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New York State Department of Environmental Conservation 

Best Available Retrofit Technology Determination 

Facility International Paper Ticonderoga Mill 

Location Ticonderoga, NY 

Essex County 

Permit ID 5-1548-00008 

Source Category Kraft Pulp Mill 

I. Introduction 

The above referenced facility contains at least one emission source that falls under the 

requirements of the federal Best Available Retrofit Technology (BART) rule under 40 CFR Part 

51 and Appendix Y, and the New York State BART regulation as codified under 6 NYCRR Part 

249. These requirements affect an emission source which fulfills the following criteria: 

1. Falls within one of 26 specific 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 other emission sources at the facility which 

fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant. 

In accordance with BART requirements, each BART-eligible facility performed a BART 

analysis of controls for sulfur dioxide, nitrogen oxides and particulate matter. This analysis took 

into account such factors as the cost of controls, energy and non-air quality environmental 

impacts of compliance, any existing pollution control technology in use at the source, the 

remaining useful life of the source, and the degree of improvement in visibility which may 

reasonably be anticipated to result from the use of such technology. 

This document summarizes the reasoning behind the Department’s BART determination, 

including the level of controls and emission limits that constitute BART for this facility’s eligible 

emission source(s). Each analysis and BART determination was submitted to the Federal Land 

Managers (FLMs) for their review in accordance with Regional Haze State Implementation Plan 

(SIP) requirements. Comments received from the FLMs on this determination will be included 

with its official submission to the U.S. Environmental Protection Agency (EPA). 

The Department has modified this facility’s Title V permit to include the enforceable BART 

limits. The modifications were noticed in New York State’s Environmental Notice Bulletin on 

December 21, 2011. Upon completion of this public notice period, the modified permit was 

submitted to EPA for review on February 1, 2012. The final modified permit was issued on 

March 19, 2012. This permit is now being submitted to EPA as a revision to the New York 

Regional Haze SIP. 

 
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II. BART Analysis Summary 

International Paper (IP) submitted a BART analysis for their Ticonderoga Mill dated September, 

2010. Supplemental information was provided by IP on December 6, 2011 in response to 

Federal Land Manager and EPA comments. The following emission sources had previously 

been identified as BART-eligible and were therefore included in the analysis: 

Power Boiler – Emission Unit POWERH; Emission Source 10044 

• This unit is an Erie City Iron Works multi-fuel fired spreader stoker boiler with a heat 

input rating of 855 mmBtu/hr. This boiler is permitted to burn a variety of fuels for the 

purpose of producing steam and electricity via a turbine generator. The fuel mix for this 

boiler is typically 80 percent residual oil and 20 percent wood residue on a heating value 

basis. Operation of this unit commenced in 1970. Current control equipment includes 

low NOx burners, overfire air, flue gas recirculation, a wet scrubber with sodium 

hydroxide injection, and a multicyclone unit. 

Recovery Furnace – Emission Unit RECOVB; Emission Source 10001 

• This unit is a Babcock & Wilcox kraft recovery furnace. It is used to recover chemicals 

from spent pulping liquor and to produce steam for the mill. It consists of a low-odor 

non-direct contact kraft recovery furnace and a smelt dissolving tank. The recovery 

furnace processes black liquor and fires No. 6 oil as an auxiliary fuel (restricted to less 

than 10 percent based on heat input). Operation of this unit commenced in 1970. The 

boiler operates with a three-level staged combustion air supply system, and an 

electrostatic precipitator (ESP) for PM control. 

IP conducted visibility modeling to demonstrate that smaller, lower-emitting BART-eligible 

emission sources had visibility impacts small enough that the sources could be omitted from the 

BART analysis. IP modeled visibility impacts for the lime kiln (EU RCAUST, ES 10005), smelt 

dissolving tank (EU RECOVB, ES 10003), and miscellaneous PM emission sources—a starch 

silo and two wood chip cyclones, which emit approximately 3.4 and 9.9 tons per year, 

respectively—at the Ticonderoga facility in order to show their negligible impacts on visibility in 

Class I areas. 

