BART Modeling Protocol: 

Plant Kraft 

Prepared by: 

Southern Company Services and ENSR Corporation 

for Savannah Electric and Power Company 

May 2006
Contents 

1.0 Introduction............................................................................................................................................... 1-1

1.1 Objectives ........................................................................................................................................ 1-1

1.2 Location of source vs. relevant Class I Areas ................................................................................ 1-1

1.3 Organization of protocol document................................................................................................. 1-1

2.0 Source description and emissions data ............................................................................................... 2-1

2.1 Unit-specific source data................................................................................................................. 2-1

3.0 Input data to the CALPUFF model ......................................................................................................... 3-1

3.1 General modeling procedures: ....................................................................................................... 3-1

3.2 Air quality database (background ozone and ammonia) ............................................................... 3-1

3.3 Natural conditions and monthly f(RH) at Class I Areas ................................................................. 3-1

4.0 Air quality modeling procedures ........................................................................................................... 4-1

4.1 Model selection and features.......................................................................................................... 4-1

4.2 Modeling domain and receptors ..................................................................................................... 4-1

4.3 Technical options used in the modeling ......................................................................................... 4-1

4.4 Light extinction and haze impact calculations ................................................................................ 4-2

5.0 Presentation of modeling results........................................................................................................... 5-1

Appendix A Basis for Source-Specific Sulfuric Acid Emissions for BART Baseline Case..............A-1 

Appendix B Field Observational Information for Secondary Organic Aerosols ................................B-1 

i 051006 Kraft BART Modeling Protocol.doc May 2006
List of Tables 

Table 2-1 Plant Kraft modeling emission parameters.............................................................................. 2-3

List of Figures 

Figure 1-1 Location of PSD Class I Areas in relation to Plant Kraft ......................................................... 1-2

ii 051006 Kraft BART Modeling Protocol.doc May 2006
1.0 Introduction 

1.1 Objectives 

The Regional Haze Rule requires Best Available Retrofit Technology (BART) for any BART-eligible source that 

‘‘emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of 

visibility” in any mandatory Class I federal area. Pursuant to federal regulations, states have the option of 

exempting a BART-eligible source from the BART requirements based on dispersion modeling demonstrating 

that the source cannot reasonably be anticipated to cause or contribute to visibility impairment in a Class I 

area. In addition, the Environmental Protection Agency (EPA) has promulgated a rule allowing states subject 

to the Clean Air Interstate Rule (CAIR) to determine that CAIR satisfies the BART requirements for SO2 and 

NOx for electric generating units (EGUs). Preliminary feedback from the Georgia Environmental Protection 

Division indicates that they anticipate making the decision that CAIR satisfies BART for SO2 and NOx for 

EGUs. Therefore, this modeling protocol focuses on performing the BART modeling analysis for particulate 

matter (PM) only. 

Units 3 and 4 at Plant Kraft, located near Savannah, which is owned and operated by Savannah Electric and 

Power Company∗

, has been identified as a BART-eligible source. The purpose of this document is to 

summarize the procedures by which a modeling analysis will be conducted for this source. The modeling 

procedures outlined will be used to determine whether the source is subject to BART requirements (exemption 

modeling). If it is determined that the source is subject to BART, then the procedures will be used to evaluate 

the visibility improvement factor in the BART determination step (determination modeling). The modeling 

procedures are consistent with those outlined in the updated final VISTAS common BART modeling protocol 

(dated December 22, 2005, revision 2 – 3/9/06), available at http://www.vistassesarm.org/BART/BARTModelingProtocol_rev2_9Mar2006.pdf. This source-specific BART modeling protocol 

references relevant portions of the common VISTAS modeling protocol. 

1.2 Location of source vs. relevant Class I Areas 

The Georgia Environmental Protection Division, which is in charge of the state’s BART program, has 

determined that units 3 and 4 at Plant Kraft are BART-eligible for PM. Figure 1-1 shows a plot of Plant Kraft 

relative to nearby Class I Areas. There are three Class I areas within 300 km of the plant: Cape Romain, 

Okefenokee, and Wolf Island. The BART exemption modeling will be conducted for each of these Class I 

areas in accordance with the referenced VISTAS common BART modeling protocol and the procedures 

described in this source-specific BART modeling protocol. If necessary, visibility improvement modeling for 

the BART determination step will be performed for those Class I areas where the exemption modeling shows a 

greater than 0.5 deciview impact. 

