Attachment H6 

BART Analyses 

Solutia, Inc 

International Paper- Courtland Mill 
Best Available Retrofit Technology Analysis 

Solutia, Inc. 

712-0010 

On December 19, 2006, Solutia, Inc. located in Decatur, Alabama submitted a Best 

Available Retrofit Technology (BART) analysis. Revised analyses containing additional 

information were received on January 25, 2007, March 22, 2007, and May 7, 2007. 

Solutia identified its BART-eligible emission units to include three coal-fired boilers (No. 

5, No. 6, and No. 7) and two coking units (Coker Boilers No. 1 and No. 2). The results of 

the BART modeling analysis for these units indicated the predicted visibility impacts at 

the Sipsey Wilderness Area, a Class I Area, were above 0.5 deciviews (dV). Therefore, 

Solutia submitted an analysis of alternative control options for its BART-eligible units for 

the following pollutants: particulate matter (PM), sulfur dioxide (SO2), and nitrogen 

oxides (NOx). 

The case-by-case engineering analysis takes into account the following six factors in 

making the determination of any BART controls and limitations: 

1) Available retrofit control options 

2) Any pollution control equipment in use at the source 

3) The costs of compliance with control options 

4) The remaining useful life of the facility 

5) The energy and non-air quality environmental impacts of control options 

6) The visibility impacts analysis 
Existing Equipment

Currently, each BART-eligible unit (i.e. three boilers and two coking units) has 

electrostatic precipitators (ESPs) for PM control. For Boiler No. 7, Solutia has installed 

the ROFA (rotating opposed fired air) system to reduce NOx formation. Although the 

basis for the installation of the ROFA system for Boiler No.7 was the Boiler MACT, the 

system has been installed and was considered as existing equipment in regards to this 

case-by-case BART analysis. 

Particulate Matter Emissions

Solutia indicated that the primary available control options for PM would include ESPs, 

baghouses, wet scrubbers, cyclones, and side stream separators. As previously stated, 

Solutia’s BART-eligible boilers and coking units are each equipped with an ESP. For 

Boilers 5&6, stack tests have shown an overall PM control efficiency for the ESPs to be 

98.8%. For Boiler 7, the PM control efficiency has been estimated from stack tests as 

99%. Although the coking boilers have not been the tested, the PM control efficiency 

from the ESPs has been estimated at 96%. 

Typically, the collection efficiency of a baghouse can be as high as 99.9%. The other 

control technologies (wet scrubbers, cyclones, etc.) have lower collection efficiencies 

than baghouses and ESPs. Solutia evaluated the option of adding a baghouse to each of 

the boilers and coking units following the existing ESPs. 

BART Unit Control 

Option 

Tons 

Removed 

Cost/Ton 

Removed 

98th Percentile 24-Hr 

Visibility Improvement 

Boiler 5 Baghouse 21.5 $79,995 0.211

Boiler 6 Baghouse 44.96 $38,316 0.21 
Boiler 7 Baghouse 409.57 $5462 0.52 

Coker 1 Baghouse 120 $13,709 0.19 

Coker 2 Baghouse 120 $13,709 0.19 

1-Boiler 5 is the same type of boiler as Boiler 6 but with a lower rated capacity. Modeling was not 

conducted for Boiler 5 but was assumed to have the same results as Boiler 6. 

Nitrogen Oxides (NOx)

Solutia indicated that the primary available control options for NOx would be categorized 

as combustion controls and post-combustion controls. The available combustion control 

options would include low excess air, burners out of service, biased burner firing, 

overfired air, low NOx burners, and reburn. Available post-combustion control options 

would include selective non-catalytic reduction (SNCR) and selective catalytic reduction 

(SCR). As previously stated, Solutia has installed a ROFA system on its No. 7 Boiler. 

The manufacture has guaranteed a NOx reduction of 48% with the system. 

For each unit, Solutia has indicated that the available and technically feasible control 

options would include 1) the ROFA system with a SNCR for each unit and 2) SCR. The 

SNCR (called Rotamix) would provide an additional 30% reduction of NOx as compared 

to the ROFA system alone. The typical NOx control efficiency from the SCR is 95%. 

