### BART Related Documentation Appendix L - 

### i Regional Haze SIP for TN Class I Areas April 4, 2008 

# Appendix L Best Available Retrofit Technology
Related Documentation

### BART Related Documentation Appendix L - 

### 1 Regional Haze SIP for TN Class I Areas April 4, 2008 

## TABLE OF CONTENTS

LIST OF ATTACHMENTS ........................................................................................................... 2

PURPOSE ....................................................................................................................... ................ 3 1. Background ................................................................................................................ ................ 4 2. Approach to Implementation of BART Requirements .............................................................. 5 3. Identification of BART-eligible Sources ................................................................................... 5

4. Contribution Threshold .................................................................................................... .......... 9 5. Exemption of Point Source Volatile Or ganic Compounds for BART Purposes ..................... 11
5.1 Method ................................................................................................................... ............ 11 5.2 Conclusions .............................................................................................................. .......... 13

6. Treatment of Ammonia Emi ssions for BART Purposes.......................................................... 13
6.1 Method ................................................................................................................... ............ 14 6.2 Conclusions .............................................................................................................. .......... 15 7. Explanation of BART Exemption Modeling ........................................................................... 16 7.1 Background ................................................................................................................ ......... 16 7.2 Tennessee BART Sources Exemption Modeling .............................................................. 17 7.3 BART-Eligible Sources in Ot her States Within 300 km of Tennessee Class I Areas ........ 26 7.4 Use of New IMPROVE Equation ....................................................................................... 27
7.5 Conclusion ................................................................................................................ .......... 29

8. BART Determinations ....................................................................................................... ...... 30 8.1 BART Subject Sources ...................................................................................................... . 30 8.1.1 BART-eligible Units and Existing Control .................................................................. 30
8.2 Baseline Contribution ..................................................................................................... .... 38 8.3 BART Determination Analysis ........................................................................................... 39
8.3.1 Control Scenarios Considered...................................................................................... 39 8.3.2 Costs of Compliance .................................................................................................... 45 8.3.3 Energy and Non-air Quality Impacts ........................................................................... 53 8.3.4 Existing Control ........................................................................................................ ... 55 8.3.5 Remaining Useful Life ................................................................................................. 5 6 8.3.6 Degree of Visibility Improvement ............................................................................... 57
8.4 Final BART Determination ............................................................................................... 5 7 8.5 BART Subject Sources in Other States Within 300 km of Tennessee I Areas .................. 57
8.6 Conclusions ............................................................................................................... .......... 58

REFERENCES: ................................................................................................................... ......... 59

### BART Related Documentation Appendix L - 

### 2 Regional Haze SIP for TN Class I Areas April 4, 2008 

## LIST OF ATTACHMENTS

Appendix L.1 – Tennessee Visi bility Protection Rule

Appendix L.2 – Tennessee BART Eligible Sources Emissions

Appendix L.3 – Tennessee BART So urces SO2 & Class I Areas

Appendix L.4 – VISTAS BART An alysis Sensitivity Modeling

Appendix L.5 – VISTAS Cal puff Modeling Protocol

Appendix L.6 – TN BART Sources Site-Specific Protocols

Appendix L.7 - Proposed BART Exemptions

Appendix L.8 – TN BART Sources Demonstrations

Appendix L.9 - New IMPROVE Equations

Appendix L.10 – Tennessee M odeling Summary Report

Appendix L.11 – VISTAS Modeling Support for BART Analyses

Appendix L.12 – BART Permit Conditions

### BART Related Documentation Appendix L - 

### 3 Regional Haze SIP for TN Class I Areas April 4, 2008 

### PURPOSE

The purpose of this appendix is to outline th e State’s strategy for complying with the requirement to set and meet Reas onable Progress Goals (RPGs) as part of our Regional Haze SIP under 40 CFR 51.308(d)(1), and the requirements for establishing best ava ilable retrofit (BART) controls under 40 CFR 51.308(e).

In the 1977 amendments to the Clean Air Act (C AA), Congress set a national goal for visibility as “the prevention of any future, and the remedyi ng of any existing, impairment of visibility in mandatory Class I Federal areas which impair ment results from manmade pollution”. The regional haze rule (RHR) at 51.308(d) requires stat es to demonstrate reasonable progress toward meeting the goal of a return to natural visibil ity conditions by 2064. As a guide for reasonable progress, the RHR directs states to graphically sh ow what would be a “uniform rate of progress” toward natural conditions for each Class I area. This is known as the “glidepath. The RHR then requires states to establish RPGs for visibili ty improvement at each affected Class I area covering each approximately 10-year period until 2064. Therefore, our first set of RPGs will comprise our long term strategy (LTS) covering the period from the present until 2018. This appendix provides an overview of this first LTS . In addition, a specif ic component of each state’s first LTS is dictated by the specific BART requirements in 40 CFR 51.308(e). This appendix will also include a discussion of our st rategy for developing those BART requirements.

Our long term strategy contai ns the following components:

I. Inventory of all controls required or expected under all federal and state regulations by 2009 and 2018. We refer to these controls as “on the books” or “on the way” (OTB/OTW). II. Modeled expected visibility improvement from OTB/OTW (Base G) controls and Comparison of Base G results for 2018 to the un iform rate of progress, or “glidepath” for each Class I area. III. Discussion of emissions sensitivity model r uns to help determine which pollutants and source categories are contributi ng the most to visibility impa irment at Class I areas (runs conducted by Georgia Institute of Technology). IV. Examination of SO2 Area of Influence (AOIs) projections for each of the State’s Class I areas, and also for any surrounding states’ Class I areas whose AOI includes any Tennessee counties, to determine which specific sources are most likely to be impairing visibility at specific Class I areas. V. Application of the four “sta tutory factors,” listed in 40 CFR 51.308(d)(1)(i )(A) to those sources identified in the previous step VI. Using the results of the four factor analyses , identification of control determinations for specific sources. VII. Identification of BART-eligible sources. VIII. BART exemption modeling for BART-eligible sources.

IX. BART determinations for sources subject to BART. X. Modeling demonstration of vi sibility improvement afte r inclusion of BART and reasonable progress control determinations.

### BART Related Documentation Appendix L - 

### 4 Regional Haze SIP for TN Class I Areas April 4, 2008 

### XI. Determination of RPGs based on the vi sibility improvement expected by 2018. 

## 1. Background

As required by the CAA, EPA included in the fi nal regional haze rule a requirement for Best Available Retrofit Technology (BART) for certain la rge stationary sources that were placed in operation between 1962 and 1977. The BART-eligible sources are those sources which have the potential to emit 250 tons or more of a visibility-impairing air po llutant, were placed in operation between August 7, 1962 and August 7, 1977, and whose operations fall within one or more of 26 specifically listed source categor ies. Under the CAA, BART is required for any BART-eligible source that a State determines ‘‘emits any air po llutant which may reasonably be anticipated to cause or contribute to any impair ment of visibility in any such area.’’ Accordingly, for stationary sources meeting these criteria, States must a ddress the BART requirement when they develop regional haze SIPs. 1 

### EPA has set guidance for identifyi ng BART-eligible sources in 40 CFR Part 51 Appendix Y.

A BART-eligible source that is re sponsible for a 1.0 deciview (dv) change or more is considered to “cause” visibility impairment. Although the a ppropriate threshold may vary, the guidelines state that the contribution threshold used for BART applicability should not be higher than 0.5 deciviews. 1 

### Thus a BART-eligible source that is res ponsible for a 0.5 dv change or more is considered to “contribute” to visibility impairme nt. Any source determined to cause or contribute to visibility impairment in any Class I area is subject to BART.

The guidelines direct that States should include SO2, NOX, and di rect particulate matter (PM) emissions, including both PM10 and PM2.5, in dete rmining whether sources cause or contribute to visibility impairment. States may use th eir best judgment to determine whether VOC or ammonia emissions are likely to have an impact on visibility in an area. 1



### To determine which BART-eligible sources are s ubject to BART, states have several options. A state may consider all BART-eligible sources su bject to BART; may perform analysis showing that the full group of BART-eligible sources in a State cumulatively may not be reasonably anticipated to cause or contribu te to any visibility impairment in any Class I areas; or may consider the individualized c ontribution of a BART-eligible source to determine whether a specific BART-eligible source is subject to BART.

Sources that are subject to BART must undergo a BART dete rmination. Section 169A(g)(7) of the CAA requires that States must consid er the following factors in making BART determinations: (1) The costs of compliance, (2) The energy and non-air quality environmental impacts of compliance, (3) Any existing pollutio n control technology in use at the source, (4) The remaining useful life of the source, and (5) The degree of improvement in visibility which may reasonably be anticipated to re sult from the use of such technology. 1



### To demonstrate the degree of improvement in vi sibility from various BA RT control options, the States may run CALPUFF or anothe r appropriate dispersion model to predict visibility impacts. Scenarios would be run for the pre-controlled an d post-controlled emission rates for each of the BART control options under review. The maxi mum 24-hour emission rate s would be modeled

### BART Related Documentation Appendix L - 

### 5 Regional Haze SIP for TN Class I Areas April 4, 2008 

### for a period of three or five year s of meteorological data. States have the flexibility to develop their own methods to ev aluate model results. 1 

## 2. Approach to Implementa tion of BART Requirements

In order to meet the SIP submittal deadline, Tennessee has used a multifaceted approach to implementation of the federal regional haze rule BART requirements. The approach consists of source identification efforts, conc urrent adoption of a framework ru le to establish a process for conducting BART determinations, use of a permitt ing process to establish any resulting BART limits for inclusion in the SIP submittal as well as participation in VISTAS BART subgroup to resolve technical issues spa nning states in the VISTAS re gion, and ongoing consultation with affected sources, and EPA and FL Ms throughout the BART process.

The state Visibility Protection rule, TAPCR Chapter 1200-3-23 (the citation of this rule is offered only for reference purposes and it is no t offered for inclusion into the Tennessee Regional Haze SIP.) Best Available Retrofit Technology, applies to sources that have the potential to emit 250 tons or more of a visibility impairing polluta nt, were in existence on August 7, 1977 and began operation after August 7, 1962, and fall within one of the 26 industrial source categories listed in 40 CFR Part 51 Appendix Y guide lines. The rule allows affected sources to demonstrate that the source does no t contribute to visibility impa irment and should be exempted. Non-exempt sources are required to undergo a determination of be st available retrofit technology. Accordingly, non-exempt sources ar e required to submit a permit application proposing BART by November 1, 2006. The rule requi res that BART controls be installed and begin operation as expeditiously as practicable bu t no later than five (5) years after approval of Tennessee’s RHR SIP by EPA. Copy of the rule is included as Appendix L-1.



## 3. Identification of BART-eligible Sources

EPA provided guidance for identifying BART-eligib le sources in 40 CFR Part 51 Appendix Y. Tennessee followed this guidance in identifying its BART-eligible sources. The Tennessee 2002 air emissions inventory was reviewed to dete rmine the population of potential BART-eligible sources. The data were initially queried fo r any sources emitting SO2, NOx, PM-10, VOC, or ammonia. The data set was refine d based on emissions, whether emi ssion units fit in any of the twenty-six listed source categories for BART, a nd available date information obtained through review of permit and inspection re ports and discussion with permits section and regional office staff familiar with the facilities.

An information packet on BART was sent to an d additional information was collected from the remaining sources regarding potential emissions and BART eligibility fro m the standpoint of source category and date criteria. Through this iterative review proce ss, the list of potential BART-eligible sources was pared down to the fi fteen BART-eligible sources listed below. The facilities are scattered th roughout the state with clos est facility proximity to Class I areas ranging from 16 km to 312 km. The facili ties include one primary aluminum facility, one pulp and paper facility, one military ordinance facility, two elec tric utilities, nine chemical manufacturers, and one nitrogen fertiliz er manufacturer.

### BART Related Documentation Appendix L - 

### 6 Regional Haze SIP for TN Class I Areas April 4, 2008 

### TN BART Eligible Sources

FACILITY NAME Aluminum Company of America (Alcoa) – South Plant DuPont White Pigment and Mineral Products (Humphreys County) Eastman Chemical Compa ny – Tennessee Operations E I DuPont de Nemours and Co mpany, Inc. (Old Hickory) E I DuPont de Nemours and Company, Inc. (Shelby County) Holston Army Ammunition Plant Intertrade Holdings, Inc. Liberty Fibers Corporation Lucite International Owens Corning Packaging Corporation of America (PCA) PCS Nitrogen Tennessee Valley Authority (TVA) – Bull Run Fossil Plant Tennessee Valley Authority (TVA) – Cumberland Fossil Plant Zinifex Weyerhaeuser Corporation (now Domtar Paper Company) – Sullivan County

Tennessee initially identified the above sixteen (16) facilities as BART-eli gible sources. Since the time that the BART-eligible sources were identified, Liberty Fibers Corporation has permanently shut down, and the BART-eligible bo ilers located at the facility have been dismantled. Additionally, Intertrade Holdings, Inc. has permanently shut down the acid plant that was determined to be BART-eligible (a reduction of sulfur dioxide of approximately 374 tons per year). Holston Army Ammunition Plant has requested a permit limit of 249 tons per year for the emissions units that make up their acid plant The Division of Air Pollution Control issued a federally enforceable permit restricting the acid plant emissions to 249 tons per year on February 25, 2008 (See Appendix L-12, pages 3-4). The subject acid plant consists of eight sources, with combined potential emissions of 638.2 tons of n itrogen oxides (NOx) before the issuance of the federally enforceable permit. However, this part of the facility has not been operated since 1997. The remaining sources with potenti al emissions above 250 TPY at th is facility were either built before August 1962 or were built or modified af ter the promulgation of major NSR rules in 1977. The power boiler (#7) at the Weyerhaeuser facility (now Domtar Paper Company) in Sullivan county has been retired and the facility is no longer BART eligible. For more detailed permit informations on theses BART exempted sources, see Appendix L-12.

The BART status of the remaining twelve (12) operational sources is as follows:

Aluminum Company of America (Alcoa) – South Plant DuPont White Pigment and Mineral Products (Humphreys County) Eastman Chemical Compa ny – Tennessee Operations E I DuPont de Nemours and Co mpany, Inc. (Old Hickory) E I DuPont de Nemours and Company, Inc. (Shelby County) Lucite International

### BART Related Documentation Appendix L - 

### 7 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Owens Corning Packaging Corporation of America (PCA) PCS Nitrogen Tennessee Valley Authority (TVA) – Bull Run Fossil Plant Tennessee Valley Authority (TVA) – Cumberland Fossil Plant Zinifex

A spreadsheet of Tennessee’s BART-eligible so urce emissions is included as Appendix L-2. A spreadsheet of TN’s BART-eligible sources’ SO2 emissions and distance to Class I areas is included as Appendix L-3.

TN BART-eligible sources were presumed to be subject to BART but were provided the opportunity to submit modeling demons trations showing that they di d not contribute to visibility impairment, i.e., had less than 0.5 deciviews (d v) impact, on any Class I area within 300 km and thus could be exempt.

### BART Related Documentation Appendix L - 

### 8 Regional Haze SIP for TN Class I Areas April 4, 2008

### BART Related Documentation Appendix L - 

### 9 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Figure 3-1. TN BART-Eligible Sources and Class I Areas.



## 4. Contribution Threshold

Determining whether a source causes or contributes to visibility impairment is one step in the BART review process. The Guidelines for BART Determinations Under the Regional Haze Rule 1 

### state that “A single source that is responsible for a 1.0 deciview change or more should be considered to ‘cause’ visibility impairment.” The guideline document also states that “the appropriate threshold for determining whether a source ‘contributes to visibility impairment’ may reasonably differ across states,” but, “As a general matter, any threshold that you use for determining whether a source ‘contri butes’ to visibility impairment should not be higher than 0.5 deciviews.” The rationale for these instructions is provided in the pr eamble to the BART guidance, in the statement, “If ‘causing’ vi sibility impairment means causing a humanly perceptible change in visibility in virtually all situations ( i.e. a 1.0 deciview change), then ‘contributing’ to visibility impairment must mean having some lesser impact on the conditions affecting visibility that need not ri se to the level of human perception.” 2 

### The guidance document itself also states that, “States remain free to us e a threshold lower than 0.5 deciviews if they conclude that the location of a large number of BART-eligible s ources within the State and in proximity to a Class I area justify this approach.”

