# Five-Factor Analysis of BARTEligible Sources

Survey of Options for Conducting BART

Determinations

Prepared by NESCAUM for the Mid-Atlantic/Northeast Visibility Union (MANE-VU) R egional Planning Organization



## June 1, 2007

### Members of Northeast States for Coordinated Air Use Management

Anne Gobin, Acting Bureau Chief Connecticut Department of Environmental Protection, Bureau of Air Management

James P. Brooks, Bureau Director Maine Department of Environmental Protection, Burea u of Air Quality

Barbara Kwetz, Director Massachusetts Department of Environmental Protectio n, Bureau of Waste Prevention

Robert Scott, Director New Hampshire Department of Environmental Services, Air Resources Division

William O’Sullivan, Director New Jersey Department of Environmental Protection, Office of Air Quality Management

David Shaw, Director N e w Y o r k D e p a r t m e n t o f E n v i r on m e n t a l C o n s e r v a t i o n , D i v i s i o n o f A i r R e s o u r c e s

Stephen Majkut, Chief Rhode Island Department of Environmental Management , Office of Air Resources

Richard A. Valentinetti, Director Vermont Department of Environmental Conservation, A ir Pollution Control Division

Arthur Marin, Executive Director Northeast States for Coordinated Air Use Managementii

# Five-Factor Analysis of BARTEligible Sources

Survey of Options for Conducting BART

Determinations

Prepared by NESCAUM for the Mid-Atlantic/Northeast Visibility Union (MANE-VU) R egional Planning Organization



## June 1, 2007iii



# FIVE-FACTOR ANALYISIS OF BARTELIGIBLE SOURCES Survey of Options for Conducting BART Determination s

Project Manager

Gary Kleiman, NESCAUM

Principal Contributors

Iyad Kheirbek and Gary Kleiman, NESCAUMiv



## Acknowledgements

NESCAUM acknowledges the support of its member agen cies and the staff time that they dedicated in providing survey information on the ty pes and level of control available for various source categories subject to the BART requi rements of the Regional Haze Rule. Their insight has allowed NESCAUM to create what it hopes will be a valuable guide for all members of MANE-VU as they proceed to conduct s ource-specific BART determinations. NESCAUM also acknowledges the fund ing for this work through U.S. EPA agreement number XA-97318101-0 to the Ozone Transport Commission in support of the MANE-VU Regional Planning Organization. NES CAUM is solely responsible for the content of this report and any errors it may co ntain.

Printed: July 2007v TABLE OF CONTENTS

Acknowledgements...................................

................................................... ...................... iv Executive Summary..................................

................................................... ..................... vii 1. Introduction....................................

................................................... .......................... 8 1.1. The BART Rule .................................

................................................... .............. 8 1.2. Overview of State BART Requirements........... .................................................. 9 1.3. Overview of Report............................

................................................... ............ 10 2. Determining BART-Eligible Sources...............

................................................... ..... 11 3. MANE-VU Approach to “Subject to BART” ........... ............................................... 11 4. Regional Five Factor Analysis...................

................................................... ............ 11 4.1. The Degree of Visibility Improvement That May Reasonably be Anticipated from the Use of BART...............................

................................................... ................ 11 4.2. Cost and Availability of Controls and Controls Already in Place .................... 15 4.2.1. Chemical Manufacturers......................

................................................... .. 19 4.2.2. Glass Fiber .................................

................................................... ............ 19 4.2.3. Coal Cleaning...............................

................................................... .......... 19 4.2.4. Electric Generation Units...................

................................................... .... 19 Coal-Fired Units...................................

................................................... .............. 19 Oil-Fired Units....................................

................................................... ............... 20 4.2.5. Incinerators ................................

................................................... ............ 20 4.2.6. Metal Production............................

................................................... ........ 21 4.2.7. Paper and Pulp ..............................

................................................... ......... 21 4.2.8. Portland Cement Plants......................

................................................... .... 21 4.2.9. Refineries ..................................

................................................... ............. 22 4.3. Energy and Non-Air Quality Environmental Impac ts ...................................... 22 4.4. Remaining Useful Life.........................

................................................... .......... 24 5. Conclusions.....................................

................................................... ....................... 24 6. References......................................

................................................... ........................ 26 Appendix A: List of BART-Eligible Sources in the MA NE-VU Region ........................ 27 Appendix B: Costs of Technologies ..................

................................................... ............ 32 Appendix C: BART Workgroup Draft Recommendations... ............................................ 34vi FIGURES Figure 4-1. Reduction potential of BART control op tions at EGUs and Paper and Pulp Sources ............................................

................................................... .................... 23 Figure 4-2. Reduction potential of BART control op tions at Cement Plants .................. 24

TABLES Table 4-1. Types of BART-eligible sources modeled in the region................................ 12 Table 4-2. Types of sources in MANE-VU region with greater than 0.1 dv impact at any Class I area (non year-round CAIR states). ......... .................................................. 1 4 Table 4-3. Possible range of SO 2 controls and costs based on survey of state staff. ....... 16 Table 4-4. Possible range of NO X controls and costs based on survey of state staff. ...... 17 Table 4-5. Possible range of PM 10 controls and costs based on survey of state staff. ..... 18vii



## Executive Summary

The 1999 U.S. Environmental Protection Agency (USEP A) “Regional Haze Rule” [64 Fed. Reg. 35714 (July 1, 1999)] requires certain em ission sources that “may reasonably be anticipated to cause or contribute” to visibilit y impairment in downwind Class I areas to install Best Available Retrofit Technology (BART ). These requirements are intended to reduce emissions specifically from large sources that, due to age, were exempted from other control requirements of the Clean Air Act. States are required to undertake three key steps to comply with the BART requirements of the Regional Haze Rule. These steps include:

• Determining if a source is BART-eligible;

• Determining if a source reasonably causes or contri butes to visibility impairment in any Class I area (subject to BART);

• Determining if additional controls or emission limi ts are necessary (BART determination). This report is intended to summarize one approach t o satisfy the BART requirements of the Regional Haze Rule that member states may consider. We also review BART-eligible sources in the MANE-VU region and provide – on a regional basis – an analysis of the general applicability of the f ive statutory factors that states must consider in determining BART controls for various s ource categories subject to BART. This analysis will allow MANE-VU states to place th eir source-specific BART determinations into the regional context of similar sources within MANE-VU. This review includes an examination of individual units’ impacts on visibility at Class I areas based on CALPUFF modeling and an evaluation of exis ting or potential controls and feasibility of these controls relative to the statu tory factors identified in the BART rule. Ultimately, the strength of the MANE-VU BART progra m, as determined by individual state control decisions and informed by this analysis, will demonstrate MANEVU’s resolve to tackle visibility and related air q uality problems in its region. As MANE-VU enters into consultations with other region al planning organizations (RPOs), its willingness to seek reasonable emission reducti ons within its own region will help set expectations for the other RPOs, and the BART progr am represents a cornerstone of this
process.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 8



## 1. INTRODUCTION
The 1999 U.S. Environmental Protection Agency (USEP A) “Regional Haze Rule” [64 Fed. Reg. 35714 (July 1, 1999)] requires certain emission sources that “may reasonably be anticipated to cause or contribute” t o visibility impairment in downwind Class I areas to install Best Available Retrofit Te chnology (BART). 1 These requirements are intended to reduce emissions specifically from large sources that, due to age, were exempted from new source performance standards (NSP S) requirements of the Clean Air Act. BART requirements pertain to 26 specified major poi nt source categories, including power plants, industrial boilers, paper a nd pulp plants, cement kilns, and other large stationary sources. To be considered BART-eli gible, sources from these specified categories must have the potential to emit at least 250 tons per year of any haze forming pollutant and must have commenced operation or come into existence in the 15 year period prior to August 7, 1977 (the date of passage of the 1977 Clean Air Act Amendments, which first required new source perform ance standards). Because of the regional focus of the 1999 haze rule , it is likely that BART requirements will be applied to a much larger numbe r of sources across a broader geographic region than has been the case historical ly (i.e., through reasonably attributable visibility impairment requirements in the 1980 haze regulations). In addition, USEPA has for the first time introduced the possibility that source-by-source, command and control type BART implementation may be replaced by more fl exible state initiatives (e.g. market-based approaches), provided such alternative s can be shown to achieve greater progress toward visibility objectives than the sour ce by source BART approach.