1.3 Organization of protocol document 

Section 2 of this protocol describes the source emissions that will be used as input to the BART exemption 

modeling and, if necessary, the BART determination modeling. Section 3 describes the input data to be used 

for the modeling including the modeling domain, terrain and land use, and meteorological data. Section 4 

describes the air quality modeling procedures and Section 5 discusses the presentation of modeling results. 

Since all of the references cited are also included in the VISTAS common BART modeling protocol (Section 

7.), no additional references section is included in this document. Appendix A and B provide additional 

information on the baseline source emissions. 

 

∗

 When the Georgia Power and Savannah Electric merger is completed within the next few months, these units will be 

owned and operated by Georgia Power Company. 

1-1 May 2006 051006 Kraft BART Modeling Protocol.doc
Figure 1-1 Location of Class I Areas in Relation to Plant Kraft 

1-2 May 2006 051006 Kraft BART Modeling Protocol.doc
2.0 Source description and emissions data 

2.1 Unit-specific source data 

The emissions data used to assess the visibility impacts at the Class I areas within 300 km of Plant Kraft is 

discussed in this section. As noted earlier, indications from the Georgia Environmental Protection Division are 

that they will issue rules stating that CAIR will suffice for EGU BART for SO2 and NOx. Therefore, this protocol 

focuses only on PM10. Since various components of PM10 emissions have different visibility extinction 

efficiencies, the PM10 emissions are divided, or “speciated,” into several components (VISTAS common 

protocol Sections 4.3.3 and 4.4.2). The VISTAS protocol (Section 5.) allows for the use of source-specific 

emissions and speciation factors or default values from AP-42. For the Kraft 3 coal-fired unit, where default 

speciation values are used, the data represents a unit where current (baseline) emission controls include 

electrostatic precipitators (ESPs), but no post-combustion NOx or SO2 control equipment exists. The PM10

emissions and speciation approach to be used for Kraft 3 is indicated in the bullets below. 

• Total PM10 is comprised of filterable and condensable emissions. 

• Baseline filterable PM10 emissions are based on the highest stack test for the most recent 3-year 

period (2003-2005). This stack test is combined with the highest 24 hour heat input value for this 

period from CEMS data to calculate the “maximum 24 hour average emission rate” as required by 

the VISTAS protocol. 

• Filterable PM10 will be subdivided by size category consistent with the default approach from AP42 Table 1-1.6, and as noted on pages 41 and 42 of the VISTAS common BART modeling 

protocol. The AP-42 Table 1-1.6 specifies for the emission controls indicated above that 55.6% of 

filterable PM10 emissions is coarse (greater than 2.5 microns in size) and 44.4% is fine. Of the 

fine portion, 3.7% is elemental carbon and the remainder is inorganic fine particulates (soil). 

• Condensable PM10 consists of inorganic and organic compounds. The inorganic portion is by 

default assumed to be H2SO4, although other non-sulfate inorganic condensables could be 

present. The organic portion is modeled as secondary organic aerosols. 

• Baseline H2SO4 emissions are calculated consistent with the method used by Southern Company 

to derive these emissions for TRI purposes. This approach assumes that the H2SO4 emissions 

released from the stack are proportional to SO2 emissions from combustion and are dependent on 

the fuel type and the removal of H2SO4 by downstream equipment (i.e., ESP and air heater). For 

eastern bituminous coal the baseline H2SO4 release rate is in the range of 0.3 to 0.4% of the SO2

emissions. Appendix A will provide the basis for the site-specific value used. 

• Baseline emissions of secondary organic aerosols (the remaining portion of condensable PM10) 

are derived based on the supporting field observational information in Appendix B and will be a 

function of SO2 emitted. 

Kraft 4 has can fire either natural gas or #6 oil. Since the highest emission rates for Kraft 4 occur when #6 oil 

is fired, where default speciation values are used they are based on this fuel. The PM10 emissions and 

speciation approach to be used for Kraft 3 is indicated in the bullets below. 

• Total PM10 is comprised of filterable and condensable emissions. 