The EPA’s documents strive to set these threshol ds in the context of the human perception of visibility change. As noted above, the EPA consid ers a 1.0-deciview change in visibility to be humanly perceptible “in virtually all situati ons.” Also, the preamble to the BART guidance 3 

### cites

1 40 CFR 51, Appendix Y, Section III.A.1

2 70 FR 39120. Footnote 31

3 70 FR 39119. Footnote 28 C

o h ut ta G

re at S

m

o M

o

u nt ai

n J

o y

c

e Ki Sl

ic kr

o

c k Li

n vi ll

e G W

A M

a

m

m ot h C N

P S hi

n ni

n g R W

A Si p

s

e y J

a

m

e

s Ri

v M in g

o W il R

ef

u

BART Evaluations # Facility Name COHU GRSM JOYC LIGO MACA SHRO SIPS JARI MING 1 DuPont - Humphreys County 203 200 225 2 DuPont - Shelby County 216 218 3 Lucite International 253 187 4 Owens Corning 297 200 187 5 PCS Nitrogen 253 186 6 Zinifex - Clarksville 312 131 247 256
7 TVA - Bull Run Fossil Plant 118 48 63 200 209 131 8 Packaging Corporation of America 299 100 273 9 Alcoa - South Plant 99 18 16 185 244 108 10 DuPont - Old Hickory 233 249 254 105 220 11 Eastman Chemical 245 98 174 85 124 289
BART Sub j ect SourceOld IMPROVE E q u. 12 TVA-Cumberland Fossil Plant 153 223 233

Proposed Exempt Source Non-exempt Source Non-exempt Utility BART Exempt Sources old IMPROVE Equ. 4 Km.

BART Exem p t SourcesOld IMPROVE E q u. 12 Km. Facility Distances to Class I Areas (Km)

BART Sub j ect SourcesNew
IMPROVE E q u.

### BART Related Documentation Appendix L - 

### 10 Regional Haze SIP for TN Class I Areas April 4, 2008 

### an analysis in an appendix of a NAPAP (N ational Acid Precipitation Assessment Program) report, which asserts that “changes in light ex tinction of 5 percent will evoke just noticeable changes in most landscapes.” 4 

### (A 5% change is approximately 0.5 dv.) But, as noted above, the preamble also states that percep tibility is not a prerequisite fo r choosing a contribution threshold. Putting all this together, it appe ars that “causing” visibility impairment means having a humanly perceptible impact (for which EPA considers the practical threshold to be 1.0 dv) while “contributing” to visibility impairment means ha ving a smaller impact (for which EPA considers the threshold to be 0.5 dv or some smaller value) that may or may not be perceptible.

The EPA argues that a contribution threshold of less than 0.5 dv impa ct per source is appropriate when multiple sources contribute, in order to limit the combined effect of these sources. As an example, EPA asserts that if there were 100 sources, each affecting visibility by 0.1 dv (presumably an imperceptible amount), their total impact would be 10 dv (which can be expected to be quite perceptible). 5 

### The point remains that multiple sources can cause a larger impact than a single one. For BART purposes, visi bility impacts are calculated as 24-hr averages of 1-hr plume impacts, so if the plumes from the various source s each impact the point of interest at some time during a 24-hr period (not necessarily all at the same hour) then the 24-hr average will reflect their combined impact.

There are no cluster of Tennessee BART sources near the GRSM/JOKI area (Figure 3-1). Only two sources, TVA-Bull Run and Alcoa are located w ithin 32 km from each other and the rest at over 100 km from one another with respect to th ese Class I areas. Similairly, Tennessee BART sources near the Memphis area (i.e., DuPont-Shel by, Lucite International and PCS Nitrogen) are all located greater than 180 km from the MI NG/SIPS/MACA Class I areas and they would not constitute a cluster of sources near a Cla ss I area for plume convergence considerations.

TDEC-APC concluded that the EPA suggested c ontribution threshold of 0.5 dv was appropriate in this situation since there are a limited number of out of state sources that impact the various Class I areas in the state.

4 “The Quadratic Detection Model” by W. Malm. A ppendix D in Acidic Deposition: State of Science and Technology, Report 24, Visibility: Existing and Hist orical Conditions -- Causes and Effects. National Acid Precipitation Assessment Program, Washington, DC. 1990.

5 70 FR 39121. 1st column

### BART Related Documentation Appendix L - 

### 11 Regional Haze SIP for TN Class I Areas April 4, 2008 Figure 4-1 Location of VISTAS BART-Eligible Sources



## 5. Exemption of Point Source Vola tile Organic Compounds for BART Purposes

The State of Tennessee has determined thr ough regional modeling that Volatile Organic Compounds (VOC) from point source s are not anticipated to cause or contribu te significantly to any impairment of visibility in Class I ar eas and should be exempt for BART purposes.

5.1 Method

The State of Tennessee determined through regiona l modeling that VOCs from point sources are not anticipated to cause or cont ribute significantly to any impairment of visibility in Class I

areas.

Modeling was conducted through The Visibility Im provement State and Tr ibal Association of the Southeast (VISTAS). VISTAS is a colla borative effort of state governments, tribal governments, and various federal agencies establ ished to initiate and coordinate activities

### BART Related Documentation Appendix L - 

### 12 Regional Haze SIP for TN Class I Areas April 4, 2008 

### associated with the management of regional haze, visibility and other air quality issues in the Southeastern United States. VISTAS contract ed with Georgia Institu te of Technology to perform model sensitivity runs to determine the impact of point source VOCs on visibility in Class I areas.

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on regional haze, annual PM2.5, and 8-hour ozone concentrations using CMAQv4.4_SOAmods on the VISTAS 12 km modeling domain, using the 2009 OTW (on the way) BaseD emissions. One such sensitivity run reduced anthropogenic, poi nt source VOCs by 100%. The purpose was to quantify the impact of VOC emissions from VISTAS BART sources on Class I areas. The percent of BART-eligible to total poin t source emissions in Tennessee is 8%. 2 

### Two episodes were examined: June 1-July 10, 2002 and November 19 – December 19, 2002. The approach included calculating the extinction coefficient in dv (deciviews), then determining the maximum impact of point source VOCs. The chart belo w shows the impact on the following twenty-two Class I areas within the VISTAS domain. 2



### BRET = Breton, LA BRIG = Brigantine NWR, NJ CACR = Caney Creek, AR CHAS = Chassahowitzka, FL COHU = Cohutta, GA DOSO = Dolly Sods, WV EVER = Everglades, FL GRSM = Great Smoky Mountains National Park HEGL = Hercules Glade, MO JARI = James River Face, VA LIGO = Linville Gorge, NC MACA = Mammoth Cave, KY MING = Mingo, MO OKEF = Okefenokee, GA ROMA = Cape Romain, SC SAMA = Saint Marks, FL SHEN = Shenandoah, VA SHRO = Shining Rock, NC SIPS = Sipsey Wilderness, AL SWAN = Swanquarter, NC UPBU = Upper Buffalo Wilderness, AR WOLF = Wolf Island, GA

### BART Related Documentation Appendix L - 

### 13 Regional Haze SIP for TN Class I Areas April 4, 2008 Figure 5-1. Maximum contributions of all VISTAS-region VOC point sources to haze in Class I areas during the CMAQ-modeled periods.



### 5.2 Conclusions

The results show that the maximum impact from eliminating all point source VOC emissions in the VISTAS 12 km domain is less than a 0.5 dv fo r all Class I areas in the VISTAS domain. Given that the fraction of the total point source VOC emissions that are also BART-eligible in the state of Tennessee is just 8% 2 

### , the expected impact of control ling VOCs from a BART source would be much less than the 0.5 dv threshold. VI STAS and the State of Tennessee conclude that VOCs from point sources are not a visibility impairing pollutant for BART purposes and that BART-eligible sources do not need to consider VOC emissions.



## 6. Treatment of Ammonia Emissions for BART Purposes

Similar to its treatment of VOCs, EPA guidance allows States the discretion to decide whether or not ammonia emissions are to be considered fo r BART purposes based on evaluations of the contributions of the emissions to haze at Class I areas in their areas of influence. One approach a State can use to determine whether applying BART will be needed is to evaluate the haze impacts of all current emissions from all BART-elig ible sources in the State. If the impact from all sources in the state is less than the contribution threshold established by the State, 0.5 dv for Tennessee, then source by source an alysis for BART is not needed. 

# Maximum Point VOC Impact

Maximum VOC Impact

0.0 0.1 0.2 0.3 0.4 0.5 0.6BRETBRIGCACRCHASCOHUDOSOEVERGRSMHEGLJARILIGOMACAMINGOKEFROMASAMASHENSHROSIPSSWANUPBUWOLF∆dV

### BART Related Documentation Appendix L - 

### 14 Regional Haze SIP for TN Class I Areas April 4, 2008 

### The State of Tennessee has determined through m odeling that with one exception (PCS Nitrogen facility near Memphis, TN) amm onia (NH3) emissions from point sources are not anticipated to cause or contribute significantly to any impairment of visibility in Clas s I areas and should be exempt for BART purposes.

6.1 Method

The State of Tennessee determined through mo deling that ammonia emissions from point sources are not anticipated to cause or contribute significantly to a ny impairment of visibility in Class I areas with the exception of one large point source in close proximity to two Class I areas out of Tennessee (i.e., PCS Nitrogen).

VISTAS contracted with Georgia Institute of Technology to perform mode l sensitivity runs to determine the impact of poi nt source ammonia on visibility in Class I areas.

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on regional haze using CMAQv4.5 with SOA mods on the VISTAS 12 km modeling domain, using the VISTAS 2009 OTW (on the way) Base F4 em issions. One such sensitivity run reduced, BART-eligible source ammonia by 100%. The purpose was to quantify the impact of ammonia emissions from VISTAS BART sources on Class I areas. Two episodes were examined: June 1- July 10, 2002 and November 19 – December 19, 2002. The approach included calculating the extinction coefficient in dv (deciviews), then determining the maxi mum impact of BARTeligible source ammonia. The chart below, taken from the VISTAS report BART in the VISTAS Region: Sensitivity to VOC, NH3, and Primary PM Emissions , included as Appendix L-4, shows the impact on the following twenty-two Cl ass I areas within the VISTAS domain. 2



## Maximum NH 3 

## Impact

0.0 0.5 1.0 1.5BRETBRIGCACRCHASCOHUDOSOEVERGRSMHEGLJARILIGOMACAMINGOKEFROMASAMASHENSHROSIPSSWANUPBUWOLF∆dV

### BART Related Documentation Appendix L - 

### 15 Regional Haze SIP for TN Class I Areas April 4, 2008 Figure 6-1. Maximum contributions of all BART-eligible NH 3 point sources in the VISTAS region

to haze in Class I areas duri ng the CMAQ-modeled periods.



### The chart shows the largest haze impact in delt a dv over the two timeframes at each Class I area. These delta dv changes represent the haze contri bution of all BART source ammonia emissions relative to assumed natural haze levels. The natural haze levels are based on EPA-default annual average natural concentrations for the Ea st and monthly-varying “climatologically representative” relative humi dity at each Class I area. During the periods modeled the ammonia emission s from all BART-eligible sources contributed more than 0.5 dv to haze at Mammoth Cave National Park (MACA), Kentucky; Mingo Wilderness (MING), Missouri, Ca pe Romain National Wildlife Refuge Area (ROMA) South Carolina, and Swanquarter National Wild life Refuge (SWAN), North Carolina.

The majority of ammonia emissions in VISTAS region come from four BART-eligible sources as shown in Table 6-1 below.

Table 6-1. Major BART NH 3 

### Sources in the VISTAS Region
Facility State NH 3 Emissions (tpy) Distance to Nearest Class 1 Area (km) Meadwestvaco Corp. SC 174 30 PCS Phosphate NC 206 31 PCS Nitrogen TN 1252 180 PCS Nitrogen GA 1765 220



### Analysis of spatial and temporal distributions of ammonia concentratio ns indicate that the primary point source ammonia contributor to the Mingo haze is the PCS Nitrogen Plant near Memphis, TN. PCS Nitrogen is located 180 km from Mingo.

6.2 Conclusions

The BART requirements of the regional haze rule allow states to determine whether or not ammonia is to be considered a visibility impairing pollutant to be addressed for BART purposes. NH3 emissions from BART sources may impair visibility; however the majority of NH3 emissions in the VISTAS region are from a fe w BART sources. Removal of the large NH3 emission sources results in minimal impact on visi bility at Class I areas in the VISTAS region. At their discretion states may ask those few larg e sources to evaluate NH3 impacts and potential controls for NH3. Based on the CMAQ sensitivity an alyses of the impact of ammonia emissions, the State determined that only one large TN source of ammonia emissions, PCS Nitrogen, would be required to evaluate those emissions for BA RT purposes. PCS Nitrogen has the potential to emit more than 250 tons per year of ammonia from three of its BART e ligible units and it is located less than 300 km from both Mingo and Si psey. Thus these emissions were included in the PCS Nitrogen BART de termination modeling.

### BART Related Documentation Appendix L - 

### 16 Regional Haze SIP for TN Class I Areas April 4, 2008 

## 7. Explanation of BART Exemption Modeling

7.1 Background

Tennessee opted to consider its BART-eligible sources subject to BART unless the source demonstrated exemption via modeling. BART-elig ible sources can be excluded from BART determinations by demonstrating that the source cannot be reasonably ex pected to cause or contribute to visibility impairment in a Class I area. The threshol d for determining that a source causes visibility impairment is set at 1.0 dv change from natural conditions over a 24 hour averaging period. The BART guidelines also propos e that the threshold at which a source may “contribute” to visibility impa irment should not be higher than 0.5 deciviews; however, depending on factors affecting a specific Class I area it may be set lower than 0.5 deciviews.

As stated in the BART regulation EPA’s pr eferred approach for determining cause or contribution is an assessment with an air quali ty model such as CALPUF F or other appropriate model followed by comparison of the estimated 24- hour visibility impacts against a threshold above estimated natural conditions to be determ ined by the State. EPA recommends that the 98 th 

### percentile value from the modeling be compared to the State’s chosen c ontribution threshold to determine if a source does not contribute to visi bility impairment and thus is not subject to BART. Comparison of the 98 th 

### percentile value to the threshold must be made for each Class I area. For an annual period, this implies the 8 th 

### highest 24-hr value at a pa rticular Class I area is compared to the contribution threshol d. For a 3-year modeling period, the 98 th 

### percentile value may be interpreted as the highest of the three annual 98 th 

### percentile values at a particular Class I area or the 22 nd 

### highest value in the combined three year record, whichever is more conservative.

Tennessee worked with the regional planning or ganization (RPO) VISTAS on development of the VISTAS Protocol for the Application of the CALPUFF Model for A nalyses of Best Available Retrofit Technology (BART) (Appendix L-5). The common protoc ol was established to provide the basis for a common understanding among the or ganizations performing BART analyses or reviewing BART modeling resu lts in the VISTAS region.