### 1.1. The BART Rule In June 2001, EPA released proposed guidelines on B ART. This guidance outlined the method for determining if a facility h as a BART-elgible source, if a source is subject to BART provisions, and methods for conduct ing a BART control review for such sources. In 2002, industry groups challenged the method EPA outlined in the Regional Haze Rule to determine the degree of visibility imp rovement resulting from application of BART controls. Under EPA’s interpretation of th e statute, a state would deem sources subject to BART if they emitted into a geographic a rea or region from which pollutants are likely transported downwind into a protected ar ea. In May 2002, the D.C. Circuit Court of Appeals agreed with industry petitioners t hat this interpretation impermissibly constrained the authority of any state that wanted to provide an exemption mechanism from BART requirements. The Court vacated those po rtions of the Regional Haze Rule dealing with BART.

1 There are seven designated Class I areas in the No rtheast and Mid-Atlantic States. They include Acadi a National Park and Moosehorn Wilderness Area in Main e; Roosevelt Campobello International Park in New Brunswick and Maine; the Lye Brook Wilderness Area in Vermont; the Great Gulf and Presidential RangeDry River Wilderness Areas in New Hampshire; and th e Brigantine Wilderness Area in New Jersey.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 9

In June 2005, EPA released the final BART guideline s that also addressed the remanded portions of the Regional Haze Rule dealing with BAR T. Under the final rule, the BART program requires states to develop an inventory of sources within each state or tribal jurisdiction that could be subject to control. Spe cifically, the rule:

• Outlined methods to determine if a source is “reaso nably anticipated to cause or contribute to haze;”

• Defined the methodology for conducting a BART contr ol analysis;

• Provided presumptive control limits for electricity generating units (EGUs) larger than 750 Megawatts;

• Provided a justification for the use of the Clean A ir Interstate Rule (CAIR) as BART for CAIR state EGUs.

Beyond the specific elements listed above, EPA prov ided the states with a great degree of flexibility in how they choose to impleme nt the BART program. The following section summarizes the core requirements for state compliance with BART regulations.



### 1.2. Overview of State BART Requirements

As finally promulgated, States are required to unde rtake three key steps to comply with the BART requirements of the Regional Haze Rule. Th ese steps include:

• Determining if a source is BART-eligible;

• Determining if a source reasonably causes or contri butes to visibility impairment in any Class I area (subject to BART);

• Determining if additional controls or emission limi ts are necessary (BART determination).

As stated earlier, eligibility is limited to source s in one of 26 source categories that have units installed and operating between 196 2 and 1977 with the potential to emit more than 250 tons per year of a visibility impairi ng pollutant. Once a source is found to be “eligible” for the BART program, states must det ermine if that source is “subject to BART,” that is, if it causes haze or contributes to the formation of haze at any Class I area. EPA’s 2005 rule outlines three options to det ermine if a source is subject to BART. These options include:

• Individual source assessment (Exemption Modeling) – This assessment uses CALPUFF or other EPA approved modeling methods. Re sults of modeling would be compared to natural background conditions. EPA defined “cause” as an impact of 1.0 deciview or more and “contribute” as an impact of 0.5 deciview or

more. 2 The rule, however, gave states discretion to set l ower thresholds for contribution.

2 Impacts are based on the difference in deciviews ( delta deciview) calculated between the best twenty percent natural visibility conditions (states have the option to use annual average conditions as an alternative) at a Class I site with and without ind ividual source contributions included.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 10

• Cumulative assessment of all BART "eligible sources ” – Under this method, a state can choose to find that all eligible sources within a geographic area or region are subject to BART. This method could also be use d to analyze an area’s contribution to visibility impairment and demonstra te that no sources are subject, based on cumulative modeling.

• Assessment based on model plants – This method provides a mechanism to exempt sources with common characteristics that are found not to impair visibility at Class I areas.

Once a source has been identified as BART-eligible and “subject” to BART, it must conduct an engineering review to determine if the i nstallation of new control requirements is appropriate. 3 This review takes into consideration five factors :

• Cost of controls

• Energy and non-air quality environmental impacts

• Existing controls at source

• Remaining useful life of source

• Visibility improvement reasonably expected from app lication of the controls.



### 1.3. Overview of Report This report is intended to summarize an approach to satisfy the BART requirements of the Regional Haze Rule based on the “cumulative assessment of contribution” option for determining if eligible so urces are subject to BART. We also review BART-eligible sources in the MANE-VU region and provide – on a regional basis – an analysis of the general applicability of the f ive factors for various source categories subject to BART. This analysis should not be viewe d as preventing states from exercising their flexibility in structuring their o wn approach to BART or in applying the five factors to that approach. Rather, this analysi s will allow MANE-VU states to place their source-specific BART determinations into the regional context of similar sources within MANE-VU. This review includes an examination of individual units’ impacts on visibility at Class I areas, based on CALPUFF model ing and an evaluation of existing or potential controls and feasibility of these control s relative to the statutory factors identified in the BART rule 4

. To that end, Section 2 of this report first develop s a list of all BART-eligible sources in the MANE-VU region. Section 3 provides an overview of the region’s approach to determining BART eligibility. Finally, Section 4 presents observations on the regional and sectoral differences among control options and the applicability of the five-factor analysis.

3 A possible exception to this requirement would exi st in the case where a state has adopted a “better than BART” alternative program that would take the place of a source-specific BART determination. The RPO is not aware of any MANE-VU states that are adoptin g such programs at this time.
4 Throughout this report we refer to the collection of sources at a stationary facility potentially sub ject to BART as a “BART-eligible source.” Individual emitt ing units at these BART-eligible sources will be referred to as “units” when emissions are modeled a nd descriptions of possible control strategies are offered.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 11



## 2. DETERMINING BART-ELIGIBLE SOURCES
To assist MANE-VU states and tribes with BART impl ementation efforts, MANE-VU developed a list of BART-eligible sources i n the region (NESCAUM, 2001; NESCAUM, 2003). Since then, the preliminary list developed in these documents was refined through consultation with state permitting staff to verify completeness and accuracy of the list. Emissions of SO 2 , NO X , and PM 10 as well as stack information were compiled through either consultation with state per mitting staff or the 2002 MANE-VU emissions inventory. The final list of sources (as well as associated 2002 emissions and stack parameters) was developed in consultation wit h state staffs (see Appendix A for a complete list of BART-eligible sources and units in the MANE-VU region).



## 3. MANE-VU APPROACH TO “SUBJECT TO BART”
Based on the MANE-VU contribution assessment (NESCA UM, 2006b), every MANE-VU state with BART-eligible sources contribute s to visibility impairment at a Class I area to a significant degree. Therefore, M ANE-VU staff continues to support the policy decision made by the MANE-VU Board in June 2 004, that if a source is eligible for BART, it is subject to BART . (i.e., no exemption test will be used). The rea sons why MANE-VU has chosen to pursue this option for demons trating its sources are reasonably anticipated to cause or contribute to visibility im pairment at Class I areas are threefold: (1) the BART sources represent an opportunity to ac hieve greater reasonable progress, (2) additional public health and welfare benefits w ill accrue from resulting decreases in fine particulate matter, and (3) to demonstrate its commitment to federal land managers (FLMs) and other RPOs as it seeks emissions reducti ons wherever it is reasonable to do

so. This recommendation is not equivalent, however, to the statement that every BART-eligible source must install controls. The ap proach presented for MANE-VU state consideration – starting with this document and con tinuing with their own source specific analyses – requires the consideration of each of th e five factors required by statute before determining whether or not controls are warranted.



## 4. REGIONAL FIVE FACTOR ANALYSIS

4.1. The Degree of Visibility Improvement That May Reaso nably be Anticipated from the Use of BART BART emission limits must be determined subject to an evaluation of the five statutory factors. These factors include:

(a) the costs of compliance, (b) the energy and non-air quality environmental im pacts of compliance, (c) any existing pollution control technology in us e at the source, (d) the remaining useful life of the source, andDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 12

(e) the degree of visibility improvement which may reasonably be anticipated from the use of BART. To begin its regional analysis of these factors, MA NE-VU staff first considered the degree of visibility improvement that could res ult from the installation of BART controls. This is slightly different than the stat utory language and is meant to reflect our first-order approach to estimating the maximum visi bility benefit that could be achieved by eliminating all emissions from the source. Whil e this is not a realistic approach to fully satisfying the intent of factor (e) above, it does provide the states a useful metric for determining which sources are unlikely to warrant B ART controls based on consideration of this factor. This analysis was achieved by first modeling 2002 e missions of SO 2 , NO X , and PM 10 from all BART-eligible units in the region. 5 A total of 136 BART-eligible sources were identified in the MANE-VU region and modeled o n the two CALPUFF platforms. Table 4-1 displays the types and numbers of sources modeled in the region.

