark Emission

Rates

The Power Boiler’s maximum daily visibility impac ts are predicted to occur at the Lye Brook

Wilderness Area. Therefore, the maximum potential visibility changes associated with the guideline

and benchmark emission rates discussed in Section 3 were evaluated at Lye Brook Wilderness Area.

Consistent with the baseline results reported in Table 6-2, modeling was conducted with the two

CALMET databases for the calendar year 2002. Pe r NYSDEC recommendation, in addition to the

highest visibility impacts, the 8 th 

# highest delta-deciview results were also reported.

Table 6-3 summarizes the modeling results at the Lye Brook Wilderness Area for the SO 2 

# guidelines

and benchmark emission rates for the Power Boiler. The results show that current SO 2 

# emissions

from the Power Boiler, which are controlled by wet scrubbing, are comparable to the cited benchmark

emission rates and that the modeled visibility impr ovements associated with the lower emission rates

are not significant. Even if the most stringent e mission rate could be achieved, the number of days

with visibility impacts greater than 0.5 deciview s would only be reduced by 1 day. In addition,

reduction in the modeled maximum impact would only be reduced by approximately 0.05 deciviews

and the eighth highest impact would only be reduced by about 0.03 deciviews.

Table 6-3: Regional Haze Impacts for SO 2 

## Emission Guidelines and Benc hmarks for IP's Power Boiler



# Table 6-4 summarizes the modeling results at the Lye Brook Wilderness Area for the NOx guidelines

and benchmark emission rates for the Power Boiler. The results show that the advanced combustion

controls including low NOx burners effectively limits visi bility impacts due to NOx emissions. If the

NOx emission rate could be reduced to 0.20 lb/MMB tu, the number of days with modeled visibility

impacts greater than 0.5 deciviews would only be reduced by about 1 day. In addition, reduction in

the modeled maximum impact would only be reduc ed by 0.08 to 0.09 deciviews and the 8 th 

# highest

impact would only be reduced by 0.03 to 0.04 deciviews . At the most stringent NOx emission rate of

0.15 lb/MMBtu, the number of days with modeled visi bility impacts greater than 0.5 deciviews would

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 6-5



# only be reduced by no more than 4 days. In add ition, reduction in the modeled maximum impact

would only be reduced by 0.17 to 0.18 deciviews and the eighth highest impact would only be reduced

by 0.07 deciviews.

Table 6-3: Regional Haze Impacts for NOx Emission Guidelines and Benchmarks for IP's Power Boiler



# 6.5 Conclusions and BART Recommendation

Baseline modeling results show that only the Power Boiler and the Recovery Boiler are subject to

BART. The Lime Kiln, Smelt Dissolving Tank, and other sources are exempt from BART because

their maximum visibility impacts are less than 0.1 deciviews.

IP’s proposed BART determination for SO 2 

# emissions from the Power Boiler is the use of wet

scrubbing to comply with the current emission limit of 309 lb/hr as a 24-hour rolling average. For NOx,

the proposed BART determination is the use of advanced combustion controls including low NOx

burners to limit emissions to 0.25 lb/MMBtu as a block 24-hour average from May 1 through

September 30 and as a 30-day average from October 1 through April 30. In addition, IP will comply

with NYSDEC’s revised NOx RACT rule which goes into effect July 1, 2014. For PM emissions,

BART is compliance with the propos ed Industrial, Commercial, Instit utional Boiler MACT standard.

Emissions from the Recovery Boiler are currently well controlled. No additional controls are available

for SO 2 

# and NOx emissions. PM emissions comply with the Subpart MM MACT standard. The

current permit limits are proposed as BART for the Recovery Boiler.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

## 7-1



# 7.0 References

ENSR, Updated CALMET Modeling Procedures for BART Visibility Improvem ent Assessments in the

MANE-VU RPO. April 2009.

ERM, Development of Parallel CALPUFF Dispersion M odeling Platforms for Sulfate Source Attribution

Studies in the Northeast U.S (Appendix D), ERM, May 2006.

Environmental Protection Agency (EPA) , AP 42, Fifth Edition, Compil ation of Air Pollutant Emission

Factors, Volume 1: Stationary Po int and Area Sources, January, 1995.

Environmental Protection Agency (EPA), Guidance for Tracking Progress Under the Regional Haze

Rule, EPA-454/B-03-003, Appendix A, Table A-3, September, 2003a.

