TSD-vAdd 

Proposed Technical Addendum to Final BART Determinations 

for Affected BART-eligible Sources 

in the State of New Jersey 

Technical Support Document 

State of New Jersey Department of Environmental Protection 

Division of Air Quality 

Bureau of Air Permits 

401 E. State Street, 2nd floor, P.O. Box 27 

Trenton, NJ 08625-0027

July 25, 2011 

 
2

1.0 ADDENDUM TO BEST AVAILABLE RETROFIT TECHNOLOGY (BART) 

DETERMINATIONS 

1.1 Introduction 

To fulfill its obligation to complete its review of facilities subject to BART,1

 the New Jersey 

Department of Environmental Protection (NJDEP) submitted its BART determinations to the 

United States Environmental Protection Agency (USEPA) Region 2 on March 2, 2011.2 These 

facilities included: 1) PSEG Hudson Generating Station, 2) Chevron Products, 3) Amerada Hess 

Port Reading Refinery, 4) ConocoPhillips Bayway Refinery, and 5) Sunoco Eagle Point. 

When asked by USEPA Headquarters to confirm its inventory of BART-eligible coal-fired 

electric generating units (EGUs) in the Region, as part of an analysis to determine if the 

Transport Rule is better than BART, USEPA Region 2 subsequently identified three EGUs listed 

that were in operation as early as 1962, but were not included in NJDEP's BART determination. 

These EGUs are: 1) Vineland Municipal Electric Utility (VMEU) - Howard M. Down, Unit 10, 

and 2) BL England Generating Station, Units 1 and 2. 

The Mid-Atlantic/Northeast Visibility Union (MANE-VU) formed a BART workgroup 

consisting of member states, including New Jersey, to assist with the BART requirements of the 

Regional Haze rule including the identification of potentially BART-eligible sources and the 

emission units that comprise them. The final MANE-VU list of applicable BART-eligible 

sources developed by NESCAUM3 was the result of an iterative process spanning several years. 

At that time, these sources were anticipated to permanently shutdown as a result of enforceable 

agreements that were negotiated concurrent with the regional BART process. These enforceable 

agreements remain, and include options to control or repower. 

NJDEP has consequently determined that these facilities should be included in this addendum to 

the Final BART Technical Support Document to provide a complete picture on the status and 

commitments to reduce visibility-impairing emissions from these facilities through shutdown, 

controls, repower, or fuel switch consistent with BART. 

1.2 BART-Eligibility 

To be BART-eligible a facility must belong to one of 26 specific source categories with existing 

stationary emission units (or pieces of equipment) which meet specific criteria for start-up dates, 

and potential emissions of any visibility impairing pollutants greater than 250 tons per year 

including NOx, SO2, and PM10.

4

 These two facilities are classified under the source category of 

 

1

http://www.state.nj.us/dep/baqp/2008%20Regional%20Haze/Regional%20Haze%20SIP%20Final2009.pdf 

2

http://www.state.nj.us/dep/baqp/sip/BART%202011_1.pdf 

3

 NESCAUM. Five-Factor Analysis of BART-eligible Sources Survey of Options for Conducting BART 

Determinations. Boston, MA; June 2007. 

4

64 Fed. Reg. 35737; July 1, 1999 
3

“Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour 

heat input.” Upon reviewing the “in operation” dates and current potential emissions from the 

applicable equipment still in existence at each named facility, NJDEP determined that Vineland 

MEU and BL England are BART-eligible sources. See Table 1A below. 

Table 1A List of Additional BART-eligible Sources in New Jersey 

Cumulative visibility impairing pollutants 

from BART applicable equipment1 

Potential to Emit (PTE) in tons per year (tpy) 

Source category/ 

Facility 

NOx SO2 PM10

BART-eligible 

source 

(PTE > 250 tpy) 

Power plants: 

Vineland MEU 

Howard M. Down

442 1,718 131 Yes 

RC Cape May

BL England

10,629 40,370 4,410 Yes 

Notes: 

1

equipment put in place August 7, 1962 through August 7, 1977. 

1.2.1 Identification of BART-eligible Sources 

NJDEP followed the step-by-step process for determining BART-eligibility provided in 

Appendix Y to Part 51, Section II.5 The steps in identifying BART-eligible sources are: 

Step 1: list existing equipment at each of these electric generating power plants; 

Step 2: verify the start-up dates of the equipment and check if within the 1962-1977 time 

window; and 

Step 3: compare the cumulative potential emissions (PTE) from qualified equipment identified in 

Steps 1 and 2 to the 250 tons per year (tpy) cutoff for any single visibility impairing pollutant. 

Tables 2A and 3A display the information gathered from the steps above for 1) Vineland MEU, 

and 2) BL England, respectively. 

