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, Meteorolog y Section**  **;**

**Jeff Crawford , Air Planning Section**  **DATE: June 12, 2009**  **SUBJ: BART Summary**  ********************************************* ***********************************



## 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 IFederal areas which impairment results from man - made air pollution. ”

 Maine has three Class I areas: 1) Acadia National Park ; 2) Mooseh orn National Wildlife Refuge Wilderness Area ; and 3) Roosevelt Campobello International Park

 In consultatio n with the states and tribes, EPA designated five Regional Planning Organizations (RPO) to assist with the coordination and cooperation needed to address the h aze issue. The Mid - Atlantic / Northeast states, including the District of Columbia, formed the M id - 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



### B **EST A** **VAILABLE R** **ETROFIT T**  **ECHNOLOGY (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 define d by the EPA as sulfur dioxide (SO 2 ), oxides of nitrogen (NO x) and particles with an aerody namic diameter less than or equal to 10 and 2.5 μm (i.e., PM 10 and PM 2.5 , respectivel y).

 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 reasonabl y be anticipated to cause or contribute to any visibility impairment in a Class I area.

 Once the SIP is approved by the E PA, 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 anal ys is of the best s ystem of continuous emission control technology available and the associated emission reductions achievable. In addition to considering available technologies, this anal ys is must evaluate five specific factors for each source (better known as the F ive - F actor Anal ys is) : 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 reasonabl y be anticipated from the us e 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 a s 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 o f 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 earl y 2009.

 EPA and the Federal Land M anagers 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 m eet 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 w orking 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 2 5 units at 11 sources as being BART e ligible (Appendix A) .  The next step is determining if any source has the option to accept federall y enforceable emission restriction limits in their air emission license to stay below 250 tons per ye ar 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 s ource that does not accept a federally e nforceable emission limit must perform the first four steps (engineering anal ys es) of the Five Factor Anal ysis. o The first part of the analysis is a technical feasibility anal ys is considering existing controls and possible controls. Guidance is found in 40 CFR Part 51 Appendix Y, Section IV. G enerall y, if possible controls versus existing controls are minimally

b etter at controlling emis sions and the impacts of the units are relatively

s mall as determined by the NESCAUM modeling (Appendix B) with the ex isting controls , BART can be determined to be the existing controls and the analysis would be complete. Sources with less than 0.1 decivi ew 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

d etermined that 1 8 of the 2 5 BART - eligible unit s have existing controls that should satisfy BART technology requirements. These units would not be subject to the fifth factor refined modeling anal ys is.

 The remaining sources must complete the fifth factor of the Five Factor Analysis as detailed in the following table :

**Modeling Protocol**  **Option s**  **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 elem ents:**   **Model version**   **Model switches and procedures**  **CALPUFF and CALGR ID modeling domains**   **Proposed r eceptor**  **s**  **Me teorological data inputs**   **Geophysical data inputs**  **Emission data inputs CALMET**  **ME TEOROLOGICAL 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 INPUT S**   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 eli gible 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 ne w 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 ne w IMPROVE algorithm [CALPOST Version 6.221 FLAG 2008 option (www.src.com)]) Use the **highest** daily predicted change - in deciview for each pre/post - control run Use the **8th highest** daily predi cted change - in deciview in each year for each pre/post- control run **FINAL SUBMITTAL OF IMPACT ANALYSES**   **Submit the final modeling protocol and all m odel input**  **, output**  **and diagnostic files**   D evelop a chart (or charts) displaying the following for each of the alternatives : 1 - Expected emission rate (tons per year, pounds per ho ur) 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 comp liance - total annualized costs ($), cost effectiveness ($/ton), and especially a cost - effectiveness measure ($/deciview) 5 - Modeled visibility impacts 6 - Com pare results of potential BART controls 

### EPA FINDING OF FA**I LURE 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. M aine is one of 34 states which failed to submit SIPs that satisfy the basic program elements .  The FR notice initiates a 2 - ye ar 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 J anuary 15, 2011. E PA 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 1 5, 2011 FIP deadline. The Department is currentl y 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 anal ys es to the Department b y September 15, 2009.Maine DEP Bureau of Air Quality 11/28/2011 Page 6 of 8



### BART REF **E RENCES**  “Five Factor Anal ys is of BART - Eligible Sources, Survey of Options for Conducting BART Determination s”, June 1, 2007, NESCAUM In formal 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, NESCAUMMaine DEP Bureau of Air Quality 11/28/2011 Page 7 of 8 

### Appendix A BART Eligible Sources Wy man 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) SAPPISomerset 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 Boil er #2 Rumford Paper Company Power Boiler #5Maine DEP Bureau of Air Quality 11/28/2011 Page 8 of 8

**APPENDIX B**  **: NESCAUM BART -**  **ELIGIBLE SOURCE MODELING RESULTS Facility**  **Name Stack Name**  **NW S CA** **LPUFF MM5 CA** **LPUFF Total**  **SO4 NO3**  **PM10 Total**  **SO4 NO3**  **PM10**

**24 -**  **hr dv impact 24**  **- hr dv impact**  **Wy man Station**  **Boi ler_4**  **0.1423 0.1276**  **0.0334 0.0010**  **0.4749 0.3846**  **0.1072 0.0005**  **Wy man 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**  **Ac quisition,**  **Old Tow**  **n #4_Recovery**  **_Boiler 0.2425**  **0.0634 0.1633**  **0.0173 0.2631**  **0.0424 0.2070**  **0.0391 Red Shield**  **Ac quisi**  **tion, Old**  **Tow n**  **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**  **SA PPI Somerset**  **Recovery _Boiler**  **0.2159 0.0151**  **0.1971 0.0087**  **0.4421 0.0179**  **0.4168 0.0158**  **SA PPI Somerset**  **Smelt_Tanks_#1_and_#2 0.0108**  **0.0034 0.0000**  **0.0095 0.0000**  **0.0000 0.0000**  **0.0000 SA** **PPI 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**  **Vers o**  **, Jay Lime_Kiln_B**  **0.0296 0.0001**  **0.0197 0.0098**  **0.0293 0.0004**  **0.0228 0.0062**  **Verso , Jay**  **Flash_Dry er**  **0.0222 0.0044**  **0.0173 0.0005**  **0.0252 0.0097**  **0.0175 0.0003**  **Katahdin Paper Millinoc**  **ket PB_#4**  **0.8293 0.6630**  **0.1569 0.0210**  **0.4458 0.3832**  **0.1164 0.0216**  **Lincoln Pa per and**  **Tissu e**  **Recover y**  **_Boiler_#2 0.1151**  **0.0141 0.0806**  **0.0224 0.1200**  **0.0073 0.0882**  **0.0322 Lincoln Paper and**  **Tissu e**  **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**  **0.00 20**  **> 0.1 dv TOTA L and a pollutant**  **> 0.1 dv TOTA L only**