Environmental Protection Agency (E PA), Guidance for Estimating Natural Visibility Conditions Under

the Regional Haze Program, EPA 454/B-03-005, September 2003b.

Environmental Protection Agency (EPA), Inter agency Workgroup on Air Quality Modeling (IWAQM)

Phase 2 Summary Report and Recommendations fo r Modeling Long Range Transport Impacts, EPA454/R-98-019, December, 1998.

National Council for Air and Stream Improvement ( NCASI), Particulate Emissions Data for Pulp and

Paper Industry Specific Sources, February 9, 2006.

National Council for Air and Stream Improvement (NCA SI), Information on Retrofit Control Measures

for Kraft Pulp Mill Sources and Boilers for NOx, SO 2 

# and PM Emissions, June 9, 2006.

Regional Haze Regulations and Guidelines for Be st Available Retrofit Technology (BART)

Determinations; Final Rule (FR Vol. 70, No. 128 published July 6, 2005).

Regional Haze Regulations; Revisions to Provisions Governing Alternative to Source-Specific Best

Available Retrofit Technology (BART) Determin ations; Final Rule (FR Vol. 71, NO. 198 published

October 13, 2006).

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

# Appendix A

Response to NYSDEC Letter

January 2010

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

# Appendix B

NCASI Emission Factors and

Retrofit Controls for Pulp Mill

Sources

# February 9, 2006



# Particulate Emissions Data for Pulp and Paper Industry Specific Sources

The following tables contain summarized particulate em issions data for sources that are specific to the

pulp and paper industry. The source categories addr essed in this document are smelt dissolving tanks,

lime kilns, and recovery furnaces. Boilers are not addressed since AP-42 emission factors for boiler

emissions are well documented and readily available including in NCASI Technical Bulletin No. 884.

Smelt Dissolving Tanks

Data for smelt dissolving tanks were compiled from NCASI Technical Bulletins Nos. 884 and 898. This

data set includes test results from the use of a dilution tunnel method which quantifies total PM 10 

# and

PM 2.5 

# particulate matter. Total PM 10 

# and PM 2.5 

# particulate matter are the sum of filterable and

condensible PM 10 

# and PM 2.5 

# particulate matter. All smelt dissolv ing tanks in the data set have wet

particulate control devices.

The filterable PM numbers are obtained from combin ing the data set of 36 sources listed in NCASI

Technical Bulletin No. 884, Table A15c, and the data set of 6 sources listed in NCASI Technical Bulletin

No. 898. The data for “Total PM 10 

# “ and “Total PM 2.5 

# ” are from the 8 sources listed in NCASI Technical

Bulletin No. 884, Table A15d. All of the CPM data was from the 6 sources listed in NCASI Technical

Bulletin No. 898. The CPM data listed in Technical Bulletin No. 884 was not used as that data is an

estimate of CPM and not results from EPA Method 202. All of the sulfate data is from the 3 sources

tested by NCASI, and listed in Technical Bulletin No. 898.

Table 1. Smelt Tank Data Summary

Measurement No. of Range Mean 5 

# Mean

Parameter Method Sources (lb/ton BLS) Percent of PM

PM EPA Method 5 42 0.03 - 0.64 0.148

6 

# Total PM 10 

# Dilution Tunnel 8 1 

# 0.031 – 0.666 2 

# 0.154 6 

# 104

6 

# Total PM 2.5 

# Dilution Tunnel 7 1 

# 0.027 – 0.570 2 

# 0.132 6 

# 89

CPM MeCl 2 

# Soluble EPA 202 6 1 

# 0.0009 - 0.0192 2 

# 0.0044 3

CPM Water Soluble EPA 202 6 1 

# 0.0039 - 0.0832 2 

# 0.0192 13

CPM EPA Method 202 6 1 

# 0.0048 - 0.1024 2 

# 0.0237 16

Sulfate IC 3 3 

# 0.0014 - 0.0297 4 

# 0.0069 % of CPM =

29

1 

# Range values were determined by applying the mean percent of PM to the range of values for PM. 2 

# Mean values

were determined by applying the mean percent of PM to mean value for PM. 3 

# Range values for sulfate were

determined by applying the mean percent of CPM to the range of CPM values. 4 

# Mean value for sulfate was

determined by applying the mean percent of CPM to the mean value for CPM. 5 

# Mean percent of PM values are

derived from individual data sets. 6 

# Values include filterable and condensible PM.

# February 9, 2006



# Recovery Furnaces

The recovery furnace data are a compilation of data in NCASI Technical Bulletins Nos. 852, 884, and as

yet unpublished NCASI data. All of the recovery furn aces in this data set use electrostatic precipitators

(ESP) for particulate control.