The lime kiln and smelt dissolving tank had their greatest impacts on the Lye Brook Wilderness 

area; the maximum impact by the lime kiln was 0.001 dv, and that of the smell dissolving tank 

was 0.017 dv. The PM sources had their greatest impacts on the Great Gulf Wilderness area, 

with a maximum impact of 0.008 dv. The 8th highest impacts from these units were <0.0005 dv, 

0.007 dv, and 0.003 dv, respectively. These values represent the changes in visibility on the 20% 

best natural background days. 

The modeling procedures were reviewed to ensure conformity with the Department’s modeling 

protocol. The Department accepts IP’s demonstration and conclusion that these units need not 

be included in the BART analysis as they cause negligible visibility impacts. 

 
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A summary of the analysis’ findings for each pollutant are as follows: 

Power Boiler 

• SO2

The Ticonderoga Mill’s power boiler currently operates with a wet-alkaline scrubber 

(installed in 1996 and designed for PM removal), which controls SO2 emissions at a rate 

of approximately 65 percent (or approximately 85 percent when taking into account the 

sulfur content of the non-condensable gases that are also controlled by the scrubber). 

Upgrades or improvements to increase the control efficiency for SO2 were ruled out by IP 

since this unit is designed as a PM control device, and operational changes may 

jeopardize the ability to meet PM emission limits. 

IP cites the combustion of natural gas or possibly lower sulfur fuel oil and/or wet or dry 

scrubbing as potential emission controls. The use of natural gas is ruled out because of 

the prohibitive distance to the nearest natural gas pipeline (approximately 70 miles). IP 

goes on to compare the existing permitted SO2 levels for the power boiler to other BART 

guidelines and policies in order to demonstrate the effectiveness of the current control 

and permitted limits. 

IP begins by citing the suggested fuel sulfur limit of 1 percent or less by weight 

established by EPA in Appendix Y for uncontrolled utility boilers. IP notes that for 

typical residual fuel oil, 1 percent sulfur results in an SO2 emission rate of 1.05 

lb/mmBtu, the equivalent of 900 lb/hr on a 24-hr average for a boiler operating at 855 

mmBtu/hr (the maximum rating for the Power Boiler). The power boiler’s current permit 

limit is well below this at 309 lb/hr on a 24-hr average. 

IP then notes MANE-VU’s BART Workgroup recommendations (from the “Five-Factor 

Analysis of BART-Eligible Sources,” June 1, 2007) for presumptive SO2 levels for 

industrial boilers of 90 percent control, compliance with the ICI Boiler MACT acid gas 

control level, or 0.55 lb/mmBtu (0.5 percent fuel sulfur limit). IP commits to complying 

with the ICI Boiler MACT acid gas control requirements when they are finalized. As 

above, IP notes that a 0.55 lb/mmBtu level is equivalent to 470 lb/hr at a rating of 855 

mmBtu/hr, whereas the power boiler already complies with a 309 lb/hr limit. 

The Department’s fuel sulfur regulations require boilers to use 0.3 and 0.37 percent sulfur 

residual fuel oil in NYC and Nassau/Rockland/Westchester Counties, respectively. 

These are equivalent to rates of 0.314 lb/mmBtu and 0.387 lb/mmBtu, or 268 lb/hr and 

331 lb/hr for an 855 mmBtu/hr boiler. IP’s permit limit is within the higher rate; they cite 

insignificant visibility improvement (0.02 dv) that would result from moving to the lower 

rate. 

Finally, IP notes the federal New Source Performance Standard (NSPS) for industrial oilfired boilers built after February, 2005 is 0.20 lb/mmBtu (40 CFR 60 Subpart Db). This 

is equivalent to 171 lb/hr at a maximum rating of 855 mmBtu/hr—lower than the 
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permitted 309 lb/hr limit. IP demonstrates that insignificant visibility improvement of 

0.07 dv would result from meeting this NSPS limit. 

IP therefore contends that the current operation of the wet-alkaline scrubber, the existing 

SO2 emission limit of 309 lb/hr as a 24-hour rolling average, and future compliance with 

the ICI Boiler MACT acid gas standard represent BART for SO2 for the Ticonderoga 

Mill power boiler. 