Table 4-1. Types of BART-eligible sources modeled in the region

Source Type Number of Sources Number of Units/MM5* Number of Units/NWS
Chemical Manufacturer 12 48 107 Chemical Plant 1 4 18 Coal Cleaning 1 1 1 EGU 59 139 296 Glass Fiber 3 14 33 Incinerator 1 2 2 Industrial Boilers 2 6 8 Lime Plant 2 4 14 Metal Production 13 64 140 Mineral Products 1 4 13 Paper and Pulp 14 39 63 Petroleum Storage 4 6 10 Portland Cement 13 49 228 Refinery 9 70 497 Total 136 455 1449 * Units with very small emissions were grouped togeth er and modeled as one stack for the MM5-based CALPUFF runs.

The two CALPUFF modeling platforms are described in greater detail elsewhere (NESCAUM, 2006b) and are driven by two respective m eteorological datasets: 1) a wind field based on National Weather Service (NWS) observations and 2) a wind field based on output from the MM5 meteorological model ( MM5, 2006). Environmental Resources Management (ERM) developed CALMET-process ed meteorology on a large domain (extending from Oklahoma City, OK up to Prin ce Edward Island, Canada). The CALMET meteorology was processed directly from the MM5 model output developed

5 Emissions information was gathered from the MANE-V U 2002 Version 2 (Base A) emissions inventory. Since then, the MANE-VU 2002 Version 3 (Base B) emi ssions inventory has been developed which includes several changes made by the OTC modeling c ommittee.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 13

on a 12-km horizontal grid by the University of Mar yland for the OTC modeling committee and MANE-VU. The Vermont Department of Environmental Conservation (VT DEC) developed CALMET meteorology (for the iden tical domain) driven by the NWS’s surface observation network, rawinsonde netwo rk, and supplemented by the Airport Surface Observation System (ASOS) network. This observation-based dataset provides an alternative to the gridded wind fields generated by the diagnostic model MM5. Modeling results from both NWS and MM5 platforms ha ve been made available to the states involved in this process. Results in clude each BART-eligible unit’s maximum 24-hr, 8 th highest 24-hr, and annual average impact at the Cl ass I area most heavily impacted, as well as the total impact from all BART sources on each Class I area. These visibility impacts were modeled relative to 2 0 percent best, 20 percent worst, and annual average natural background conditions. For the purposes of this analysis, we examined the 24-hr maximum visibility impact relati ve to the 20 percent best days. On July 19, 2006, EPA provided clarification to guidan ce that states may use either estimates of 20 percent best or annual average natural backgr ound visibility conditions as the basis for calculating the deciview difference that indivi dual sources would contribute for BART exemption modeling purposes. MANE-VU has opte d to use the best conditions estimates for their consideration of the “degree of visibility improvement” modeling because it is more protective to the region. Given that no modeling of 2018 “post-BART” emission levels has been conducted yet, the 2002 modeling, in essence, provi des MANE-VU with an estimate of the maximum improvement in visibility that could re sult from installation of BART controls at Class I areas in the region (i.e., if t he source was zeroed out). In virtually all instances, the installation of BART controls would result in less visibility improvement than what is represented by a source’s 2002 impact, but this does provide a consistent means of identifying those sources whose emissions represent a more significant contribution to visibility impairment than others. In July of 2004, MANE-VU submitted comments to EPA that included visibility impact analysis of a representative sample of EGUs across the country. Based on that representative sample, MANE-VU determined that the value of the maximum 24-hour impact relative to natural conditions that would in clude 98 percent of the cumulative visibility impact on MANE-VU sites was likely betwe en 0.1 and 0.2 dv. However, this dataset was limited in that it only explored the re lationship of EGUs and did not provide an indication of how the total frequency impact mig ht change with numerous smaller, non-EGU, BART-eligible sources. With this new CALP UFF modeling data, we were able to repeat this analysis for the dataset that i ncluded all BART-eligible units in the region. This analysis remains limited that in that it includes only MANE-VU sources. It is likely that the additional sources from VISTAS a nd MWRPO would add to the total visibility impairment experienced at MANE-VU class I areas and, to some extent, to the top 98 percent of the visibility impacts. Without knowing the exact contribution of extraregional BART sources to impairment at our Class I sites, it is impossible to determine the cumulative 98 th percentile frequency precisely. Notwithstanding this limitation, the results of thi s new analysis showed that 98 percent of the cumulative frequency visibility impa ct from all MANE-VU BART-eligibleDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 14

sources corresponds to a maximum 24-hr impact of 0. 22 dv from the NWS-driven data and 0.29 dv from the MM5 data. We therefore conclu ded that a range of 0.2 to 0.3 dv would represent a “significant” impact at MANE-VU C lass I areas on an average basis. Given the analysis and the limitation due to exclus ion of sources outside of MANE-VU, we decided to place increased weight on sources wit h an individual visibility impact greater than 0.1 dv for this 1 st order regional 5-factor analysis. This threshold is overly inclusive relative to exemption processes being con ducted by other RPOs, but still provides MANE-VU states flexibility in choosing the weight to be given to the first of the five factors considered (i.e., the degree of vi sibility improvement that could result from BART).

As an additional demonstration that sources whose i mpact were below the 0.1 dv level were too small to warrant BART controls, the entire MANE-VU population of these units was modeled together to examine their cumulat ive impacts on each Class I site. The result of this simulation showed that the maxim um 24-hr impact at any Class I area of all modeled sources with individual impacts below 0.1 dv was only a 0.35 dv change relative to the estimated best days natural conditi ons at Acadia National Park. This value is below the 0.5 dv impact recommended by EPA for e xemption modeling and we can be fairly certain that sources below the 0.1 dv level have very small individual impacts on visibility at Class I areas. Among the sources with a greater than 0.1 dv total impact at any Class I area were 29 EGUs with 95 BART-eligible units that are locate d in states subject to CAIR. These CAIR-eligible EGU units may use the CAIR program to satisfy BART for SO 2 and in most cases NO X BART. We did not consider these sources further w ith the exception of the three EGU sources (eight units) that had greate r than 0.1 dv contribution for PM alone. These three EGU sources, along with 14 add itional EGU sources in states that are not subject to CAIR (17 EGUs total), and 36 additio nal non-EGU sources with visibility impacts that may warrant BART controls are listed i n Table 4-2 by type.

Table 4-2. Types of sources in MANE-VU region with greater than 0.1 dv impact at any Class I area (non year-round CAIR sta tes).

Source Type Number of Sources Number of Units/MM5* Chemical Manufacturer 1 3 Coal Cleaning 1 1 EGU 17 30 Glass Fiber 1 6 Incinerator 1 2 Metal Production 2 7 Paper and Pulp 12 30 Portland Cement 12 25 Refinery 5 37 Total 53 142 *Only MM5 Data were used for this analysis.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 15



### 4.2. Cost and Availability of Controls and Controls Alre ady in Place The second and third steps of the MANE-VU five-fact or analysis involved evaluating current controls at sources and costs of additional controls at these sources – factors (a) and (c) above. To address these factor s, the list of these 53 highest impacting sources, including all the BART-eligible units at t hese sources (142 units), was sent out to state permitting staff for feedback on possible controls recommendations for these types of units and cost information for typical ins tallation of these controls. Several states informed us that some of the eligible source s are subject to future controls under existing state regulations that will achieve “BART- like” levels of control. In these cases, we have listed the control level where applicable, or designated the control as “Currently Controlled” if the controls are already in place. Other states are considering a cost threshold to determine whether controls are feasibl e. If potential additional controls are above any known cost thresholds, then it is likely that a state would not feel that additional controls beyond those currently in place are warranted and we have therefore designated such units as “No Further Controls Warra nted.” In situations where we did not have sufficient information to assess current o r potential future controls, the unit has been designated as “No Known Further Controls.” In cases where other control programs such will satisfy BART, the control program is list ed. Finally, we have listed the control technology as “No Known Further Controls” for BART- eligible sources where no information was available on possible control optio ns. NESCAUM compiled the available survey results prov ided by state staffs on expected or potential controls on these units and p rojected 2018 emissions from these units. Summaries of these results are found in Tab le 4-3 to Table 4-5. Cost information for various control options was obtained from a var iety of sources including individual states, previous NESCAUM reports (NESCAUM, 2005), a nd other RPO analyses. Cost estimates from NESCAUM (2005) as well as the low, m edium, and high cost designations described in the Tables 4.3-4.5 are su mmarized in Appendix B. Obviously, more detailed analysis of the cost of various contr ol options will have to be conducted at the source-specific level by the states as they con duct source-specific BART determinations.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 16

Table 4-3. Possible range of SO 2 controls and costs based on survey of state staff