The PM data for DCE recovery furnaces is from the 23 sources listed in NCASI Technical Bulletin No.

884, Table A11c. The PM 10 

# data for the DCE recovery furnaces is from the 4 DCE sources listed in

Technical Bulletin No. 884, Table A11d. The PM 2.5 

# data for DCE recovery furnaces is from the 4 DCE

sources listed in Technical Bulletin No. 884, Table A11d, plus a further two from as yet unpublished

NCASI data. The DCE CPM data is from two source s listed in Technical Bulletins Nos. 852 and 884,

and two sources from as ye t unpublished NCASI data.

The PM data for the NDCE recovery furnaces is fro m the 20 sources listed in NCASI Technical Bulletin

No. 884, Table A12b. The PM 10 

# data for the NDCE recovery furnaces is from the 13 NDCE sources

listed in Technical Bulletin No. 884, Table A12c. The PM 2.5 

# data for NDCE recovery furnaces is from the

11 DCE sources listed in Technical Bulletin No. 884, Table A12c, plus a further source from as yet

unpublished NCASI data. The NDCE CPM data is fro m 6 sources listed in Technical Bulletin No.884,

and one source from as yet unpublished NCASI data.

# February 9, 2006



# Table 2. Recovery Furnace Data Summary

Kraft DCE Recovery Furnace

Measurement No. of Range Mean 5 

# Mean

Parameter Method Sources (lb/ton BLS) Percent of PM

PM EPA Method 5 23 0.07 - 2.58 0.74

PM 10 

# EPA CTM-040 4 1 

# 0.05 - 1.88 2 

# 0.54 73

PM 2.5 

# EPA CTM-040 6 1 

# 0.04 - 1.44 2 

# 0.41 56

CPM MeCl 2 

# Soluble EPA 202 4 1 

# 0.014 - 0.516 2 

# 0.148 20

CPM Water Soluble EPA 202 4 1 

# 0.13 - 4.75 2 

# 1.36 184

CPM EPA Method 202 4 1 

# 0.14 - 5.29 2 

# 1.52 205

Sulfate IC 3 3 

# 0.05 - 1.85 4 

# 0.53 % of CPM = 35

Kraft NDCE Recovery Furnace

Measurement No. of Range Mean 5 

# Mean

Parameter Method Sources (lb/ton BLS) Percent of PM

PM EPA Method 5 20 0.02 - 3.50 0.65

PM 10 

# EPA CTM-040 13 1 

# 0.01 - 2.35 2 

# 0.44 67

PM 2.5 

# EPA CTM-040 11 1 

# 0.01 - 1.82 2 

# 0.34 52

CPM MeCl 2 

# Soluble EPA 202 3 1 

# 0.003 - 0.560 2 

# 0.104 16

CPM Water Soluble EPA 202 3 1 

# 0.016 – 2.84 2 

# 0.53 81

CPM EPA Method 202 7 1 

# 0.02 - 3.40 2 

# 0.63 97

Sulfate IC 2 3 

# 0.007 - 1.16 4 

# 0.21 % of CPM = 34

1 

# Range values were determined by applying the mean percent of PM to the range of values for PM. 2 

# Mean values

were determined by applying the mean pe rcent of PM to the mean value for PM. 3 

# Range values for sulfate were

determined by applying the mean percent of CPM to the range of CPM values. 4 

# Mean value for sulfate was

determined by applying the mean percent of CPM to the mean value for CPM. 5 

# Mean percent of PM values are

derived from individual data sets.

# February 9, 2006



# Lime Kilns

The lime kiln data are a compilation of data from NCASI Technical Bulletins Nos. 852, 884, and 898.

The emissions data are separated by control device type . The majority of lime kilns in this data set use

wet control devices for particulate control. Two of the lime kilns in this data set use an ESP for

particulate control, followed by a wet scrubber for SO 2 

# control. The remainder use an ESP for particulate

control.

The PM data for lime kilns using wet control de vices is from 30 sources listed in NCASI Technical

Bulletin No. 884, Table A13c. The PM 10 

# and PM 2.5 

# data for lime kilns using wet control devices is from

NCASI Technical Bulletin No. 884, Table A13d. The CPM and sulfate data for lime kilns using wet

control devices is from Technical Bulletin No. 898.