1.2.2 Vineland Municipal Electric Utility – Howard M. Down (PI#75507) – Vineland, 

Cumberland County 

The VMEU currently has four pieces of equipment, one No. 6 fuel oil-fired boiler (E10), 

ancillary equipment (E12 and E13) and an emergency generator (E22), that fall within the 

applicable BART time frame. The cumulative permitted PTE from these qualified units exceed 

the BART threshold for NOx and SO2 emissions (442 and 1718, respectively), and therefore this 

facility is a BART-eligible source. See Table 2A below. 

 

5

http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/40cfr51AppY.pdf 
4

Unit 10 (E10) is a 357 MMBtu//hr boiler that currently combusts No.6 fuel oil. Coal operation 

ceased in 2010, as a result of State and federal enforcement agreements. The bottom ash 

handling system (E12) and the fly ash handling system (E13) are support systems to E10 with the 

potential to emit particulate emissions only. The bottom ash and the fly ash handling systems 

have blower filters, and the PTE totals for these qualified units are below de minimis6

 levels for 

PM10. The distillate fuel oil-fired emergency generator (E22), rated at 2.3 MMBtu/hr, has not 

operated in more than ten years as reported to NJDEP in its electronic emission statements. The 

facility is also required to maintain a record of emergency use. 

The NJDEP Administrative Consent Order (NEA070001) required elimination of coal operation 

of E10 after December 31, 2010 (permit activity BOP090003 – effective). Moreover, the federal 

Consent Decree (Civil Action No. 1:11-cv-1826-RMB-JS) requires VMEU to add on selective 

non-catalytic reduction (SNCR) for NOx control by September 1, 2012, or cease operating E10 

by September 1, 2012. VMEU decided to permanently cease operation of E10. 

VMEU submitted a deactivation request to Pennsylvania-New Jersey-Maryland (PJM) 

Interconnection on June 6, 2011, and also submitted a written certification to USEPA Region 2 

and NJDEP on July 1, 2011. No later than July 30, 2011, VMEU is required to request a 

modification to the Title V operating permit to delete E10. When this boiler permanently shuts 

down, the cumulative permitted PTE for NOx and SO2 emissions from the remaining qualified 

units do not exceed the BART threshold this source. This facility will no longer be considered 

BART-eligible. NJDEP anticipates E10 permanently shutting down by September 1, 2012. See 

Attachments 1, 2, 3, and 4. 

Table 2A List of Equipment, Start-up Date, Potential Emissions, and Eligibility Determination – 

Vineland Municipal Electrical Utility 

VMEU Howard M. Down (PI#75507)

Identify emission units Verify dates If yes, compare PTE to 250 tpy cutoff 

Potential to Emit (PTE) 

in tons per year (tpy) 

Equip. 

NJID 

Equipment 

Description 

Start-up 

Date 

8/7/62 – 

8/7/77 

NOx SO2 PM10

BART 

eligible 

E10 Unit 10 boiler 1969 Yes 438 1,718 131 Yes1

E11 Unit 11 turbine 2010 No –– –– –– No 

E12 Bottom ash 

Handling 

1969 Yes N/A N/A D2 No2

E13 Fly ash handling 1969 Yes N/A N/A D2 No2

E14 Bottom ash silo 1952 No –– –– –– No 

E22 Em. generator 1969 Yes 3.5 0.18 0.33 Yes1

Visibility Impairing Pollutants NOx SO2 PM10 PTE

Totals (tpy): 442 1718 131 > 250 

Notes: 

 

6

http://www.state.nj.us/dep/aqm/Sub8.pdf 
5

1

equipment with applicable emissions to be considered cumulatively in determining the facility’s 

BART eligibility 

2De minimis (D) – potential to emit below de minimis level (less than 0.05 pounds per hour) 

1.2.3 BL England – RC Cape May (PI#73242) – Beesleys Point, Cape May County 

BL England currently has five pieces of equipment, or sources, and one emission unit that 

includes the fuel handling equipment, which fall within the BART time frame with cumulative 

permitted PTE above the 250 tpy applicability thresholds for NOx, SO2, and PM10 (10,629, 

40,370 and 4,410, respectively). Therefore, this facility is a BART-eligible source. See Section 

1.52 for details regarding existing controls and BART determinations. 

BL England is subject to an Administrative Consent Order (ACO) issued by NJDEP and agreed 

to by Atlantic City Electric Company on January 24, 2006. RC Cape May, current 

owner/operator, assumed the obligations of the ACO in subsequent amendments with a revised 

timeline to either repower or meet the NOx, SO2, and PM performance standards of the ACO. 

The amended ACO primarily affects Units 1 and 2. 