The VISTAS protocol describes common procedur es for carrying out air quality modeling to support BART determinations that are cons istent with the 40 CFR Part 51 Appendix Y guidelines. The protocol provides a consistent model, CALP UFF, and modeling guidelines for BART determinations, clearly delineated m odeling steps, a common CALPUFF configuration, guidance for site-specific mode ling, and common expectations for reporting model results. Details of the CALPUFF system can be found in Chapter 3 of the VISTAS protocol, specific recommendations for its applic ation for BART purposes are found in Chapter 4, and specific information that should be included in si te-specific protocols is found in Chapter 5.

VISTAS contracted EarthTech to develop a ve rsion of the CALPUFF model appropriate for BART purposes. The VISTAS version of th e CALPUFF model is CA LPUFF Version 5.754 and CALMET Version 5.7.

### BART Related Documentation Appendix L - 

### 17 Regional Haze SIP for TN Class I Areas April 4, 2008 

### For BART modeling purposes VISTAS made pu blicly available 12-km CALMET output files for the entire VISTAS modeling domain (easte rn United States) and provided CALMET output files for five 4-km grid subdomains covering th e VISTAS states and VISTAS Class I areas. To generate the CALMET input files, the VISTAS contractor used the MM5 databases developed by EPA for 2001, VISTAS for 2002, and Midwest RPO for 2003. For the 12 km grid large domain covering the entire VISTAS region, the No-Obs setting was used. For the 4 km grid available surface and upper air observations were used in addition to MM5 meteorological model outputs. Specific model settings were provide d with the CALMET files and via the CALPUFF website so that work could be replicated.

For CALPUFF modeling, source emissions were to be defined using the maximum 24-hour actual emission rate during normal operation for the most recent 3 or 5 years. If maximum 24- hour actual emissions were not av ailable, continuous emission data, permit allowable emissions, potential emissions, and emission f actors from AP-42 source profiles could be used as available.

Key points on specific CALPUFF, CALPOST, and POSTUTIL configuration that were to be used for BART modeling are:

• After running CALPUFF for an individual f acility, NO3 should be repartitioned in POSTUTIL.

• Ozone data from non-urban monitors shoul d be used as the background ozone input.

• The Pasquill-Gifford disper sion method should be used.

• In CALPOST Method 6 with monthly aver age RH for calculating extinction as recommended by EPA should be used.

• EPA default calculations of light extin ction under current and natural background conditions should be used. In addition a sour ce may also calculate visibility using the recently revised IMPROVE algorithm.

Additional discussion of the CALPUFF model a nd VISTAS recommended settings can be found in the VISTAS protoc ol in Appendix L-5.

7.2 Tennessee BART Sources Exemption Modeling

TDEC-APC requested that its s ources follow the VISTAS modeling protocol in development of their site-specific protocols and explain any deviations that they proposed to use. In the sitespecific modeling demonstrations submitted by Tennessee’s BART-eligible sources, the CALPUFF model incorporating thr ee years of pre-processed MM5 meteorological data was used to evaluate the deciview change compared to na tural background conditions at each of the Class 1 areas within 300 km of the source. The 12 km and 4 km MM5 dataset prepared by VISTAS were used. For the 12 km screening runs, the highest daily delta-deci view (dv) value was applied, and for the 4 km refined runs, the 98 th 

### percentile dv value was determined similarly at each Class 1 area and compared to the 0.5 dv cont ribution threshold. For a source located within 50 km from a Class I area (i.e., the Alcoa facili ty) screening analysis is conducted at 4 km and refined modeling analysis is conducted at 1 km.

### BART Related Documentation Appendix L - 

### 18 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Six of the twelve facilities submitted site-specific modeling protocols and subsequent modeling demonstrations based upon the VISTAS modeli ng protocol. Modeling of the other six BARTeligible sources – DuPont-Humphreys, DuPont-S helby, Lucite International, Owens Corning, PCS Nitrogen, and Zinifex-Clarks ville, were conducted by VI STAS contractor using the VISTAS common protocol. The site-specific protocols are found in Appendix L-6 and the demonstrations are found in Appendix L-7 (BAR T exempt demonstrations) and Appendix L-8 (BART non-exempt demonstrations). The protoc ols and demonstrations were reviewed by Tennessee’s Air Pollution Control Division and al so shared with both EPA and FLMs for their review and comment. Their comments were shared with the facilities.

The individual facility modeling demonstrations were also shared with both EPA and FLMs for their review and comment. The resulting comments were in turn shared with the facilities. TDEC-APC worked with EPA and FLMs throughout the process to resolv e many of the issues and concerns reflected in their comments. TDEC -APC staff reviewed th e demonstrations to determine whether the sources have less than 0.5 de icview (dv) impact on any Class I area within 300 km of the source. Sources demonstrating less than 0.5 dv impact are considered exempt. Sources contributing 0.5 dv impact or greater are considered s ubject to BART and required to proceed to an analysis of what control measur es, if any, constitute BART for the source.

Review of the demonstrations submitted led to th e determination that the BART-eligible source at each facility in Table 7-1 should be exempt from BART determination requirements. The modeled impacts from the facilities in Ta ble 7-1 ranged from 0.033 to 0.465 dv at Mammoth Cave. Based upon these demonstrations, TDEC-APC proposes exemption of sources at these eight facilities. Table 7-1 below provides a su mmary of the impacts of each facility’s BARTeligible source on the affected Class I areas.

Table 7-1. BART Exemption Modeling Results for Sources using Old IMPROVE Equation – 12 Km. CALMET – Round 1

Facility Class 1 Areas Distance To Class I Area (km) Impact (Change in dv)

DuPont – Humphreys County (for SO 2 

### , NOx, and PM10) Mammoth Cave National Park 203 0.338 Mingo Wildlife Refuge 225 0.128 Sipsey Wilderness Area 200 0.369

DuPonrt – Shelby County (for SO2, NOx and PM10) Mingo Wildlife Refuge 218 0.151 Sipsey Wilderness Area 216 0.147 Lucite International (for SO 2 

### , NOx, and PM10) Mingo Wilderness Area 187 0.053 Sipsey Wilderness Area 253 0.040

### BART Related Documentation Appendix L - 

### 19 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Owens Corning (for SO 2 

### , NOx, and PM10) Mammoth Cave National Park 297 0.045

Mingo Wildlife Refuge

Sipsey Wilderness Area 187

200 0.064

0.040

PCS Nitrogen (for SO 2 

### , NOx, NH 3 

### and PM10) Mingo Wildlife Refuge 186 0.166

Sipsey Wilderness Area 253 0.074

Zinifex – Clarksville (for SO 2 

### , NOx, and PM10) Cohutta Wilderness Area 312 0.099 Mammoth Cave National Park 131 0.465

Mingo Wildlife Refuge 256 0.125 Sipsey Wilderness Area 247 0.237

Two additional facilities conducted modeling in an effort to demonstrate a contribution less than 0.5 dv utilizing refined modeling demonstration at 4 Km CALMET. The modeled impacts from the facilities in Table 7-2 ranged from 0.033 dv at Mammoth Cave to 0.445 dv at Great Smoky Mountains. Based upon these demonstrations, TDEC -APC proposes exemption of sources at these two facilities. Table 7-2 below provides a summary of the impacts of each facility’s BART-eligible source on the affected Class I areas.

Table 7-2. BART Exemption Modeling Result s for Sources using Old IMPROVE Equation – 4 Km. CALMET – Round 2

Facility Class 1 Areas Distance To Class I Area (km) Impact (Change in dv)

TVA – Bull Run Fossil Plant (for PM10) Cohutta Wilderness Area 118 0.126 Great Smoky Mountains NP 48 0.445
Joyce Kilmer-Slickrock WA 63 0.226
Linville Gorge Wilderness Area 200 0.063

Mammoth Cave National Park 209 0.033

### BART Related Documentation Appendix L - 

### 20 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Shinning Rock Wilderness Area 131 0.081
Packaging Corporation of America (for SO 2 

### , NOx and PM10 ) Mammoth Cave National Park 299 0.101

Mingo Wilderness Area 273 0.064 Sipsey Wilderness Area 100 0.247

Two of Tennessee’s BART-eligib le sources are electric gene rating units (EGUs). These are TVA-Bull Run and TVA-Cumberland. Consistent with BART regulation requirements and EPA guidance, BART-eligible sources at electric util ities complying with EPA’s Clean Air Interstate Rule (CAIR) that wished to demonstrate exemp tion were allowed to model only direct PM fine emissions. Compliance with CAIR constitutes BART for these sources for emissions of NOx and SO2.

The USEPA has determined that , as a whole, the CAIR cap -and-trade program improves visibility more than implementing BART for indi vidual sources in states affected by CAIR. A State that opts to partic ipate in the CAIR program under 40 CFR 96.201-.224 (Subpart AAA through EEE) need not require affected BART-elig ible EGU to install, operate, and maintain BART for SO2 or NOx emissions. Given that all BART-eligible units are installing scrubbers and NOx controls, and since Tennessee is partic ipating in CAIR and accepts USEPA’s overall finding that CAIR “substitutes” for BART for NOx and SO2, Tennessee’s EGUs were allowed to submit BART exemption modeling demonstra tions for PM emissions only. TVA-Bull Run demonstrated that it does not contribute to vi sibility impairment in any Class I area.

In total, eight (8) of Tenness ee’s twelve (12) BART-eligible s ources were able to demonstrate that they did not cause or contri bute to visibility impairment in a ny Class I area within 300 km of the source.

Four of the twelve facilities were unable to demonstrate less than 0.5 dv impact via modeling. The visibility impact results for these four facilities are included in Table 7-3 below.

Table 7-3. Modeling Determination Results for BART-Subject Sources

Facility Class 1 Areas Distance To Class I Area (km) Impact (Change in dv) Alcoa – South Plant ( 1 ) 

### (for SO 2 

### , NOx, and PM10) Cohutta Wilderness Area 99 0.335

### BART Related Documentation Appendix L - 

### 21 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Great Smoky Mountains 18 1.310

Joyce Kilmer-Slickrock

Linville Gorge WA

Mammoth Cave NP (2)



### Shinning Rock WA 16

185

244

108 0.686

0.370

0.350

0.463

DuPonrt – Old Hickory (for SO2, NOx and PM10) Mammoth Cave NP (3) 

### 105 0.504

Cohutta Wilderness Area

Great Smoky Mountains

Joyce Kilmer-Slickrock

Sipsey Wilderness Area 233

249

254

220 0.160

0.220

0.190

0.310

Eastman Chemical (4) 

### (for SO 2 

### , NOx, and PM10) Cohutta Wilderness Area 245 0.292

Great Smoky Mountains

James River WA

Joyce Kilmer-Slickrock

Linville Gorge WA

Shinning Rock WA 98

289

174

85

124 0.992

0.289

0.470

0.875

0.543

TVA-Cumberland (5) 

### (for PM10)

Mammoth Cave NP 153 1.359

### BART Related Documentation Appendix L - 

### 22 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Mingo Wildlife Refuge

Sipsey Wilderness Area 233

223 0.404

0.557

(1) Alcoa BART base case, refined 1-km runs, highest-1 st to 8 th -high value, 3% sulfur coal using New Improve Equation.

(2) Alcoa exemption modeling, screening 4-km runs, 1 st highest value, using Old Improve Equation only for MACA.

(3) DuPont BART base case Mammoth Cave (MACA) modeling, refined 4-km runs, 8 th highest value (occurs only 7 days in 2003 at 24 hour maximum firing rate). A maximum delta DV of 0.36 is obtained at only 3 days occurrence in 2003 at monthly averaged maximum emis sion rate, which is more representative of the firing patterns for the Boilers. Revised summer time 24-hour maximum emission rates resulte d in a 0.474 DV at MACA. This source is still subject to BART control assessment.

(4) Eastman BART control case, refined 4-km runs, 8 th highest value, SDA/FF Controls, using New Improve Equation.

(5) TVA-Cumberland BART base case, refined 4-km runs, 8 th highest value, hydrated lime , using Old Improve Equation.

### BART Related Documentation Appendix L - 

### 23 Regional Haze SIP for TN Class I Areas April 4, 2008 Table 7-3. BART Subject Sources and AOI Modeling Results

Class 1 Areas Delta- Within
Facility 

### Impacted Deciview AOI ?

Alcoa – South Plant Cohutta Wilderness Area 0.335 NO

(BART Subject) Great Smoky Mountains NP 1.310 YES Joyce Kilmer-Slickrock WA 0.686 YES
Linville Gorge Wilderness Area 0.370 NO

Mammoth Cave NP 0.350 NO Shinning Rock Wilderness Area 0.463 NO DuPont – Old Hickory Great Smoky Mountains NP 0.220 NO

(BART Subject) Sipsey Wilderness Area 0.310 NO Joyce Kilmer-Slickrock WA 0.190 NO

Cohutta Wilderness 0.160 NO

Mammoth Cave NP 0.504 1 NO

Eastman Chemical Great Sm oky Mountains NP 0.992 YES

(BART Subject) James River Wilderness Area 0.289 NO Joyce Kilmer-Slickrock WA 0.470 YES

Cohutta Wilderness 0.292 NO Linville Gorge Wilderness Area 0.875 YES Shinning Rock Wilderness Area 0.543 YES

TVA - Cumberland Mammoth Cave NP 1.359 YES

(BART Subject) Mingo Wildlife Refuge 0.404 NO Sipsey Wilderness Area 0.557 NO

TVA – Bull Run Great Smok y Mountains NP 0.445 YES

(BART Exempt) Joyce Kilmer-Slickrock WA 0.226 YES

Cohutta Wilderness 0.126 YES Linville Gorge Wilderness Area 0.063 YES Shinning Rock Wilderness Area 0.081 YES

(1) In later modeling using revised summe r time emission rates with new IMPROVE equation baseline impact was 0.474.



### From a Class I area standpoint, Alcoa is within the area of influence of GRSM, JOKI, and SHRO. Eastman Chemical is within the area of influence of GRSM, JOKI, LIGO, and SHRO, TVA-Cumberland is within the area of influence of MACA and SIPS.

### BART Related Documentation Appendix L - 

### 24 Regional Haze SIP for TN Class I Areas April 4, 2008 Table 7-4. TN Sources Impacting TN Class I Areas 

### TN BART-Eligible Sources w/in 300 km TN Class I Area GRSM JOKI Alcoa – South Plant X X DuPont - Humphreys DuPont – Old Hickory DuPont -Shelby Eastman Chemical X X Lucite International Owens Corning Packaging Corporation of America PCS Nitrogen TVA – Bull Run TVA - Cumberland Zinifex 2 2

Four TN BART-eligible sources modeled im pacts at Great Smoky Mountains and Joyce Kilmer-Slickrock, but only two contributed to visibility impairment. Although all modeled impacts, only three of the BART-eligible sources c ontributed to visibility impairment at Class I areas outside of Tennessee.

Table 7-5. Impacts of TN BART-Eligible Sources on Class I Areas Within TN

TN BART-Eligible Sources w/in 300 kmGRSMFractionof AOI (%)JOKIFractionof AOI (%)



### Alcoa – South Plant 1.310 0.2437 0.686 0.1205 

### DuPont – Old Hickory 0.220 0 0.190 0



### Eastman Chemical 0.992 0.0423 0.470 0.0180



### TVA – Bull Run 0.445 0.1414 0.226 0.0849

### BART Related Documentation Appendix L - 

### 25 Regional Haze SIP for TN Class I Areas April 4, 2008 Table 7-6. Impacts of TN BART-Eligible Sources on Class I Areas Outside TN

TN BARTEligible Sources w/in 300 km 

### Class I AreasCOHUFractionof AOIJARIFractionof AOILIGOFractionof AOIMACAFractionof AOISHROFractionof AOISIPSFractionof AOIMINGFraction



### AlcoaSouth Plant 0.335 0.0064 0.686 0.370 0.0086 0.350 0.463 0.0152

DuPont – Humphreys 0.338 0.0006 0.369 0.0004 0.128

DuPont – Old Hickory 0.160 0.504 0.0185 0.310 0.0053

DuPont – Shelby 0.147 0.151

Eastman Chemical 0.292 0.0054 0.289 0.2429 0.543 0.0445

Lucite Internationa l 0.040 0.053

Owens Corning 0.045 0.040 0.064

Packaging Corp. of America 0.101 0.247 0.064

PCS - Nitrogen 0.074 0.166

TVA Bull Run 0.126 0.0152 0.063 0.0122 0.033 0.081 0.0132

TVA - Cumberland 0.712 0.0344 0.287 0.0112 0.404

Zinifex 0.099 0.465 0.237 0.125

### BART Related Documentation Appendix L - 

### 26 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Note: For purposes of this table if any emission unit is in the AOI for SO2 the facility is noted as being in the AOI.

