Maine DEP Bureau of Air Quality 11/28/2011

MEMO

TO: James Brooks, Bureau Director, Bureau of Air Quality

FROM: Marc Cone, Air Licensing Section; Tom Downs, Meteorology Section;

Jeff Crawford, Air Planning Section

DATE: June 12, 2009

SUBJ: BART Summary

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BART SUMMARY

BACKGROUND

 The federal requirements that states must meet to achieve national visibility goals 

are contained in the “Regional Haze Rule”. These regulations were adopted on 

July 1, 1999, and went into effect on August 30, 1999. On June 15, 2005, EPA

finalized the rule addressing a Court remand.

 The principle goal is: “Congress hereby declares as a national goal the 

prevention of any future, and the remedying of any existing, impairment 

of visibility in mandatory Class I Federal areas which impairment results 

from man-made air pollution.”

 Maine has three Class I areas: 1) Acadia National Park; 2) Moosehorn National 

Wildlife Refuge Wilderness Area; and 3) Roosevelt Campobello International

Park

 In consultation with the states and tribes, EPA designated five Regional Planning 

Organizations (RPO) to assist with the coordination and cooperation needed to 

address the haze issue. The Mid-Atlantic / Northeast states, including the District 

of Columbia, formed the Mid-Atlantic / Northeast Visibility Union (MANE-VU)

 Among the required elements of the SIPs, states must include determinations of 

Best Available Retrofit Technology (BART) and long term strategies to ensure 

that reasonable progress is being made to meet the national goal by 2064.

 The regional haze SIPs were due to EPA by December 17, 2007.
Maine DEP Bureau of Air Quality 11/28/2011 Page 2 of 8

BEST AVAILABLE RETROFIT TECHNOLOGY (BART)

 The Best Available Retrofit Technology (BART) requirement of Section 169A of 

the Clean Air Act (42 U.S.C.§7491(b)(2)(A)) and implementing rules (40 C.F.R. 

Part 51, Appendix Y) are intended to reduce visibility impairing pollutants 

emitted from existing stationary sources which were grandfathered from the New 

Source Review (NSR).

 The visibility impairing pollutants are defined by the EPA as sulfur dioxide (SO2), 

oxides of nitrogen (NOx) and particles with an aerodynamic diameter less than or 

equal to 10 and 2.5 μm (i.e., PM10 and PM2.5, respectively).

 The BART requirements apply to existing facilities having any of 26 types of 

stationary sources which began operation between August 7, 1962 and August 7, 

1977, with a cumulative potential to emit 250 tons per year or more of any single 

visibility impairing pollutant and may reasonably be anticipated to cause or 

contribute to any visibility impairment in a Class I area.

 Once the SIP is approved by the EPA, the BART facility has up to five years to 

install the appropriate controls and comply with the established emission 

standards. Maine is requiring sources subject to BART to install, operate and 

maintain BART rather than implement an emissions trading program or other 

alternative measure.

 In June 2005, EPA adopted the final BART rule. The BART rule requires 

states/tribes to develop an inventory of sources within each state or tribal 

jurisdiction that would be eligible for controls. 

 The federal BART rule requires that, for each BART-eligible source within the 

state, any BART determination must be based on an analysis of the best system of 

continuous emission control technology available and the associated emission 

reductions achievable. In addition to considering available technologies, this 

analysis must evaluate five specific factors for each source (better known as the 

Five-Factor Analysis):

1. The costs of compliance,

2. The energy and non-air quality environmental impacts of compliance,

3. Any existing pollution control technology in use at the source,

4. The remaining useful life of the source, and

5. The degree of visibility improvement which may reasonably be 

anticipated from the use of BART.
Maine DEP Bureau of Air Quality 11/28/2011 Page 3 of 8

BART STATUS

 In an effort to establish a consistent BART determination for all BART-eligible 

Maine sources and remove any existing statutory limitations in regulating sulfur 

dioxide as part of a BART determination, in 2007 the Maine Legislature enacted 

enabling legislation establishing deadlines and control requirements for BART 

eligible units in Maine. 38 MRSA §603-A, sub-§8 states:

“8. Best available retrofit technology or BART requirements. For those BART eligible units 

determined by the department to need additional sulfur air pollution controls to improve 

visibility, the controls must:

A. Be installed and operational no later than January 1, 2013; and

B. Either:

(1) Require the use of sulfur oil having 1% or less of sulfur by weight; or

(2) Be equivalent to a 50% reduction in sulfur emissions from a BART eligible unit 

based on a BART eligible unit source emission baseline determined by the 

department under 40 Code of Federal Regulations, Section 51.308 (d)(3)(iii)(2006) 

and 40 Code of Federal Regulations, Section 51 Appendix Y (2006).”