Unit 1 (E1) is a coal-fired boiler, limited to ozone season operation, that must meet performance 

standards for NOx, SO2 and PM by no later than December 15, 2013, as set forth in the ACO 

Amendment dated January 13, 2010.7 See Table 9A for a summary of requirements set forth in 

the ACO Amendment. RC Cape May has indicated that there is some uncertainty regarding the 

commencement date of operation for this boiler. NJDEP has included it at this time presuming 

that the “in operation” date occurred after August 7, 1962. If during the public comment period, 

the date of operation is determined to be outside the BART time frame based on new 

documentation, NJDEP will update its determination before finalizing its BART submittal to 

USEPA Region 2. Whether this unit is BART-qualified or not, the enforceable agreements 

ensure that this unit will meet BART requirements. 

Unit 2 (E2) is a coal-fired boiler that must meet performance standards for SO2 and PM by no 

later than May 1, 2010, and NOx performance standards by May 1, 2012, as set forth in the ACO 

Amendment dated January 13, 2010.8 See Table 10A for a summary of requirements set forth in 

the ACO Amendment. 

Unit 3 boiler (E3) is permitted to burn No. 6 fuel oil, and primarily operates during the ozone 

season as a high electric demand day (HEDD) unit.9

 

 

The coal fuel handling systems (E9 – 20), as applicable, emit particulate emissions only and 

support the coal-fired units (E1 and E2). The conveying systems are covered and the fugitive 

emissions are controlled with wet suppression. The cooling tower (E21) also emits particulates 

only and supports Unit 3 (E3). One other BART-qualified equipment includes an emergency fire 

water pump. See Table 3A below. 

 

7

http://www.epa.gov/compliance/resources/cases/civil/caa/psegfs.pdf 

8

Ibid. 

9

http://www.state.nj.us/dep/aqm/Sub19.pdf 
6

Table 3A List of Equipment, Start-up Date, Potential Emissions, and Eligibility Determination – 

BL England Generating Station 

BL England Generating Station (PI#73242)

Identify emission units Verify dates If yes, compare PTE to 250 tpy cutoff 

Potential to Emit (PTE) 

in tons per year (tpy) 

Equip. 

NJID 

Equipment 

Description 

Start-up 

Date 

8/7/62 – 

8/7/77 

NOx SO2 PM10

BART 

eligible 

E1 Unit 1 boiler 1962 Yes 4,0802 314573 1,198 Yes1

E2 Unit 2 boiler 1964 Yes 5,0224 1,015 9525 Yes1

E3 Unit 3 boiler 1974 Yes 1,506 7,897 2,215 Yes1

E4 Diesel electric 

generator EG1 

E5 Diesel electric 

generator EG2 

E6 Diesel electric 

generator EG3 

E7 Diesel electric 

generator EG4 

1961 No –– –– –– No 

E8 Em. fire water 

diesel engine 

1968 Yes 21.6 1.49 1.53 Yes1

E9 – 

20 

1968 Yes Yes1

E11 1989 

E17 & 

E18 

Coal fuel 

handling 

1995 

No 

N/A N/A 6.16 

No 

E21 Cooling tower 1974 Yes N/A N/A 127.5 Yes1

Visibility Impairing Pollutants NOx SO2 PM10 PTE

Totals (tpy): 10,629 40,370 4,410 > 250 

Notes: 

1

equipment with applicable emissions to be considered cumulatively in determining the facility’s 

BART eligibility 

2

until December 14, 2013; on and after December 15, 2013 NOx (total) shall be 626.3 tons per 

year (85% reduction) 

3

until December 14, 2013; on and after December 15, 2013 SO2 (total) shall be 854.1 tons per 

year (97% reduction) 

4

until April 30, 2012; on and after May 1, 2012 NOx (total) shall be 770.9 tons per year (85% 

reduction) 

5

to be established from stack test results after SCR installation 

6

annual emission limit for E9 – E20 (combined, Unit 7) 
7

1.3 Subject to BART 

Based on the cumulative assessment of all BART-eligible sources in the MANE-VU region, all 

member states with BART-eligible facilities contribute to visibility impairment at Class I areas.10 

Therefore, as a member state of MANE-VU, the State of New Jersey adhered to the MANE-VU 

Board decision that any source that meets the BART eligibility requirements is subject to BART 

review.11 

 

1.4 Evaluation of BART Analyses 

For each qualified emission unit at an eligible facility, BART must be established for pollutants 

reasonably anticipated to impair visibility. NJDEP developed tables summarizing each facility’s 

current compliance requirements, including enforceable consent decree requirements, and recent 

rule development to help determine the best control options, establish emission limits, and set 

compliance deadlines for the BART-qualified emission units.12

 

1.5 Fossil fuel-fire steam Electric Power Plants of more than 250 Million British 

 Thermal Units (BTU) per Hour Heat Input

Power plants are one of 26 specific source categories identified as being applicable to the BART 

requirement. The BART requirement applies to qualified emission units located at Fossil fuelfire steam Electric Power Plants of more than 250 Million British thermal units (BTU) per hour 

heat input that generate electricity for sale. Appendix Y Guidelines for BART require coal-fired 

electric generating units (EGUs) greater than 200 MW located at greater than 750 MW power 

plants meet 0.15 lb/MMBtu emission limit for SO2; and for any size oil-fired units, the sulfur 

fuel content must be limited to 1 percent or less by weight. The BART guidelines also set yearround use of SCR or SNCR as the presumptive BART for NOx for EGUs currently using these 

controls. For oil and gas-fired EGUs current combustion controls should be part of the BART 

determination. 