• Since stack tests are not performed for Kraft 4, baseline filterable PM10 emissions are based on 

AP-42 emissions factors and the highest 24 hour heat input for the most recent 3-year period 

(2003-2005). This results in the “maximum 24 hour average emission rate” as required by the 

VISTAS protocol. 

2-1 May 2006 051006 Kraft BART Modeling Protocol.doc
• Filterable PM10 will be subdivided by size category consistent with the default approach from AP42 Table 1-3.4, and as noted on pages 41 and 42 of the VISTAS common BART modeling 

protocol. The AP-42 Table 1-3.4 specifies for an uncontrolled boiler that 26.8% of filterable PM10

emissions is coarse (greater than 2.5 microns in size) and 73.2% is fine. Of the fine portion, 7.4% 

is elemental carbon and the remainder is inorganic fine particulates (soil). 

• Condensable PM10 consists of inorganic and organic compounds. The inorganic portion is by 

default assumed to be H2SO4, although other non-sulfate inorganic condensables could be 

present. The organic portion is modeled as secondary organic aerosols. 

• Baseline H2SO4 emissions are calculated consistent with the method used by Southern Company 

to derive these emissions for TRI purposes. This approach assumes that the H2SO4 emissions 

released from the stack are proportional to SO2 emissions from combustion and are dependent on 

the fuel type and the removal of H2SO4 by downstream equipment (i.e., Kraft 4 includes air 

heater). Appendix A provides the basis for the site-specific value used. 

• Baseline emissions of secondary organic aerosols (the remaining portion of condensable PM10) 

are derived consistent with the default approach based on AP-42 Table 1.3-2 (i.e., 0.225 lb/1000 

gal). 

In practice, CALPUFF allows for the user to input certain components of PM10 as separate species and 

separate sizes, which will result in more accurate wet and dry deposition velocity results and also more 

accurate effects on light scattering. As noted above, the particle size distribution information is provided in 

AP-42 Tables 1-1.6 and 1-3.4, and will be used for the BART exemption modeling as well as the BART 

determination modeling, if needed. 

Table 2-1 provides a summary of the modeling emission parameters to be used in the BART CALPUFF 

modeling, consistent with the source emissions data presented in Appendix A for the baseline. All of the 

emissions for Kraft 3 in Table 2-1 were extracted from CEMS data for the 2003 to 2005 period and represent 

the maximum 24-hour average lb/hr rates (excluding days where startup, shutdown, or malfunctions occurred). 

For NOx and SO2 the values are directly from CEMS. Filterable PM10 emissions were calculated using the 

highest stack test over the 2003 to 2005 period and multiplying these value times the maximum 24-hour 

average heat input derived from CEMS. These values were then adjusted using AP-42 factors from Table 1.1-

6 that indicate that PM10 is 67% of total PM for a PC unit with an ESP. PM10 speciation was then performed as 

indicated above. 

For Kraft 4, baseline emission values for NOx, SO2, and PM10 are based on AP-42 factors for a #6 oil-fired 

boiler considering the highest 24 hour heat input for the most recent 3-year period (2003-2005). PM10

speciation was then performed as indicated above. 

If the BART exemption modeling indicates that a BART determination is required, then one or more particulate 

matter control options will be considered for the modeling to determine visibility improvement from the baseline 

case. The BART engineering analysis will provide the justifications for the selected, technically feasible 

options and the species-specific control efficiencies. Table 2-1 will be updated to provide the modeling 

parameters for these feasible options and resubmitted to the Georgia Environmental Protection Division for 

review. Any site-specific deviations from the default particulate matter speciation guidance would be outlined 

at that time. 

2-2 May 2006 051006 Kraft BART Modeling Protocol.doc
2-3 

051006 Kraft BART Modeling Protocol.doc

Table 2-1 Plant Kraft modeling emission parameters 

Location UTM 

(Zone 17 NAD-83) Emissions1 P

Case Source / Unit UTM 

East 

UTM 

North 

Stack 

Ht 

Base 

Elev. 