 Pursuant to the above statute the Department issued air emission licenses 

implementing the prescribed BART requirements.

 The draft Regional Haze State Implementation Plan (SIP), including the BART 

determinations, was submitted to EPA and federal land managers in early 2009.

 EPA and the Federal Land Managers provided the Department with comments on 

the draft SIP; and both indicated the state’s legislation adopted in 2007 and the 

BART license amendments did not fully meet the federal BART rule 

requirements of the five factor analysis, and that the proposed Maine regional 

haze SIP submittal did not address all of the regional haze pollutants.

 The Department is currently working with the BART-eligible sources, EPA, and 

the federal land mangers to ensure completion of an approvable Five-Factor 

Analysis. 

FIVE FACTOR BART ANALYSIS

 The first step is identifying the BART eligible sources:

o The Department has identified 25 units at 11 sources as being BART eligible

(Appendix A).

 The next step is determining if any source has the option to accept federally 

enforceable emission restriction limits in their air emission license to stay below 

250 tons per year of SOx, NOx, or PM and thus no longer be a BART-eligible 

source. The Department expects two sources to utilize this option.
Maine DEP Bureau of Air Quality 11/28/2011 Page 4 of 8

 Every source that does not accept a federally enforceable emission limit must 

perform the first four steps (engineering analyses) of the Five Factor Analysis.

o The first part of the analysis is a technical feasibility analysis considering 

existing controls and possible controls. Guidance is found in 40 CFR Part 51 

Appendix Y, Section IV. Generally, if possible controls versus existing 

controls are minimally better at controlling emissions and the impacts of the 

units are relatively small as determined by the NESCAUM modeling

(Appendix B) with the existing controls, BART can be determined to be the 

existing controls and the analysis would be complete. Sources with less than 

0.1 deciview impact on Class 1 areas are presumed to have small impacts. In 

general, if there are emission reduction strategies for units that have minimal 

existing controls then possible further emission reduction control options are 

modeled to determine the most cost effective visibility emission reduction 

strategy that will be determined to be BART.

 Using the first four factors plus the NESCAUM modeling the Department has 

preliminarily determined that 18 of the 25 BART-eligible units have existing 

controls that should satisfy BART technology requirements. These units would 

not be subject to the fifth factor refined modeling analysis. 

 The remaining sources must complete the fifth factor of the Five Factor Analysis 

as detailed in the following table:

Modeling Protocol Options

1 YEAR CALPUFF ANALYSIS OPTION 3 YEAR CALPUFF ANALYSIS OPTION

SUBMIT A CALPUFF/CALMET/CALPOST MODELING PROTOCOL FOR REVIEW with 

detailed discussions of the following elements:

 Model version

 Model switches and procedures

 CALPUFF and CALGRID modeling domains

 Proposed receptors

 Meteorological data inputs

 Geophysical data inputs

 Emission data inputs

CALMET METEOROLOGICAL DATA SET

Use 1 year of MM5 data, with mandatory 

observational data (Mass DEP has 2002 data 

currently processed in this manner) – EPA and 

FLMs have indicated they will accept this option.

Use 3 years of MM5 data with observational 

data - highly recommended by both USEPA and 

FLMs.

PRE-CONTROL EMISSION INPUTS

 Choose highest 24-hour emission rate during normal operating conditions (i.e., excluding 

malfunctions, startups/shutdowns, etc.)