Type of Source Number

of Sources Control Strategies Number of Emission Units Control Strategy May Apply Total 2002

SO 2 Emissions Total

Estimated Decrease in SO 2 (tons/yr) Estimated Cost

($/Ton SO2) Notes SO2 Scrubber 1 24000 9600 400-8000 Mid Range (1) Chemical Manufacturer 3 Currently Controlled 2 80 NA 0
Glass Fiber 6 Currently Controlled 6 17 0 0 Coal Cleaning 1 No Known Further Controls 1 68 0 0

Dry Scrubber 4 58000 52600 200-500 Mid Range, assume 90% scrubber efficiency EGU/Coal 5 0.33 lb/MMBtu 1 4000 1200 NA

0.3% fuel sulfur limit 3 1400 340 0 Switch to 0.3% has already occurred for 3 boilers. 0.56 lb/MMBtu 1 85 NA NA 2.0 % Fuel Sulfur Limit 1 600 300 NA 1.5% Fuel Sulfur Limit 1 5200 3900 NA 0.33 lb/MMBtu 1 4000 3100 NA 3.0 lb/MWh 5 31000 NA NA 1.1-1.2 lb/MMBtu 2 480 NA NA EGU/Oil (Resid and Dist) 17 Currently Controlled 3 1200 0 0 Incinerator 2 Currently Controlled 2 84 0 0 No Further Controls Warranted 5 2200 0 0

Metal Production 7 Increased efficiency of the facility's wet scrubber 2 3000 300 Limited Cost Low Range FGD (SO 2 Scrubber) 3 13000 11000 400-8000 Mid Range (1) 1.8% Fuel Oil 2 6050 3000 NA

2.0% Fuel Oil 1 2800 1400 NA

No Known further controls 3 10000 0 0 Paper and Pulp 30 Currently Controlled 21 4000 0 0
Fuel switching: CE of SOx 10% 3 2300 230 NA

No Further Controls Warranted 5 3700 0 0

No Known Further Controls 7 300 0 0 Portland Cement 25 SO 2 Scrubber 10 26000 19000 400-8000 Mid Range (1)
Refinery RACT 9 5400 NA 0
SO2 Scrubber 3 NA NA 400-8000 Mid Range (1)

Refinery 37 No Known Further Controls 25 NA NA 0

(1) Cost estimate from NESCAUM 2005 for Industrial Boilers NA- No information currently available.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 17

Table 4-4. Possible range of NO X controls and costs based on survey of state staff

Type of Source Number

of Sources Control

Strategies Number of

Emission Units Control Strategy May Apply Total 2002

NO x Emissions Total

Estimated Decrease in NO x (tons/yr) Estimated

Cost ($/Ton NO x ) Notes SCR 1 4900 3400 1300-10000 (2) Chemical Manufacturer 3 Currently Controlled 2 5000 0 0

Glass Fiber 6 Currently Controlled 6 180 0 0

Coal Cleaning 1 Low NOx burners, CE of 15% 1 160 25 1-2 Million (capital cost) Low Range Currently Controlled 2 2900 820 0 SCR and 1.5 lb/MWh 2 9800 NA 1000-1500 Mid Range (1)

EGU/Coal 5 NOx Budget & 1.5 #/MWh 1 2300 NA NA Currently Controlled 6 3200 0 0 No Known Controls 3 390 0 0 NOx Budget 3 700 NA NA NOx Budget and 1.5 lb/MWh 4 5300 NA NA EGU/Oil 17 SNCR, 1.5 lb/MWh 1 2400 NA 500-700 Mid Range (1)

Incinerator 1 Currently Controlled 2 720 0 NA

2 Currently

Controlled 2 0 0 0 Metal Production 5 No Further Controls Warranted 5 110 0 0

SCR or SNCR 2 710 430 1300-10000 Mid to High Range (2) No Known Further Controls 13 4500 0 0

Paper and Pulp 30 Currently Controlled 15 4600 0 0 Low NOx burners 3 2800 430 200-3000 Mid Range (3) Low NO x Burners and Mid Kiln Firing, 40% Reduction 2 8500 3400 1200-10000 Mid Range (2)
SCR, 65% Red. 1 740 480 1300-10000 (2)
No Known Further Controls 9 2000 0 0 Currently Controlled 1 1700 0 0 Portland Cement 25 SNCR 9 7100 2900 900-1200 Mid Range (3) Refinery RACT 9 2300 NA NA No Known Further Controls 25 0 0 0 SCR 2 460 40 1300-10000 (2) Refinery 37 SNCR 1 1000 560 1300-10000 (2)

(1) Cost estimate from NESCAUM 2005, EGU controls (2) Cost estimate from NESCAUM 2005, Industrial Boi ler controls (3) Cost estimate from NESCAUM 2005, Portland Cemen t Kilns NA-No information currently available.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 18

Table 4-5. Possible range of PM 10 controls and costs based on survey of state staff

Type of Source Number of

Sources Control

Strategies Number of

Emission Units Control Strategy May Apply Total 2002

PM 10 Emissions Total

Estimated Decrease in PM 10 (tons/yr) Estimated

Cost ($/Ton PM 10 ) Notes
Chemical Manufacturer 3 Currently Controlled 3 200 0 0

Coal Cleaning 1 No Known Further Controls 1 46 0 0 Currently Controlled ESP 7 2000 0 0 PM co-benefit reductions expected due to FGD-25-50% reduction 2 1500 370 0 EGU/Coal 10 Baghouse 1 1500 NA $50 M Capital Cost

EGU/Natural Gas 2 Controls information included with oil/coal boilers 2 13 NA NA Currently Controlled 13 410 42 0

EGU/Oil 18 No Known Further Controls 5 50 0 0

Incinerator 2 Currently Controlled Fabric Filter 2 0 0 0

Glass Fiber 6 Currently Controlled 6 190 0 0

Metal Production 7 Currently Controlled 7 41 0 0 Upgrade from ESP to baghouse, CE of 4% estimate 2 180 7 $15 M Capital Cost
No Known Further Controls 7 280 0 0 Currently Controlled (ESP, Venturi Scrubbers, Demister, or MultiCyclones) 9 690 0 0 Paper and Pulp 30 Current Controls 7 670 0 NA Upgrade on current ESP, CE of 5% 3 210 11 Limited Cost
No Known Further Controls 15 300 0 0 Currently Controlled 6 370 0 0

Portland Cement 25 Baghouse or electric precipitator 1 4 NA NA

No Known Further Controls 28 NA 0 0 Refinery 37 Refinery RACT 9 270 NA NA

NA-No information currently available.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 19

Table 4-3 through Table 4-5 display general summary information from state surveys on possible BART control efforts as well as cost information gathered from several sources. The sections below will describe the contents of these tables in further detail.



### 4.2.1. Chemical Manufacturers In the MANE-VU region, one chemical manufacturing s ource showed visibility impacts greater than 0.1 dv at a Class I area. At this source the state is considering SO 2 scrubber installation at one boiler unit (emission unit containing three oil and coal fired boilers) that could result in a decrease of 9600 to ns of SO 2 emitted from this source annually. The State is also considering an install ation of an SCR (Selective Catalytic Reduction) at this unit that could result in a decr ease of 3400 tons of NO x emissions annually from the three boilers. This unit current ly has an ESP installed for PM control which is expected to satisfy BART.



### 4.2.2. Glass Fiber There is one glass fiber source in the region with a significant visibility impact on a Class I area in MANE-VU. Recent conversion from air/natural gas firing to oxygen/natural firing in 2000 has led to to an 85% reduction from the previous configuration which adequately satisfies BART.



### 4.2.3. Coal Cleaning One coal cleaning source in the region showed a sig nificant visibility impact at Class I areas. Low NO X burners for NO X control are considered a low-cost option for the thermal coal dryer unit at this source (Appendix B) .. Additional control options for SO 2 and PM may not be warranted based on a survey of st ate staff. Low NO X burners could result in approximately 24 tons of NO X reduced annually.



### 4.2.4. Electric Generation Units Of the 58 EGUs modeled in the region, 40 sources ar e located in states implementing a year-round CAIR program, while 15 so urces are located in states implementing an ozone season CAIR program. Units c overed in a year-round CAIR program were removed from further SO 2 and NO X analysis because BART would likely be satisfied through CAIR requirements. Visibility modeling was conducted for all EGUs in the region and of the 18 EGU sources in MAN E-VU states without a year-round CAIR program under development, 13 showed a signifi cant impact at Class I areas in the region. In addition, three sources in states with a year-round CAIR program showed a significant PM impact, and were included in the PM control and cost analysis.



