AIR QUALITY PLANNING 

SECTION 

Karen Smith 

Air Management Services, 

STATE OF DELAWARE 

DEPARTMENT OF NATURAL RESOURCES 

& ENVIRONMENTAL CONTROL 

DIVISION OF AIR QUALITY 

655 SOUTH BAY ROAD, SUITE 5N 

DOVER,DELAWARE19901 

October 15, 2014 

321 University A venue, 2nd Floor, 

Philadelphia, PA 19104, 

Telephone: (302) 739- 9402 

Fax No.: (302) 739- 3106 

Re: Department of Public Health Air Management Services (AMS) Reasonably Available 

Control Technology (RACT) State Implementation Plan (SIP) Revision under the 1997 8-Hour 

Ozone National Ambient Air Quality Standards (NAAQS) 

Dear Ms. 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 nitrogen oxides (NOx). 

All emission sources in Delaware are currently well controlled yet Delaware's air quality does 

not meet the health based air quality 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 Pollution Rule (CSAPR), has demonstrated that emissions from Pennsylvania significantly 

contribute to unhealthy air quality in Delaware. Given this, we have examined the AMS 

proposed emission limits for NOx with particular interest. 

Delaware notes that the emission limits in this AMS proposal are in many instances much 

lower and more reflective of RACT relative to the limits previously imposed under the 1-hour 

ozone NAAQS. Despite this, Delaware has identified four areas of concern, 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 of meeting by the application of 

control technology that is reasonably available considering technological 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 Paper 
Air Management 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, "Load and NOx concentration variations with the 

boilers makes placement of the catalyst difficult and makes it difficult to 

maintain a proper ammonia irifection rate." SNCR technology does not include 

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 reduction technique 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 

this control technology. 

• Temple University - Health Sciences Campus. For boilers 1, 2 and 3, the 

proposal discusses the capability and ability of ultra-low NOx burners (ULNBs) 

to operate in a retrofit situation. There appear to be a number of misconceptions 

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 of application, 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, 

and balance draft application. The Flue Gas Recirculation (FGR) referred to for 

ULNBs is typically a function of the flame shaping to bring the flue gas into the 

developing flame as an internal function/shape/dynamic ofthe developing flame 

and not a traditional FGR system. Further, use of preheated air (maintaining the 

function of any 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 

controls based upon more recent ULNB 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 (as 
Air Management Services 

October 15, 2014 

Page 3 

opposed to thermal NOx) and that there is an efficiency loss associated with the 

water injection. Water injection is a proven 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 a particular source is capable of meeting by the application 

of control technology that is reasonably available considering technological and 

economic feasibility (44 FR 53762). 

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 of other states, 

particularly states within the same nonattainment area boundaries, should not be 

discarded as economically unreasonable based on this low cost threshold. Delaware 

recommends that AMS revisit the following determinations, as additional emission 

controls appear economically reasonable. 

• Philadelphia Energy Solutions Refining and Marketing LLC (PES). ULNB 

and SNCR NOx control on Unit 860-2H2, 860-2H4, 864-PH1, 137 F-1, and 

137 F-2 appear economically reasonable at between $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) at a cost of 3836 $/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. 
Air Management 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 

for boiler 25. 

• Veolia-Energy Efficiency (PA) LLC, September 4, 2014. For boilers 1 and 

2, OFA and LNBs appear economically reasonable at $4674/ton for OFA 

and $4571/ton for 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 of summertime high electric 

demand tend to coincide with conditions conducive to ozone formation. These 

units should be subject to installation of emission controls or short term NOx 

emission rate limits representative of operation with NOx emission controls 

such as water injection, 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 

Turbine Electric Generating Unit Emissions. 

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 

calculated cost effectiveness values. 
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October 15, 2014 

Page 5 

Delaware and the Ozone Transport Commission (OTC) have been using 6% cost of 

capital and a 20 year life for control equipment in estimating the cost and cost 

effectiveness of emission 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 of the control equipment. Delaware 

recommends that AMS determine economic reasonableness using an interest rate of 

6% and a control equipment life of 20 years. 

Thank you for your attention to these concerns, and please contact me or Ron Amirikian of my 

staff if you would like to discuss them or if we can assist you in any way. 

Enclosure 

cc: Thomas Huynh, AMS 

Diana Esher, EPA Region 3 

/#~ Director