 Choose highest 24-hour emission rate from 3 years of emissions data using years 

representative of current existing controls

 Examine emissions on a pollutant-by-pollutant basis for each BART eligible unit (highest 

24-hour emission rate could potentially be from different days for different pollutants)
Maine DEP Bureau of Air Quality 11/28/2011 Page 5 of 8

MODEL RUNS

For each BART-eligible unit, run CALPUFF at pre-control and all post-control emission rates 

according to the accepted methodology in the CALPUFF modeling protocol

Calculate, for each receptor, the change in 

deciview compared against 20% best visibility

conditions (use new IMPROVE algorithm 

[CALPOST Version 6.221 FLAG 2008 option 

(www.src.com)])

Calculate, for each receptor, the change in 

deciview compared against natural visibility

conditions (use new IMPROVE algorithm 

[CALPOST Version 6.221 FLAG 2008 option 

(www.src.com)])

Use the highest daily predicted change-indeciview for each pre/post-control run

Use the 8th highest daily predicted change-indeciview in each year for each pre/post-control 

run

FINAL SUBMITTAL OF IMPACT ANALYSES

 Submit the final modeling protocol and all model input, output and diagnostic files 

 Develop a chart (or charts) displaying the following for each of the alternatives:

1 - Expected emission rate (tons per year, pounds per hour)

2- Emissions performance level (e.g. percent pollutant removed, emissions per unit product,

 lb/MMBtu, ppm)

3 - Expected emissions reductions (tons per year)

4 - Costs of compliance - total annualized costs ($), cost effectiveness ($/ton), and especially

 a cost-effectiveness measure ($/deciview)

5 - Modeled visibility impacts

6 - Compare results of potential BART controls

EPA FINDING OF FAILURE TO SUBMIT SIP

 On January 9, 2009 EPA signed a Federal Register notice making a finding of 

failure to submit all or a portion of their regional haze SIPs for 37 states, DC, and 

the Virgin Islands. Maine is one of 34 states which failed to submit SIPs that 

satisfy the basic program elements.

 The FR notice initiates a 2-year deadline for EPA to issue a Federal 

Implementation Plan (FIP); the 2-year period is referred to as the “FIP clock”. 

The FIP will provide the basic program requirements for each state that has not 

completed an approved plan of their own by January 15, 2011. EPA must 

approve the State’s plan before the FIP clock is turned off. This notice does not

initiate sanctions.

 The Department expects to submit a complete regional haze plan well before the 

FIP deadline. Since EPA will need a number of months to complete the review 

and approval of the regional haze plan, Maine will need to submit the completed 

plan well in advance of the January 15, 2011 FIP deadline. The Department is 

currently working with the Federal Land Managers and EPA to address concerns 

with its preliminary draft Regional Haze Plan, and expects to hold a public 

hearing and submit its final Regional Haze Plan by January 31, 2010. We believe 

that this schedule will provide sufficient time for a complete review and approval 

of the Maine SIP, including BART analyses. Please submit your analyses to the 

Department by September 15, 2009.
Maine DEP Bureau of Air Quality 11/28/2011 Page 6 of 8

BART REFERENCES

“Five Factor Analysis of BART-Eligible Sources, Survey of Options for Conducting 

BART Determinations”, June 1, 2007, NESCAUM

Informal guidance from EPA on Regional Haze Questions/Answers, August 25, 2006

“BART Resource Guide”, August 23, 2006, NESCAUM

“Assessment of Control Technology Options for BART-Eligible Sources, Steam Electric 

Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities”, March 2005, 

NESCAUM

MANE-VU Board decided in June 2004 that a BART determination would be made for 

all sources, without exception.

“A Basis of Control for BART-Eligible Sources”, July 24, 2001, NESCAUM
Maine DEP Bureau of Air Quality 11/28/2011 Page 7 of 8

Appendix A 

BART Eligible Sources

Wyman Station Boiler #3 (expect full 5 factor analysis)

Boiler #4 (expect full 5 factor analysis)

Domtar Industries Power Boiler #9 

Lime Kiln

Dragon Products Kiln (expect full 5 factor analysis)

Red Shield Acquisition #4 Recovery Boiler

Lime Kiln

Verso Paper Bucksport Boiler #5 (expect 250 TPY restriction)

SAPPI Somerset Lime Kiln

Recovery Boiler

Smelt Tanks #1 and #2

Verso Paper Jay Power Boilers #1 and #2 (expect full 5 factor analysis)

Waste Fuel Incinerator

Recovery Boilers #1 and #2

Smelt Tanks #1 and #2 

Lime Kilns A and B

Flash Dryer 

Katahdin Paper Millinocket Power Boiler #4 (expect 250 TPY restriction)