### Coal-Fired Units States with coal-fired EGU units are considering tw o options for SO 2 control; dry scrubber installation (a mid level cost option) and a 0.33 lb/mmBTU capacity limit. A dry scrubber could result in over 90 percent SO 2 decrease while a capacity limit of 0.33DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 20

lb/mmBTU could result in a decrease of 1200 tons SO 2 at one unit considering this option.

In terms of NO X control, two boilers in the region have current co ntrols of LowNOx concentric firing systems and SCR that are bein g considered sufficient for BART. Two units are looking at SCR controls to achieve a 1.5 lb/MWh emission rate, a mid level cost option for this source. One unit’s cont rol level under the NO X Budget Program will simultaneously control for BART. The majority of coal-fired units at EGUs in the reg ion are currently fit with ESPs and further PM control recommendations are not warr anted. For the units without ESPs, one state was looking at baghouse installation as a possible option and another expects sufficient reductions due to a PM co-benefit from t he installation of an FGD (Fluid Gas Desulfurization) scrubber for SO 2 control.



### Oil-Fired Units The majority of BART-eligible oil-fired EGU boilers in the region were found in one state. For these units, input- and output-base d capacity limits established under other programs for which the BART-eligible units were cov ered may satisfy SO 2 BART control requirements. The levels of those programs are 0.56 and 1.1 lb/MMBtu for two different EGUs respectively, and 3.0 lb/MWh output- based limit for several other EGUs. Another control option being considered by other st ates is a fuel sulfur limit (0.3 percent) or an equivalent 0.33 lb/MMBtu emissions r ate. Four BART-eligible units in the region have been controlled at this level since 2002 and would consider this level of control appropriate for BART. This BART control op tion has reduced total SO 2 emissions by 3100 tons annually at the one controll ed sources, but is not anticipated to achieve as great a reduction at the other three BAR T-eligible sources, which are smaller. One unit is considering a 1.5 percent fuel sulfur l imit that could result in approximately 3900 tons (or approximately 75 percent reduction) o f SO 2 emissions from the one candidate for this option. We have no information on potential controls for two other BART-eligible units in the region. Regarding NO X controls on oil-fired boilers, possible technologi es being considered for BART include SNCR (Selective Non-Cat alytic Reduction) installation. Several units in the region are either currently co ntrolled, with further controls considered unwarranted, or are under a NO X budget program that would serve as BART. Current controls on oil-fired boilers at EGUs include SNCR, boiler excess air control, and LowNO x burners. For several of these units, information on BART recommendations was unavailable. As with the coal-fired units, the majority of oil-f ired boilers in the region have existing PM control technologies like ESPs, multicy clones, and mechanical collectors.



### 4.2.5. Incinerators The lone BART-eligible incinerator source in the re gion has already achieved an approximately 75 percent reduction in SO 2 emissions through the installation of a dry scrubber. This source already has SNCR NO X controls and reverse air fabric filters for PM controls and therefore further controls are not warranted. The air pollution controlsDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 21

on this source are the same controls required by ne w municipal waste combustion facilities MACT requirements.



### 4.2.6. Metal Production Two metal production sources consisting of seven BA RT eligible units showed significant visibility impact on the region For on e source, the state was looking at low cost, better efficiency measures for the SO 2 scrubber that would result in an increase of SO 2 control efficiency by 10 percent at two aluminum o re reduction units. A preliminary cost analysis conducted by the state at another sou rce showed that SO 2 controls were not warranted at the sources BART eligible units (bakin g furnaces and potlines). The survey of state staff indicated that current controls for PM would likely satisfy BART for all metal production units in the region. Two unit s in the region are currently controlled for NOx while a cost analysis for NO x controls at 5 units indicated that no further controls were warranted.



### 4.2.7. Paper and Pulp There are 30 eligible units at paper and pulp sourc es with significant visibility impact in the region. While the majority of these u nits are industrial boilers, this category also contains lime kilns, smelt tanks, and other pr ocess units. States are contemplating FGD scrubber installations for SO 2 control for at least three industrial boiler units as possible BART control options. This is a mid-range cost technology for typical installations that could result in an estimated 20, 000 fewer tons of SO 2 for these three units alone. At three industrial boiler units, a f uel switching option is being considered by the state. Two boilers switching to 1.8% Sulfur fuel oil could result in 3000 tons of SO 2 being reduced while one boiler switching to 2.0% s ulfur fuel oil could result in 1400 tons of SO 2 reduced. Twenty-one units are currently controlle d at a level such that existing controls are likely to satisfy BART, while no known further controls are expected for three units in this category. Current controls on these boiler units are generally wet scrubbers. For the majority of paper and pulp units, either th e existing Low NO X burner controls or current capacity limits may satisfy BAR T or we did not have information about possible controls for units. Possible contro l options being considered for uncontrolled sources include SCR or SNCR technologi es on boilers that could achieve 60 to 80 percent NO X control. This is a mid to high cost control optio n, depending on the source. Installation of these technologies is esti mated to result in a decrease of 430 tons of NO X emissions at two units considering this option. Most of the units at paper and pulp sources with si gnificant visibility impacts in the region have existing PM controls including ESPs , baghouses, multicyclones, and venturi scrubbers and were therefore not viewed as candidates for further controls. One state is considering upgrading ESPs on two coal fir ed industrial boilers to baghouses that would result in a decrease of 7 tons of PM emitted per year.



### 4.2.8. Portland Cement Plants Twenty-five Portland cement units in MANE-VU are lo cated at BART-eligible sources with significant visibility impacts on Clas s I areas in the region. At theseDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 22

sources, states are considering installation of SO 2 scrubbers at 10 cement kilns at these sources, which would significantly reduce the amoun t of SO 2 emitted from this sector. If installed, scrubbers at these kilns would result in a decrease in emissions of 19,000 tons of SO 2 annually. Another BART control option being considered for ce ment kilns in the region is fuel switching. Units considering this option for kilns could decrease annual SO 2 emissions by 230 tons. Twelve units in this sector either have existing controls that will likely satisfy BART, or control information for SO 2 is currently unknown. Control technologies under consideration for NO X at cement plants were varied according to our survey information. Low NO X burners are a possible control option for uncontrolled cement kilns. This is a mid range cost option that could result in an annual decrease of 430 tons of NO X emitted from three units. Another possible contro l option is Low NO X burners with mid-kiln firing. At a mid level cost , this technology could result in a decrease of 3400 annual tons of NO X emissions at units where this option is applicable. SCR installation is being considered a t one unit, also a mid level cost option that could decrease emissions from unit by 480 tons annually. SNCR control technology is a mid level cost option, which if in place at un its considering this option, could result in a decrease of 2900 tons of NO X emissions. Ten of the 25 units in this category e ither have existing controls that will likely satisfy BAR T or controls for NO X are currently unknown. Most of the units at these Portland cement plants e ither have existing PM controls or potential control information is unknown. Where no controls exist, possible control options include installation of a baghouse or an ES P. One state is considering a recommendation of upgrading ESPs at three units, a low cost option that would reduce annual emissions of PM by 11 tons.



### 4.2.9. Refineries At this time, for the majority of the units in this category, control information is unknown. One possible control option for SO 2 is installation of a scrubber on fluid catalytic cracking units, a mid range cost option b eing considered for three units in the region. Nine of these units are currently subject t o refinery RACT (Reasonably Available Control Technology) controls for 8-hour ozone and t hese control levels for SO 2 , NO X , and PM are likely to satisfy BART requirements. St ates are also considering SCR or SNCR controls for three fluid catalytic cracking un its in the region for possible NO X control, also a mid level cost option.



### 4.3. Energy and Non-Air Quality Environmental Impacts

While there are certain to be several issues that a rise on a source-specific basis with respect to individual control technologies (e. g., water quality impacts or solid waste disposal issues), we are unable to address these is sues in a regional analysis. One environmental benefit that should be considered in weighing control options for BART is the regional impact on acid deposition in MANE-VU. An analysis of combined SO 2 and NO X reduction potential of BART control options by sector showed similar results for EGUs a nd paper and pulp sources. FigureDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 23

4-1 shows the amount of SO 2 and NO X that could be reduced if BART control options were implemented at the units for which likely cont rol options are known. Figure 4-1 shows that generally, when emission reduction optio ns are known, the emissions reduction potential is evenly distributed across th e range of sources in the region. This is important as states are weighing whether controls a re warranted or not for EGUs or paper and pulp boilers. However, for the majority of uni ts with significant visibility impact in these sectors, the amount of SO 2 and NO X reduction potential is currently unknown, limiting the power of this analysis.