The evaluation of NOx controls for each BART-eligible unit is shown in the table below: 

BART Unit Control Option Tons 

Removed 

Cost/Ton 

Removed 

98th Percentile 24-Hr 

Visibility Improvement 

Boiler 5 ROFA with 

SNCR(Rotamix) 

52.84 $15,529 01

Boiler 5 SCR 86.54 $8,675 01

Boiler 6 ROFA with 

SNCR(Rotamix) 

57.28 $18,091 0 

Boiler 6 SCR 93.81 $5,461 0 

Boiler 7 SNCR(Rotamix)2 217.35 $4,118 0 
Boiler 7 SCR2 654.84 $1,986 0 

Coker 1 ROFA with 

SNCR(Rotamix) 

265 $4,510 0 

Coker 1 SCR 435 $2,607 0 

Coker 2 ROFA with 

SNCR(Rotamix) 

265 $4,510 0 

Coker 2 SCR 435 $2,607 0 

1-Boiler 5 is the same type of boiler as Boiler 6 but with a lower rated capacity. Modeling was not 

conducted for Boiler 5 but was assumed to have the same results as Boiler 6. 

2-The cost, emissions, and improvements are based on the addition of the SNCR/SCR to the ROFA system, 

which is considered as existing control for Boiler 7 for this analysis. 

Sulfur Dioxides (SO2)

Solutia indicated that the primary available control options for SO2 would include the 

utilization of lower sulfur coals, physical coal cleaning, and post-combustion flue gas 

desulfurization (which would include sorbent injection or wet scrubbers). Since physical 

coal cleaning is not effective in removing organic sulfur and creates a loss in the heating 

content of the coal, this option was not considered. 

Currently, Boiler No. 7 is already required to utilize low sulfur coal. Therefore, the 

utilization of lower sulfur coal would only provide a reduction of 7%. The use of low 

sulfur coal (1.4 lbs SO2/MMBTU) in Boiler 5 and 6 would provide a reduction of 

approximately 43% and a reduction of approximately 16% for the cokers. In combination 

with the ROFA system, Solutia has a manufacturer guarantee that the use of a furnace 

sorbent injection (FSI) system would reduce SO2 by as much as 60% in Boiler No. 7. The 

FSI system would inject a calcium-based sorbent such as limestone into the upper furnace 

region. The evaluation of SO2 controls for each BART-eligible unit is shown in the table 

below: 
BART Unit Control Option Tons 

Removed 

Cost/Ton 

Removed 

98th Percentile 24-Hr 

Visibility Improvement 

Boiler 5 Low Sulfur Coal 1438.88 $1065.54 0.321

Boiler 5 ROFA/FSI 1876.79 $663.45 0.341

Boiler 5 Wet Scrubber 2815.19 $1075.46 0.401

Boiler 6 Low Sulfur Coal 1587.72 $1065.54 0.32 

Boiler 6 ROFA/FSI 2070.95 $615.80 0.34 

Boiler 6 Wet Scrubber 3106.42 $977.86 0.40 

Boiler 7 Low Sulfur Coal 168.09 $16,034.55 0.03 

Boiler 7 ROFA/FSI 1440.8 $931.95 0.24 

Boiler 7 Wet Scrubber 2161.21 $1854.90 0.36 

Coker 1 Low Sulfur Coal 302.09 $8739 0.05 

Coker 1 ROFA/FSI 1599.10 $1090.20 0.36 

Coker 2 Low Sulfur Coal 302.09 $8739 0.05 

Coker 2 ROFA/FSI 1599.10 $1090.20 0.36 

Cokers Wet Scrubber 4797.30 $600.20 0.41 

1-Boiler 5 is the same type of boiler as Boiler 6 but with a lower rated capacity. Modeling was not 

conducted for Boiler 5 but was assumed to have the same results as Boiler 6. 

Cost of Compliance

In reviewing the cost of controls based on emissions removed, Solutia indicated that the 

additional controls for particulate and NOx emissions would not be cost effective. The 

current particulate controls (ESPs) achieve removal efficiencies between 96%-99% and 

an adequately control of the particulate emissions. The additional NOx controls indicated 

relatively small to no reduction in visibility impacts for the reported costs (see NOx 

section). 

The costs for additional SO2 controls appear to be more cost effective and provide some 

visibility improvement. Solutia has indicated that the cost of installation and operation of 

the FSI system or wet scrubbers would severely impact the facility’s sustainability and 

viability. 
 For both of the coking units, Solutia has indicated that the addition of any controls would 

negate the viability of the coking units. The requirement of the additional controls would 

result in a net loss and thus require the units to be shutdown. 