All of the PM, CPM, and sulfate data for lime kiln s using an ESP followed by a wet control device is

from two sources listed in NCASI Technical Bulletin No. 898.

The PM data for lime kilns using an ESP alone are from the 7 sources listed in NCASI Technical Bulletin

No. 884, Table A13c. The PM 10 

# and PM 2.5 

# data are from the 6 sources listed in Technical Bulletin No.

884, Table A13d. The CPM and sulfate data are from 3 sources listed NCASI Technical Bulletin Nos.

852 and 884.

# February 9, 2006



# Table 3. Lime Kiln Data Summary

Lime Kilns with Wet Particulate Control Devices

Measurement No. of Range Mean 5 

# Mean

Parameter Method Sources (gr/dscf) @10% O 2 

# Percent of PM

PM EPA Method 5 30 0.014 - 0.346 0.0995

6 

# Total PM 10 

# Dilution Tunnel 6 1 

# 0.014 - 0.349 2 

# 0.100 101

6 

# Total PM 2.5 

# Dilution Tunnel 7 1 

# 0.012 - 0.304 2 

# 0.088 88

CPM MeCl 2 

# Soluble EPA Method 202 3 1 

# 4.2E-5 - 0.0010 2 

# 0.0003 0.3

CPM Water Soluble EPA Method 202 3 1 

# 0.0008 - 0.0208 2 

# 0.0060 6

CPM EPA Method 202 3 1 

# 0.0009 - 0.0218 2 

# 0.0063 6.3

Sulfate IC 2 3 

# 0.0002 - 0.0046 4 

# 0.0013 % of CPM = 21

*These data are the result of dilution tunnel testing, therefore the PM 10 

# and PM 2.5 

# values reflect the sum of

filterable and condensible PM 10 

# and PM 2.5 

# particulate.

Lime Kilns with a Dry ESP for Particulate Control Followed by a Wet Scrubber

Measurement No. of Range Mean 5 

# Mean

Parameter Method Sources (gr/dscf) @10% O 2 

# Percent of PM

PM EPA Method 5 2 0.003 - 0.004 0.004

PM 10 

# No Data No Data

PM 2.5 

# No Data No Data

CPM MeCl 2 

# Soluble EPA Method 202 2 0.0004 - 0.0081 0.0042 140

CPM Water Soluble EPA Method 202 2 0.0038 - 0.0054 0.0046 131

CPM EPA Method 202 2 0.006 - 0.012 0.009 271

Sulfate IC 1 0.002 0.002 % of CPM = 34

Lime Kilns with a Dry ESP for Particulate Control

Measurement No. of Range Mean 5 

# Mean

Parameter Method Sources (gr/dscf) @10% O 2 

# Percent of PM

PM EPA Method 5 7 0.002 - 0.033 0.010

PM 10 

# EPA CTM-040 6 1 

# 0.001 - 0.211 2 

# 0.006 64

PM 2.5 

# EPA CTM-040 6 1 

# 0.0005 - 0.0079 2 

# 0.0024 24

CPM MeCl 2 

# Soluble EPA Method 202 3 1 

# 0.0013 - 0.0208 2 

# 0.0063 63

CPM Water Soluble EPA Method 202 3 1 

# 0.003 - 0.045 2 

# 0.014 137

CPM EPA Method 202 3 1 

# 0.004 - 0.066 2 

# 0.020 200

Sulfate IC 3 3 

# 0.0035 - 0.0581 4 

# 0.0176 % of CPM = 88

1 

# Range values were determined by applying the mean percent of PM to the range of values for PM. 2 

# Mean values

were determined by applying the mean pe rcent of PM to the mean value for PM. 3 

# Range values for sulfate were

determined by applying the mean percent of CPM to the range of CPM values. 4 

# Mean value for sulfate was

determined by applying the mean percent of CPM to the mean value for CPM. 5 

# Mean percent of PM values are

derived from individual data sets. 6 

# Values include filterable and condensible PM.

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

# Appendix C

NYSDEC BART Guidance