Tennessee BART-eligible sources modeled impacts at seven out-of-state Cla ss I areas including James River Face Wilderness Area in Virginia , Mammoth Cave National Park in Kentucky, Cohutta in Georgia, Sipsey Wilderness Area in Alabama, MingoWildlife Refuge in Missouri, sand Linville Gorge and Shinning Rock in North Carolina. Two TN sources, representing % of the 2018 total SO2 emissions in the AOI, modeled impacts at James River. Five TN sources, representing % of the 2018 total SO2 emissions in the AOI, modeled impacts at Cohutta. Eight TN sources, representing % of the 2018 total SO2 emissions in the AOI, modeled impacts at Mingo. Nine TN sources, representing % of th e 2018 total SO2 emissions in the AOI, modeled impacts at Sipsey. Three TN sources, represen ting % of the 2018 total SO2 emissions in the AOI, modeled impacts at Shining Rock. Three TN sources, representing % of the 2018 total SO2 emissions in the AOI, modeled impacts at Linvi lle Gorge. The modeled impacts ranged from 0.033 dv to 0.712 dv at Mammoth Cave. Only two Te nnessee BART-eligible sources, Alcoa and TVA-Cumberland, modeled a contri bution in access of 0.5 dv at tw o out-of-state Class I areas (i.e., SHRO and MACA) respectively.

7.3 BART-Eligible Sources in Other States Im pacting the AoI of Tennessee Class I Areas

At this time the VISTAS states are at various points in their processe s for addressing BART. Tennessee intends to provide a summary of the BA RT decisions to date for any BART subject sources that fall into the AoI (1% contribution or more) of any of Tennessee’s Class I areas for the SIP that is made available for public heari ng. Tables 7-7 and 7-8 list outside sources that impact the AoIs of Great Smokys and Joyce Kilmer-Slickrock .

Table 7-7. Outside Sources Impacting Great Smoky Mountains

SO2 Tons CE Distance Fraction

State Plant ID Plant Point ID (2002 G) (2018 G) (%)* (km) Q/d Q/d^2 RT Max** Q/d*RTMax Contribution

NC 3708700159 BLUE RIDGE PAPER PRODUCTS - CANTON MILL G-25 2,195 2,565 0 100.17 25.61 0.26 50.35 1289.46 0.0118



### Table 7-8. Outside Sources Impacting Joyce Kilmer

SO2 Tons CE Distance Fraction

### BART Related Documentation Appendix L - 

### 27 Regional Haze SIP for TN Class I Areas April 4, 2008 State Plant ID Plant Point ID (2002 G) (2018 G) (%)* (km) Q/d Q/d^2 RT Max** Q/d*RTMax Contribution

SC 0200-0004 DUKE ENERGY:LEE 003 4,384 7,274 0 164.50 44.22 0.27 27.54 1217.82 0.0198

GA 07700001 GEORGIA POWER COMPANY, YATESSTEAMELECT SG07 14,024 16,530 0 229.18 72.13 0.31 16.05 1157.69 0.0188

GA 07700001 GEORGIA POWER COMPANY, YATESSTEAMELECT SG06 15,175 16,367 0 229.18 71.42 0.31 16.05 1146.29 0.0186

GA 20700008 GEORGIA POWER COMPANY, SCHERER STEAM-ELE SG03 18,149 27,735 0 258.20 107.42 0.42 8.94 960.33 0.0156

GA 20700008 GEORGIA POWER COMPANY, SCHERER STEAM-ELE SG04 20,771 26,616 0 258.20 103.09 0.40 8.94 921.62 0.0150

GA 20700008 GEORGIA POWER COMPANY, SCHERER STEAM-ELE SG01 25,286 26,264 0 258.20 101.72 0.39 8.94 909.38 0.0148

GA 20700008 GEORGIA POWER COMPANY, SCHERER STEAM-ELE SG02 24,966 26,075 0 258.20 100.99 0.39 8.94 902.85 0.0147

SC 0200-0004 DUKE ENERGY:LEE 001 2,386 4,347 0 164.54 26.42 0.16 27.54 727.61 0.0118

SC 0200-0004 DUKE ENERGY:LEE 002 2,643 4,140 0 164.50 25.17 0.15 27.54 693.18 0.0113

GA 01500011 GEORGIA POWER COMPANY, BOWENSTEAMELECT SG04 42,634 6,294 90 163.76 38.44 0.23 17.63 677.70 0.0110

NC 3708700159 BLUE RIDGE PAPER PRODUCTS - CANTON MILL G-25 2,195 2,565 0 104.38 24.58 0.24 26.88 660.71 0.0107

GA 01500011 GEORGIA POWER COMPANY, BOWENSTEAMELECT SG03 42,900 6,111 90 163.76 37.32 0.23 17.63 657.95 0.0107

AL 0008 TVA - WIDOWS CREEK 008 9,181 10,185 90 170.64 59.69 0.35 10.74 641.07 0.0104 

### 7.4 Use of New IMPROVE Equation

During the regional haze SIP development process, the IMPROVE Steering Committee made recommendations for a new IMPROVE equation. Among other things, the new equation includes

### BART Related Documentation Appendix L - 

### 28 Regional Haze SIP for TN Class I Areas April 4, 2008 

### components that take into account the effects of s ea salt and site specific Rayleigh scattering. Additional discussion of the new IMPROVE equation can be found in Appendix L-9.

VISTAS contracted Dr. Ivar Tombach to develo p a post processor to allow CALPOST outputs to be used with the new IMPROVE equation. TDEC-A PC submitted to US EPA Region 4 a request for approval to use the new IMPROVE equatio n and postprocessor developed by Dr. Tombach in BART modeling. A discussion of the rati onale for use of the new IMPROVE equation follows. The new IMPROVE postprocessor and instru ctions are included in the request to EPA for approval of its use in Appendix L-9.

Rationale for Need for Use of New IMPROVE Equati on The new IMPROVE equation is a much better repres entation of the effects of particulate matter on light extinction than the old e quation and takes into account the latest scientific understanding of several parameters.

1. The new algorithm overcomes biases of the old algorithm on the haziest days and the clearest days as demonstrated by compar ing the measured light extinction from nephelometers at Class I areas to light exti nction calculated using each of the equations. 2. The new algorithm recognizes spatial and tem poral variation in light extinction as size distribution of the aerosol changes by increasi ng extinction efficiency as sulfate, nitrate and organics concentrations increase. 3. The new algorithm incorporates a term to reflect the contribution of fine sea salt and its hygroscopic growth with in creasing relative humidity recognizing research findings showing that fine sea salt can be an importa nt contributor to light extinction in coastal

areas. 4. The new algorithm reflects research finding that the mass concentration of particulate organic matter in rural areas is greate r than represented by the old equation. 5. The new algorithm includes a NO 2 

### term to represent times when light absorption by NO 2 

### is a meaningful contribu tor to light extinction. 6. The new algorithm incorporates site-speci fic Rayleigh scattering values to better represent sites close to sea level or with very hot or cold climates.

With this combination of revisions to the IM PROVE equation, the resulting apportionment of extinction to various components is more accura te on the haziest and clearest days. This is important for development of emission control st rategies since the benefits of control of concentrations of each species will be repres ented more correctly with the new algorithm.

Three of Tennessee’s BART eligible sources, Alcoa, Eastman Chemical, and DuPont –Old Hickory have requested the application of this new equation as a better science in assessing the haze impacts. The ability to appropriately repr esent the contribution of sea salt for BART sources is important in determining their cont ribution to haze and evaluating the benefit of potential control strategies. US EPA Region 4, National Park Service, and the US Fish & Wildlife Service determined that adding site-specifi c data to account for the impact of sea salt

### BART Related Documentation Appendix L - 

### 29 Regional Haze SIP for TN Class I Areas April 4, 2008 

### and Rayleigh scattering to the old IMPROVE equa tion is not appropriate, but rather the entire new IMPROVE equation should be used. The spreadsheet developed by Dr. Tombach to implement the entire new IMPROVE equation fo r use with CALPUFF c ontains a modification of CALPOST that calculates the light extinction from the CALPU FF output. In their review of the spreadsheet and supporting documentation, EPA Region 4 sta ff commented that the VISTAS methodology contained in the spreadsheet develo ped by Dr. Tombach appropriately implements the features of the new IMPROVE equation, with the exception of the nitrogen dioxide term. EPA Region 4 further stated that with the a ddition of their recommendation for addressing the NO 2 

### term, the VISTAS methodology to incorporat e the new IMPROVE equation is acceptable on a case-by-case basis upon consul tation with the EPA Regional Office. The use of the full new IMPROVE equation makes a difference for three Tennessee’s sources as shown in Table 7-9.

Table 7-9. Comparison of Old versus New IMPROVE Results



### BART-Eligible Source

Class I Area Old IMPROVE



### delta dv New
IMPROVE



### delta dv Alcoa – South Plant GRSM 1.62 1.31 Eastman Chemical LIGO 1.06 0.875 DuPont – Old Hickory MACA 0.929 0.504 EPA’s approval of Tennessee’s request to use the new IMPROVE equation for BART purposes is found in Appendix L-9.

7.5 Conclusion

In total eight of Tennessee’s twelve BART-eligible sources were able to demonstrate that they did not cause or contribute to visibility impair ment in any Class I area within 300 km of the source. Six sources used the old IMPROVE equa tion and a 12 km CALMET screening analyses in efforts to demonstrate exemption. Two sources , Packaging Corporation of America (PCS) in Counce, TN and TVA-Bull Run near Clinton, TN, we re able to demonstrate exemption using the old IMPROVE equation and a refi ned 4 km CALMET assessment.

Four sources, Alcoa in Alcoa, TN, Eastman Chemical in Kingspor t, TN, DuPont-Old Hickory in Old Hickory, TN and TVA-Cumb erland near Cumberland, TN were unable to demonstrate a contribution of less than 0.5 dv at all Class I areas within 300 km from their BART-eligible sources which caused those sources to be consid ered “subject to BART”. These four sources were required to submit permit applications containing their evalua tion of potential BART options and proposed BART determination. Discu ssion of the BART determinations for these four sources is included in Section 9.0 below. All of them utilized the new IMPROVE equation in their BART modeling assessments w ith the exception of TVA-Cumberland.

A spreadsheet summarizing all the BART-eligible sources in Tennessee, their distance to and impact on Class I areas, version(s) of the IM PROVE equation used and difference in results, whether a BART determination was required, the f acilities’ potential emissions, the version of

### BART Related Documentation Appendix L - 

### 30 Regional Haze SIP for TN Class I Areas April 4, 2008 

### CALPUFF and its components used, who conduc ted the modeling, existing controls, and proposed controls resulting from BART de terminations is included as Appendix L-10. (Note: This is a spreadsheet that was provided by EPA Region 4 as one suggested way of summarizing the BART information for the SIP.)



## 8. BART Determinations

For those facilities subject to BART, the state must determine what constitutes BART controls for the source by considering vari ous control options and selecting the best alternative taking into consideration any pollution control equipment in use at the so urce, the costs of compliance with control options, the remaining useful life of the facility, the energy and non air-quality environmental impacts of compliance, and the de gree of improvement in visibility that may reasonably be anticipated to result from th e use of such technology. Under Tennessee’s approach, facilities that are s ubject to BART were required to propose BART considering these factors via a permitting process.

8.1 BART Subject Sources

There are four BART-eligible sources in Te nnessee that emit any ai r pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in any Class I area. These four facilities, Alcoa in Alcoa, TN, Eastman Chemical in Kingsport, TN, TVACumberland in Cumberland, TN, and DuPont-Old Hickory in Old Hickory, TN, were unable to demonstrate less than a 0.5 dv impact on one or more Class I areas and thus are subject to BART.

In accordance with Tennessee’s framework BART rule, TAPCR 1200-3-23, Best Available Retrofit Technology (Appendix L-1), the four fac ilities submitted permit a pplications proposing BART for their sources (Appendix L-8). Upon recei pt, the proposed BART determinations were provided to US EPA Region 4 and the FLMs for their review and comment. TDEC-APC also held conference calls with US EPA Region 4 and the FLMs to discuss their comments and concerns regarding each of the facilities’ submittals.

TDEC-APC permitting staff reviewed th e permit applications proposing BART.

8.1.1 BART-eligible Units and Existing Control

8.1.1.1 Alcoa - BART-eligible Un its and Existing Control

Alcoa has twenty-four BART-eligible emission un its that comprise the BART-eligible source. The majority of these units are currently controll ed. A description of these units taken from the Alcoa BART demonstration submittal (See Appendix L-8) follows.