Non-Air Quality Environmental Impacts

Solutia has indicated that the additional SO2 controls would generate additional waste. 

Solutia estimated that the FSI system would generated an additional 14,000 tons of fly 

ash per boiler and the addition of the wet scrubber would generate 20 tons/day of sludge. 

Proposed BART Limitations

NOx

• Solutia has proposed no add on controls for Boiler 5, Boiler 6, and the Cokers for 

the control of NOx emissions. 

• Boiler 7 would be required to meet an emission limit of 0.36 lb NOx/MMBTU 

with the installation of a ROFA system or a comparable technology. 

SO2

• Solutia has proposed to limit Boilers 5 and 6 to burning coal with a sulfur content 

resulting in SO2 emissions less than 1.40 lbs/MMBTU. 

• Boiler 7 would be required to meet a limitation of 0.47 lb SO2/MMBTU with the 

installation of the FSI system or a comparable technology. 

• Solutia has proposed no add on controls for the Cokers. 
PM10

• The existing electrostatic precipitators will be utilized to control PM emissions for 

each BART unit (Boiler 5-7, Cokers 1-2). 

The Table below presents the summarized BART emission limits for Solutia. 

Solutia BART Emission Limitations 

Emission Limitations 

Emission Unit 

NOx SO2 PM10

Boiler 5 101.22 lb/hr1

1.40 lb/MMbtu & 

406 lb/hr 

0.12 lb/MMbtu & 34.8 

lb/hr 

Boiler 6 109.72 lb/hr1

1.40 lb/MMbtu & 

448 lb/hr 

0.12 lb/MMbtu & 38.4 

lb/hr 

Boiler 7 

0.36 lb/MMbtu & 193 

lb/hr 

0.47 lb/MMbtu & 

252 lb/hr 

0.10 lb/MMbtu & 64.33 

lb/hr 

Coker 1 104.43 lb/hr1

3.57 lb/MMbtu & 

1,370.1 lb/hr 

0.12 lb/MMbtu 

Coker 2 104.43 lb/hr1

3.57 lb/MMbtu & 

1,370.1 lb/hr 

0.12 lb/MMbtu 

1-NOx emission limit from base line emissions 

The Department concurs with the proposed BART limitations. For Boiler 7, Solutia 

would be required to install a continuous emission monitor system (CEMS) for 

determining compliance with the SO2 and NOx emission limitations. The limitations 

established under BART may be changed through the NSR (New Source Review) permit 
process which should include a visibility analysis prior to the modification. 

Visibility Impact

As previously stated, modeling was conducted to show the predicted visibility impact on 

the closest Class I Area (Sipsey Wilderness Area). From the chosen options, an 

improvement of 0.32 dV is expected from each of Boiler 5 and 6, and an improvement of 

0.24 dV for Boiler 7 from SO2 controls. 

Recommendation

The proposed limitations appear to meet the requirements for BART. Therefore, I 

recommend that the attached Air Permits be issued. 

_________________________ 

Adrienne Newton 

Chemical Branch 

Air Division 

September 13, 2007

Date 
Best Available Retrofit Technology Analysis 

IP Courtland 

707-0001 

IP Courtland submitted a Best Available Retrofit Technology Analysis (BART) on 

October 10, 2006. A revised analysis containing additional information was received on 

June 1, 2007. IP submitted this analysis since the BART exemption modeling showed 

that the mill contributed to visibility impairment to Class I areas within 300 Km of the 

mill. Since sources at the mill contributed to a 24hr visibility change of greater that 0.5 

deciview (dV) visibility change over natural conditions in the Sipsey Wilderness Area the 

mill had to conduct a Case-by-Case Bart Analysis. IP identified the BART eligible 

sources at the mill as the No. 1 Combination Boiler, No. 2 Combination Boiler, Package 

Boiler, No 2 Recovery Furnace, No 2 Smelt Dissolving tank, No. 1 Lime Kiln, and No. 2 

Lime Kiln. 

IP analyzed each BART eligible source, determined which controls would be feasible for 

these sources and ranked them according to the potential visibility improvements. IP’s 

Analysis determined that the No. 2 Combination Boiler and the No. 2 Recovery Furnace 

were the sources with the largest contribution to the mill’s visibility impacts on the 

Sipsey Wilderness Area. Therefore IP attempted to develop a control scenario around 

these 2 units, since controlling these 2 units would give the greatest improvement. 

