AIR QUALITY PLANNING SECTION

Karen Smith AirManagement Services, STATE OF DELAWARE DEPARTMENT OF NATURAL RESOURCES & ENVIRONMENTAL CONTROL DIVISION OF AIR QUALITY 655 SOUTH BAY ROAD, SUITE5N DOVER,DELAWARE19901

October 15, 2014

321 UniversityAvenue, 2ndFloor, Philadelphia, PA 19104, Telephone: (302) 739- 9402 Fax No.: (302) 739- 3106

Re: Department ofPublic Health Air Management Services (AMS) Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision under the 19978-Hour OzoneNationalAmbientAirQualityStandards (NAAQS)
DearMs. Smith:
Thank you for the opportunity to comment on your proposal to satisfy the Clean Air Act (CAA) RACT requirements under the 1997 ozone NAAQS for several major sources of volatile organic compounds (VOC) and nitrogenoxides (NOx).
All emission sources in Delaware are currently well controlled yet Delaware's air quality does notmeetthe healthbased airquality standard for ozone. This AMS proposal is very important to us because all major modeling efforts conducted to date, to include modeling that the Environmental Protection Agency (EPA) has conducted in connection with their Cross State Air PollutionRule (CSAPR), has demonstrated that emissions from Pennsylvania significantly contribute to unhealthy air quality in Delaware. Given this, we have examined the AMS proposedemissionlimitsforNOxwithparticularinterest.
Delaware notes that the emission limits in this AMS proposal are in many instances much lower and more reflective ofRACT relative to the limits previously imposed under the 1-hour
ozone NAAQS. Despite this, Delaware has identified four areas ofconcern, and provides the following comments.
1. Technological feasibility determinations. The EPA has defined RACT as the lowest emission limitation that a particular source is capable ofmeeting by the application of control technologythat is reasonably available consideringtechnological and economic feasibility (44 FR 53762). Delaware requests AMS revisit the following proposed technological feasibility determinations.

**De~aware's** 

## good nature 

## depends on you ' Printed on Recycled PaperAirManagement Services October 15, 2014 Page 2

• Honeywell International, Frankford Plant. For boilers 1 and 2, the proposal indicates that Selective Non-Catalytic Reduction (SNCR) is not a feasible NOx control technology because, "LoadandNOx concentration variations with the boilers makes placement ofthe catalyst difficult and makes it difficult to maintainaproperammonia irifection rate." SNCRtechnology does notinclude catalysts, and can be engineered and installed to be effective over a wide unit operating range. Delaware believes it is unlikely that SNCR is technically infeasible for these applications, and requests that AMS revisit this determination.

• Honeywell International, Frankford Plant. For boiler 3, the proposal indicates that water/steam injection is technically infeasible, indicating that it is ineffective for #6 fuel oil in boilers. Water/steam injection is technically feasible and an effective NOx reductiontechnique for boilers firing any fuel. It would seem likely that it would also be technically feasible for this installation. Delaware recommends that AMS conduct additional technical evaluation for thiscontrol technology.

• Temple University

- Health Sciences Campus. For boilers 1, 2 and 3, the proposal discusses the capability and ability ofultra-lowNOx burners (ULNBs) to operate in aretrofit situation. There appearto be anumber ofmisconceptions in the discussion. For example, the document indicates that ULNB can only be used in bottom fired, balance draft installations. While there may be certain ULNBs designed specifically for this type ofapplication, ULNBs are available in service for multiple firing configurations, including wall fired installations, and are also available from some manufacturers for natural draft, forced draft, andbalance draft application. The Flue Gas Recirculation (FGR) referredto for ULNBs is typically a function ofthe flame shapingto bringthe flue gas into the developing flame as an internal function/shape/dynamic ofthedeveloping flame andnot atraditional FGR system. Further, use ofpreheated air (maintainingthe function ofany exiting air pre-heating device) is still possible using ULNBs. It appears that the inaccuracies may have contributed to the assessment that ULNBs are not feasible. Delaware recommends that AMS further evaluate controlsbasedupon morerecentULNB capabilities.

• Temple University-Main Campus. For the three BMCEP boilers, the proposal indicates that water injection is not technologically feasible since the primary contributor to NOx emissions during oil-fired combustion is fuel NOx (asAirManagement Services October 15, 2014 Page 3 opposedto thermal NOx) and thatthere is an efficiency loss associated withthe water injection. Water injection is aproven NOx reduction technology for oilfired boilers that is in commercial use. Delaware does not agree that that water injection is technologically infeasible for these boilers. Delaware recommends further analysis, and that any additional operating costs associated with efficiency loss due to water injection be assessed in the cost effectiveness evaluation.