1.5.1 Power Plants

New Jersey adopted a rule at N.J.A.C. 7:27-27 to control mercury emissions from specific 

sources including coal-fired boilers.13 Compliance with the mercury standard for coal-fired 

boilers was contingent upon the installation and operation of air pollution control systems to 

meet the NOx, SO2, and PM standards shown in Table 4A below by December 15, 2012. Note 

 

10 NESCAUM. Five-Factor Analysis of BART-eligible Sources Survey of Options for Conducting BART 

Determinations. Boston, MA; June 2007. 

11 Ibid. 

12 http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/40cfr51AppY.pdf 

13 http://www.state.nj.us/dep/aqm/Sub27.pdf 
8

that the maximum allowable SO2 and PM emission rates for any size coal-fired boiler are 0.150 

lb/MMBtu based on 30-day rolling average and 0.030 lb/MMBtu based on 3-hour average. 

. 

Table 4A N.J.A.C. 7:27-27.7(b) – Maximum Allowable NOx, SO2 and PM Emission Rates for 

Coal-fired boilers (Operative on and after December 15, 2012) 

Pollutant Emission Limit 

(lb/MMBtu) 

Boiler Type 

NOx 0.100 Dry bottom 

0.130 Wet bottom 

SO2 0.150 

PM 0.030* 

*also found under N.J.A.C 7:27-4.2(c) 

More recently, NJDEP amended N.J.A.C. 7:27-4 Control and Prohibition of Particles from 

Combustion of Fuel on March 20, 2009, to restrict particle emissions from any coal-fired boiler 

with particle control that is constructed, installed or reconstructed as of May 19, 2009, to no 

greater than greater than 0.0150 lbs/MMBtu. 

NJDEP’s NOx rules for boilers serving EGUs were also revised on March 20, 2009. Unless 

subject to more stringent permit limits or otherwise specified in an enforceable agreement, the 

rules require more stringent NOx limits for boilers serving EGUs based on output and measured 

in pounds per megawatt-hour (lbs/MW-hr) beginning May 1, 2015. See Table 5A below. 

Table 5A N.J.A.C. 7:27-19.4 Table 3 – Maximum Allowable NOx Emission Rates for Boilers 

Serving Electric Generating Units (Operative on and after May 1, 2015) 

Fuel Type lbs/MWhr 

Coal 1.50 

Heavier than No. 2 fuel oil 2.00 

No. 2 and lighter fuel oil 1.00 

Gas only 1.00 

Also on March 20, 2009, New Jersey adopted an amendment to its Sulfur in Solid Fuels rule at 

N.J.A.C. 7:27-10.2(h) which specifies that on and after December 15, 2012, the owner or 

operator of any source that combusts solid fuel shall cause it to emit SO2 at a 24-hour emission 

rate no greater than 0.250 lbs/MMBTU gross heat input for every calendar day, and at a 30-

calendar-day rolling average emission rate no greater than 0.150 lbs/MMBTU gross heat input.14

The coal-fired boilers addressed in this document are permitted to combust No.6 fuel oil. In 

2010, NJDEP amended N.J.A.C. 7:27-9, Sulfur in Fuels, to lower the maximum sulfur content 

 

14 http://www.state.nj.us/dep/aqm/Sub10.pdf 
9

standard of all grades of fuel oil in most Zones. VMEU and BL England are located in Zone 1.15 

See Table 6A below. 

Table 6A N.J.A.C. 7:27-9 – Sulfur in Fuels 

Maximum Allowable Sulfur Content Standards – for Zone 1 only from Tables 1A and 1B 

Through 06/30/2014 Effective 07/01/2014 -

06/30/2016 

Fuel Effective 07/01/2016 

grade 

% by wt ppm % by wt ppm % by wt ppm 

No. 2 0.3 3,000 0.05 500 0.015 15 

No. 6 2.0 20,000 0.5 5,000 0.5 5000 

1.5.2 Vineland Municipal Electric Utility (PI#75507) BART Analysis 

Based on the current Title V permit, Unit 10 is a 357 MMBtu/hr boiler that was "in operation" in 

May, 1970. The NJDEP’s mercury rule allows facilities to shut down any coal-fired boiler in 

lieu of meeting the mercury standard. VMEU entered into an enforceable agreement with 

NJDEP to shut down Unit 10 by December 15, 2012. VMEU also agreed in the State’s ACO to 

cease burning coal after December 31, 2010. See Attachment 1. 