During the development of this analysis IP determined that controlling the No. 2 

Recovery would not be cost effective; therefore, alternative means of reduction were 

evaluated. IP then evaluated the other control options for the other BART sources at the 
mill and developed a control strategy for visibility improvement at the Courtland Mill. IP 

has proposed to install low NOx Burners on the No. 2 Combination Boiler and either 

install low NOx Burners or only operate the No. 1 Combination Boiler when one of the 

following emissions units are either not operating or in periods of start-up or shutdown: 

the No. 2 Combination Boiler the No. 2 Recovery Furnace, the No. 3 Combination 

Boiler, or the No. 3 Recovery Furnace. 

IP’s Application followed EPA’s guidance by conducting the BART analysis using a top 

down approach which consisted of the following 5 steps. 

• Identify all available retrofit control technologies 

• Eliminate technically infeasible options 

• Evaluate control effectiveness of control technologies 

• Evaluate impacts 

o Cost of Compliance 

o Energy and non-air quality environmental impacts 

o Remaining useful life 

• Evaluate visibility impacts 

The Department has chosen to evaluate the IP submittal based on the following criteria: 

• Existing air pollution control technology in use 

• Available retrofit control technologies 

• Remaining useful life of the source 

• Cost of Compliance 
• Energy and non-air quality environmental impacts 

• The degree of visibility improvement which may reasonably be anticipated from 

the use of BART. 

Background/Existing Equipment 

The No. 1 Combination Boiler, also known as the No.1 Power Boiler, is designed to burn 

bark, natural gas, and fuel oil and is operated as a swing boiler. Bark from the woodyard 

is fed to a bark bin which supplies both the No.1 and No.2 Combination Boilers. In 

addition, the No. 1 Combination Boiler has the capability to combust the dilute noncondensable gas (HVLC) stream from the pulp mill and chemical recovery areas. The 

No. 1 Combination Boiler is vented to a venturi scrubber where the gases are scrubbed 

with water to remove particulate matter. The Visibility Impairing Pollutants (VIP) which 

the No. 1 Combination Boiler emits and will require a BART analysis are SO2, NOx, and 

PM10. 

The No. 2 Combination Boiler, also known as the No. 2 Power Boiler, fires coal, bark, 

and natural gas. The primary fuel for this boiler is bark, which is supplied to the boiler 

by the bark handling system. The other primary fuel for this boiler is coal. There are 

three coal mills associated with the No. 2 Combination Boiler which consist of a 

pulverizer and a primary air fan that is used to dry the coal and blow the coal in the boiler 

as well as provide excess air for the combustion of the coal. Each of the pulverizers 

provides coal to two burners, and each of the burners is equipped with a gas igniter. The 

No. 2 Combination Boiler also has the capability to combust the dilute non-condensable 
gas (HVLC) stream from the pulp mill and chemical recovery areas. The No. 2 

Combination Boiler is vented to two electrostatic precipitators to remove particulate 

matter. The flue gas is then vented to a high pressure venturi scrubber for the removal of 

SO2. The VIP’s which the No. 2 Combination Boiler emits and will require a BART 

analysis are SO2, NOx, and PM10. 

The Package Boiler is utilized as a back-up boiler and is fired by natural gas. The 

Package Boiler has no external emission control devices and the VIP’s which the 

Package Boiler emits and will require a BART analysis are SO2, NOx, and PM10. 

The No. 2 Recovery Furnace is designed to fire black liquor, with natural gas and fuel oil 

as supplemental fuels. In the furnace the liquor is dried and burned. The organic portion 

of the liquor burns which provides heat for steam generation. The inorganic portion of 

the liquor is recovered to produce cooking liquor for the digesters. The combustion gases 

from the furnace are vented to an electrostatic precipitator for particulate matter control. 

The VIP’s which the No. 2 Recovery Furnace emits and will require a BART analysis are 

SO2, NOX, and PM10. 

 

The No.2 Smelt Dissolving Tank is a recovery operation for the No. 2 Recovery Furnace. 

The inorganics in the Recovery Furnace accumulate on the furnace floor and drain into 

the No. 2 Smelt Dissolving Tank as molten smelt. The smelt is mixed with weak wash to 

form green liquor which is sent to the causticizing area. The No. 2 Smelt Dissolving 

Tank is vented through a separate scrubber system for particulate matter control. The 
VIP’s which the No. 2 Smelt Dissolving Tank emits and will require a BART analysis are 

SO2 and PM10. 