Figure 4-1. Reduction potential of BART control op tions at

EGUs and Paper and Pulp Sources

0 2 4 6 8 10 12 14 16 18 20

Unknown <1000 1000-3000 3000-5000 >5000

Combined Tons SO2 and NOx Reduced by BART Control O ptionsNumber of Units

EGUs Paper and Pulp

For Portland cement plants, possible emissions redu ction data were more complete and allowed for a clearer analysis of SO 2 and NO X control. Figure 4-2 shows the emissions reduction potential that would be ach ieved by BART if the survey control options were implemented for units in this sector. While several units would benefit from BART control options with emissions being redu ced by greater than 3,000 tons of combined SO 2 and NO X , the majority of the cement plant units would redu ce emissions by less than 1,000 tons. As states weigh whether a dditional controls are warranted for cement plants, this non air-quality environmental f actor may play less of a role for these

sources. For other source categories, the statistics are gen erally too small to make an analysis meaningful, but as a general rule, the rem aining source categories tend to have lower overall emissions and lower overall reduction potential, which may factor into control decisions accordingly.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 24

Figure 4-2. Reduction potential of BART control op tions at Cement Plants

0 2 4 6 8 10 12

Unknown <1000 1000-3000 3000-5000 >5000

Combined Tons SO2 and NOx Reduced by BART Control O ptionsNumber of Units

Cement Plants



### 4.4. Remaining Useful Life The MANE-VU BART Workgroup has considered what weig ht to give to this factor in conducting BART determinations and has re commended that remaining useful life of a source will be addressed in the following way. A BART-eligible source that is found to have reasonable control options available to it should either control emissions from that BART-eligible source prior to 2013 or acc ept a federally enforceable permit limitation or retirement date prior to each state’s public notice and hearing processes and FLM review of BART SIP elements.



## 5. CONCLUSIONS
As MANE-VU states prepare to conduct source-specifi c BART determinations for the eligible units in their jurisdictions, this report provides a regional assessment of the five factors that must be considered in determi ning whether additional controls are warranted for an individual BART source. This inf ormation is intended to lay out a regional approach and provide regional context for individual control decisions that will be made by the MANE-VU member states. This informa tion may also serve as an important regional basis for dialogue and internal MANE-VU consultations as states consider what level of stringency is justified and reasonable based on consideration of the five factors. Important findings of this analysis include the ide ntification of BART-eligible sources in the region, the numbers of units in vari ous categories subject to BART consideration, BART control technology options bein g considered in the region, andDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 25

estimates of the total emissions and reduction pote ntial from units contributing to potentially significant visibility impacts at Class I areas. Table 4-1 and Table 4-2 indicate that 136 BART-elig ible sources exist in the region with 53 contributing to potentially signific ant visibility impairment at a Class I area. The majority of BART-eligible sources in the region are EGUs, however, most of these sources fall under a year-round CAIR program that will satisfy BART. Of the BART-eligible source categories with potenti ally significant visibility impacts, the non-CAIR EGU sector was the largest em itter of SO 2 , NO X , and PM 10 in 2002. BART-eligible EGUs with significant visibili ty impacts included 17 sources with 30 units emitting 110,000 tons SO 2 , 28,000 tons NO X , and 7,000 tons PM 10 in 2002. The majority of these units are anticipating controls f or SO 2 and NO X to satisfy BART requirements. Although the amount of expected reduc tions is currently unknown, we can expect significant reductions in emissions from thi s sector given widely available control technologies for SO 2 and NO X with proven cost-effectiveness. Most of these uni ts are currently controlled for particulate matter and fur ther controls are not expected. Portland cement plants and paper and pulp sources a re sectors with many BARTeligible units that made significant contributions to visibility impairment and total pollutant emissions in the region. Paper and pulp sources with significant visibility impacts emitted 36,000 tons SO 2 , 10,000 tons NO X , and 2,000 ton PM 10 at 30 units in 2002. Although information on controls is currentl y unknown for many of these units, information from units considering controls indicat es that significant reductions can be achieved from this sector (19,000 tons SO 2 reduced if scrubbers are installed at 13 units and 400 tons NO X reduced if SCR controls are introduced to two unit s). Portland cement sources with significant visibility impacts emitted 32,000 tons SO 2 , 23,000 tons NO X , and 850 tons PM 10 at 25 units in the region. With more complete inf ormation for cement plants, we estimated a reduction of 19,000 tons SO 2 at 13 units and 7,000 tons NO X at 15 units when considering controls that would satisfy BART. Ultimately, the strength of the MANE-VU BART progra m, as determined by individual state control decisions and informed by this analysis, will demonstrate MANEVU’s resolve to tackle visibility and related air q uality problems in its region. As MANE-VU enters into inter-RPO consultations, its wi llingness to seek reasonable emission reductions within its own region will help set expectations for the other RPOs, and the BART program represents a cornerstone of th is process.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 26



## 6. REFERENCES

MM5 website http://www.mmm.ucar.edu/mm5/

NESCAUM. 2005. Assessment of Control Technology O ptions for BART-Eligible Sources. Available at: http://www.nescaum.org/documents/bart-control-asses sment.pdf/

NESCAUM. 2006a. BART Resource Guide. Available a t: http://www.nescaum.org/documents/bart-resource-guid e/bart-resource-guide-08-23-06- final.pdf/

NESCAUM. 2003. Technical Memorandum #6. Developm ent of a List of BARTEligible Sources in the MANE-VU Region: Interim Re port. Available at: http://www.nescaum.org/documents/memo6-bart.pdf/

NESCAUM. 2006b. Contributions to Regional Haze in the Northeast and Mid-Atlantic United States. Appendix D: Development of Paralle l CALPUFF Dispersion Modeling Platforms for Sulfate Source Attribution Studies in the Northeast U.S. Available at: http://www.nescaum.org/documents/contributions-to-r egional-haze-in-the-northeast-andmid-atlantic--united-states/appendixd--2006-0831.pd f/

NESCAUM. 2001. A Basis for Control of BART-Eligib le Sources. Available at: http://www.nescaum.org/documents/a-basis-for-contro l-of-bart-eligiblesources/basis.pdf/DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 27



# Appendix A: List of BART-Eligible Sources in the

MANE-VU Region

State Plant Type Number of Units CT Middletown Power LLC (NRG) EGU 2 CT Montville Power LLC (NRG) EGU 1 CT Norwalk Power LLC (NRG) EGU 1 CT PSEG Power CT Bridgeport Harbor Station EGU 1 CT PSEG Power CT New Haven Harbor Station EGU 1

CT Sprague Paperboard Caraustar Fossil Fuel Boiler (>250 MMBtu 1 DC Benning (PEPCO -15) EGU 1 DC Benning (PEPCO -16) EGU 1 DE City of Dover - Mckee Run EGU 1 DE Connectiv Edgemore EGU 2 DE NRG- Indian River EGU 1 MA Exxon Mobil Everett Petroleum Storage 1 MA Global Petroleum Revere Petroleum Storage 1 MA Gulf Oil Chelsea Petroleum Storage 1

MA Solutia Chemical Process Plant 3 MA Braintree Electric EGU 1 MA Brayton Point EGU 4

MA Eastman Gelatin (boilers only) Chemical Process Plant/Industrial Boilers 4 MA General Electric Lynn EGU 1 MA Harvard U (Blackstone) EGU 2 MA Mirant Kendall LLC EGU 3 MA Mirant-Canal Electric EGU 2 MA Mystic EGU 1 MA New Boston EGU 1 MA Salem Harbor EGU 1 MA TMLP - Cleary Flood EGU 3 MA Trigen - Kneeland St EGU 1

MA Wheelabrator -Saugus Municipal Incinerator 2 MD CONSTELLATION POWER SOURCE GENERATION CP CRAN E EGU 7

MD CONSTELLATION POWER SOURCE GENERATION HERBERT WAGNER EGU 2

MD EASTALCO ALUMINUM Primary Aluminum Ore Reduction Plant 2 MD INDEPENDENT CEMENT ST LAWERENCE Portland Ceme nt 1 MD LEHIGH PORTLAND CEMENT Portland Cement 3DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 28

MD METTIKI COAL CORPORATION Coal Cleaning 1

MD MILLENIUM INORGANIC CHEMICALS Chemical Process Plants 5 MD MIRANT MID ATLANTIC LLC MORGANTOWN EGU 2 MD MIRANT MID ATLANTIC DICKERSON EGU 1 MD PEPCO CHALK POINT EGU 3

MD TRIGEN LEADENHALL STREET Fossil Fuel Boiler (>250 MMBtu 4 MD VIENNA GENERATING STATION EGU 1