Subsequently VMEU entered into an enforceable agreement with the USEPA on March 10, 

2011, to install SNCR on Unit 10, or deactivate no later than September 1, 2012. See 

Attachment 2. VMEU decided to permanently shut down the operation of Unit 10 and on June 

6, 2011, requested that PJM retire this unit from service. See Attachment 3. On July 1, 2011, 

USEPA Region 2 and NJDEP received a written certification of its decision. By July 30, 2011, 

VMEU is required to submit a request to remove Unit 10 from its Title V operating permit 

effective September1, 2012. See Attachments 3 and 4. Note that PJM has requested additional 

information from the facility, and as of July 22, 2011, the facility has yet to submit the permit 

modification request to NJDEP. The requirements of the ACO and CD are summarized in Table 

7A below. 

Table 7A Summary of 2011 Consent Decree (CD)16 and 2007 Administrative Consent Order 

(ACO)17 for Unit 10 – Vineland Municipal Electrical Utility (PI#75507) 

Equip. 

NJID 

Pollutant Control strategy Emission limit Compliance 

date 

E10 NOx Interim: 

LNB & OFA Annual tonnage Effective 

 

15 http://www.state.nj.us/dep/aqm/Sub9.pdf 

16Consent Decree; Civil Action No. 1:11-cv-01826 (RMB-JS); filed 05/02/11, p8 

17 01/24/2006 Administrative Consent Order, p2 (NEA070001) 
10

Equip. 

NJID 

Pollutant Control strategy Emission limit Compliance 

date 

 cap (438 tpy); 

0.28 lb/MMBtu 

30-day avg. 

BOP100003 

Final: 

Install SNCR, or permanently 

cease operation of Unit 10 

 September 1, 

2012 

Interim: 

Cease burning coal –– Effective 

BOP100003 

SO2

Use low sulfur No. 6 fuel oil – 

0.7% by wt. 

Annual tonnage 

cap (1,718 tpy); 

392.3 lb/hr 

Effective 

BOP080001 

NJDEP has determined that once shut down, VMEU no longer qualifies as a BART-eligible 

source. Receipt of the modification request to delete Unit 10 from the Title V operating permit is 

required no later than July 30, 2011. 

1.5.3 BL England Generating Station (PI#12202) BART Analysis 

 

BL England Generating Station is a 449 MW electric utility steam generating plant with three 

boilers serving electric generating units (EGUs) that are subject to BART review. E1 and E2 are 

coal-fired and subject to controls and enforceable emission limits due to an Administrative 

Consent Order (ACO) and supplemental Amendments. E3 combusts No.6 fuel oil. 

Unit 1 is limited to blended coal including bituminous and low sulfur coal and supplemented 

with up to 8% tire derived fuel (TDF), or No. 6 fuel oil. The unit’s coal authorization plan was 

extended by the ACO until December 14, 2013, when it is required to meet more stringent short 

term SO2 standards as part of the agreement. OFA, SNCR, and ESP provide continuous air 

pollution control of NOx, SO2 and PM emissions. SCR and scrubber will be installed by 

December 15, 2013. Operation of SNCR after installation of the SCR is optional. 

Unit 2 is limited to blended coal including bituminous and low sulfur coal and supplemented 

with up to 8% tire derived fuel (TDF), or No. 6 fuel oil. NOx, SO2 and PM emissions from this 

boiler are continuously controlled with OFA, SNCR, wet FGD scrubber, and ESP. SCR will be 

installed by May 1, 2012. Operation of SNCR after installation of the SCR is optional. 

 

Unit 3 boiler combusts No. 6 fuel oil and is permitted to use No. 2 fuel oil for start-up. NOx and 

PM emissions from this boiler are continuously controlled with SNCR and a mechanical cyclone, 

respectively. 
11

The coal fuel handling systems (E9, E10, E12, E13, E14, E15, E16, E19, and E20) are support 

systems to the coal-fired boilers (E1 and E2). The unloading, processing, and transferring 

systems are covered, and fugitive particulate emissions are controlled with surfactant-based wet 

suppression as required by the Title V permit. The cooling tower (E21) supports Unit 3 boiler 

(E3) and has the potential to emit particulate emissions only. The natural draft cooling tower 

(E21) circulates treated sea water in a closed loop system and is equipped with high efficiency 

drift eliminators, which is BART for cooling towers. These pieces of equipment, E9 – 20, as 

applicable, and E21, are either de minimis or have BART control. See Table 8A for a summary 

of current compliance requirements. 
Table 8A Summary of Current Title V Permit Conditions for BART Qualified Equipment (BOP100003) – BL E