• NOx

The power boiler presently operates with low NOx burners, overfire air, and flue gas 

recirculation which limit NOx emissions to 0.25 lb/mmBtu. Maximum baseline 

emissions during the 2005 to 2009 period were 178 lb/hr as a 24-hour average; at the 

maximum capacity of 855 mmBtu/hr, maximum permitted NOx emissions are 214 lb/hr. 

IP again compares the existing permitted NOx levels for the power boiler to other BART 

guidelines and policies in order to demonstrate the effectiveness of the current control 

and permitted limits. IP notes that EPA’s BART rule did not set specific presumptive 

NOx limits for oil-fired boilers, but that states should generally consider “current 

combustion control technology.” 

The NSPS for industrial oil-fired boilers built after February 28, 2005 is 0.20 lb/mmBtu 

(40 CFR 60 Subpart Db). At a maximum capacity of 855 mmBtu/hr, this equates to 171 

lb/hr. IP sites insignificant visibility improvement by meeting this standard—i.e., 

maximum and eighth-highest visibility improvements of only 0.08 to 0.09 dv and 0.03 to 

0.04 dv, respectively. 

The Department’s recently revised NOx RACT regulation, Part 227, sets a presumptive 

NOx emission rate of 0.15 lb/mmBtu for the power boiler. This relates to a 128 lb/hour 

rate at maximum capacity. IP again sites minimal visibility improvement by meeting this 

standard: maximum and eighth-highest visibility improvements of 0.17 - 0.18 dv and 

0.07 dv, respectively. IP, however, is required to comply with the new 0.15 lb/mmBtu 

emission rate by July 1, 2014 under Part 227, and is currently conducting its required 

control analysis. 

Based on these arguments, IP contends that the current maximum NOx emission rate of 

0.25 lb/mmBtu and future compliance with the Department’s NOx RACT regulation 

should be considered BART. 

• PM 

IP cites EPA’s upcoming ICI Boiler and Process Heaters MACT standard (40 CFR 63 

Subpart DDDDD), which would establish particulate limits applicable to the power 

boiler. Compliance with this upcoming MACT is proposed as sufficient for BART 

compliance. 
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Recovery Furnace 

• SO2

The recovery furnace at the Ticonderoga Mill processes black liquor and uses No. 6 oil as 

an auxiliary fuel. In general, black liquor contains a significant amount of sulfur, 

nominally 3 to 5 percent by weight of the dissolved solids. Operation of the recovery 

furnace, however, differs from that of conventional steam boilers in that the primary 

objective is to recover and re-use the sulfur. Proper operation of a recovery furnace itself 

results in considerable control of SO2 emissions. Additionally, this unit is a non-direct 

evaporation recovery furnace which inherently results in low SO2 emissions. The last 

stack test performed on the recovery furnace revealed SO2 emissions of less than 1 lb/hr. 

The available retrofit technologies for SO2 control from kraft mill recovery furnaces are 

staged combustion systems and wet scrubbers. The Ticonderoga Mill’s recovery furnace 

is already equipped with a three-level staged combustion air control system. Regarding 

the installation of a wet scrubbing device, IP sites the technical infeasibility of installation 

downstream of the existing ESP. The reaction products from dry scrubbing would 

necessitate collection in the ESP, but would contaminate the sodium sulfate (salt cake) 

that the ESP collects and recycles back to the pulping process. 

IP also notes that only three recovery furnaces in the U.S. are equipped with wet 

scrubbers in addition to ESPs, though none were installed for the purpose of SO2

removal; instead, two were installed for heat recovery purposes and the third was 

installed on a unit equipped with a direct contact evaporator to prevent liquid droplets 

from being entrained and emitted to the atmosphere. The inherent SO2 concentration in 

recovery furnace flue gas is also much lower than that of emission units to which wet 

scrubbers are routinely applied (e.g., fossil fuel-fired steam generators). 

IP proposes that existing operation of the recovery furnace through the use of three-level 

staged combustion air control system with ESPs be considered as BART. 