Lime mud from the Causticizing Area is converted to lime in one of the three lime kilns 

at the facility. Lime Kilns No. 1 and No. 2 are subject to BART. Both the No. 1 and No. 

2 Lime Kilns are fired with natural gas and/or fuel oil and have low-NOx burners. 

Concentrated non-condensable gases (LVHC) and the foul condensate stripper gases are 

incinerated in the lime kilns. Both the No.1 and No. 2 Lime Kilns are vented to a 

scrubber to control particulate emissions. The VIP’s which both the No. 1 and No. 2 

Lime Kilns emit and will require a BART analysis are SO2, NOx, and PM10. 

 

Case by Case Analysis

The first step in the BART control technology analysis is to develop a comprehensive list 

of the potential control technologies and improvements to existing control equipment that 

could potentially reduce Visibility Impairing Pollutants (VIP). Then review these to 

determine if they are technically feasible for the source. Once a control technology has 

been deemed technically feasible by both IP and the Department, an evaluation on the 

effectiveness and cost of compliance will be reviewed. These steps were followed for 

each unit and for each pollutant requiring a BART analysis. The case by case BART 

analysis of each unit can be found below, grouped by pollutant. 
NOx BART Analysis 

IP Courtland identified the following control technologies for the control of NOx

emissions at the Courtland Mill. 

• Selective Catalytic Reduction (SCR) 

• Selective Non-Catalytic Reduction (SNCR) 

• Low NOx Burners 

• Combustion Control Techniques 

• Flue Gas Recirculation 

IP has identified all but the SCR as technically feasible control technologies at the 

Courtland Mill. Table 1 below shows the results of IP’s control effectiveness review for 

all BART-eligible units for NOx. 

Table 1. NOx Control Effectiveness Review Summary 

Emissions Reduction Cost 

Visibility 

Improvement 

Unit 

Control 

Option % 

Reduction

Tons 

Removed

($/Ton) 

98th Percentile 24-

hr 

(dV) 

No. 1 Combo SNCR 35 142.8 $6,097 0.020 

Low NOx

Burners 

30 122.3 $1,188 0.013 
No. 2 Combo SNCR 35 518.2 $2,081 0.097 

Low NOx

Burners 

30 444.2 $585 0.083 

SCR 90 108 $12,375 0.037 

SNCR 50 60 $16,024 0.017 

Package 

Boiler 

Low NOx w/ 

FGR 

50 60 $2,767 0.017 

Due to the inherit nature of a Recovery Furnace, no other controls where deemed feasible 

besides Combustion Controls. 40 CFR Part 51, Appendix Y, does not require a cost 

effectiveness review and visibility study as long as federally enforceable limits are in 

place. Therefore a cost effectiveness review and visibility study was not conducted on 

the No. 2 Recovery for NOx, since Combustion Control Techniques are common practice 

for this unit and are presently in-place, and there are no other technically feasible control 

technologies available. 

Since both the No.1 and No.2 Lime Kilns currently employ Low-NOx Burners in the 

form of combustion flame tuning to reduce NOx emissions, and no other controls where 

deemed feasible a cost effectiveness review and visibility study was not conducted as 

allowed by 40 CFR Part 51, Appendix Y. 
SO2 BART Analysis 

IP Courtland identified the following control technologies for the control of SO2

emissions at the Courtland Mill. 

• Lower Sulfur Fuels 

• Dry Scrubbing 

• Semi-dry Scrubbing 

• Low pressure drop scrubber 

• Low pressure drop Wet Scrubbing with a Wet ESP (WESP) 

• High pressure drop scrubber 

• Addition of Caustic to existing Scrubber 

IP has identified all of the above listed control technologies as technically feasible at the 

Courtland Mill. Table 2 below shows the results of IP’s control effectiveness review for 

all BART-eligible units for SO2. 

Table 2. SO2 Control Effectiveness Review Summary 

Emissions Reduction Cost 

Visibility 

Improvement 

Unit Control Option 

% 

Reduction

Tons 

Removed

($/Ton) 

98th Percentile 24-

hr 

(dV) 

No. 1 

Combo 

Addition of 

Caustic to 

93 180.7 $7,260 0.013 
existing 

Scrubber 

Dry Scrubbing 93 180.7 $14,574 0.013 

Semi-dry 

Scrubbing 

93 180.7 $11,420 0.013 

High ∆P Wet 

Scrubbing 

No. 2 93 1149 $3,633 0.063 

Recovery 

High ∆P Wet 

Scrubbing / 

WESP 

93 1149 $4,336 0.063 

Since the No. 2 Combo Boiler is currently controlled by a wet scrubber, which is 

considered the most stringent control technology for this unit, a control effectiveness 

review study was not performed. 