Heat Input NOx SO2 P

Allowable emission limit 

Allowable emission limit 

Equip. NJID 

Equipment Description 

(MMBtu/hr)

Fuel type Existing 

Control 

(lb/hr) 

Existing Control 

(lb/hr) 

Existing Control 

1. E1 U1 boiler 

(129 MW) 

1300 Coal 

w/ up to 8% TDF*or #6FO 

SNCR& OFA 

780 For coal: 0.60 lb/MMBtu calendar day avg. (5/1-9/30) 0.60 lb/MMBtu 30-day rolling avg.(10/1-4/30) For oil: 0.43 lb/MMBtu calendar day avg. (5/1-9/30); 0.43 lb/MMBtu 30-day rolling avg.(10/1-4/30) 

Low sulfur coal plan 1.9% monthly; 1.7% 12-month; Low sulfur fuel oil 1% by wt

7,182 ESP 
Heat Input NOx SO2 P

Allowable emission limit 

Allowable emission limit 

Equip. NJID 

Equipment Description 

(MMBtu/hr)

Fuel type Existing 

Control 

(lb/hr) 

Existing Control 

(lb/hr) 

Existing Control 

See note. 0.110 

lb/MMBtu 30-day roll avg.& 0.150 lb/MMBtu 24-hr avg. (effective 12/15/13) 

See note. 0.150 

lb/MMBtu 

(30-day roll. avg.); 0.250 lb/MMBtu 24-hr avg. (effective 12/15/13) 

See note. 

2. E2 U2 boiler 

(160 MW) 

1600 Coal 

w/ up to 8% TDF* and/or #6 FO

SNCR& OFA 

960 For coal: 0.60 lb/MMBtu calendar day avg. (5/1-9/30) 0.60 lb/MMBtu 30-day rolling avg.(10/1-4/30) For oil: 0.43 lb/MMBtu calendar 

FGD wet scrubber & sorbent injection; Low sulfur fuel oil 1% by wt

1,336 0.150 lb/MMBtu (30-day roll. avg.); 0.250 lb/MMBtu 24-hr avg. (effective 05/01/10) 

ESP (updated to meet ACO standard); ESP need not be energized during 

18 Administrative Consent Order Amendment, certified 01/13/2010, p6; and 01/24/2006 Administrative Consent Order 19 Ibid. 
Heat Input NOx SO2 P

Allowable emission limit 

Allowable emission limit 

Equip. NJID 

Equipment Description 

(MMBtu/hr)

Fuel type Existing 

Control 

(lb/hr) 

Existing Control 

(lb/hr) 

Existing Control 

day avg. (5/1 -9/30) 0.43 lb/MMBtu 30-day rolling avg.(10/1-4/30) 

OFA & install SCR by 05/01/12 

0.110 lb/MMBtu 30-day roll avg.& 0.150 lb/MMBtu 24-hr avg. (effective 12/15/12) 

No.6 oil operation 

3. E3 U3 boiler 

(160 MW) 

1720 #6FO 

& #2FO for S/U 

SNCR (year round) 

344 0.2 lb/MMBtu 

Low sulfur fuel oil 1% by wt

1803 Cyclone 

4. E8 U6 emergency 

fire water pump engine 

1.12 diesel None 4.94 0.3% S 

by wt 

0.43 None 
Heat Input NOx SO2 P

Allowable emission limit 

Allowable emission limit 

Equip. NJID 

Equipment Description 

(MMBtu/hr)

Fuel type Existing 

Control 

(lb/hr) 

Existing Control 

(lb/hr) 

Existing Control 

5. E9 E10 E12 E13 E14 E15 E16 E19 E20 

U7 Coal and tire-derived fuel handling 

N/A N/A N/A N/A All 

operations covered; All wet spray dust suppressoused for fugitive dust except E15, E19 and E20 

6. E21 U8 Unit 3 

Cooling tower 

N/A N/A N/A N/A High eff. 

drift eliminator 

 Note: a new SCR and scrubber, as well as an ESP upgrade, will be required to meet ACO Performance Standards on U1  * tire derived fuel (TDF)  ** “Repower” means the replacement of an existing coal-fired boiler with a new heat source (e.g. natural gas or 

 combustion technology (e.g. circulating fluidized bed boilers or integrated gasification combined-cycle (IGC

 01/24/2006 Administrative Consent Order. 

*** De minimis (D) – potential to emit below de minimis level (less than 0.05 pounds per hour)
16

Unit 1 Boiler (E1):

Unit 1 is a 1300 MM/Btu Babcock and Wilcox, cyclone-fired, wet bottom boiler with a rating of 

129 MW. According to the ACO amendment, Unit 1 must repower by December 15, 2011, or 

meet performance standards by December 15, 2013 as shown in Table 9A. If Unit 1 does not 

meet the emission rates by December 15, 2013, Unit 1 may not restart unless RC Cape May 

obtains a permit modification which incorporates advances in the art of air pollution control 

according to N.J.A.C. 7:27-22.35. If RC Cape May decides to repower, it must incorporate 

advances in the art of air pollution control which may result in more stringent emission limits. 

