New York State Department of Environmental Conservation DRAFT || Best Available Retrofit Technology Determination || DRAFT

Facility Samuel A. Carlson Generating Station

Location Jamestown, NY Chautauqua County

Permit ID 9-0608-00053

Source Category Fossil-fuel fired steam electric plant of more than 250 mmBtu/hr heat input

I. Introduction

The above referenced facility contains at least one emission source that falls under the requirements of the federal Best Available Retr ofit Technology (BART) rule under 40 CFR Part 51 and Appendix Y, and the New York State BA RT regulation as codified under 6 NYCRR Part 249. These requirements affect an emission s ource which fulfills the following criteria:

1. Falls within one of 26 sp ecific source categories,

2. Was not in operation prior to August 7, 1962 and was in existence on August 7, 1977, or

underwent reconstruction between August 7, 1962 and August 7, 1977, and

3. Has a potential to emit (collectively, with ot her emission sources at the facility which fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant.

Emission sources that are deemed eligible by the above criteria may be exempted by the BART analysis through severa l means, as follows:

1. A permit condition may be accepted which restrict s the eligible source’s potential to emit to less than 250 tons per year (tpy) for each visibility-impairing pollutant, as per Part 249.1(c)(1).

2. A permit condition may be accepted that requires the source to permanently shut down the unit by January 1, 2014, as per Part 249.1(c)(2).

3. The facility may show through modeling or other means acceptable to the Department that it does not or will not emit any combina tion of visibility-impairing pollutants that results in a visibility impairment equal to or greater than 0.1 deciviews in any federal Class I area, as per Part 249.1(c)(3).

II. Proposed BART Compliance Method

The Jamestown Board of Public Utilities (JBPU) initially submitted a letter to the Department, dated September 27, 2010, regarding its BART-eligible unit at the Sa muel A. Carlson Generating Station. The S.A. Carlson facility ’s eligible unit, “Unit 12,” is a coal-fired steam boiler with a nominal heat input rate of 297 mmBtu/hr. At the time, JBPU proposed to shut down Unit 12 as compliance with BART under Part 249.1(c)(2), though it requested flexibility and an additional year for compliance (a permanent shut down da te of December 31, 2014) due to reliability concerns on the District Heating System.

12 The Department did not accept JBPU’s argument for extending the BART compliance date via shutdown by an additional year. After JBPU considered capping the un it out of the BART requirements instead, it was eventually determin ed that Unit 12 could indeed be shut down by January 1, 2014 without compromising system inte grity, thus complying with the Department’s required deadline.

III. BART Determination

The Department and JBPU are in agreement that S.A. Carlson Generating Station Unit 12 will be shut down by January 1, 2014. This will meet comp liance with the state’s BART regulation via Part 249.1(c)(2). The Department formalized this requirement in an Air State Facility (ASF) permit modification, which was issued on February 8, 2012. This modified ASF permit is being

submitted to EPA as a revision to the New Yo rk Regional Haze State Implementation Plan.