Although the package boiler is a BART eligible source for SO2, a control effectiveness 

review study was not performed since this source only emits approximately 1 tpy of SO2. 

Since this unit only fires natural gas the emissions from this unit are minimal and there 

would be virtually no impact on visibility, therefore no BART controls were reviewed. 

Due to the inherit nature of a Smelt Dissolving Tank, the SOx emissions are variable and 

depend on the recovery furnace. IP estimated the SO2 emissions from this unit to be 
approximately 1 tpy; therefore a technical feasibility study nor a cost effectiveness review 

and visibility study was performed since there would b4 virtually no impact on visibility . 

The No. 1 and No. 2 Lime Kilns are BART eligible sources for SO2; however 40 CFR 

Part 51, Appendix Y exempts units from performing a technical feasibility study and a 

cost effectiveness review and visibility study if they are complying with MACT 

Standards. Since both these Lime Kilns are subject to and are complying with 40 CFR 

Part 63 Subpart MM through the use of wet scrubbers, and since the inherit nature of lime 

kilns minimize SO2 emissions IP considers the current approach to MACT II compliance 

should serve as BART for SO2 for these Lime Kilns. 

PM10 BART Analysis 

IP Courtland identified the following control technologies for the control of PM10

emissions at the Courtland Mill. 

• Wet Scrubber 

• Multi Tube Dust Collector with ESP 

• ESP 

Since the No. 1 Combo Boiler is currently controlled by a wet scrubber, which is 

considered the most stringent control technology for this unit and will comply with 

ADEM Admin. Code R. 335-3-11-.06(107) [Boiler MACT], a control effectiveness 

review study was not performed. 
Since the No. 2 Combo Boiler is currently controlled by a multi tube dust collector with 

ESP, which is considered the most stringent control technology for this unit and will 

comply with ADEM Admin. Code R. 335-3-11-.06(107) [Boiler MACT], a control 

effectiveness review study was not performed. 

The Package Boiler is a natural gas fired boiler and the PM10 emissions are less than 10 

tpy. Natural gas fired boiler typically to not require add on controls for PM10 and since 

this unit is also typically utilized only during the winter months a control effectiveness 

review study was not performed. 

The No.2 Recovery, No. 2 Smelt Tank, No. 1 and No. 2 Lime Kilns are BART eligible 

sources for PM10; however 40 CFR Part 51, Appendix Y exempts these units from 

performing a technical feasibility study and a cost effectiveness review and visibility 

study since these units are subject to and complying with a particulate MACT Standard, 

(40 CFR Part 63, Subpart MM). 

Cost of Compliance 

In reviewing the cost of controls based on the amount of emissions removed, IP has 

indicated that additional controls for SO2 would not be cost effective at the Courtland 

Mill. IP has also indicated that the Control of NOx is only cost effective for the No. 2 

Combination Boiler and that no other add-on controls would be cost effective for all other 

sources. The current add-on controls which control particles at the Courtland mill have 

efficiencies of greater than 90% therefore no additional controls would be cost effective 
options. 

Energy and Non-Air Quality Environmental Impacts 

IP has indicated that there would be a reduced energy efficiency and an increase in fuel 

usage as a result of the installation of Low NOx burners on the No. 1 Combo and No. 2 

Combo boilers. The Department has reviewed these concerns and had determined that 

the small reduction in energy efficiency and increase in fuel usage for the No. 2 Combo 

boiler does not offset the visibility improvements or the cost effectiveness of $585/ton of 

NOx removed. IP has also indicated that additional NOx controls for other units would 

cause significant impacts to the energy efficiencies and potentially allow other pollutants 

to be emitted to the atmosphere. 

IP has suggested that any additional control of SO2 at any of the BART eligible sources at 

IP would cause an significant increase in energy usages and/or generate a waste stream 

that would have to be disposed of; thereby incurring disposal costs and possible 

permitting issues with other medias. 