Before repowering, or installing new controls, RC Cape May will optimize the existing NOx

control to minimize NOx emissions in the interim. 

 

Table 9A Summary of 2010 Amendment to 2006 Administrative Consent Order20 for Unit 1 – 

BL England (PI#73242) 

Equip. 

NJID 

Pollutant Control strategy Emission limit Compliance 

date 

Interim: 

SNCR & OFA 4,080.7 tpy 

0.60 lb/MMBtu 

calendar day avg. 

(5/1 -9/30) 

0.60 lb/MMBtu 

30-day rolling 

avg. (10/1-4/30) 

Effective until 

12/14/13 

BOP100003 

Final: 

NOx

Install SCR* (use of SNCR is 

optional after installation and 

operation of SCR) & OFA 

626.3 tpy 

0.110* 

lb/MMBtu 

30-day rolling 

avg. 

0.150 lb/MMBtu 

24-hr avg. 

Effective from 

12/15/13 

BOP100003 

Interim: 

Reauthorized low sulfur coal 

plan 

31,457 tpy 

7,182 lbs/hr and 

1852 ppmvd 

Effective until 

12/14/13 

BOP100003 

Final: 

E1 

SO2

Install scrubber. 854.1 tpy 

0.150 

lbs/MMBtu 

Effective from 

12/15/13 

BOP100003 

 

20Administrative Consent Order Amendment, certified 01/13/2010, p6; and 01/24/2006 Administrative Consent 

Order, p37 

 
17

Equip. 

NJID 

Pollutant Control strategy Emission limit Compliance 

date 

30-day rolling 

avg. 

0.250 

lbs/MMBtu 

24-hr avg. 

Interim: 

ESP 569.4 tpy 

0.150 

lbs/MMBtu 

Effective until 

12/14/13 

BOP100003 

Final: 

PM 

ESP update 170.8 tpy 

0.030 

lbs/MMBtu 

3-hr avg. 

Effective from 

12/15/13 

BOP100003 

Other Repower by 12/15/11, or meet NOx, SO2 and PM performance 

standards by 12/15/2013 

Note: a new SCR and scrubber, as well as an ESP upgrade, will be required to meet ACO Performance 

Standards on U1

Unit 2 Boiler (E2):

Unit 2 is a 1600 MM/Btu Babcock and Wilcox, cyclone-fired, wet bottom boiler with a rating of 

160 MW. According to the ACO amendment, Unit 2 must repower by December 15, 2011, or 

meet performance standards for SO2 and PM by no later than May 1, 2010 (completed), and NOx

performance standards by May 1, 2012. Before installing and operating the new SCR, RC Cape 

May will optimize the existing NOx control to minimize NOx emissions in the interim. See 

Table 10A. 

Table 10A Summary of 2010 Amendment to 2006 Administrative Consent Order21 for Unit 2 – 

BL England (PI#73242) 

Equip. 

NJID 

Pollutant Control strategy Emission limit Compliance 

date 

E2 NOx Interim: 

SNCR& OFA 5,022.4 tpy 

0.60 lb/MMBtu 

calendar day avg. 

(5/1 -9/30) 

Effective until 

04/30/12 

BOP100003 

 

21Administrative Consent Order Amendment, certified 01/13/2010, p6; and 01/24/2006 Administrative Consent 

Order 

 
18

Equip. 

NJID 

Pollutant Control strategy Emission limit Compliance 

date 

0.60 lb/MMBtu 

30-day rolling 

avg. (10/1-4/30) 

Final: 

Install SCR* (use of SNCR is 

optional after installation and 

operation of SNCR) & OFA 

770.9 tpy 

0.110 lb/MMBtu 

30-day rolling 

avg. 

0.150 

lbs/MMBtu 

24-hr avg. 

Effective from 

05/01/12 

BOP100003 

SO2 Final: 

FGD wet scrubber & sorbent 

injection 

1051.2 tpy 

0.150 

lbs/MMBtu 

30-day rolling 

avg. 

0.250 

lbs/MMBtu 

24-hr avg 

Effective 

05/01/10 

BOP080001 

PM Final: 

ESP update 210.2 tpy 

0.030 

lbs/MMBtu 

3-hr avg. 

Effective 

05/01/10 

BOP080001 

Other Repower by 12/15/11, or meet NOx performance standards by 

05/01/12 

Unit 3 Boiler (E3):

 

Unit 3 is a 1720 MMBtu/hr Combustion Engineering, oil-fired, tangential boiler with a rating of 

160 MW. This unit typically operates as a HEDD unit during hot summer days. Table 11A 

below shows the hours of operation reported to NJDEP in its electronic emission statements. 