MD WESTVACO FINE PAPERS Kraft Pulp Mill/Fossil Fuel Boiler (>250 MMBtu 3

ME Domtar Ind Industrial Boiler/Kraft Pulp Mill 2 ME Dragon Products Portland Cement 1

ME Georgia Pacific Old Town Industrial Boiler/Kraft Pulp Mill 2

ME IP Bucksport Fossil Fuel Boiler (>250 MMBtu 1

ME IP Jay Industrial Boiler/ Kraft Pulp Mill 9

ME Katahdin Paper Millinocket Fossil Fuel Boiler (>250 MMBtu 1

ME Lincoln Paper and Tissue Industrial Boiler/Kraft Pulp Mill 2 ME Rumford Paper Industrial Boiler 1

ME SAPPI Somerset Industrial Boiler/Kraft Pulp Mill 4 ME Wyman Station EGU 2 NH PSNH Merrimack Station EGU 1 NH PSNH Newington Station EGU 1 NJ Amerada Hess Corporation-Port Reading Re Petr oleum Refinery 13 NJ Bayway Refinery Petroleum Refinery 257 NJ Chevron Products Company Petroleum Refinery 22 NJ COASTAL EAGLE POINT OIL COMPANY Petroleum Ref inery 145 NJ Hudson Generation Station EGU 4

NY 3M TONAWANDA Chemical Process Plants/Industrial Boilers 4

NY ALCAN ALUMINUM CORPORATION Primary and Secondary Aluminum Production 9

NY ALCOA MASSENA OPERATIONS (WEST PLANT) Primary and Secondary Aluminum Production 25 NY ARTHUR KILL GENERATING STATION EGU 2 NY ASTORIA GENERATING STATION EGU 2 NY BOWLINE POINT GENERATING STATION EGU 5DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 29

NY BUFFALO COLOR CORP - LEE ST PLANT Chemical Process Plants/Industrial Boilers 5 NY CON ED-59TH ST STA EGU 4 NY DANSKAMMER GENERATING STATION EGU 2 NY EF BARRETT POWER STATION EGU 44

NY ERWIN MANUFACTURING COMPLEX Glass Fiber Processing Plants 3

NY GENERAL ELECTRIC SELKIRK PLASTICS PLT Chemical Process Plants/Industrial Boilers 16 NY GLENS FALLS LEHIGH CEMENT COMPANY Portland Ce ment 46

NY INTERFACE SOLUTIONS INC Kraft Pulp Mill/Industrial Boilers 9

NY INTERNATIONAL PAPER TICONDEROGA MILL Kraft Pulp Mill/Industrial Boilers 11

NY KODAK PARK DIVISION Chemical Process Plants/Industrial Boilers 20

NY LACKAWANNA PLANT- REPUBLIC ENG PROD INC Primary Metal Production/Industrial Boilers 3 NY LAFARGE BUILDING MATERIALS INC Portland Cemen t 31

NY LOVETT GENERATING STATION EGU 4 NY NORTHPORT POWER STATION EGU 17 NY OSWEGO HARBOR POWER EGU 3

NY OWENS-CORNING DELMAR PLANT Glass Fiber Processing Plants 27

NY RAVENSWOOD GENERATING STATION EGU 60

NY REVERE SMELTING & REFINING CORP Primary Metal Production/Industrial Boilers 8 NY RIVERBAY CORP-CO-OP CITY Industrial Boilers 4

NY RIVERHEAD TERMINAL-CONOCOPHILLIPS Petroleum Storage/Industrial Boilers 7 NY ROSETON GENERATING STATION EGU 4 NY SAMUEL A CARLSON GENERATING STATION EGU 2

NY SCHENECTADY INTERNATIONAL ROTT JCT FAC Chemical Plant/Industrial Boilers 18 NY ST LAWRENCE CEMENT CORP-CATSKILL QUARRY Portl and Cement 37

NY WASHINGTON MILLS ELECTRO MINERALS Glass Fiber Processing Plants 3 PA ALLEGHENY_LUDLUM_CORP_BRACKENRIDGE EGU 8

PA EASTMAN_CHEMICAL_RESINS_INC Chemical Process Plants/Industrial Boilers 2 PA ESSROC/BESSEMER Portland Cement 14DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 30

PA NEVILLE_CHEMICAL_COMPANY Chemical Process Plants 5 PA ORION_POWER_MIDWEST_CHESWICK_STATION EGU 2

PA USS_CLAIRTON_WORKS Metal Production/Industrial Boilers 4

PA AK STEEL CORP BUTLER WORKS Iron and Steel Mill Plants 16 PA ALLEGHENY ENERGY SUPPLY CO HATFIELDS FER EGU 5 PA ALLEGHENY ENERGY SUPPLY CO MITCHELL POWE EGU 19 PA AMER REF GROUP BRADFORD Petroleum Refinery 4

PA APPLETON PAPERS SPRING MILL Kraft Pulp Mill/Industrial Boilers 9 PA CARMEUSE LIME INC MILLARD LIME PLT Lime Plant 8 PA CEMEX INC WAMPUM CEMENT PLT Portland Cement 9 PA CONOCOPHILLIPS CO TRAINER REF Petroleum Refin ery 10

PA DUFERCO FARRELL CORP FARRELL PLT Iron and Steel Mill Plants 1

PA DYNO NOBEL INC DONORA Chemical Process Plants 9 PA ESSROC NAZARETH LOWER CEMENT PLT 1 Portland C ement 1 PA EXELON GENERATION CO EDDYSTONE EGU 6

PA EXIDE TECH READING SMELTER Secondary Metal Production 9 PA HOMER CITY OL HOMER CITY GEN STA EGU 6

PA HORSEHEAD CORP MONACA SMELTER Primary Zinc Smelter 25

PA INDSPEC CHEM CORP PETROLIA Chemical Process Plants 17

PA INMETCO ELLWOOD CITY Iron and Steel Mill Plants 6

PA ISG PLATE LLC COATESVILLE Iron and Steel Mill Plants 20 PA KEYSTONE PORTLAND CEMENT EAST ALLEN Portland Cement 4 PA LAFARGE CORP WHITEHALL PLT Portland Cement 28 PA LEHIGH CEMENT CO EVANSVILLE CEMENT PLT Portl and Cement 42 PA LEHIGH CEMENT CO YORK OPERATIONS Portland Cem ent 11 PA LWB REFRACTORIES CO W MANCHESTER Mineral Prod ucts 13 PA MERCER LIME & STONE BRANCHTON Lime Plant 6 PA NEW CASTLE POWER PLT EGU 2 PA PA POWER CO BRUCE MANSFIELD PLT EGU 18

PA PH GLATFELTER CO SPRING GROVE Paper and Pulp/Industrial Boilers 8 PA PPL BRUNNER ISLAND L BRUNNER ISLAND EGU 4 PA PPL MARTINS CREEK LLC MARTINS CREEK EGU 2 PA PPL MONTOUR LLC MONTOUR SES EGU 4 PA RELIANT ENERGY NORTHEAST CONEMAUGH PLT EGU 6 PA RELIANT ENERGY NORTHEAST MGMT KEYSTONE POWER PLT EGU 2

PA RELIANT ENERGY PORTLAND GENERATING STATION EG U 2 PA SUNOCO CHEMICALS (FORMER ALLIED SIGNAL) Chemi cal Process 17DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 31

Plants

PA SUNOCO INC (R&M) MARCUS HOOK REFINERY Refiner y 10 PA SUNOCO INC (R&M) Refinery 26 PA TRIGEN - EDISON EGU 4 PA TRIGEN - SCHUYLKILL EGU 1 PA UNITED REFINING CO WARREN PLT Refinery 10

PA VICTAULIC CO AMER FORKS FACILITY Secondary Metal Production 12DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 32



# Appendix B: Costs of Technologies

From NESCAUM, 2005.