Proposed BART 

NOx

• Install low NOx Burners or only operate the No. 1 Combination Boiler when one 

of the following emissions units is either not operating or in periods of start-up of 

shutdown: the No. 2 Combination Boiler the No. 2 Recovery Furnace, the No. 3 

Combination Boiler, or the No. 3 Recovery Furnace. 
• Install low NOx Burners, which will give a 30% baseline reduction in emissions, 

on the No. 2 Combination Boiler. 

• IP has proposed using existing combustion control techniques for the control of 

NOx on the Package Boiler. 

• The No. 2 Recovery Furnace will utilize existing combustion control techniques 

for the control of NOx. 

• IP proposed the existing Low NOx burners for the No. 1 and No. 2 Lime Kilns for 

control of NOx emissions for these units. 

SO2

• IP has proposed no add on controls for the No. 1 Combination Boiler, No. 2 

Recovery Furnace, No. 2 Smelt Tank, No. 1 Lime Kiln, and No. 2 Lime Kiln for 

the control of SO2 emissions. 

• The existing Wet Scrubber will be utilized to control SO2 emissions from the No. 

2 Combination Boiler. 

• Since the Package Boiler only fires natural gas, no add-on controls are warranted. 

The firing of only natural gas will be a federally enforceable limit 

PM10

• IP has proposed utilizing the existing Venturi Scrubber for the control of PM 

emissions from the No. 1 Combination Boiler. 

• The No. 2 Combination Boiler will utilize the existing multi tube dust collectors 

with electrostatic precipitator for the control of PM emissions. 
• IP had proposed no controls for the Package Boiler due to the low particulate 

emissions associated with the firing of natural gas. 

• The existing electrostatic precipitator will be utilized to control PM emissions for 

the No. 2 Recovery Furnace. 

• IP has proposed to utilize the existing wet scrubber which is required by 40, CFR 

Part 63, Subpart MM, as the BART control device for the control of PM 

emissions from the No. 2 Smelt Tank 

• The existing Venturi Scrubbers will be utilized to control PM emissions from both 

Lime Kilns No. 1 and No. 2. 

Table 3 below presents the summarized BART emission limits for the IP Courtland Mill. 

Table 3. BART Emission Limits 

Emission Limitations Emission Unit NOx SO2 PM10

No. 1 Combo 93.15 lb/hr or 

operational 

limitations 

147.3 lb/hr 0.17 gr/sdcf @ 50% 

Excess Air 

No. 2 Combo 338.13 lb/hr 1.20 lb/MMbtu 

& 65.5 lb/hr 

0.10 lb/MMbtu 

Package Boiler 0.20 MMbtu & 

<1,200 million ft3

 of 

natural gas / 12 month 

period 

1.80 lb/MMbtu 0.10 lb/MMbtu 

No. 2 Recovery 152 lb/hr 432 lb/hr 0.044 grains/SDCF at 

8 % O2 and 67 lb/hr 

No. 2 Smelt Tank NA 0.20 lb/hr 0.20 lb/ ton of black 

liquor solids 

No. 1 Lime Kiln 3.5 lb/hr 0.10 lb/hr 1.0 lb/air dried ton of 

pulp 

No. 2 Lime Kiln 19.40 lb/hr 0.23 lb/hr 0.067 gr/sdcf at 10% 

O2

The Department concurs with the proposed BART limitations. These limitations will be 
written into air permits and will be effective by January 1, 2013. The limitations 

established under BART (Best Available Retrofit Technology) may be changed through 

the NSR (New Source Review) permit process which should include a visibility analysis 

prior to the modification. 

Evaluate Visibility Impacts 

The modeled visibility improvement as a result of installing the proposed add on BART 

controls, federally enforceable limits, and operational limitations would range between 

0.2 and 0.4 deciviews improvement in the Sipsey Wilderness Area. Although this is a 

small visibility improvement it has a large reduction in the number of days above 0.5 

deciviews in the Sipsey Wilderness Area. Relative to the base case of 98 days above 0.5 

deciviews, the three modeled scenarios indicate only 40, 59, and 56 days above 0.5 

deciviews, which equates to an average improvement of 45 days. 

Recommendation

The proposed limitations appear to meet the requirements for BART. Therefore, I 

recommend that the attached Air Permit be issued. 

_________________________ 

C. Scott Sanders 
Industrial Chemicals Section 

Chemical Branch 

Air Division 

October 22, 2007

Date