The declining use of No. 6 fuel oil is a general trend in the power industry. 

Table 11A Reported Operating Time of Unit No. 3 Firing No. 6 Fuel Oil 

U3, OS1 – Utility boiler firing No. 6 fuel oil 

Emission 

Year 

Operating time 

(hours) 

Emission 

Year 

Operating time 

(hours) 

1999 2,777 2005 1,462 

2000 1,854 2006 881 

2001 2,045 2007 1,102 
19

U3, OS1 – Utility boiler firing No. 6 fuel oil 

Emission 

Year 

Operating time 

(hours) 

Emission 

Year 

Operating time 

(hours) 

2002 2,039 2008 373 

2003 2,452 2009 172 

2004 901 2010 159

 

On May1, 2015, Unit 3 is required to meet an efficiency-based NOx emission limit of 2.00 

lb/MW-hr that is approximately equivalent to the current input-based emission limit of 0.2 

lb/MMBtu in the Title V permit. Additionally, effective 07/01/2014, the sulfur in fuel content of 

No. 6 fuel oil will decrease, from the permitted 0.7% by wt, to an allowable 0.5% pursuant to 

N.J.A.C. 7:27-9.2. 

1.7 Final BART Requirements 

Under the Regional Haze rule, States must identify the best system of continuous emission 

control technology for each eligible source that is subject to BART. After a State has identified 

the level of control representing BART, it must establish an emission limit representing BART 

and must ensure compliance with that requirement no later than five years after the USEPA 

Region 2 approves the State Implementation Plan. The BART requirements must be included as 

operating permit conditions according to the procedures established in 40 CFR part 70, and the 

State regulations promulgated at N.J.A.C. 7:27-22. 

With the anticipated shutdown of Unit 10 at VMEU by September 1, 2012, the cumulative PTE 

from qualified equipment is well below the emissions threshold for BART eligibility, and not 

subject to further BART review. BL England has two coal units which are subject to an 

enforcement agreement to install modern air pollution control by the end of 2012 and 2013; and 

an oil-fired boiler. RC Cape May, owner/operator of this power plant, has indicated it is 

evaluating the conversion of all three electric steam generating units to natural gas or No. 2 fuel 

oil. To the extent that RC Cape May decides to convert one or all of the units, NJDEP 

anticipates that RC Cape May would submit a specific proposal that addresses applicable 

requirements including BART. 

Vineland Municipal Electric Utility: 

On May 20, 2011, the USEPA entered into a CD with VMEU. As a result of its decision not to 

install SNCR on Unit 10, VMEU is required to submit a modification to NJDEP by July 30, 

2011, requesting the deletion of Unit 10 boiler from its Title V operating permit effective 

September 1, 2012. NJDEP anticipates a timely permit modification submittal from VMEU to 

incorporate the effective shutdown date for Unit10 boiler. 
20

BL England: 

BL England currently has three boilers serving electric generating units (E1, E2 and E3), a fire 

pump engine, coal fuel handling systems (E9, E10, E12, E13, E14, E15, E16, E19, and E20) and 

a cooling tower that are subject to BART review. The fuel handling systems support the coalfired boilers (E1 and E2). All of the fuel unloading, processing, and transferring operations are 

covered, and, with the exception of E15, E19 and E20, fugitive particulate emissions are 

controlled with surfactant-based wet suppression as required by the Title V permit. The cooling 

tower (E21) supports the Unit 3 boiler (E3) with the potential to emit particulate emissions only. 

According to the Title V permit requirements, the salt water tower has drift eliminators to control 

salt water drift. NJDEP has determined that the existing particulate controls are BART for the 

fuel handling systems and the cooling tower. 

On January 13, 2010, the NJDEP entered into an ACO Amendment with RC Cape May. NJDEP 

has determined that the NOx, SO2, and PM controls, emission limits, averaging times, and 

compliance dates from the ACO for the process are BART for E1 & E2. The ACO Amendment 

requirements for E1 and E2, are already included in the current approved Title V operating 

permit, BOP100003. 

NJDEP has determined that the existing SNCR and mechanical cyclone air pollution control 

systems for oxides of nitrogen (NOx), and particulate matter (PM), respectively, for E3, are 

BART and are included as applicable requirements in the current approved Title V operating 

permit, BOP100003. Beginning May 1, 2015, Unit 3 is subject to N.J.A.C. 7:27-19.4 Table 3 

that restricts the maximum allowable NOx emission rate to no greater than 2.00 lbs/MW-hr. In 

addition, a more stringent sulfur content of 0.5% by wt. for No. 6 fuel oil is effective on July 1, 

2014, pursuant to NJDEP’s sulfur in fuel rule at N.J.A.C.7:27-9.2. 

 

 
21

 

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