Diameter Gas Exit Vel. Stack Gas Exit Temp. SO2 NOX PM10 Filt. PM10 Fine PM 

km km m ft m m/s deg K lbs/hr lbs/hr lbs/hr lbs/hr lbs/hr 

Plant Kraft current 

Baseline Unit 3 486,248 3,556,917 83.8 5 6.7 17.8 413.6 1828 754 45.8 40.4 17.9 Baseline Unit 4 486,248 3,556,917 83.8 5 6.7 17.8 413.6 2774 212 185.2 131.3 96.1 

Plant Kraft future, if BART is required4Control 1 Unit 3 

È Unit 3 

Control n Unit 3 Control 1 Unit 4 

È Unit 4 

Control n Unit 4 

1 SO2 and NOx emissions are not BART-applicable for EGU sources in CAIR states, if the state agency agrees with EPA’s interpr

rule. The emissions for SO2 and NOx are provided for information purposes, and for reference in the computation of certain par

2 Elemental carbon (EC) and Fine PM are a part of Filterable PM10 and H2SO4 and Organics are a part of Condensable PM10. 3 Total Condensable PM10 = H2SO4 + Organic. The Organic emission value will be provided later. 4 This data will be provided later if a BART determination analysis is required. 
3.0 Input data to the CALPUFF model 

3.1 General modeling procedures: 

VISTAS has developed five sub-regional 4-km CALMET meteorological databases for three years (2001-

2003) (VISTAS common protocol Section 4.4.2). The sub-regional modeling domains are strategically 

designed to cover all potential BART eligible sources within VISTAS states and all PSD Class I areas within 

300 km of those sources (to the nearest edge). The extents of the 4-km sub-regional domains are shown in 

Figure 4-4 of the VISTAS common BART modeling protocol. The BART modeling for Plant Kraft will be done 

using the 4-km subdomain 4. 

USGS 90-meter Digital Elevation Model (DEM) files were used by VISTAS to generate the terrain data at 4-km 

resolution for input to the 4-km sub-regional CALMET run. Likewise, USGS 90-meter Composite Theme Grid 

(CTG) files were used by VISTAS to generate the land use data at 4-km resolution for input to the 4-km subregional CALMET run. 

Three years of MM5 data (2001-2003) were used by VISTAS to generate the 4-km sub-regional 

meteorological datasets. See Sections 4.3.2 and 4.4.2 in the VISTAS common BART modeling protocol for 

more detail on these issues. 

It is intended that all of the modeling for Plant Kraft will use the 4-km subdomain 4. However, if the results 

indicate that the modeling could be improved with a CALPUFF run using a finer grid, then refinements in the 

modeling procedures will be considered and the Georgia Environmental Protection Division will be asked to 

approve these refinements. 

In the event that a finer grid resolution is used, CALMET must be rerun. Other modifications to inputs of 

CALMET would include the extent of the modeling domain, the resolution of the terrain and land use data, and 

other relevant settings. The same MM5 data and observations as used for the 4-km sub-regional CALMET 

simulations would be used. The extent of the modeling domain may need to be changed because of disk 

space restrictions. The size of the CALMET output is directly proportional to the grid resolution of the run. The 

domain would be limited to the source and the exclusive Class I area(s) being assessed with a higher grid 

resolution, including a 50-km buffer in all directions. 

If CALMET needs to be run at even a finer grid resolution, then the appropriate model setting/files (specifically 

the GEO.DAT file) will be modified. A summary of these modifications would be provided to the Georgia 

Environmental Protection Division for review and approval. 

3.2 Air quality database (background ozone and ammonia) 

Hourly measurements of ozone from all non-urban monitors, as generated by VISTAS and available on the 

VISTAS CALPUFF page on the Earth Tech web site (http://www.src.com/verio/download/sample_files.htm), 

will be used as input to CALPUFF. For ammonia, the approach recommended by VISTAS will be followed. 

However, since only PM emissions are being modeled, ozone and ammonia data is not really needed given 

that this data has no affect on PM results in CALPUFF. 

3.3 Natural conditions and monthly f(RH) at Class I Areas 

For each of the applicable Class I areas, natural background conditions must be established in order to 

determine a change in natural conditions related to a source’s emissions. The modeling described by this 

protocol document intends to use annual average natural background light extinction (EPA 2003 values). 

3-1 May 2006 051006 Kraft BART Modeling Protocol.doc
To determine the input to CALPUFF, it is first necessary to convert the deciviews to extinction using the 

equation: 

Extinction (Mm-1) = 10 exp(deciviews/10). 

For example, the EPA guidance document indicates for Great Smoky Mountains National Park that the 

deciview value for the average of the days is 7.60. This is equivalent to an extinction of 21.38 inverse 

megameters (Mm-1). 

