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New York State Department of Environmental Conservation 

Best Available Retrofit Technology Determination 

Facility EF Barrett Power Station 

Location Hempstead, NY 

Nassau County 

Permit ID 1-2820-00553 

Source Category Fossil-fuel fired steam electric plants 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 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 7, 2011. Upon completion of this public notice period, the modified permit was 

submitted to EPA for review on February 7, 2012. The final modified permit was issued on 

March 27, 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 

National Grid submitted a BART analysis for the EF Barrett Power Station to the Department 

dated September 27, 2010. The following emission source had previously been identified as 

BART-eligible and was therefore included in the analysis: 

Boiler No. 2 – Emission Unit U-00002; Emission Source ES002 

• This unit (“Unit 2”) is a Combustion Engineering tangentially-fired boiler rated at a 

maximum hat input of 1,825 mmBtu/hr. This boiler is capable of firing natural gas or oil, 

though it fires natural gas almost exclusively, with oil serving as a backup in case of gas 

shortages. Operation of this unit commenced in 1963. 

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

• SO2

The EF Barrett facility primarily burns natural gas, which results in negligible SO2

emissions. The facility is currently permitted to burn oil with a maximum sulfur content 

of 0.37 percent by weight under state regulation (6 NYCRR Part 225-1). National Grid 

notes that this low-sulfur fuel is well below the 1.0 percent sulfur limit in oil referenced 

by the Appendix Y guidance, and proposes it for BART. 

This unit is required to burn oil at times, as required by local reliability rule I-R5 (the 

“minimum oil burn” rule) which states that “the NYS bulk power system shall be 

operated so that a loss of a single gas facility does not result in the uncontrolled loss of 

electric load within the Long Island zone.” For this reason the facility is unable to accept 

a permit condition limiting the amount of oil burned in order to further reduce SO2

emissions, as such a limit would detract from the operational flexibility needed to meet 

the reliability requirement. The amount of oil burned is a factor of load level and the 

number of units online, though real-time conditions may arise that require variations from 

the scheduled operation. 

• NOx

In 2006 and 2007, National Grid began the evaluation of NOx control technologies in 

anticipation of future regulatory requirements (i.e. the Clean Air Interstate Rule and 

revisions to NOx RACT regulations). The primary technologies evaluated were selective 

catalytic reduction (SCR), selective non-catalytic reduction (SNCR), and separated 

overfire air (SOFA). 

SCR was the first add-on technology to be evaluated because it offers the greatest 

potential NOx reductions. One issue with SCR technology is that effectiveness degrades 

with non-steady state operation, and this unit is no longer a base load unit but rather a 

load following unit. The cost of an SCR unit for this facility was estimated at $30M. At 

100 percent operation, this resulted in an annual control cost of $12,447 per ton of NOx
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reduced. This exceeds the $5,500/ton cost threshold established by the Department for 

BART. 

SNCR was also investigated during this time period, and had been evaluated in the mid 

1990’s as well. The resulting finding was that SNCR produced benefits no greater than 

that of SOFA, with additional operational constraints. The ineffectiveness of SNCR 

(with vendor quotes of control efficiency no higher than 20 percent) was in large part due 

to the load-following operation of the boiler; SNCR is much more effective for base load 

units, as the temperature profile inside the boiler is held constant. 

National Grid is proposing SOFA as the control technology to be installed on Unit 2, to 

be operating by January 1, 2014. The effectiveness of the application of SOFA had been 

previously determined on this boiler. National Grid is committing to NOx emission rates 

of 0.20 lb/mmBtu on oil and 0.10 lb/mmBtu on gas, for compliance on a 24-hour average 

basis. Because National Grid selected the most stringent NOx control option that was 

technically and economically feasible, they did not proceed with a visibility analysis. 

• PM 

Because Unit 2 is fired with natural gas (and low sulfur oil as backup), particulate 

emissions for this unit are low. An economic analysis of an electrostatic precipitator 

(ESP) for this unit indicated a cost-effectiveness of $45,500 per ton of PM removed when 

assuming a $17M capital cost and 100 percent operation. National Grid notes that a 

baghouse would be similarly costly. National Grid proposes that no controls be required 

to fulfill BART. 

III. BART Determination 

The Department finds that the following shall constitute BART for EF Barrett Power Station 

Boiler No. 2: 

• SO2

The Department accepts the current fuel sulfur limit of 0.37 percent by weight as BART 

for SO2. This is in line with the guidance provided by EPA for sulfur in fuel of 1.0 

percent or less by weight (Appendix Y, Section IV.E.4, “SO2 limits for Utility Boilers”). 

EPA also notes in the BART rule that “the most appropriate control option for oil-fired 

EGUs, regardless of capacity, is to set limits on the sulfur content of the fuel oil burned in 

the unit” (70 FR 39133). 

• NOx

The Department accepts National Grid’s commitment to installing SOFA as BART for 

NOx. Other options were ruled out due to economic infeasibility (SCR) or lower control 

efficiency (SNCR). National Grid is accepting NOx emission rates of 0.20 lb/mmBtu on 

oil and 0.10 lb/mmBtu on gas, for compliance on a 24-hour average basis. 
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• PM 

The Department accepts that no controls are necessary for compliance with BART for 

PM. National Grid adequately demonstrated that potential options were economically 

infeasible. This boiler will continue to operate with a 0.1 lb/mmBtu particulate emission 

limit.