New York State Department of Environmental Conservation

Best Available Retrofit Technology Determination

Facility Con Ed – 59 th Street Station

Location Manhattan, NY
New York County

Permit ID 2-6202-00032

Source Category Fossil-fuel boilers 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.

In accordance with BART requirements, each BART-eligible facility performed a BART analysis of controls for sulfur dioxide, nitrogen oxides and particul ate matter. This analysis took

into account such factors as the cost of c ontrols, energy and non-air quality environmental impacts of compliance, any existing pollution co ntrol technology in use at the source, the remaining useful life of the source, and the de gree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

This document summarizes the reasoning be hind the Department’s BART determination, including the level of cont rols 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 pub lic notice period, the modified permit was submitted to EPA for review on January 31, 2012. The final modified permit was issued on March 20, 2012. This permit is now being submitt ed to EPA as a revision to the New York Regional Haze SIP.

1II. BART Analysis Summary

Consolidated Edison (Con Ed) submitt ed its BART analysis for the 59 th Street Station, dated September, 2010. The following emission sources had previously been identified as BARTeligible and were therefore included in the analysis:

Steam Boiler #114 – Emission Unit 5-90020; Emission Source 00114

Steam Boiler #115 – Emission Unit 5-90020; Emission Source 00115

• Each of these units is a Combustion Engin eering fixed-tangential boiler with a design maximum heat input capacity of 805 mmBtu/hr. Both units burn low sulfur No. 6 fuel oil (0.3 percent sulfur by weight) as the primar y fuel, with natural gas being used for ignition. They were installed in 1966. Th ese are steam-only boilers that do not produce electricity and follow steam load, which results in limited operation and significant unused capacity. Because of the similarity in the technical and operational aspects of these boilers, this BART an alysis combines the analyses for Boilers 114 and 115.

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

• SO 2

For compliance with the low-sulfur fuel oil standards contained in 6 NYCRR Part 225-1,

the 59 th Street Station has a permit condition whic h limits the maximum sulfur content of the fuel oil to 0.3 percent by weight for Boilers 114 and 115. This low-sulfur fuel is well below the 1.0 percent sulfur limit in oil refe renced by the Appendix Y guidance. Con Ed therefore requests that the cu rrent use of low-sulfur fuel be considered BART for SO 2

.

• NO

x

Con Ed identified seven potential control tec hnologies as BART for Boilers 114 and 115. The following table lists the options identified, with technically infeas ible options crossed out. For the options that remain feasible, the expected control efficiency has been provided along with the cost -effectiveness values under fu ll operation and expected operation.

NO

x Control Option Control Efficiency (%) Cost Effectiveness,

8,760 hr/yr ($/ton) Cost Effectiveness,
Expected
Operation ($/ton)

Low NOx Burners N/A N/A N/A

Ultra Low NOx Burners N/A N/A N/A

Water Injection 10 $3,368 $8,717

Flue Gas Recirculation (FGR) 10 $12,296 $31,825

Selective Catalytic Reduction (SCR) 47 $8,788 $22,747

Selective Non

‐ Catalytic Reduction (SNCR) 20 $9,633 $24,934

Overfire Air (OFA) 20 $6,625 $17,147

2The water injection option re mains feasible under full load when considering the $5,500/ton threshold established by the Department for BART. When taking into account actual operations of these units, as directed by the Appendix Y guidance, the reduced capacity drives the co st-effectiveness to over $8,500/ton.

Tables 3-1 and 3-2 of the Con Ed analysis demonstrate the visibility impacts of implementing the water injection cont rol. A conservative 20 percent NO

x reduction was utilized for this step. Visibility impact modeling indicated minimal improvement in downwind areas: At the maximally impacted Class I area, visibility improvement was 0.04 deciviews (dv), or 4 percent, using th e Vermont meteorological data and 0.02 dv, or 2.6 percent, using AECOM data. Ninety-eig hth percentile results were approximately 0.01 dv (1.8 percent) and 0.01 dv (2.6 percent) with Vermont and AECOM meteorological data , respectively.

Based on these results, Con Ed recommends that no additional control is needed to satisfy

BART for NO

x for Boilers 114 and 115.

• PM

Con Ed identified three potential add- on control technologies for PM at 59 th Street Station: an electrostatic pr ecipitator (ESP), a fabric filter /baghouse, and a cyclone. In each case, Con Ed notes that the control technology does not appear to be demonstrated in practice for a utility boiler that burns oil as the primary fuel. Con Ed therefore deems each as technically infeasible.

Con Ed requests that current operations be accepted as BART for PM. Good combustion practices and the use of low sulfur fuel serve to minimize PM emissions from 59 th Street

Station Boilers 114 and 115.

III. BART Determination

The Department finds that the following shall constitute BART for Con Ed 59 th Street Station

Boilers 114 and 115:

• SO 2

The Department accepts the current fuel sulfur limit of 0.3 percent by weight as BART

for SO 2 . This is in line with the guidance pr ovided by EPA for sulfur in fuel of 1.0 percent or less by weight (A ppendix Y, Section IV.E.4, “SO 2 limits for Utility Boilers”).

EPA also notes in the BART rule that “the most appropriate contro l 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).

34 • NO

x

The Department accepts the finding that no fu rther control is requi red as BART for NO

x . Although the water injection control option was within the Department’s $5,500/ton BART threshold under full, 24/7 operati on, it exceeds $8,500/ton when taking into account actual operating conditi ons. In addition, Con Ed ad equately demonstrated the minimal visibility improvement that would result from this type of controls, even when using a conservative control effectiveness estimate. All other NO

x control options were found to be technically or economically infeasible. A NO

x limit of 0.32 lb/mmBtu, based on a rolling 30-day average, has be en established for both boilers.

• PM

The Department accepts the finding that no furt her control is required as BART for PM.

Potential controls were found to be techni cally infeasible due to the operational characteristics of these boilers. These boilers will continue to operate with a 0.1 lb/mmBtu particulate emission limit.