Table 8.1.1.1 Primary Aluminum Reduction Emission Units, Alcoa Inc. – Tennessee

### BART Related Documentation Appendix L - 

### 31 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Operations

Emission Unit ID Emission Unit Description Visibility Impairing Pollutants Existing Pollution Controls 05-0008-81 Potline 1 Electrolytic reduction operations that convert alumina and other raw materials to molten aluminum in the potline. PM, SO 2 Reactor / Fabric Filter

05-0008-85 Potline 2 Electrolytic reduction operations that convert alumina and other raw materials to molten aluminum in the potline. PM, SO 2 Reactor / Fabric Filter

05-0008-18 Anode Baking Furnace This emission unit includes the 261N, 262N, and 262S anode baking furnaces, which are controlled by the A-446. PM, SO 2 , NO X Reactor / Fabric Filter



### Table 8.1.1.1 (Continued)

Emission Unit ID Emission Unit Description Visibility Impairing Pollutants Existing Pollution Controls 05-0008-02 Coke Unloading and Storage This emission unit includes operations that unload virgin coke from railcars and store it for feed to the Electrode Plant "A” operations. Emissions are controlled by dust collector 8. PM Fabric Filter

05-0008-03 Electrode Plant A This emission unit includes all operations controlled by baghouse 12, which include the screening and blending of virgin coke and ground anode butts and green scrap before feeding to the carbon paste mixers. PM Fabric Filter

05-0008-12 Stub Dipping This emission unit covers the operation where anode rods are dipped in to a coating to ensure separation of cast iron. Volatile Organic Compounds

05-0008-14 Butts Blasting Butts blasting uses a blasting media to remove residual bath from the spent anodes following butts cleaning. Emissions are controlled via a dust collector. PM Fabric Filter

05-0008-16 Induction Furnaces This emission unit covers the process of melting cast iron and pouring it into the anodes to bond the rods to the anode blocks. Emissions are controlled via baghouse. PM, SO 2 Fabric Filter

05-0008-19 Ball Mill This emissi on unit receives carbon that is to be pulverized by the Electrode Plant "A” operations, crushes these, and returns the carbon fines. Emissions are controlled by dust collector 10. PM Fabric Filter

05-0008-20 Pitch Tanks Coal Tar Pitch Storage Tanks 217A, B, and C. Volatile Organic Compounds

### BART Related Documentation Appendix L - 

### 32 Regional Haze SIP for TN Class I Areas April 4, 2008 05-0008-26 Stripping Presses This emission unit includes two stripping presses that remove the carbon and cast iron from the anode assemblies following the butts blasting operation. PM Fabric Filter

05-0008-30 Butts Intermediate Classifying System This emission unit is currently idled. When operable, it serves as a classifying system for intermediate-sized recy cled carbon. Emissions are controlled via dust collector 9. PM Fabric Filter

05-0008-31 Ore Unloading, Trans. and Storage This emission unit covers unloading of raw materials, bulk storage of those materials, and transfer to the potline 1 and 2 material handling systems (process weight rate is 300 tons/hour). This emission unit includes sodastorage tank 141L, conveyor B-4, conveyor B4A, tower 3A, conveyor B-2, fresh ore tank 142N, fresh ore tank 142S, fresh ore tank 143N, fresh ore tank 143S, feed tank 141A, fluoride storage tank 141F, feed tank 141K,feed tower 2, rail unloading, and conveyor B5 discharge/B-6. All emission points are controlled with dust collection except fluoride storage tank 141F and soda storage tank 141F, which are uncontrolled and identified as insignificant emission units. PM Fabric Filter



### Table 8.1.1.1 (Continued)

Emission Unit ID Emission Unit Description Visibility Impairing Pollutants Existing Pollution Controls 05-0008-33 Bath Crushing/ Crucible Digging This emission unit covers the operations receiving bath from butts cleaning and crucible digging, and includes bath crushing, storage, and mixing with alumina for return to the potlines, transfer, or sales. This emission unit includes a bucket fill station. PM Fabric Filter

05-0008-51 Carbon Reclamation This emission unit is baghouse controlled. The process weight rate 150,000 lb/hour. PM Fabric Filter

05-0008-54 Packing Material Handling This emission unit includes railcar unloading of virgin packing material and storage and transfer of clean an d recycled packing material for use in the anode baking furnaces and is baghouse controlled. PM Fabric Filter

05-0008-62 Butts Cleaning Butts cleaning removes bath from the spent anodes and is the first step in the carbon reclamation process. This emission unit is baghouse controlled. PM Fabric Filter

05-0008-98 Initial Carbon Paste Mixing Operations and Green Mill Anode Forming This emission unit receives virgin and recycled carbon and mixe s these with pitch to form a paste. The paste is compacted into the shape of new green anodes. PM, Volatile Organic Compounds Reactor / Fabric Filter

### BART Related Documentation Appendix L - 

### 33 Regional Haze SIP for TN Class I Areas April 4, 2008 05-0008-10 Potline I Material Handling (North Courtyard) Alumina feed tanks 142NE and 142NW, airlifts 142NE and 142 NW, and dust collectors. PM Fabric Filter

05-0008-39 Potline I Material Handling Alumina feed tanks 142SE and 142SW, airlifts 142SE and 142 SW, and dust collectors. PM Fabric Filter

05-0008-43 Potline I Material Handling Alumina feed fill station, air slide 101S, air slide 102S, air slide 101N, air slide 102N, north discharge air slide, and south discharge air slide. PM Fabric Filter

05-0008-44 Potline II Material Handling Conveying and storage of raw materials for potline 2. The emission unit includes air lift 146N, air lift 146S, air slide 103N, air slide 103S, air slide 104N, air slide 104S, ore tank 146N, and ore tank 146S. PM Fabric Filter

05-0008-47 143N-TP002 LII North Conveying of raw materials for potline 2. PM Fabric Filter

05-0008-86 143S-TP002 LII South Conveying of raw materials for potline 2. PM Fabric Filter



### Potlines 1 and 2 emit SO 2 

### and particulate matter (PM), and the anode bake furnace emits

lesser amounts of SO 2 

### , nitrogen oxides (NO X 

### ), and PM. These three emission units are already
equipped with sophisticated emission control e quipment for PM, so the BART determination for
these emission units focuses primarily on potential reductions for SO 2 

### and NO X



### .

The remaining 21 emission units identified in Table 8.1.1.1 are material handling and
transfer operations that support the potlines a nd the anode bake furnace. Two of these support
operations are negligible sources of volatile organic compounds. Emissions from 19 of these
support operations consist of relatively small amounts of PM that are controlled by fabric filter
type control devices. Fabric filt ers effectively remove >99% of particulate emissions and, based
on a control technology review, repr esent the best available contro l for these types of material
handling and transfer operations. Given the level of emissions and that fabric filters represent the
best available control, these emission sources were excluded from both visibility modeling and
further BART engineering anal ysis. Based on visibility modeling results for the aluminum
reclamation melting furnaces, which have a compar able PM emission rate, visibility impacts

from individual fabric f ilters are projected to be ≤ 0.01 deciviews (dv). BART for these support
operations was determined to be the existing level of control.

### BART Related Documentation Appendix L - 

### 34 Regional Haze SIP for TN Class I Areas April 4, 2008 

### 8.1.1.2 Eastman Chemical - BART-eligi ble Units and Existing Control

Table 8.1.1.2 shows the list of BART-eligible units that are located at Tennessee Operations (TNO) in Kingsport, TN. This table includes general information on the size and emissions of the emission units. Speci fic information on stack parameters and maximum daily emissions of the emission un its is included in the BART Modeling Protocols (included as Appendix L-6).



## Table 8.1.1.2 Eastman Chemical BART-eligible Emission Units

MSOP PES Vent ID Emission Unit Description NOx 2005 Actual Emissions Allowable Existing Controls 2005 Actual Emi Tons Basis Tons B Coal-fired industrial boilers 02 B-253-1 A-E Boilers #25 - #29(pulverized coal, tangentially fired, 655 MBtu/hr each) 4,555 CEMS N/A LNB (ozone season) 14,309 CE M

02 B-83-1 C Boiler 24 (overfeed stoker, 500 MBtu/hr) 569 CEMS N/A None 1,494 Fue l Usa g Sul fu Con t Cracking Furnaces (Natural Gas-Fired) 16 B-6C-1 A Furnace 27 (18 MBtu/hr) 6.5 AP-42, Fuel Usage 10.6 tpy None 0.16 AP- 4 Fue l Usa g 16 B-6C-1 B Furnace 28 (18 MBtu/hr) 6.5 AP-42, Fuel Usage 10.6 tpy None 0.16 AP- 4 Fue l Usa g Others25 OCBATCH Various (see Title V applicat ion) General Purpose Batch Chemical Manufacturing 14.0 tpy Scrubbers

### BART Related Documentation Appendix L - 

### 35 Pre-Hearing Draft January 18, 2008 Regional Haze SIP for TN Class I Areas 

### 8.1.1.2.1 BART Control Options Review and Analysis

1.1 Building 253 Powerhouse, Coal-fired Boilers #25-#29

1.1.1 Emission Unit Description

These five boilers are located side-by-side in Building 253 at the Kingsport plant. All of these bo ilers are Combustion Engineering tangentially-fired pulverized coal boilers started up between 1966 and 1972. They are rated at a maxi mum heat input capacity of 655 MBtu/hr. Eastern Kentucky and we stern Virginia type bituminous coal is the only fuel burned in these units (other than natural gas for startups).

These units are used for co-produc tion of steam and electricity in support of manufacturi ng operations at the Kingsport plant. A high level of reliability and the abil ity to handle boiler load swings are requirements for any emissions control system. Although these units are typically base loaded, at times individual boiler load can swing as much as 100 klb/hr in a minute or two in response to a steam or electric load upset.

Existing Particulate Matter Controls : Each boiler has a five field electrostatic precipitator (ESP) with collecting area of 167,416 ft2 and a design flue gas flow rate of 286,000 acfm. The electrostatic precipita tors are located at ground level. These precipitators were inst alled in the early 1990s.

Existing NOx Controls: During 2001-2003, the burners on these boilers were retrofitted with the Alstom P2 system. This system incorporates vaned close-coupled ov erfire-air (separates the upper end auxiliary air from the fire creating a mini-SOFA within the windbox) with modified coal tips th at provide for flame attachment closer to the burners. When fi red in low NOx mode during the NOx SIP call ozone season (May through September), average NOx emission rates have run around 0.32 lb/MBtu. However, performance depends on boiler loa d. At high boiler loads, three mills operation is required. At lower loads, the boiler can run on only two mills. This latter mode of operation is, in essence, equivalent to a NOx control st rategy know as Burner Out of Service (BOOS) and results in sign ificantly lower NOx emissions. For our evaluations of further NOx control measures, we are assuming an average emission rate of 0.35 lb/MBtu to account for uncertainty in future boiler lo ad demands dictated by unplanned outages or site steam load requi rements. For a given control

### BART Related Documentation Appendix L - 

### 36 Regional Haze SIP for TN Class I Areas April 4, 2008 

### strategy, this assumption will result in higher estimates of emission reductions and correspondingly lowe r cost-effectiveness estimates.

Existing SO2 Controls : Other than purchase of low to medium sulfur coal to meet the SIP limit of 2.4 lb/MBtu, there are no existing controls of sulfur dioxide emissions. The average emission rate for calendar year 2005 was 1.4 lb/MBtu.

8.1.1.3 DuPont – Old Hickory - BART-eligible Units and Existing Control

The DuPont Old Hickory Plan t Title V Air Permit includes the following information relative to the two BART-eligi ble boilers, Boilers 20 and 24:

Source Description:

• Boiler 20- Rated capacity- 445 million Btu/hr ; installation date- 1968; tangentially fired; primary fuel- coal; #1 standby fuel - natural gas; #2 st andby fuel- No.2 Fuel Oil

• Boiler 24- Rated capacity- 315 million Btu/hr ; installation date- 1966; tangentially fired; primary fuel- coal; #1 standby fuel - natural gas; #2 st andby fuel- No.2 Fuel Oil

Mass and Visible Emission Standards and Operating Schedule Limitations

• Boilers 20 and 24- visibl e emission standard- 20%

• Boilers 20 and 24- operating schedule limitations- 24 hrs/day, 8,760 hr/year

• Boiler 20 (Emission Point 009) mass emission standards:

Pollutant Lb/hr Lb/day Rolling 12 Month Tons PM 10 

### 77.4 1858 339.1 SO 2 

### 1295.2 31,086 5673 NOx 241.2 5789 1056.4 CO 10.4 251 45.7 VOC 2.4 57 10.51

• Boiler 24 (Emission Point 011) mass emission standards:

Pollutant Lb/hr Lb/day Rolling 12 Month Tons PM 10 

### 54.8 1315 240.1 SO 2 

### 916.9 22,004 4015.8 NOx 179.6 4309 786.4 CO 7.4 177 32.4 VOC 1.7 41 7.45

### BART Related Documentation Appendix L - 

### 37 Regional Haze SIP for TN Class I Areas April 4, 2008 

### • Boilers 20 and 24 are subject to MCL 10.56.200 (Davidson County-Local Program) which limits the maximum sulfur content of any solid or liquid fuel to 2.0% sulfur by weight. The above sta ndards are based on a maximum sulfur content of 0.05% by wei ght for No.2 Fuel Oil.

• Boilers 20 and 24 are subject to 40 CF R 75, Subpart H, NOx Budget Trading Program.

• All boilers are subject to 40 CFR 63, Subpart DDDDD, Industrial, Commercial, and Institutional Boilers and Process Heaters with a compliance date of September 13, 2007.

The two Boilers at DuPont’s Old Hickory Pl ant in Old Hickory, TN are BART eligible based on their installation date and design heat input as indicated above. These Boilers are designated Boiler 20 and Boiler 24. The em issions from these boilers were modeled to determine the possible visibility impact on nearby Class 1 areas.

8.1.1.4 TVA – Cumberland - BART-eligible Units and Existing Control

The TVA Cumberland Fossil Plant (CUF), located in Stewart County, TN, has two pulverized-coal-fired steam generators that ar e considered BART eligible. Units 1 and 2 are nominally rated at about 1325 MW each. Both units are equipped with flue gas desulfurization (FGD) systems for sulfur dioxide (SO 2 

### ) control, selective catalytic reduction systems for contro lling nitrogen oxides (NO x 

### ), and electrostatic precipitators (ESPs) to control particulate matter (PM) em issions. In addition, CUF currently uses hydrated lime injection on both uni ts to mitigate stack opacity.

The two units at CUF are subject to the EPA Clean Air Interstate Rule (CAIR). Based on guidance from EPA and TDEC-APC, comp liance with CAIR satisfies BART requirements for SO 2 

### and NO x 

### emissions at electric genera ting units. As a result, the BART analysis only considerd PM 10 

### emissions.

Table 8.1.1.4 .1 Stack Parameters for CUF

Table 8.1.1.4.2. Emissions profiles from SMOKE for EGUs (provided by VISTAS). Stack Parameter Unit 1 Unit 2 Stack Height (m) 194 194 Base Elevation (m) 118 118 Stack Diameter (m) 11.7 11.7 Gas Exit Velocity (m/s) 19.7 19.7 Stack Gas Exit Temperature ( o 

### K) 321 321

### BART Related Documentation Appendix L - 

### 38 Regional Haze SIP for TN Class I Areas April 4, 2008 profile Pllt species split divisor mass_frac

22001 PM2_5 PEC 0.0183 1 0.0183

22001 PM2

_ 5 PMFINE 0.852 1 0.852

22001 PM2

_ 5 PNO3 0 1 0

22001 PM2

_ 5 POA 0.0107 1 0.0107

22001 PM2

_ 5 PSO4 0.119 1 0.119



### Table 8.1.1.4.3 Emission Rates for CUF 1 and CUF 2

Species CUF 1 Hydrated Lime Emission Rates (g/s) PM800 PM425 PM187 PM112 PM081 PM056 Total PM10 56.389 PMC 3.3293 4.1126 7.44 SOIL 2.2631 0.5658 0.3772 2.2630 5.47

EC 0.0870 0.0217 0.0145 0.0869 0.21 H2SO4 36.15

SOA 3.5607 3.5607 7.12 NO3/HNO3 0.00
Species CUF 2 Hydrated Lime Emission Rates (g/s) PM800 PM425 PM187 PM112 PM081 PM056 Total PM10 79.053 PMC 9.0798 11.2162 20.30 SOIL 6.1721 1.5430 1.0287 6.1721 14.92

EC 0.2371 0.0593 0.0395 0.2371 0.57 H2SO4 36.15

SOA 3.5607 3.5607 7.12 NO3/HNO3 0.00 Species CUF 1 and CUF2 Wet ESP Emission Rates (g/s) PM800 PM425 PM187 PM112 PM081 PM056 Total PM10 35.342 PMC 4.5399 5.6081 10.148 SOIL 3.0860 0.7716 0.5143 3.0860 7.458

EC 0.1186 0.0296 0.0198 00.1186 0.287 H2SO4 10.328

SOA 3.5607 3.5607 7.121 NO3/HNO3 0.00



### 8.2 Baseline Contribution

Alcoa’s BART source baseline contribution to vi sibility impairment is 1.31 dv at GRSM and 0.686 dv at JOKI. Eastman Chemical’s BART source baseline contribution to

### BART Related Documentation Appendix L - 

### 39 Regional Haze SIP for TN Class I Areas April 4, 2008 

### visibility impairment is 2.06 dv at LIGO, 2.55 dv at GRSM, 1.44 dv at SHRO, 1.67 dv at JOKI, 1.01 dv at COHU, and 0.79 dv at JARI. DuPont-Old Hickory’s source baseline contribution to visibility im pairment is 0.504 dv at MACA. TVA-Cumberland’s BART source baseline contribution to visibility impairment is 1.359 dv at MACA and 0.557 dv at SIPS.