This extinction includes the default 10 Mm-1 for Rayleigh scattering. The remaining extinction is due to 

naturally occurring particles, and should be held constant for the entire year’s simulation. Therefore, the data 

provided to CALPOST for Great Smoky Mountains would be the total natural background extinction minus 10 

(expressed in Mm-1), or 11.38. This is most easily input as fine soil concentrations (11.38 μg/m3) in 

CALPOST, since the extinction efficiency of soil (PM-fine) is 1.0 and there is no f(RH) component. The 

concentration entries for all other particle constituents would be set to zero, and the fine soil concentration 

would be kept the same for each month of the year. The monthly values for f(RH) that CALPOST needs will 

be taken from "Guidance for Tracking Progress Under the Regional Haze Rule" (EPA, 2003) Appendix A, 

Table A-3. 

3-2 May 2006 051006 Kraft BART Modeling Protocol.doc
4.0 Air quality modeling procedures 

This section provides a summary of the modeling procedures outlined in the VISTAS protocol that will be used 

for the refined CALPUFF analysis to be conducted for Plant Kraft. 

4.1 Model selection and features 

As noted in the VISTAS protocol (Summary, Recommendations Section II.), VISTAS will use CALPUFF 

Version 5.754 and CALMET Version 5.7, which can be obtained at 

http://www.src.com/verio/download/download.htm#VISTAS_VERSION. These versions contain 

enhancements funded by the Minerals Management Service (MMS) and VISTAS. They were developed by 

Earth Tech, Inc. and they are maintained on Earth Tech’s Atmospheric Studies Group CALPUFF website for 

public access. This release includes CALMET, CALPUFF, CALPOST, CALSUM, and POSTUTIL as well as 

CALVIEW. 

The major features of the CALPUFF modeling system, including those of CALMET and the post processors 

(CALPOST and POSTUTIL), are referenced in Section 3 of the VISTAS protocol. 

4.2 Modeling domain and receptors 

The initial Plant Kraft BART runs will use the sub-domain 4, 4-km CALMET data to be supplied by VISTAS, as 

discussed above. This domain includes all Class I areas within 300 km of the source, plus a 50-km buffer. If 

there is the need for a refined analysis with a finer grid, a supplement to this modeling protocol will be provided 

describing the proposed procedures. 

The receptors used for each of the Class I areas are based on the NPS database of Class I receptors, as 

recommended by the VISTAS common protocol (Section 4.3.3). 

The BART exemption modeling will be conducted for Kraft units 3 and 4 (BART eligible units) for each Class I 

area within 300 km of the source. If necessary, unit 3 and 4 will each be modeled separately for the visibility 

improvement modeling for the BART determination step for the Class I areas where exemption modeling 

shows a greater than 0.5 deciview impact. 

4.3 Technical options used in the modeling 

CALMET modeling for the VISTAS-provided 4-km subdomains will be performed per the procedures specified 

in the VISTAS common BART modeling protocol. If it is decided to conduct additional modeling with a finer 

grid than 4 km, this modeling protocol will be updated to specify the technical options to be used in the 

CALMET run, in order to allow for state agency review and approval . 

For CALPUFF model options, Plant Kraft will follow the VISTAS common BART modeling protocol (Section 

4.4.1), which states that we should use IWAQM (EPA, 1998) guidance. The VISTAS protocol (Section 4.3.3) 

also notes that building downwash effects are not required to be included unless the state directs the source to 

include these effects. Since Plant Kraft is more than 50 km from the nearest Class I area, building downwash 

effects will not be included in the CALPUFF modeling. 

The POSTUTIL utility program (VISTAS common protocol Section 4.4.2) will be used to repartition HNO3 and 

NO3 using VISTAS-provided ammonia concentrations derived from previous 2002 CMAQ modeling conducted 

by EPA or the alternate ammonia concentrations approach recommended by VISTAS, if the CMAQ data is 

unavailable. As indicated earlier, since only PM emissions are being modeled, the treatment of ammonia 

should not have an affect on PM results from CALPUFF. 

4-1 May 2006 051006 Kraft BART Modeling Protocol.doc
4.4 Light extinction and haze impact calculations 

The CALPOST postprocessor will be used as prescribed in the VISTAS protocol for the calculation of the 

impact from the modeled source’s primary and secondary particulate matter concentrations on light extinction. 

