1 New York State Department of Environmental Conservation
Best Available Retrofit Technology Determination

Facility Syracuse Energy Corporation

Location Geddes, NY Onondaga County

Permit ID 7-3132-00052

Source Category Fossil-fuel fired steam electric plant 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.

Emission sources that are deemed eligible by the above criteria may be exempted by the BART analysis through severa l means, as follows:

1. A permit condition may be accepted which restrict s the eligible source’s potential to emit to less than 250 tons per year for each vi sibility-impairing pollutant, as per Part 249.1(c)(1).
2. A permit condition may be accepted that requires the source to permanently shut down the unit by January 1, 2014, as per Part 249.1(c)(2).
3. The facility may show through modeling or other means acceptable to the Department that it does not or will not emit any combina tion of visibility-impairing pollutants that results in a visibility impairment equal to or greater than 0.1 deciviews in any federal Class I area, as per Part 249.1(c)(3).

II. Proposed BART Compliance Method

The Syracuse Energy Corporation facility contai ns one eligible unit (“Unit 1”) which is a pulverized coal-fired boiler of greater than 250 mmBtu per hour heat input. Syracuse Energy submitted a letter, dated September 22, 2010, to the Department regarding the BART eligibility
of Unit 1. This letter declared their intention to either accept NESCAUM/Department visibility modeling results if they showed an insignifican t impact as per 249.1(c)(2), or otherwise shut down the boiler to comply under Part 249.1(c)(3).2 In early 2010, the Department requested emissions da ta from BART-eligible facilities in order to update earlier NESCAUM modeling results whic h did not completely adhere to EPA and Department modeling protocol. Syracuse Energy submitted the requested data, but a lack of NESCAUM information on this unit prevented the Department from doing a direct scaling of visibility impacts. It was, however, possible to approximate this unit’s impact by comparing
emissions to other facilities in the central New York region for which visibility impacts were known. These results indicated that the visibility impairment resulting from this unit’s emissions
would exceed the 0.1 deciview contribution thres hold set by the Department for being “subject” to BART. Syracuse Energy declined the option to conduct more refined visibility modeling of
its own.

III. BART Determination

Because the available data cannot conclusively pl ace the visibility impacts of Unit 1 below the 0.1 deciview exemption threshold, the Department is accepting Syracuse Energy’s decision to shut down this unit by January 1, 2014, in compliance with Part 249.1(c)(2). The Department formalized this requirement in a Title V pe rmit modification, which was issued on May 24, 2012. This modified permit is being submitted to EPA as a revision to the New York Regional Haze State Implementation Plan.