PresentationsNYSDECGuidanceandProtocolforVisibilityAssessmentofBARTEligibleSourcesLeonSedefian andMargaretValisImpactAssessmentandMeteorologySection518‐402‐8403FederalLandManagers•NationalParkServiceSServiceNationalService,U..ForestServiceandU.S.FishandWildlifeService•CAAgivestheFLMaffirmativeresponsibilitytoaffirmativeresponsibilityprotecttheClassIareas,especiallyvisibility.A il blidifiClI•Availableguancespecctoassareas:EPA‐InteragencyWorkgrouponAirQualityModeling(IWAQM)Phaserevised(IWAQM)‐2reviseddraftMay,2009.FLMs:FederalLandManagersAirQualityRelatedValuesGroup(FLAG).revision6/27/08.Work(FLAG).Latestrevision6/27/08.VisibilityScales•VisualRange(V)‐greatestdistanceatwhichadarkobjectcanbeseen.•Extinctioncoefficient(bext)‐theattenuationoflightduetoscatteringandabsorptionbyparticlesandsomegases.•V=3.91/bext•decivieworhaziness‐dv=10ln(bext/0.01km‐1)definedtobelinearwithfractionalchangeinbext orperceivedvisualchange.A1dvhb thib tditiblcangeisaou10%cangenexanspercepechange.Also,greaterthan5%changeinbext producesJustNoticeableChange.IMPROVEAlgorithms•Newbext=2.2fS(RH)[smallsulfates]+4 8fL(RH)[largesulfates]+2 4fS(RH)[small4.8fL(RH)[largesulfates]+2.4fS(RH)[smallnitrates]+5.1fL(RH)[largenitrates]+2.8[smallorganics]+1[largeorganics]+10[elemental6.1[largeorganics]+10[elementalcarbon]+1[finesoil]+1.7fSS(RH)[seasalt]+0 6[coarsematter]+Rayleighscatteringsalt]+0.6[coarsematter]+Rayleighscattering(sitespecific)+0.33[NO2(ppb)]ProtocolDefaultRecommendations•UseCALPUFF/CALMETv5.8(settodefault)andCALPOSTv6.221(Method8,Mode5‐simulatedbychoosingFLAGoptionasinput).(e.g.SeeJohnNotar’s 5/13/09presentationatEPARegionalMeteorologistsWorkshop‐SCRAMwebsite).•ReceptorsatsevenClassIareasprovidedatNPSwebsite.•Maximumoftheactual24houremissionrateforNOx,SO2andPM(includingcondensiblesperEPAAP42orNPS(includingcondensibles‐webpage).•2002“NWS‐only”and“hybrid”MM5/NWSAECOMt lild ttmeeorologicalaases.•ImplicitinFLM’sacceptanceof1yearofdataistheuseofmaximumimpactsand20%bestnaturalbackground.RequiredOutputsThresholdsandThresholds•Forexemptiondemonstration‐usemaximumexemptiondemonstrationmaximumimpactsforcombinedthreepollutants<0.1dv.•ForBARTdemonstrationsprovide:demonstrationsprovide:1)Maxand8thhighestforpreandpostBARTcontrolalternatives.2)numberofdaysofexceedences of0.1,0.5and1dv.3)ff ili ii hhihorfacilitieswtmoretanoneunt,tecumulativemaximumimpacts.CALPUFF•CALPUFFistheEPArecommendedmodelforvisibilityassessmentsandforlongrangetransportapplications(>50km)Nt dt tffdi id l•on‐seay‐saepuspersonmoe•Capableoftreatingtime‐varyingpoint,area,lineandvolumesources•Includesalgorithmsforsubgrid scaleeffects(suchasterrainimpingement),aswellaslongerrangeeffects(suchaspollutantremovalduetowetscavenginganddrydeposition,chemicaltransformation,andvisibilityeffectsparticulateconcentrations).ofparticulatematterconcentrations).MANE‐VUCALPUFFDomainFigureD‐13.Examplemidnightwindfieldat750tfVTDECCALMETmeersor.1ResponsestoCommentsTimeframe:RetainingOctober1,2010deadlineforanalysisdTimeisrequireforEPA,FLMreviewandpubliccommentperiodpriortoEPA’sJan.152011deadlineforapprovalUnabletodelayforresultsofRNAorEPAinitiativesMovingbackdateofcompliancetoJanuary1,2014P idthfbiifl irovesoverreeyearsromsumssonoanayss2ResponsestoCommentsCostthresholdofcontrols:Intendtousethresholdof$5,500pertonreducedlhl blRACTvaueconsistentwitappicaiitytoexistingsourcesAllowsforoneanalysistobeusedforRACTandBARTforNOxShouldalsoconsidera$/deciviewreducedmetricE