8.3 BART Determination Analysis

Section 169A(g)(7) of the CAA requires that States must consider the following factors in making BART determinati ons: (1) The costs of compliance, (2) The energy and nonair quality environmental impacts of comp liance, (3) Any existing pollution control technology in use at the source, (4) The remain ing useful life of the source, and (5) The degree of improvement in visibility which ma y reasonably be anticipated to result from the use of such technology. Th ese factors are incorporated in the BART regulation and 40 CFR Part 51 Appendix Y. Although these factors are to be considered, according to the BART guidelines states have flexibility in how the factors are wei ghted in making their determinations regarding what constitutes BART. (See 70 FR 39170, 1 st 

### col., July 6, 2005.)

8.3.1 Control Scenarios Considered

Each facility reviewed severa l potential control alternatives . These control alternatives considered and the associated visibility impr ovement that would result are summarized inTables 8.3.1.1 through 8.3.1.6 below taken from the Alcoa, Eastman Chemical, TVACumberland, and DuPont-Old Hickory BART determination submittals respectively.

Table 8.3.1.1 Alcoa - SO 2 

### Post-Control Emission Rates a

Control Scenario SO2 Control Technology SO2 NOX PM2.5 PM10

Emissions (tons/year) % Reduction (Increase)b Emissions (tons/year) % Reduction (Increase)b Emissions (tons/year) % Reduction (Increase)b Emissions (tons/year) % Reduction (Increase)b 1 3.5% Sulfur Coke with Potlines Wet Scrubber 1,202 81 101 0 815 (116) 924 (87)

2 3.0% Sulfur Coke with Anode Bake Furnace Wet Scrubber 4,830 12c 101 0 413 (10)c 529 (7)c

3 3.0% Sulfur Coke Potlines 5,517 14 101 0 377 0 494 0

and Anode

Bake Furnace Current 3.5% Sulfur 6,436 101 377 494

Potential Coke Potlines

### BART Related Documentation Appendix L - 

### 40 Regional Haze SIP for TN Class I Areas April 4, 2008 Emissions and Anode

Bake Furnace

a Emission rates include the potline primary control system, the potline roof emissions, and the anode bake furnace.

b Compared with current poten tial emissions unless noted.

c Compared with 3.0% sulfur coke since this scenario would only occur with Control Scenario 3.



### Table 8.3.1.2 Alcoa BART Evaluation Visibility Impacts Summary

Modeling Scenario Modeled Visibility Impacts

(dv) Visibility Improvement (delta -dv) Great Smokey Joyce Kilmer Great Smokey Joyce Kilmer

Baseline (Current 3% Sulfur Coal w/ PTE 3.5% Sulfur Coal) 1.310 0.686 -- --

Scenario #1 (95% SO2 Control on Potlines w/ Wet Scrubbers) 0.598 0.419 0.712 0.267



### Table 8.3.1.3 Eastman BART Evaluation Visibility Impacts Summary

Modeling Scenario Modeled Visibility Impacts

(dv) Visibility Improvement (delta -dv)

LIGO GRSM SHRO JOKI COHU JARI LIGO GRSM SHRO JOKI COHU JARI

### BART Related Documentation Appendix L - 

### 41 Regional Haze SIP for TN Class I Areas April 4, 2008 Baseline (Boilers 24- 29) 2.06 2.55 1.44 1.67 1.01 0.79 - - - - - -

Scenario #1 (SDA/ESP at B-253) 1.10 1.42 0.65 0.79 0.41 0.38 0.96 1.13 0.79 0.88 0.60 0.41

Scenario #2(SDA/FF at B253) 0.87 0.99 0.54 0.47 0.29 0.29 1.19 1.56 0.90 1.20 0.72 0.50

Scenario #3 (Wet FGD at B-253) 0.85 0.97 0.53 0.45 0.28 0.25 1.21 1.58 0.91 1.22 0.73 0.54

Scenario #4 (Wet FGD at B-253 + Wet FGD at Boiler 24) 0.65 0.87 0.45 0.37 0.23 0.24 1.41 1.68 0.99 1.30 0.78 0.55

Scenario #5 (Scenario 3 +

LNB Yearround at B253) 0.67 0.79 0.38 0.36 0.23 0.23 1.39 1.76 1.06 1.31 0.78 0.56

Scenario #6 (Scenario 5 +SOFA at B253) 0.67 0.79 0.38 0.36 0.23 0.23 1.39 1.76 1.06 1.31 0.78 0.56

Scenario #7 (Scenario 6 +SNCR at B253) 0.49 0.59 0.28 0.35 0.18 0.17 1.57 1.96 1.16 1.32 0.83 0.62

Baseline (Boiler 24

Only) 0.21 0.24 0.15 0.18 0.13 0.07 - - - - - -

### BART Related Documentation Appendix L - 

### 42 Regional Haze SIP for TN Class I Areas April 4, 2008 Baseline

(B-6C Furnaces and

OC-Batch) 0.00 0.01 0.00 0.00 0.00 0.00 - - - - - -



### Table 8.3.1.4 TVA-Cumberland BART Evalua tion Visibility Impacts Summary

Modeling Scenario Modeled Visibility Impacts

(dv) Visibility Improvement (delta -dv) Mammoth Cave Sipsey Mammoth Cave Sipsey

Baseline (Two Coal-fired Boilers with

Hydrated Lime Injection) (Per Unit CUF) 0.712 0.287 -- --

Scenario #1 (PM10 Control on Boilers w. Wet ESP) (Per Unit CUF) 0.240 0.095 0.472 0.192



### Table 8.3.1.5 DuPont-Old Hickory BART Eval uation Visibility Impacts Summary @ Daily Maxi,um Rates (Old Improve Equation)

Modeling Scenario Modeled Visibility Impacts

(dv) Visibility Improvement

(delta -dv)

Mammoth Cave Mammoth Cave 

### SO2 Cases (9 scenarios)

A. Baseline Case Using Current Coal 0.929 (*)

- F. 1.5% Sulfur Coal with No Scrubbing 0.792 0.137 K. 1.0% Coal with No Scrubbing 0.599 0.330 E. Current Coal with Sodium Wet Scrubber on Boiler 20 Only 0.439 0.490

### BART Related Documentation Appendix L - 

### 43 Regional Haze SIP for TN Class I Areas April 4, 2008 J. 1.5% Sulfur Coal with Sodium Wet Scrubber on Boiler 20 Only 0.398 0.531

O. 1.0% Sulfur Coal with Sodium Wet Scrubber on Boiler 20 Only 0.332 0.597

C. Current Coal with Sodium Wet Scrubber on both Boilers 20 & 24 0.305 0.624

H. 1.5% Sulfur Coal with Sodium Wet Scrubber on Both Boilers 20 & 24 0.291 0.638

M. 1.0% Sulfur Coal with Sodium Wet Scrubber on Both Boilers 20 & 24 0.272 0.657

P. Current Coal with 50% Natural Gas Cofiring on Both Boilers 20 & 24 0.605 0.324



### NOx Cases (7 Scenarios)

A. Baseline Case Using Current Coal 0.929 (*)

- D1. LNB on Boiler 20 only 0.917 0.012 D2. SNCR on Boiler 20 only 0.917 0.012 B1. LNB on Both Boilers 20 & 24 0.917 0.012 B2. SNCR on Both Boilers 20 & 24 0.917 0.012 E. LNB Plus SCR on Boiler 20 Only 0.902 0.027 C. LNB Plus SCR on Both Boilers 20 & 24 0.890 0.039B3. Current Coal with 50% Natural Gas Cofiring on Both Boilers 20 & 24 0.605 0.324

(*) Eighth-highest impact was later reduced to 0.507 dv based on New Improve Equation

### BART Related Documentation Appendix L - 

### 44 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Table 8.3.1.6 – DuPont-Old Hickor y – MACA Visibility Assessment Summary of the Control Scenario Visibi lity & Cost Impacts @ Daily Maximum Emission Rate and Highest Day Coal Quality (Old Improve Equation) Case Description Expected Emission rate Expected Emission

Rate Total Annualized cost of control Tons Removed Av erage cost Effectiveness Greatest Change in Modelled 98 % day

from baseline % Change in

Light extinction % of 31.37 dV (the starting point for the Mammoth Cave Glide

Path) Incremental % Improvement of % visibility Impact as a % of 31.17 dV

SO 2 Cases T/yr lb/hr $ t/yr $/ton removed dV % % % A. Baseline Case Using Current Coal 7,040 1,607 0.929 9.29 2.96 F. 1.5% Sulfur Coal with No Scrubbing 5,617 1,282 $1,970,962 1,423 $1,385 -0.15 1.5 2.50 0.46 K. 1.0% Sulfur Coal with No Scrubbing 3,745 855 $2,956,443 3,295 $897 -0.349 3.49 1.86 1.10 E. Current Coal with Sodium Wet Scrubber on Boiler 20 Only 1,690 386 $14,222,449 5,351 $2,658 -0.508 5.08 1.35 1.61 J. 1.5% Sulfur Coal with Sodium Wet Scrubber on Boiler 20 Only 1,348 308 $11,196,391 5,692 $1,967 -0.532 5.32 1.27 1.69 O. 1.0% Sulfur Coal with Sodium Wet Scrubber on Boiler 20 Only 899 205 $12,211,479 6,142 $1,988 -0.597 5.97 1.07 1.90 C. Current Coal with Sodium Wet Scrubber on Both Boilers 20 & 24 352 80 $23,566,812 6,688 $3,524 -0.624 6.24 0.98 1.98 H. 1.5% Sulfur Coal with Sodium Wet Scrubber on Both Boilers 20 & 24 281 64 $17,033,708 6,759 $2,520 -0.638 6.38 0.93 2.03 M. 1.0% Sulfur Coal with Sodium Wet Scrubber on Both Boilers 20 & 24 187 43 $18,056,198 6,853 $2,635 -0.657 6.57 0.87 2.09 P. Current Coal with 50% Natural Gas Cofiring on Both Boilers 3,520 804 $14,190,215 3,520 $4,031 -0.369 3.69 1.80 1.16
NOx Cases A. Baseline Case Using Current Coal 1,233 282 0.929 9.29 2.96 D1. LNB on Boiler 20 Only 843 192 $572,769 391 $1,466 -0.033 0.33 2.87 0.09 D2. SNCR on Boiler 20 Only 843 192 $821,184 391 $2,102 -0.033 0.33 2.87 0.09 B1. LNB on Both Boilers 20 & 24 740 169 $963,413 493 $1,953 -0.055 0.55 2.80 0.16 B2. SNCR on Both Boilers 20 & 24 740 169 $1,105,732 493 $2,241 -0.055 0.55 2.80 0.16 E. LNB Plus SCR on Boiler 20 Only 374 85 $2,904,607 859 $3,380 -0.13 1.3 2.56 0.40 C. LNB Plus SCR on Both Boilers 20 & 24 148 34 $5,081,539 1,085 $4,682 -0.178 1.78 2.41 0.55 B3 Current Coal with 50% Natural Gas Co firin g o n B ot h B o il e r s 740 169 $14

, 190

, 215 493 $28

, 759 -0.369 3.69 1.80 1.16

### BART Related Documentation Appendix L - 

### 45 Regional Haze SIP for TN Class I Areas April 4, 2008 

### 8.3.2 Costs of Compliance

For Alcoa visibility improvement ranged from 0.267 dv at JOKI to 0.712 dv at GRSM at costs ranging from $6,697/ton to $8,274/ton (vendor estimat e range). The costs for the (Wet Scrubber scenario 1)are summarized in Table 8-3.2.1 be low taken from the Alcoa BART determination permit application submittal (Appendix L-8). Th e facility proposed that BART is taking a pollution prevention limit of 3% sulfur in the calcined petrol eum coke used to manufacture anodes.

Table 8.3.2.1 Alcoa - Summary of the Impacts Analysis for SO 2 

### Control Scenarios

Control Scenari

o Control Technology Evaluated Emission Rate (tons/year) Emissions Reductions (tons/year) Installed Capital Cost ($000) Total Annualize d Control

Costs ($000) Incremental Cost Effectiveness ($ per

ton of pollutant removed) Energy Impact (000 kWhour/year) C I

o P 1 3.5% Sulfur Coke with Potlines Wet Scrubber 1,202 5,234 a $217,000 $39,000 $7,500 33,200 4 P

2 3.0% Sulfur Coke with Anode Bake Furnace Wet Scrubber 4,830 687 b 30,400 5,600 8,200 2,800 3 P

3 3.0 % Sulfur Coke Potlines 5,517 919

and Anode Bake

Furnace Current None 6,436

Potentia l Emissio

ns

a Compared with potential emissions since 3.5% sulfur coke could be used.

b Compared with 3.0% sulfur coke emissions since this scenario would only occur with Control Scenario 3.

### BART Related Documentation Appendix L - 

### 46 Regional Haze SIP for TN Class I Areas April 4, 2008 

### For Eastman Chemical visibility improvement resulting fr om control scenarios considered ranged from 0.41 dv to 1.96 dv with costs ranging from $1,649/ton of SO2 removed or $89,000/ton/dv to $2,085/ton of pollutant remove d or $110,294/ton/dv, respectively. The costs for each of the scenarios considered are summarized in Tables 8.3.2.2 and 8.3.2.3 below taken from the Eastman BART determination permit application submittal (Appendix L-8). The facility proposed that BART is the application of Spray Dryer Absorber with Fabric Filtration (SDA/FF) which is a dry flue-gas desulfuriz ation using a SDA followed by a fabric filter (scenario 2 in the demonstration) for the fi ve Coal-fired Boilers #25-#29 (powerhouse B-253).

Table 8.3.2.2 – SO2 Costs Effe ctiveness Summary (5 Boilers) Technology Capital Cost $M Annual O/M Cost $M Assumed Percent Control Efficiency Annual SO2 Reduced

(tons) CostEffectiveness ($/ton) IncrementalCostEffectiveness ($/ton) SDA/ESP $97.8 M $6.1 M 71% 10,815 $1,649 -- SDA/ESP-FF Conversion $139.1 M $7.9 M 92% 13,930 $1765 $2,185 (vs. SDA/ESP) Caustic scrubbers $87.8 $8.1 M 95% 14,385 $1,295 $410 vs. SDA/ESP Dual alkali* $106.8 M $7.1 95% 14,385 $1,009 $857 (vs. SDA/ESP) LSFO $185.8 M $7.7 M 95% 14,385 $2,085 $3,533 vs SDA/ESP or $12,775 (vs. SDA/ESP-FF Conversion) *Dual alkali provided for information. Its large footprint either eliminates it as an option or drives up cost considerably to relocate buildings, railroad tracks, ash pon ds, etc. Also, its use has been extremely limited and Eastman's confidence that it can be successfully operated is low.

Table 8.3.2.3 Cost-effectiveness Comparison, B-253 SO2 Options Scenario Annualized Cost Average Dv-yr Change in Average

Dv-yr Average CostEffectiveness $/dv-yr IncrementalCostEffectiveness $/dv-yr Baseline N/A 401 -- -- Scenario 1 (SDA/ESP) $17.8 M 201 200 $89,000 --

Scenario 2 (SDA/FF) $24.6 M 138 263 $93,536 $107,936 (vs. Scenario 1) Scenario 3a (Caustic Scrubbing) $18.6 M 129 272 $68,382 $11,111 (vs. Scenario 1)

Scenario 3b (LSFO) $30.0 M 129 272 $110,294 $169,444 (vs. Scenario 1)

### BART Related Documentation Appendix L - 

### 47 Regional Haze SIP for TN Class I Areas April 4, 2008 

### For TVA-Cumberland visibility improvement resulting from the control scenario considered of Wet ESP for both boilers ranged from 0.192 dv at SI PS to 0.472 dv at MACA with costs at over $85,000/ton of SO2 removed for each boiler The co sts for the Wet ESP are summarized in Tables 8.3.2.4 and 8.3.2.5 below taken from the TVA-Cumberland BART determination permit application submittal (Appendix L-8). The facility pr oposed that BART is no additional controls.