The formula that is used is the existing (not the November 2005 revised) IMPROVE/EPA formula, which is 

applied to determine a change in light extinction due to increases in the particulate matter component 

concentrations. Using the notation of CALPOST, the formula is the following: 

bext = 3 f(RH) [(NH4)2SO4] + 3 f(RH) [NH4NO3] + 4[OC] + 1[Soil] + 0.6[Coarse Mass] + 10[EC] + bRay

The concentrations, in square brackets, are in ug/m3 and bext is in units of Mm-1. The Rayleigh scattering term 

(bRay) has a default value of 10 Mm-1, as recommended in EPA guidance for tracking reasonable progress 

(EPA, 2003a). However, as recommended in the VISTAS protocol (Section 6.2.4), for refined 4-km grid (or 

smaller) CALPUFF runs, the Rayleigh scattering term will be modified for the specific elevation of the Class I 

area receptors. The Rayleigh term for estimating natural background will also, be adjusted to be consistent 

with this approach. 

The assessment of visibility impacts at the Class I areas will use CALPOST Method 6 (VISTAS common 

protocol Section 4.3.2). Each hour’s source-caused extinction is calculated by first using the hygroscopic 

components of the source-caused concentrations, due to ammonium sulfate and nitrate, and monthly Class I 

area-specific f(RH) values. The contribution to the total source-caused extinction from ammonium sulfate and 

nitrate is then added to the other, non-hygroscopic components of the particulate concentration (from coarse 

and fine soil, secondary organic aerosols, and from elemental carbon) to yield the total hourly source-caused 

extinction. 

The BART rule significance threshold for the contribution to visibility impairment is 0.5 deciviews. The VISTAS 

protocol (Section 4.3.2) indicates that with the use of the 4-km sub-regional CALMET database, a source does 

not cause or contribute to visibility impairment if the 98th percentile (or 8th highest) day’s change in extinction 

from natural conditions does not exceed 0.5 deciviews for any of the modeled years (an added check is: the 

22nd highest prediction over the three years modeled should also not exceed 0.5 deciviews for a source to be 

exempted from a BART determination). Both the 98th percentile (or 8th highest) day's change in extinction 

from natural conditions for any modeled year and the 22nd highest prediction over the three years modeled 

will be evaluated. The maximum impact from each method must should not exceed 0.5 deciviews for the 

source to be exempted from a BART determination. 

Figure 4-1 of the VISTAS common BART modeling protocol presents a flow chart showing the components of 

that modeling protocol for the analysis to determine whether a source is subject to BART. Again, it should be 

noted that the modeling for Plant Kraft will focus on Subregional Fine-Scale modeling as depicted in the lower 

half of the figure. 

If the exemption modeling demonstrates that Plant Kraft does not cause or contribute to visibility impairment, 

then the source will not be subject to BART requirements, and no further analysis is needed. Otherwise, the 

source will proceed to perform BART determination modeling for the baseline and each control option in a 

similar manner as has been described in this document. This protocol will be supplemented with a revised 

Table 2-1 if the source is determined to be subject-to-BART. 

4-2 May 2006 051006 Kraft BART Modeling Protocol.doc
5.0 Presentation of modeling results 

The BART exemption and, if necessary, the BART determination modeling results for Plant Kraft will be 

provided to the state agency in a manner as described in the VISTAS protocol (Section 4.5). A report will be 

produced that includes the following elements (as suggested in the VISTAS protocol): 

1. A map of the source location and Class I areas within 300 km of the source. 

2. For the CALPUFF modeling domain, a table listing all Class I areas in the VISTAS domain and those 

in neighboring states and impacts from the BART 4-km grid exemption modeling at those Class I 

areas within 300 km of the source, as illustrated in Table 4-3 of the VISTAS protocol. 

3. A discussion of the number of Class I areas with visibility impairment due to source emissions for the 

98th percentile days in each year (and the 98th percentile over all three years modeled) greater than 

0.5 dv. 

4. For the Class I area with the maximum impact, a discussion of the number of days beyond those 

excluded (e.g., the 98th percentile for refined analyses) that the impact of the source exceeds 0.5 

dv, the number of receptors in the Class I area where the impact exceeds 0.5 dv, and the maximum 

impact. 