Lincoln Paper and Tissue Recovery Boiler #2

Rumford Paper Company Power Boiler #5
Maine DEP Bureau of Air Quality 11/28/2011 Page 8 of 8

APPENDIX B: NESCAUM BART-ELIGIBLE SOURCE MODELING RESULTS

Facility Name Stack Name NWS CALPUFF MM5 CALPUFF

Total SO4 NO3 PM10 Total SO4 NO3 PM10

24-hr dv impact 24-hr dv impact

Wyman Station Boiler_4 0.1423 0.1276 0.0334 0.0010 0.4749 0.3846 0.1072 0.0005

Wyman Station Boiler_3 0.2212 0.1715 0.0704 0.0004 0.3049 0.2545 0.0508 0.0014

Domtar Ind. #9_Power_Boiler 1.3630 0.2828 0.7988 1.3134 1.6506 0.1815 0.7279 1.3717

Domtar Ind. Lime_Kiln 0.5296 0.0559 0.4309 0.1207 0.4589 0.0427 0.3820 0.1048

Dragon Products Kiln 2.0155 0.2434 1.7614 0.0604 1.8626 0.3208 1.7234 0.0413

Red Shield 

Acquisition, Old 

Town #4_Recovery_Boiler 0.2425 0.0634 0.1633 0.0173 0.2631 0.0424 0.2070 0.0391

Red Shield 

Acquisition, Old 

Town Lime_Kiln 0.0851 0.0171 0.0433 0.0278 0.1338 0.0138 0.0855 0.0463

Verso, Bucksport Boiler_#5 0.0543 0.0260 0.0267 0.0021 0.1591 0.0817 0.0721 0.0098

SAPPI Somerset Recovery_Boiler 0.2159 0.0151 0.1971 0.0087 0.4421 0.0179 0.4168 0.0158

SAPPI Somerset Smelt_Tanks_#1_and_#2 0.0108 0.0034 0.0000 0.0095 0.0000 0.0000 0.0000 0.0000

SAPPI Somerset Lime_Kiln 0.0380 0.0270 0.0105 0.0012 0.0651 0.0455 0.0187 0.0010

Verso, Jay Power_Boiler_#1 0.6948 0.5720 0.1235 0.0094 1.7631 1.2176 0.5867 0.0290

Verso, Jay Power_Boiler_#2 0.7223 0.5948 0.1287 0.0095 1.8289 1.2646 0.6105 0.0293

Verso, Jay Waste_Fuel_Inc_ 0.4256 0.0036 0.3651 0.0591 0.4956 0.0064 0.4544 0.0367

Verso, Jay Recovery_Boiler_#1_and_#2 0.1101 0.0454 0.0598 0.0078 0.3856 0.0952 0.2723 0.0215

Verso, Jay Smelt_Tank_#1 0.0139 0.0002 0.0000 0.0137 0.0122 0.0002 0.0000 0.0120

Verso, Jay Smelt_Tank_#2 0.0129 0.0004 0.0000 0.0125 0.0135 0.0006 0.0000 0.0129

Verso, Jay Lime_Kiln_A 0.0441 0.0001 0.0273 0.0167 0.0457 0.0004 0.0337 0.0123

Verso, Jay Lime_Kiln_B 0.0296 0.0001 0.0197 0.0098 0.0293 0.0004 0.0228 0.0062

Verso, Jay Flash_Dryer 0.0222 0.0044 0.0173 0.0005 0.0252 0.0097 0.0175 0.0003

Katahdin Paper 

Millinocket PB_#4 0.8293 0.6630 0.1569 0.0210 0.4458 0.3832 0.1164 0.0216

Lincoln Paper and 

Tissue Recovery_Boiler_#2 0.1151 0.0141 0.0806 0.0224 0.1200 0.0073 0.0882 0.0322

Lincoln Paper and 

Tissue Boiler_#6 0.0182 0.0139 0.0047 0.0004 0.0119 0.0075 0.0051 0.0006

Rumford Paper PB_#5 0.0369 0.0039 0.0327 0.0026 0.1025 0.0108 0.0897 0.0020

> 0.1 dv TOTAL and a pollutant > 0.1 dv TOTAL only