Table 8.3.2.4 Capital Costs for Wet ESP: CUF Unit 1 or 2

Direct Costs Basis Cost Purchased Equipment Costs (PEC) ESP+auxiliary equipment (ESP) $69,700,000 Instrumentation 0.10 ESP $6,970,000 Sales taxes 0.03 ESP $2,091,000 Freight Included -- PEC $78,761,000

Direct Installation Costs (DIC) Foundations & supports 0.04 PEC $3,150,440 Handling & erection 0.50 PEC $39,380,500 Electrical 0.08 PEC $6,300,880 Piping 0.01 PEC $787,610 Insulation for ductwork 0.02 PEC $1,575,220 Painting 0.02 PEC $1,575,220 DIC $52,769,870

Total Direct Costs (DC) $131,530,870

Indirect Costs Engineering 0.20 PEC $15,752,200 Construction and field expenses 0.20 PEC $15,752,200 Contractor fees 0.10 PEC $7,876,100 Start-up 0.01 PEC $787,610 Performance test 0.01 PEC $787,610 Model study 0.02 PEC $1,575,220 Contingencies 0.03 PEC $2,362,830 Total Indirect Costs (IC) $44,893,770

Total Capital Investment (TCI)=DC+IC $176,424,640

*Wet ESP equipment costs based on vendor estimate. Other costs are based on information from the EPA Air Pollution Control Cost Manual, Sixth Ed

.



### Table 8.3.2.5 Annual Costs for Wet ESP: CUF Unit 1 or 2

### BART Related Documentation Appendix L - 

### 48 Regional Haze SIP for TN Class I Areas April 4, 2008

Direct Annual Costs (DC) Bases & Assumptions

Operating Labor Operator $ 32,850 2 hrs/shift, 365 days/yr, $15/hr Supervisor $ 4,928 15% of operator labor Coordinator $ 10,950 1/3 of operator labor Maintenance Labor $ 69,063 SCA=103 ft 2 /1000 cfm, 4.5 million cfm Material $ 787,610 1% of PEC
Utilities Electricity-fan $ 599,342 2" H 2 O ∆ p, $0.06/kWhElectricityoperating $ 330,830 capacity factor (CF)=0.7 Water $ 1,655,640 5 gal/min per 1000 cfm, $0.2/1000 gal, CF=0.7 Waste Disposal $ 16,556,400 $2/1000 gal Total DC $ 20,047,613

Indirect Annual Costs (IC) Overhead $ 543,241 60% of operating labor and materials Administrative charge $ 3,528,493 2% of TCI Payment in lieu of taxes $ 1,764,246 1% of TCI Insurance $ 1,002,169 1% of TCI Capital recovery $ 23,619,516 CRF = 0.1339 Total IC $ 30,457,664

Total Annual Cost $ 50,505,277

*Based on information from the EPA Air Pollution Control Cost Manual, Sixth Ed . Capital recovery factor (CRF) based on 12% interest rate and 20-yr equipment life.



### ForDuPont-Old Hickor y visibility improvement resulting fr om the nine (9) control scenarios considered of SO2 reductions ranged fr om 0.137 dv to 0.657 dv at MACA and for NOx reductions (7 scenarios) ranged from 0.012 dv to 0.324 dv at MACA too. Table 8.3.1.6 (above) outlined the control scenarios for reducing SO2 and NOx emissions. The economic analyses for Boilers 20 and 24 are addressed in Tables 8.3.2.6, 8.3.2.7, and 8.3.2.8. The costs for the most practical controls are summari zed in Table 8.3.2.9 below taken from the DuPont-Old Hickory additional submittal letter dated January, 24, 2008. This letter addresses revised cost effectiveness/visibility improvement on feasib le controls and a proposed BART control determination for the two boilers. This additional information is a compliment to their BART determination permit application submittal (Appendi x L-8). The facility proposed that BART is taking emission limitations as total combined daily emissions for Boilers 20 and 24 based upon the following operating limits st ated in Table 8.3.2.10 below.

### BART Related Documentation Appendix L - 

### 49 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Table 8.3.2.6 BART Economic Analysis for DuPont Old Hickory Boilers 20 & 24 at Maximum Combined Daily Emissions

BART For SO2 and NOx for Both Boilers 20 & 24 Based on Maximum Emissions Day for 2005-06

SO2 Model Case Identifier--> A FKM H C P O
Boilers 20 & 24 Boilers 20
SO2 ECONOMIC PARAMETERS BASELINE+ Boilers 20 & 24 Boilers 20 & 24 Boilers 20 & 24 Boilers 20 & 24 Boilers 20 & 24 Boilers 20 & 24 using Co
FACTORED ESTIMATE FROM RTP DATABASE Current Coal 1 Coal 2 Coal 3 using Coal 3 using Coal 2 using current Coal using current Coal Boiler 20 O n Control Option --> No FGD No FGD No FGD 95% WSS 95% WSS 95% WSS 50% Gas Cofiring 95% W S Coal Percent Sulfur--> 1.88 1.50 1.00 1.00 1.50 1.88 1.88 1.00 A&E Emission Rate, lb/MMBtu --> 3.13 2.49 1.66 0.08 0.12 0.16 3.13 0.08 SO2 Emission Rate at DHI, lb/hr--> 2,375 1,895 1,264 63 95 119 1188 561

Annual SO2 Emissions, TPY--> 7,040 5,617 3,745 187 281 352 3520 899 Equivalent Annual Average Hourly SO2 Emissions, lb/hr--> 1,607 1,282 855 43 64 80 804 205 A&E Total Capital Requirement: $63,365,423 $63,365,423 $63,365,423 $35,425, 1 O&M Costs @ 8% + reagent + waste disposal: $7,778,324 $7,741,314 $16,245,380 $5,001,2 Range: +50/-30 +50/-30 +50/-30 +50/-3 0 Coal Change Incremental Cost Per Ton vs Baseline: $0 $10 $15 $15 $10 $0 $0 $15 Coal Change Annual Additional Cost : $1,970,962 $2,956,443 $2,956,443 $1,970,962 $0 $2,956, 4 Natural Gas Cofiring Incremental Cost Increase: $14,190,215 Capital Recovery Costs: $6,957,183 $6,957,183 $6,957,183 $3,889, 4 Total Annual Costs Excluding Coal Change: $14,735,506 $14,698,497 $23,202,562 $8,890,7 Annual Emissions Reduction vs Baseline Current Coal: 1,423 3,295 6,853 6,759 6,688 3,520 6,142 Annual Emissions Reduction vs Coal 2: 1,872 5,430 5,336 5,265 2,097 4,718 Annual Emissions Reduction vs Coal 3: 3,558 3,464 3,393 225 2,846 Downtime at Gas Fuel Price Difference: $3,317,550 $3,317,550 $3,317,550 $3,317, 5 Amotized Downtime at Gas Fuel Price Difference: $364,249 $364,249 $364,249 $364,2 4 Total Annualized Cost: $1,970,962 $2,956,443 $18,056,198 $17,033,708 $23,566,812 $14,190,215 $12,211, 4 Cost Effectiveness Relative to Baseline Current Coal, $/Ton Removed: $1,385 $897 $2,635 $2,520 $3,524 $4,031 $1,98 8 Cost Effectiveness Relative to Coal 2, $/Ton Removed: $526 $2,962 $2,823 $4,102 $5,827 $2,17 0 Cost Effectiveness Relative to Coal 3, $/Ton Removed: $4,244 $4,064 $6,075 $49,997 $3,25 2

NOx Model Case Identifier--> A B1 B2 C B D1 D2 E
NOx ECONOMIC PARAMETERS BASELINE+ Boilers 20 & 24 Boilers 20 & 24 Boilers 20 & 24 Boilers 20 & 24 Boiler 24 As-Is & Boiler 24 As-Is & Boiler 24 A s FACTORED ESTIMATE FROM RTP DATABASE using current Coal Boiler 20 Only w/ Boiler 20 Only w/ Boiler 20 O n Control Option --> CC LNB SNCR LNB+SCR 50% Gas Cofiring LNB SNCR LNB+S C NOx Emission Rate at DHI, lb/hr--> 421 252 252 50 252 324 324 208

Annual NOx Emissions, TPY--> 1233 740 740 148 740 843 843 374 Equivalent Annual Average Hourly NOx Emissions, lb/hr--> 282 169 169 34 169 192 192 85 A&E Total Capital Requirement: $5,215,728 $3,122,793 $31,225,760 $2,607,864 $1,856,689 $17,355, 3 O&M Costs: $208,629 $580,742 $1,470,994 $104,315 $435,205 $816,9 6 Range: +50/-30 +50/-30 +50/-30 +50/-30 +50/-30 +50/-3 0 Natural Gas Cofiring Incremental Cost Increase: $14,190,215 Capital Recovery Costs: $572,659 $342,866 $3,428,421 $286,329 $203,854 $1,905, 5 Total Annual Costs Excluding Downtime Gas Cost: $781,288 $923,608 $4,899,414 $390,644 $639,059 $2,722, 4 Annual Emissions Reduction: 493 493 1,085 493 391 391 859 Downtime at Gas Fuel Price Difference: $1,658,775 $1,658,775 $1,658,775 $1,658,775 $1,658,775 $1,658,7 Amotized Downtime at Gas Fuel Price Difference: $182,125 $182,125 $182,125 $182,125 $182,125 $182,1 2 Total Annualized Cost: $963,413 $1,105,732 $5,081,539 $14,190,215 $572,769 $821,184 $2,904, 6 Cost Effectiveness Relative to Baseline Current Equipment, $/Ton Removed: $1,953 $2,241 $4,682 $28,762 $1,466 $2,102 $3,38 0 Incremental Cost Effectiveness Relative to LNB on Boiler 20 Only, $/Ton Removed: $3,803 $5,189 $6,490 $132,585 $4,97 4

A

C

### BART Related Documentation Appendix L - 

### 50 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Table 8.3.2.7 BART Economic Analysis for Du Pont Old Hickory Boiler 20 at Combined Maximum Daily Emissions

SO2 Model Case Identifier--> A FKM H CP O J CF as annual

o p eratin g rate= 80%

BASES ---> CF as annua l average % of

max daily emissions= 92% Coal HHV, Btu/lb As-Received= 11,428 Per Boiler MMBtu/hr = 445 Per Boiler SCFM

= 107,453 Natural Gas Price Differential Over Coal, $/MMBtu= $6.00

SO2 ECONOMIC PARAMETERS BASELINE+ Coal 2 Coal 3 Boiler 20 Boiler 20 Boiler 20 Boiler 20 Boiler 20 Boiler 20 B o FACTORED ESTIMATE FROM RTP DATABASE Current Coal 1 using Coal 3 using Coal 3 using Coal 2 using Coal 2 using current Coal using current Coal using c u Control Option --> No FGD No FGD No FGD 85% SDA+FF 95% WSS 85% SDA+FF 95% WSS 85% SDA+FF 95% WSS 50% G a Coal Percent Sulfur--> 1.88 1.50 1.00 1.00 1.00 1.50 1.50 1.88 1.88 1 A&E Emission Rate, lb/MMBtu --> 3.13 2.49 1.66 0.25 0.08 0.37 0.12 0.47 0.16 3 SO2 Emission Rate at DHI, lb/hr--> 1391 1110 740 111 37 166 55 209 70

Annual SO2 Emissions, TPY--> 5632 4494 2996 449 150 674 225 845 282 2 Equivalent Annual Average Hourly SO2 Emissions, lb/hr--> 1286 1026 684 103 34 154 51 193 64 A&E Total Capital Requirement: $52,388,658 $35,425,148 $52,388,658 $35,425,148 $52,388,658 $35,425,148 O&M Costs @ 8% + reagent + waste disposal: $5,057,064 $5,001,297 $5,019,522 $4,971,689 $10,010,512 $9,968,709 Range: +50/-30 +50/-30 +50/-30 +50/-30 +50/-30 +50/-30 Coal Change Incremental Cost Per Ton vs Baseline: $0 $10 $15 $15 $15 $10 $10 $0 $0 Coal Change Annual Additional Cost : $0 $1,576,779 $2,365,168 $2,365,168 $2,365,168 $1,576,779 $1,576,779 $0 $0 Natural Gas Cofiring Incr emental Cost Increase: $11, Capital Recovery Costs: $5,751,993 $3,889,491 $5,751,993 $3,889,491 $5,751,993 $3,889,491 Total Annual Costs Excluding Coal Change: $10,809,057 $8,890,788 $10,771,515 $8,861,180 $15,762,505 $13,858,200 Cost Effectiveness for Scrubbing w/o Gas Cost vs Coal 3: $4,245 $3,124 $4,639 $3,198 $7,328 $5,106 Annual Emissions Reduction vs Baseline Current Coal: 1,138 2,636 5,183 5,482 4,958 5,408 4,787 5,351 2 Annual Emissions Reduction vs Coal 2: 1,498 4,044 4,344 3,820 4,269 3,649 4,212 1 Annual Emissions Reduction vs Coal 3: 2,546 2,846 2,322 2,771 2,151 2,714 8 Weeks Downtime at Gas Fuel Price Difference: $3,317,550 $3,317,550 $3,317,550 $3,317,550 $3,317,550 $3,317,550 Amotized Downtime at Gas Fuel Price Difference: $364,249 $364,249 $364,249 $364,249 $364,249 $364,249 Cost Effectiveness Relative to Baseline Current Coal: $1,385 $897 $2,612 $2,120 $2,564 $1,998 $3,369 $2,658 $ 4 Cost Effectiveness Relative to Coal 2: $526 $2,958 $2,312 $2,915 $2,161 $3,987 $3,002 $ 5 Cost Effectiveness Relative to Coal 3: $4,388 $3,252 $4,457 $3,045 $6,398 $4,369 $ 4

NOx Model Case Identifier--> A BBC B DD E NOx ECONOMIC PARAMETERS BASELINE+ Boiler 20 Boiler 20 Boiler 20 Boiler 20 FACTORED ESTIMATE FROM RTP DATABASE using current Coal Control Option --> CC LNB SNCR LNB+SCR 50% Gas Cofiring A&E Emission Rate, lb/MMBtu --> 0.542 0.325 0.325 0.065 0.325 NOx Emission Rate at DHI, lb/hr--> 241 145 145 29 145

Annual NOx Emissions, TPY--> 977 586 586 117 586 Equivalent Annual Average Hourly NOx Emissions, lb/hr--> 223 134 134 27 134 A&E Total Capital Requirement: $2,607,864 $1,856,689 $17,355,321 O&M Costs: $104,315 $435,205 $816,962 Range: +50/-30 +50/-30 +50/-30 Natural Gas Cofiring Incr emental Cost Increase: $11,352,241 Capital Recovery Costs: $286,329 $203,854 $1,905,521

Total Annual Costs: $390,644 $639,059 $2,722,483 Cost Effectiveness w/o Gas Cost: $1,000 $1,636 $3,168

Annual Emissions Reduction: 391 391 859 391 4 Weeks Downtime at Gas Fuel Price Difference: $1,658,775 $1,658,775 $1,658,775 Amotized Downtime at Gas Fuel Price Difference: $182,125 $182,125 $182,125 Overall Cost Effectiveness: $1,466 $2,102 $3,380 $29,059

ESTIMATE USING USEPA REFERENCES LOW LNB SNCR LNB+SCR Emission Rate, lb/MMBtu --> 0.54 0.325 0.325 0.065