• NOx

The current permitted NOx emission rate for the recovery furnace is 100 ppm (by 

volume) corrected to 8% O2. The majority of NOx formed in the recovery furnace is 

believed to be primarily fuel NOx due to the low temperatures in the furnace’s 

combustion zone. Fuel NOx emissions from recovery furnaces are typically low due to 

the low nitrogen content of black liquor solids. The furnace’s three-level staged 

combustion system can also be operated to minimize NOx formation/emissions. 

Due to the unique nature of recovery furnace operation, IP is able to rule out traditional 

boiler controls such as selective catalytic reduction (SCR), selective non-catalytic 

reduction (SNCR), low NOx burners, and flue gas recirculation as being technically 

infeasible. IP’s recommended compliance with BART for NOx is the currently installed 

three-level staged combustion air control system with ESPs. 
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• PM 

Particulate emissions from the recovery furnace are currently controlled with a threechamber ESP. In addition to ESPs, IP identified wet scrubbers and fabric filters as 

potential PM controls. IP previously discounted the feasibility of a wet scrubber on the 

recovery furnace. Fabric filters have not been applied to recovery furnaces at kraft pulp 

mills and are not considered to be an available control alternative. 

IP notes that it complies with the Chemical Recovery MACT standard (40 CFR 63 

Subpart MM) and that EPA states in its BART rule, “...you may rely on the MACT 

standards for purposes of BART” (70 FR 39164). IP therefore proposes that current PM 

controls and emission levels satisfy BART. 

III. BART Determination 

The Department finds that the following shall constitute BART for the International Paper 

Ticonderoga Mill emission sources: 

Power Boiler 

• SO2

The Department accepts that the current SO2 permit limits of 309 lb/hr (rolling 24-hr 

avg.) and 435 lb/hr (rolling 3-hr avg.) represent BART for SO2. IP adequately 

demonstrated that the existing limit compares favorably to other benchmarks, and that 

lowering the limit would have negligible impact on visibility. IP’s December 2011 

follow-up demonstrated that upgrades/improvements to the existing scrubber were 

technically infeasible. 

It should be noted that the Department is pursuing a regulatory revision to 6 NYCRR Part 

225-1 to lower the acceptable sulfur limit in no. 6 fuel oil to 0.5 percent statewide (not 

including the New York City and lower Hudson Valley areas, which are already subject 

to more stringent limits). This revision is tentatively scheduled to be effective for 2014, 

and may supersede proposed BART and MACT limits. 

• NOx

The Department accepts that the use of current combustion control technology represents 

BART for NOx. The Department is also requiring IP to conduct a top-down NOx control 

analysis pursuant to the updated NOx RACT limits of Part 227-2. The Department 

accepts the existing 0.25 lb/mmBtu NOx emission limit as BART, and will require IP to 

meet the updated 0.15 lb/mmBtu NOx emission limit by July 1, 2014, unless this 

emission limit is unattainable due to technical or economic infeasibility. 
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• PM 

IP will be required to comply with the ICI Boiler and Process Heaters MACT standard. 

Compliance with the final MACT emission standards is expected to be required in 2015. 

The Department deems compliance with the MACT limit as acceptable for BART. This 

unit is also currently subject to a particulate emission limit of 0.1 lb/mmBtu. 

Recovery Furnace 

• SO2

The Department finds that the staged combustion system and operational practices 

currently employed on the recovery furnace represent BART for SO2. Alternative control 

options considered by IP were determined to be technically infeasible. As noted, SO2

emissions are inherently low from this unit; the most recent stack test revealed SO2

emissions to be less than one pound per hour. 

As discussed above, the Department is intending to revise its Part 225-1 fuel sulfur limit 

regulations, with a target effective date in 2014. This would reduce the recovery 

furnace’s no. 6 fuel sulfur content from 1.5 percent to 0.5 percent. 

• NOx

The Department accepts that the existing staged combustion system represent BART for 

NOx. Alternative control options are considered technically infeasible due to the 

recovery furnace’s unique design. The recovery furnace will retain its current 100 ppm 

NOx limit. 

• PM 

The Department accepts the current use of an ESP as BART for PM. Alternative options 

are considered technically infeasible. This unit complies with the Chemical Recovery 

MACT standard (40 CFR 63 Subpart MM) with a limit of 0.03 grains/dscf, which is 

deemed adequate for BART.