tith h ldxemponthreshold:Maintaining0.1dv thresholdforunitexemptions3ResponsestoCommentsModelingIssues:DepartmentupdatingoriginalNESCAUMmodelingtob tttEPAiddteerrepresenguanceanmorerecenemissionsscenariosCAIR:Won’tbeconsideredassufficientforNOxandSO2.EPA’sfindingofCAIRbeinganequivalentprogramwasbasedonphasesI+II.Noguaranteere‐proposedCAIRprogramwillbeasstringentoverallprogramstringentoverall4ResponsestoCommentsCAIRandADRP:ControlsinstalledundertheseprogramswillbetakenintoaccountduringanalysisBARTneededtoreachReasonableProgressgoalsasanenforceablemeasureSmallemissionunitswithnegligibleimpacts:Especiallyofconcernfornon‐EGUsourcesUididseengineerngjugmenttodecewhatunitstofocusonDocumentunitswhicharetechnicallyeligiblebuttoosmallforcontrolsandprovidebasisforthisdetermination—workhOiiwitus(C..staff,RAPCE)upfrontonthisdecson5ResponsestoCommentsAccountingfor‘peaking’operations:Costeffectivenesscalculationsbasedonmaximumi ib tldbl tdithdi lemssons,ushouesuppemenedwaaogueofoperatingcharacteristics6“GuidelinesforDeterminationsBARTDeterminationsUndertheRegionalHazeRule”Implementationguidanceavailableat:40CFRPart51AppendixY,or70FR39156(July6,2005)7ConsiderationsofFive‐FactorAnalysisCase‐by‐casecontrolanalysiswillweighfivefactors:•CostsofComplianceEiliifli•nergyandnon‐arquatympactsocompance•Existingpollutioncontroltechnologyatthesource•RemainingusefullifeofthesourceRemaining•Degreeofvisibilityimprovementthatcanbeanticipatedfromtheinstallationofcontrols8StepsofFive‐FactorAnalysisStep1:IdentifyallavailableretrofitcontroltechnologiesSih i lli f iblitep2:ElimnatetecncayinfeasibleoptonsStep3:EvaluatecontroleffectivenessofremainingcontroltechnologiesStep4:EvaluateimpactsanddocumenttheresultsCostsofcompliance;energyimpacts;non‐airqualitycompliance;impacts;qualityenvironmentalimpacts;remainingusefullifeStep5:Evaluatevisibilityimpacts9WaystoAvoidtheAnalysisFacility:AcceptemissionscapforallBART‐eligibleunitstob ldtfll t teowacombine250pyoreachpouanIndividualUnit:Unitfallsbelowthe0 1dvcontributionthreshold.contributionthresholdUtilityboilers:acceptpresumptiveSO2orNOxlimitAnalysisforotherpollutantsstillrequired10WtA idthM d liStfaysovoeoengeporaParticularPollutant(Complete&DocumentonlySteps1‐4)AcceptthemoststringentcontroloptionNocontroloptionsfoundtobetechnicallyandeconomicallyfeasibleForNOxfulfillRACTrequirementunderrecently,fulfillrequirementrecentlyrevisedPart220(cementplants,glassplants)orSubpart22‐2(combustionsources)711Controls/LimitsforUtilityBoilersSO2:Uncontrolledunits>200MWatpowerplants>750MW:lflbPresumptiveimito95percentcontrolor0.15/mmBtuOil‐firedunits,regardlessofsize:Evaluatelimitingsulfurcontentoffueloilburnedto1percentEvaluatelimitingcontentpercentorless,byweightFii hi ilidorotheruntswtpre‐exstngcontros,guancerecommendsconstruction/upgradeofscrubber12Controls/LimitsforUtilityBoilersNOx:ConsiderNOxRACTdeterminationunderrecentlyi dSb ttirevseupar227‐2asmeengBART13ScheduleAnalysisofBARTcontrolsduetoDECbyOctober1,20106di0‐ayFLMreview;EPArevew30‐daypubliccommentperiodEPAapprovalbyJanuary15,2011Approvedcontrolstobeinstalled&operatingbyJanuar1,2014.y14

## AECOM Environment

Five Factor BART Analysis for International Paper Ticonderoga Mill September 2010 

# Appendix D

Modeling Archive