EGU Cost Effectiveness
Pollutant Control Cost Units Cost Bin SO2 Wet/Dry Scrubbers (FGD) 200-500 Dollars per ton SO2 Low NOx Gas Reburn 500-2000 Dollars per ton NOx Mid NOx Low-NOx Burners 200-500 Dollars per ton NOx Low NOx Overfire Air 250-600 Dollars per ton NOx Low NOx SCR 1000-1500 Dollars per ton NOx Mid NOx SNCR 500-700 Dollars per ton NOx Mid PM ESP 15-40 Dollars per Actual Cubic Feet per Minute PM Fabric Filters 12-40 Dollars per Actual Cubic Fe et per Minute

Industrial Boilers Cost Effectiveness
Pollutant Control Cost Units Cost Bin NOx Low NOx-Burners 200-3000 Dollars per ton NOx Mid NOx SNCR 1300- 10000 Dollars per ton NOx Mid to High NOx SCR 4000- 15000 dollars per MMBtu/hr High SO2 Wet/Dry Scrubbers 400-4000 Dollars per ton SO2 (coal) Mid SO2 Wet/Dry Scrubbers 800-8000 Dollars per ton SO2 (oil) Mid to High PM ESP 15-40 Dollars per Actual Cubic Feet per Minute PM Reverse Air Fabric Filter 15-40 Dollars per Actu al Cubic Feet per Minute PM Pule Jet Fabric Filter 17-40 Dollars per Actual Cubic Feet per Minute PM Venturi Scrubber 12-40 Dollars per Actual Cubic Feet per Minute PM Cyclone 1-5 Dollars per Actual Cubic Feet per MinuteDRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 33

Portland Cement Kilns Cost Effectiveness
Pollutant Control Cost Units Cost Bin SO2 Spray Dryer 10.96-54.67 dollars/ton Clinker SO2 Wet Scrubber 10.83-47.00 dollars/ton Clinker NOx Process Modifications 3100-8800 Dollars per ton NOx Mid to High NOx Low NOx Burners

w/Indirect Firing 5800-8100 Dollars per ton NOx High

NOx Low NOx Burners

w/Indirect Firing and MidKiln Tire Injection 1-1800 Dollars per ton NOx Low to Mid

NOx Mid-Kiln Injection of Fuel 5100-11500 Dollars p er ton NOx Mid to High NOx CemStar 0-600 Dollars per ton NOx Low NOx Low NOx Precalciner 2700-3600 Dollars per ton N Ox Mid NOx SNCR 900-1200 Dollars per ton NOx Mid NOx Biosolids Injection 100-1800 Dollars per ton NO x Low to Mid PM ESP 3.33-41.00 dollars/ton clinker PM Baghouse 4.00-16.67 dollars/ton clinker

Paper and Pulp Cost Effectiveness Not Available

Cost levels SO2 NOx
Low <800 <500
Mid 800-2000 500-10000 High >2000 >10000DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 34



# Appendix C: BART Workgroup Draft

Recommendations

Draft BART Recommendations to MANE-VU Air Directors September 7, 2006 Under the U.S. Environmental Protection Agency’s (U SEPA) 1999 “regional haze rule” [64 Fed. Reg. 35714 (July 1, 1999)], cer tain emission sources that “may reasonably be anticipated to cause or contribute” t o visibility impairment in downwind Class I areas are required to install Best Availabl e Retrofit Technology (BART). 6 These requirements are intended to reduce emissions speci fically from large sources that, due to age, were exempted from other control requirements of the Clean Air Act (CAA). BART requirements pertain to 26 specified major poi nt source categories, including power plants, industrial boilers, paper a nd pulp plants, cement kilns and other large stationary sources. To be considered BART-el igible, sources from these specified categories must have the potential to emit at least 250 tons per year of any haze forming pollutant and must have commenced operation in the fifteen year period prior to August 7, 1977 (the date of passage of the 1977 Clean Air Act Amendments (CAAA), which first required new source performance standards). MANE-VU formed the BART workgroup as part of an ef fort to assist states and tribes as they prepare to comply with the Best Avai lable Retrofit Technology Requirements (BART) of the Regional Haze Rule. To date states have made substantial progress in identifying sources that are BART-eligi ble, however that is only the first step in the process. Once a source is identified as “BA RT eligible”, an analysis must be conducted to determine what will constitute BART co ntrol levels. The Haze Rule requires states to determine the most stringent tec hnologically feasible system of controls that can reasonably be installed at each source eli gible for BART. The BART workgroup has developed a list of draft recommendations for t he BART control process that will be submitted to the MANE-VU Directors. Feedback on th ese recommendations will be useful to assist the Air Directors in their review. The recommendations include overall BART policies and specific “presumptive” levels and types of control. These recommendations will serve as a regional foundation for conducting BART engineering reviews on a state-by-state basis. The workgroup r ecommendations are presented below:

1. Any BART-eligible facility may “cap-out” of BART vi a a permit emission limit, however all permit modifications must be finalized prior to December 16, 2006* in order to eliminate BART-eligibility. Caps must limit emissions from BART eligible units below 250 tons per year of any visib ility impairing pollutant

6 There are seven designated Class I areas in the No rtheast and Mid-Atlantic States. They include Acadi a National Park and Moosehorn Wilderness Area in Main e; Roosevelt-Campobello International Park in New Brunswick and Maine; the Lye Brook Wilderness Area in Vermont; the Great Gulf and Presidential RangeDry River Wilderness Areas in New Hampshire; and th e Brigantine Wilderness Area in New Jersey.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 35

* It is not clear from the final rule when a feder ally enforceable permit limitation would need to be in place in order to avoid BART-e ligibility. We are recommending to EPA that they allow permit limits which go into place prior to December 16, 2006. This will enable states to tak e action to get permit limitations in place and achieve emission limits ( though probably not reductions) prior to SIP submission avoiding the need for form al BART determinations. The 2006 date will give states one full year prior to the submission deadline for public notice and hearing processes on a final SIP packag e.

2. MANE-VU staff continues to support the policy decis ion made by the MANEVU Board in June 2004, that if a source is eligible for BART, it is subject to BART . (i.e. no exemptions will be given).

3. Regional performance standards or cost thresholds a re appropriate for many individual categories of BART eligible sources. Th e attachment contains an initial round of recommended presumptive levels of control for EGUs, industrial boilers and cement kilns. The workgroup may develo p additional presumptive levels in the future.

4. Remaining useful life of a source will be considered in the following wa y: Sources have the option to either control a BART-eligible facility prior to 20 13 or accept federally enforceable permit limitation o r retirement date prior to December 16, 2006.

5. Control technology in place (other than for source categories covered by the attached list of presumptive control levels) will likely have to be dealt with on a source by source basis . (i.e. no regional recommendation)

6. Energy and non-air quality environmental impacts wi ll likely have to be dealt with on a source by source basis . (i.e. no regional recommendation) however the workgroup is still considering regional recommendat ions for non-air quality environmental impacts.

7. If data does not exist to accurately determine the installation date for emission unit(s)within a facility then the unit will be treated as though it IS withi n the BART date range unless the facility can provide pro of otherwise (i.e., proof that the unit was in operation prior to 1962) . Many states are having difficulty identifying installation dates for pre-1977 units. All states felt they could easily identify post-1977 units. Therefore, the workgroup supported a policy position that when the state could not accurately determine the "in existence" date, the burden of proof lay with the facility in proving th at the unit was installed prior to 1962.DRAFT – Five-Factor Analysis of BART-Eligible Sourc es Page 36

MANE-VU BART Workgroup Recommendations DRAFT Presumptive Control Levels *Updated September 7, 2006*

Non-CAIR EGUs:

• SO 2 – Coal - 95% control or 0.15 lb/MMBtu* Oil - 95% control or 0.33 lb/MMBtu (0.3% sulfur c ontent)*

• NO X

o in NO X SIP call area, extend use of controls to year-roun d

o 0.1 – 0.25 lb/MMBtu, depending on boiler and fuel t ype

• PM

– 0.02 – 0.04 lb/MMBtu**

CAIR EGUs:

• SO 2 – CAIR requirements

• NO X – CAIR requirements

• PM

– 0.02- 0.04 lb/MMBtu** If an EGU is only enrolled in CAIR for one or two p ollutants, it still must complete an analysis for the remaining visibility impairing pol lutants such as particulate matter.

Industrial Boilers

• SO 2 – 90% control, MACT acid gas control level, ICI- RACT, or 0.55 lb/MMBtu (0.5% fuel sulfur limit)

• NO X

o 0.1 – 0.4 lb/MMBtu, depending on boiler and fuel ty pe***

• PM

– 0.02 - 0.07 lb/MMBtu

Cement Kilns No common emission threshold has been identified. T he following lists, however, recommend control technologies to evaluate.

• SO 2

o in process removal

o wet or dry scrubbers

o conversion from wet kiln to dry kiln

• NO X

o Combustion optimization

o Low NO X burners

o Secondary combustion control (SNCR/SCR)

o Mid-Kiln firing

o Flame shape adjustment

• PM

o baghouse

o electrostatic precipitator

o baghouse/ESP upgrades of existing controls *Consistent with EPA presumptive BART for EGUs and OTC Control Strategy ** PM measures are based on front-half (Method 5) p articulate matter measures *** Consistent with OTC Control Strategies and NO X SIP call emission limits