5. For any finer grid CALPUFF exemption modeling, results for those Class I areas for which impacts of 

the source exceeded 0.5 dv in the 4-km initial modeling. We would report the same type of results 

as provided for 4-km exemption modeling. 

The BART determination modeling will be performed for those Class I areas shown in the exemption modeling 

to exceed 0.5 dv impact. The extent of the BART determination modeling results will depend on the number of 

technically viable controls identified in the engineering analysis phase of the BART assessment. The results 

presented will be a comparison of the 98th percentile value for the baseline and each control strategy derived 

as is outlined above for the exemption modeling. The same statistics as those mentioned above in Steps 3 

and 4 would be provided, and a summary of the relative results among all emission scenarios run would be 

produced. 

Additionally, the appropriate electronic files used to conduct the CALPUFF modeling will be submitted on CDROM or DVD media. 

5-1 May 2006 051006 Kraft BART Modeling Protocol.doc
Appendix A 

Basis for Source-Specific Sulfuric Acid Emissions for BART 

Baseline Case 

051006 Kraft BART Modeling Protocol.doc A-1 May 2006
Appendix A 

Basis for Source-Specific Sulfuric Acid Emissions for BART Baseline Case 

Sulfuric Acid (H2SO4) Emissions

During the combustion of sulfur-containing fuels, a percentage of the SO2 formed is further oxidized to SO3. 

As the flue gas cools across the air heater, this SO3 combines with flue gas moisture to form vapor-phase 

and/or condensed sulfuric acid (H2SO4). The baseline H2SO4 emissions shown in Table 2-1 of this BART 

modeling protocol were calculated consistent with the method used by Southern Company to derive these 

emissions for Toxics Release Inventory (TRI) purposes. This method is documented in a report entitled 

Estimating Total Sulfuric Acid Emissions from Stationary Power Plants: Revision 3 (2005) prepared by Keith 

Harrison and Dr. Larry Monroe (Southern Company Services) and Edward Cichanowicz (Consultant). The 

approach described in this report assumes that H2SO4 emissions released from the stack are proportional to 

SO2 emissions from combustion and are dependent on the fuel type and the removal of H2SO4 by downstream 

equipment (i.e., ESP and air heater). 

The calculations below show baseline sulfuric acid emissions that are expected. Since this facility does not 

contain post combustion emissions controls, the baseline sulfuric acid emissions estimate only accounts for 

the manufacture of H2SO4 through combustion and loss or removal within the system. 

Sulfuric Acid Manufactured from Combustion (EMComb): 

EMComb = K x F1 x E2 

where, 

EMComb = total sulfuric acid manufactured from combustion, lbs/yr 

K = Molecular weight and units conversion constant = 98.07 / 64.04 * 2000 = 3,063 

(98.07 = Molecular weight of sulfuric acid; 64.04 = Molecular weight of SO2; Conversion from tons per 

year to pounds per year – multiply by 2000.) 

F1 = Fuel Impact Factor (from the emissions estimating report) 

E2 = Sulfur dioxide emissions, tons (from CEMS data). 

Sulfuric Acid Manufactured from Combustion is: 

Kraft 3: 

EMComb = 3,063 x 0.008 x 1,828.5 lbs/hr / 2000 = 22.4 lbs/hr 

Kraft 4: 

EMComb = 3,063 x 0.025 x 2,774.8 lbs/hr / 2000 = 106.2 lbs/hr 

Sulfuric Acid Released from Combustion (ERComb) 

Kraft 3 

ERComb = EMComb x F2 (technology impact factors for air heater and ESP) 

ERComb = EMComb x (0.49) x (0.49) 

ERComb = 22.4 lbs/hr x (0.24) = 5.4 lbs/hr 

Kraft 4: 

ERComb = EMComb x F2 (technology impact factor for air heater) 

ERComb = EMComb x (0.49) 

ERComb = 106.2 lbs/hr x (0.49) = 52.1 lbs/hr 

051006 Kraft BART Modeling Protocol.doc A-2 May 2006
Appendix B 

Field Observational Information for Secondary Organic Aerosols 

(To Be Provide Later) 

051006 Kraft BART Modeling Protocol.doc B-1 May 2006