2. Economic feasibility determinations. The EPA has defined RACT as the lowest emission limitation that aparticular source is capable ofmeeting by the application of control technology that is reasonably available considering technological and economic feasibility (44 FR53762).
AMS has proposed a $2,500 per ton cost threshold to judge RACT economic feasibility. Delaware and other States have determined, and required, emission controls costing more than four times this threshold to be economically cost effective. Emission controls that are currently required in the SIPs ofother states, particularly states within the same nonattainment area boundaries, should not be discarded as economicallyunreasonablebased onthis lowcostthreshold. Delaware recommends that AMS revisit the following determinations, as additional emission controlsappeareconomicallyreasonable.

• Philadelphia Energy Solutions Refining and Marketing LLC (PES). ULNB and SNCRNOx control onUnit 860-2H2, 860-2H4, 864-PH1, 137 F-1, and 137 F-2 appeareconomicallyreasonable atbetween$3104 and $4499/ton.

• Honeywell International, Frankford Plant. For the boiler 3, SCR appears economically reasonable, as AMS estimates it would reduce NOx by 85% (425 tpy) atacostof3836 $/ton.

• Paperworks Industries, Inc. For boiler 1, the following control options appear cost effective: $4481/ton for FOR, $3693/ton for SNCR, and $4165/to for SCR.

• Newman and Company, Inc. FOR on boiler 1 appears cost effective at $3564/ton.

• Temple University

- Health Sciences Campus. SCR appears economically reasonable at $3024/ton.AirManagement Services October 15, 2014 Page4

• Grays Ferry Cogeneration Partnership. SNCR at $4407/ton, ULNB at $3496/ton, and ULNB 

### + OFA at $4063 all appear economically reasonable forboiler25.

• Veolia-Energy Efficiency (PA) LLC, September 4, 2014. Forboilers 1and 2, OFA and LNBs appear economically reasonable at $4674/ton for OFA and $4571/tonfor LNBs.

3. Consideration of daily em1ss10ns. Emission control technology that was deemed not cost effective on diesel fired units in the proposal, in all cases, was based on tons per year estimates. In Delaware's experience diesel-fired units

are typically operated on a daily or hourly basis, and as such significantly contribute to episodic ozone concentrations. Evaluation of emission control cost effectiveness on a $/ton basis for units that operate in this fashion is not appropriate.
For the Exelon Generating Company

- Southwark Station, the proposal addresses four 15.5 MW combustion turbine EGUs firing #2 fuel oil. The proposal provides that the existing 5% annual capacity factor limitation represents RACT. Delaware does not agree that an annual capacity factor limitation adequately represents RACT. These combustion turbine EGUs tend to operate as peaking devices, operating at high outputs during periods of summertime high electric demand. These periods ofsummertime high electric demand tend to coincide with conditions conducive to ozone formation. These units should be subject to installation ofemission controls or short term NOx emission rate limits representative of operation with NOx emission controls suchas waterinjection, ULNBs, etc. Delaware suggests that AMS address daily emissions from diesel and combustion turbine units by adopting requirements similar to what Delaware has done in 7 DE Admin. Code 1144, Control of Stationary Generator Emissions, and 7 DE Admin. Code 1148, Control of Stationary Combustion TurbineElectric GeneratingUnitEmissions.
4. Interest rate and life usage. The interest rate and control equipment life, which are major inputs to an economic analysis, are extremely variable throughout the AMS proposal. Many appear unrealistically conservative at 20% interest combined with

a control equipment life of 10 years, and others appear reasonable at 4% interest and 20 years. Unrealistically conservative values tend to greatly increase the calculatedcosteffectivenessvalues.AirManagement Services October 15, 2014 Page 5
Delaware and the Ozone Transport Commission (OTC) have beenusing 6% cost of capital and a 20 year life for control equipment in estimating the cost and cost effectiveness ofemission control projects. 6% reflects a conservative value for a long duration debt. In fact, current actual values are significantly lower, ranging from about 5% down to about 2% over the last few years, reflecting the low Treasury rates and relatively low economic growth. A 20 year life is reasonable given that the calculations include operating and maintenance costs (including catalyst replacement for SCR) that are anticipated to be needed to keep the control equipment functioning properly over the life ofthe control equipment. Delaware recommends that AMS determine economicreasonableness using an interestrate of 6% and acontrol equipmentlife of20 years.

Thankyoufor your attentionto these concerns, andplease contactme orRon Amirikianofmy staffifyouwouldliketo discussthemorifwe canassistyouinanyway.

Enclosure

cc: Thomas Huynh, AMS DianaEsher, EPARegion 3 

# /#~ Director