New York State Department of Environmental Conservation 

Best Available Retrofit Technology Determination 

Facility Arthur Kill Generating Station 

Location Staten Island, NY 

Richmond County 

Permit ID 2-6403-00014 

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 28, 2011. Upon completion of this public notice period, the modified permit was 

submitted to EPA for review on February 2, 2012. The final modified permit was issued on 

March 20, 2012. This permit is now being submitted to EPA as a revision to the New York 

Regional Haze SIP. 

 

1 
II. BART Analysis Summary 

NRG submitted a BART analysis for the Arthur Kill Generating Station, dated August 4, 2010. 

The following emission source had been established as BART-eligible and was therefore 

included in the analysis: 

Boiler No. 30 – Emission Unit A-K0001; Emission source 00030 

• This unit is a Combustion Engineering tangentially-fired boiler, rated at 5,502 mmBtu/hr. 

It is classified as a “very large boiler,” and has the capability to burn natural gas or No. 6 

oil, though it has fired exclusively natural gas for the last 10 years. Operation of this unit 

commenced in June, 1969. 

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

• SO2

In Appendix Y of 40 CFR Part 51, “Guidelines for BART Determinations Under the 

Regional Haze Rule,” EPA presents presumptive limits for sulfur dioxide for utility 

boilers. EPA states that “[y]ou must require 750 MW power plants to meet specific 

control levels for SO2 of either 95 percent control or 0.15 lb/mmBtu, for each EGU 

greater than 200 MW that is currently uncontrolled...” 

Arthur Kill Unit 30 has only burned gas for the past 10 years and emits SO2 at an average 

rate of 0.0006 lb/mmBtu, well below EPA’s presumptive level. NRG proposes that the 

fuel currently being burned be accepted as BART. NRG proposes to revise its permit 

limit equal to the New York City sulfur in fuel limit of 0.3 percent or 0.3 lb/mmBtu for 

BART purposes. 

• NOx

The Department recently revised its NOx RACT regulations under 6 NYCRR Part 227 

and, because of the common $5,500 per ton threshold and similarity in the evaluation 

methodology, allowed BART-eligible facilities to fulfill NOx RACT and NOx for BART 

through one common demonstration. 

The revised Part 227 establishes a presumptive NOx emission limit for large oil/gas-fired 

boilers of 0.15 lb/mmBtu. The annual average measured rate for Unit 30 is 0.088 

lb/mmBtu. Unit 30 achieves this rate through the application of existing combustion 

controls. NRG proposes to revise the permit for Unit 30 to meet this new presumptive 

RACT limit of 0.15 lb/mmBtu on a 24-hour average during the ozone season and 30-day 

rolling average during the non-ozone season. 

• PM 

NRG investigated the installation of an electrostatic precipitator (ESP) and a baghouse to 

control PM emissions. Scrubbing systems were not analyzed, as these were assumed to 

2 
3 

have greater costs with no additional PM reductions. The total annual costs were found 

to be approximately $3.98M for the ESP and $4.25M for the baghouse. Using the 

maximum 12-month PM mass over the last five years (329 tons) as a basis, and assuming 

these units achieve 99.9 percent capture and control, the cost effectiveness would be 

greater than $12,000 per ton for each control technology. NRG therefore requests that 

current operations be accepted as BART. 

NRG calculated that an ESP operating at 99.9 percent—the cheaper of the two control 

options—would be cost-effective when Unit 30 emits 724 tons per year (tpy). NRG 

initially proposed this as the PM limit for Unit 30; later, NRG realized the unit is actually 

capable of emitting only 359 tpy at full operation. NRG proposes to accept a 359 tpy 

permit limit to comply with BART. 

III. BART Determination 

The Department finds that the following shall constitute BART for Arthur Kill Generating 

Station Boiler No. 30: 

• SO2

The Department finds that the current operation of Unit 30 is adequate as BART, and 

easily meets the presumptive limit established by EPA in Appendix Y. The Department 

is modifying Arthur Kill’s permit to include EPA’s presumptive SO2 emission limit of 

0.15 lb/mmBtu, and is also adding a stipulation that Unit 30 will fire exclusively natural 

gas to maintain low SO2 emissions. 

• NOx

The Department is approving a BART NOx limit of 0.15 lb/mmBtu, based on a 24-hour 

average during the ozone season and 30-day rolling average during the non-ozone season. 

• PM 

The Department accepts that current operations represent BART for PM. NRG 

adequately determined that potential PM controls were not economically feasible. The 

Department is accepting the proposed 359 tpy limit.