Total Capital Requirement: $400,500 $1,112,500 $2,562,142 O&M Costs: $44,500 $222,500 $199,674 Range: LOW HIGH NA Capital Recovery Costs: $43,973 $122,147 $281,309

Total Annual Costs: $88,473 $344,647 $480,983 Annual i nt er est r

at e (

f r act

i onal

) : 0. 07 Cost Effectiveness: $226 $882 $560 C ont r ol syst em l

i f e (

year

s) : 15 Annual Emissions Reduction: 391 391 859 Capi t al r

ecover y f

act

or (

syst

em ) : 0.110 BART FOR SO2 & NOX BOILER # 20 BASED ON MAXIMUM EMISSIONS DAY FOR 2005-06



### Table 8.3.2.8 BART Economic Analysis for DuPont Old Hickory Boiler 24 at Maximum Combined Daily Emissions

### BART Related Documentation Appendix L - 

### 51 Regional Haze SIP for TN Class I Areas April 4, 2008 SO2 Model Case Identifier--> A FKM H CP O J E CF as annual

o p eratin g rate= 20%

BASES ---> CF as annua l average % of

max daily emissions= 33% Coal HHV, Btu/lb As-Received= 11,428 Per Boiler MMBtu/hr = 315 Per Boiler SCFM

= 81,478 Natural Gas Price Differential Over Coal, $/MMBtu= $6.00

SO2 ECONOMIC PARAMETERS BASELINE+ Coal 2 Coal 3 Boiler 24 Boiler 24 Boiler 24 Boiler 24 Boiler 24 Boiler 24 Boiler 2 FACTORED ESTIMATE FROM RTP DATABASE Current Coal 1 using Coal 3 using Coal 3 using Coal 2 using Coal 2 using current Coal using current Coal using curre n Control Option --> No FGD No FGD No FGD 85% SDA+FF 95% WSS 85% SDA+FF 95% WSS 85% SDA+FF 95% WSS 50% Gas C o Coal Percent Sulfur--> 1.88 1.50 1.00 1.00 1.00 1.50 1.50 1.88 1.88 1.88 A&E Emission Rate, lb/MMBtu --> 3.13 2.49 1.66 0.25 0.08 0.37 0.12 0.469 0.156 3.13 SO2 Emission Rate at DHI, lb/hr--> 985 786 524 79 26 118 39 148 49 492

Annual SO2 Emissions, TPY--> 1408 1123 749 112 37 169 56 211 70 704 Equivalent Annual Average Hourly SO2 Emissions, lb/hr--> 321 256 171 26 9 38 13 48 16 161 A&E Total Capital Requirement: $41,319,616 $27,940,275 $41,319,616 $27,940,275 $41,319,616 $27,940,275 O&M Costs @ 8% + reagent + waste disposal: $3,522,056 $2,777,027 $3,512,670 $2,769,625 $7,018,208 $6,276,670 Range: +50/-30 +50/-30 +50/-30 +50/-30 +50/-30 +50/-30 Coal Change Incremental Cost Per Ton vs Baseline: $0 $10 $15 $15 $15 $10 $10 $0 $0 $0 Coal Change Annual Additional Cost : $0 $394,183 $591,274 $591,274 $591,274 $394,183 $394,183 $0 $0 Natural Gas Cofiring Incremental Cost Increase: $2,837, 9 Capital Recovery Costs: $4,536,672 $3,067,692 $4,536,672 $3,067,692 $4,536,672 $3,067,692 Total Annual Costs Excluding Coal Change: $8,058,727 $5,844,719 $8,049,342 $5,837,317 $11,554,880 $9,344,362 Cost Effectiveness for Scrubbing w/o Gas Cost vs Coal 3: $12,659 $8,215 $13,868 $8,426 $21,488 $13,771 Annual Emissions Reduction vs Baseline Current Coal: 285 659 1,296 1,371 1,240 1,352 1,197 1,338 704 Annual Emissions Reduction vs Coal 2: 374 1,011 1,086 955 1,067 912 1,053 419 Annual Emissions Reduction vs Coal 3: 637 711 580 693 538 679 45 Downtime at Gas Fuel Price Difference: $0 $0 $0 $0 $0 $0 Amotized Downtime at Gas Fuel Price Difference: $0 $0 $0 $0 $0 $0 Cost Effectiveness Relative to Baseline Current Coal: $1,385 $897 $6,676 $4,696 $6,812 $4,610 $9,655 $6,986 $4,03 1 Cost Effectiveness Relative to Coal 2: $526 $8,165 $5,563 $8,429 $5,469 $12,235 $8,500 $5,82 7 Cost Effectiveness Relative to Coal 3: $12,659 $8,215 $13,528 $8,141 $20,388 $12,900 $49,9 9

NOx Model Case Identifier--> A B B C B NOx ECONOMIC PARAMETERS BASELINE+ Boiler 24 Boiler 24 Boiler 24 Boiler 24 FACTORED ESTIMATE FROM RTP DATABASE using current Coal Control Option --> CC LNB SNCR LNB+SCR 50% Gas Cofiring A&E Emission Rate, lb/MMBtu --> 0.57 0.342 0.342 0.068 0.342 NOx Emission Rate at DHI, lb/hr--> 180 108 108 22 108

Annual NOx Emissions, TPY--> 257 154 154 31 154 Equivalent Annual Average Hourly NOx Emissions, lb/hr--> 59 35 35 7 35 A&E Total Capital Requirement: $2,607,864 $1,266,104 $13,870,439 O&M Costs: $104,315 $145,537 $654,032 Range: +50/-30 +50/-30 +50/-30 Natural Gas Cofiring Incremental Cost Increase: $2,837,974 Capital Recovery Costs: $286,329 $139,011 $1,522,900

Total Annual Costs: $390,644 $284,548 $2,176,931 Cost Effectiveness w/o Gas Cost: $3,803 $2,770 $9,634

Annual Emissions Reduction: 103 103 226 103 Downtime at Gas Fuel Price Difference: $0 $0 $0 Amotized Downtime at Gas Fuel Price Difference: $0 $0 $0 Overall Cost Effectiveness: $3,803 $2,770 $9,634 $27,632

ESTIMATE USING USEPA REFERENCES LOW LNB SNCR LNB+SCR Emission Rate, lb/MMBtu --> 0.57 0.342 0.342 0.068

Total Capital Requirement: $283,500 $787,500 $2,063,784 O&M Costs: $31,500 $157,500 $157,419 Range: LOW HIGH NA Capital Recovery Costs: $31,127 $86,463 $226,592

Total Annual Costs: $62,627 $243,963 $384,011 Annual i nt er est r

at e (

f r act

i onal

) : 0. 07 Cost Effectiveness: $610 $2,375 $1,699 C ont r ol syst em l

i f e (

year

s) : 15 Annual Emissions Reduction: 103 103 226 C api t al r

ecover y f

act

or (

syst

em ) : 0.110 BART FOR SO2 & NOX BOILER # 24 BASED ON MAXIMUM EMISSIONS DAY FOR 2005-06

### BART Related Documentation Appendix L - 

### 52 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Table 8.3.2.9 DuPont-Old Hickory BART Control Cost Effectiveness Evaluation Summary @ Daily Maxi,um Rates (Old Improve Equation)

Modeling Scenario Total Annualized Cost of Control Greatest Change in dv from baseline Cost per dv improvement



### SO2 Cases (Most Practical Control Scenarios)

A. Baseline Case Using Current Coal (0.929 dv at MACA) (*) F. 1.5% Sulfur Coal with No Scrubbing $1,970,962 -0.15 dv $13,139,746/dv

K. 1.0% Coal with No Scrubbing E. Current Coal with Sodium Wet Scrubber on Boiler 20 Only $14,222,449 -0.508 dv $27,996,946/dv

J. 1.5% Sulfur Coal with Sodium Wet Scrubber on Boiler 20 Only O. 1.0% Sulfur Coal with Sodium Wet Scrubber on Boiler 20 Only C. Current Coal with Sodium Wet Scrubber on both Boilers 20 & 24 H. 1.5% Sulfur Coal with Sodium Wet Scrubber on Both Boilers 20 & 24 M. 1.0% Sulfur Coal with Sodium Wet Scrubber on Both Boilers 20 & 24P. Current Coal with 50% Natural Gas Cofiring on Both Boilers 20 & 24 

### NOx Cases (Most Practical Control Scenarios)

A. Baseline Case Using Current Coal (0.929 dv at MACA) (*) D1. LNB on Boiler 20 only $572,769 -0.033 dv $17,356,636/dv

D2. SNCR on Boiler 20 only $821,184 -0.033 dv $24,884,363/dv

B1. LNB on Both Boilers 20 & 24 B2. SNCR on Both Boilers 20 & 24 E. LNB Plus SCR on Boiler 20 Only C. LNB Plus SCR on Both Boilers 20 & 24B3. Current Coal with 50% Natural Gas Cofiring on Both Boilers 20 & 24 (*) Eighth-highest impact was later reduced to 0.507 dv based on New Improve Equation



### Table 8.3.2.10 DuPont-Old Hickory BART Cont rol Determination–Proposed Emission Limitations Operating Limits SO2 (lb/day) NOx (lb/day) Summer Months (May-September) 32260 6120 NON-Summer Months (O ctober -April) 38570 6770

### BART Related Documentation Appendix L - 

### 53 Regional Haze SIP for TN Class I Areas April 4, 2008 

### 8.3.3 Energy and Non-air Quality Impacts

For Alcoa , a wet scrubber removes SO 2 

### by forcing the exhaust gas through a spray tower or absorber where it contacts water droplets that contain the unreacted lime or limestone. Energy is required to overcome the resistance of the scrubb er components as well as falling water droplets. A substantial amount of energy is associated with a fan to move approximately 2,000,000 acfm through the scrubber. The fan alone would require 1,730–1,960 kW. Other energy is required for the slurry pumps, instrument ation, and miscellaneous items (e.g., lighting). The total energy required, based on an average of the two proposal s, would be approximately 3,800 kW. As listed in Table 8.3.2.1, this is equivalent to 33,200,000 kW-hours of electricity per year. A wet scrubber on the anode bake furnace would add 2,800,000 kW-hours per year. For non-air quality impacts, both of the wet scrubber proposals were based on the Limestone Slurry Forces Oxidation (LSFO) process.

This process oxidizes the spent slurry to gypsum, which may be landfilled or commercially sold. There is no way to know at this time whethe r the gypsum would have commercial value or whether there would be any dema nd for it. Therefore, it must be assumed that 17,600 tons of waste from the potlines wet scrubber and 2,300 tons of waste from the anode bake furnace wet scrubber would be landfilled each year. It is es timated that 180 million gallons of water will be required annually to operate the potline we t scrubber at a cost of $270,000. This will significantly impact the community infrastructure in that this will increase daily water demand by approximately 4%. There will be relativel y no impact due to water discharge, at approximately 4 gallons/minute. It is also estim ated that 36 million kWh would be needed to operate the scrubbers annuall y. This would impact power demand in the community and therefore also have an environmental impact due to power production equivalent to adding over 3,000 new households in the community.

For Eastman Chemical , the cost estimates include any chan ges, positive or negative, on energy consumption. For non-air quality environmenta l impacts, the cost estimates include any changes, positive or negative, on solid waste disposal and wastewater treatment. The Spray Dryer Absorber (SDA) options, the dual alkali, and the LSFO options would all generate solid waste streams that would be disposed at Eastma n's on-site nonhazardous waste landfill. Eastman has estimated this additional waste would shorte n the landfill life by about 5 years (15 percent reduction in remaining life). Since the SDAs wo uld be placed before the particulate removal devices, the calcium sulfate byproduct would be mixed with the flyash and any sales of flyash to the concrete industry would be lo st. We have estimated this lo ss of flyash sales at 11,000 tons per year and that this volume would shorten the la ndfill life by an additional year or two. Loss of this volume of flyash to the concrete industr y would mean that much more cement would be required resulting in consumption of additional en ergy (natural gas) and raw materials to produce the cement along with the associated air emissions. It would also result in an incr eased price of concrete. The loss of landfill space due to either of these reasons (calcium sulfate sludge or loss of flyash sales) should not cause a direct envi ronmental impact as the landfill has liners and leachate collection systems and shou ld have no impact on groundwater.

Any leachate or stormwater runoff collected in the landfill's stormwater basins is permitted for

### BART Related Documentation Appendix L - 

### 54 Regional Haze SIP for TN Class I Areas April 4, 2008 

### discharge to the South Fork Holston River. Ho wever, once the landfill is full, a new one will have to be sited, likely further from Eastman's facility. Inevitably, a new landfill will result in loss of natural habitat and re sult in other community impacts such as noise and scenic concerns. 

### The caustic scrubber option would generate a sc rubber blowdown stream containing dissolved salts which would require discharge to the Sout h Fork Holston River (SFHR) through an NPDES permitted outfall. The salts in this blowdown stream would be comprised of sodium sulfate (99.5 %), sodium fluoride (0.4 %), and sodium chloride (0.06 %). The volume of the discharge is expected to be approximately 0.5 MGD. Under normal operating conditions the blowdown would increase Eastman's Total Dissolved Solid s (TDS) loading to the river by approximately 238,000 lb/day.

The worst-case maximum TDS loading could in crease by as much as 351,000 lb/day. The SFHR immediately downstream of Eastman and the city of Kingsport is classified for use as an industrial water supply by the Te nnessee Department of Environm ent and Conservation. Due to this classification, an ambient water quality criterion of 500 mg/L TDS applies in this reach of the river. Based on the three most recent years of quarterly data, the current average ambient TDS concentration downstream of Kingsport is 196 mg/L. Under normal scrubber blowdown discharge conditions and average river flow, th e discharge of the sc rubber blowdown would result in an increase in TDS of approximately 17 mg/L downstream of Kingsport. Therefore, due to the blowdown discharge, the average TDS concentration downstream of the discharge is projected to increase to 213 mg/L (196 + 17).

This projected value is below the 500 mg/L stan dard and within the range of values currently measured in the river. A worst-case evaluati on of the impact of the blowdown discharge was performed based on low flow in the river comb ined with the maximum upstream river TDS concentration, the maximum projected increase in loading (351,000 lb/day) discharged by the scrubber, and the maximum simultaneous discharge of TDS from all area point sources. This worst-case analysis resulted in a projected downstream concentration of 349 mg/L. The discharge of scrubber blowdown, while increasi ng the level of TDS in the SFHR, would not result in an exceedence of the 500 mg/L wa ter quality criterion even under worst-case conditions.

For TVA-Cumberland , the energy costs associated with a Wet ESP are listed in Table 8.3.2.5 above. This cost is over $930,000.00 on an a nnual basis for electricity usage alone. For the non-air Environmental Impacts, a Wet ESP is a water intensive system.

According to the EPA Air Pollution Control Cost Manual , a wet ESP uses at least 5 gal/min of water per 1,000 cfm of flue gas. Based on this ratio, operating wet E SPs on both units at CUF would consume over 16 billion gallons per year of additional water and re quire treatment of an equivalent volume of wastewater.

For DuPont – Old Hickory , this analysis does not provide de tailed quantification of energy and non-air quality environmental impacts for each co mpliance option since this is a high level analysis. However, those impact s and be described qualitatively.

### BART Related Documentation Appendix L - 

### 55 Regional Haze SIP for TN Class I Areas April 4, 2008 

### Use of lower sulfur alone coal would not entail any significant changes to energy use or non-air quality environmental impacts.

Use of a spray dry scrubber would require use of lime as the reagent. Solid waste disposal would increase over the current coal ash-only conditi on by the quantity of ca lcium sulfite/sulfate formed in the scrubber. This can be estim ated based on removal percent and expected calcium/sulfur stoichiometric ratio. Costs for th at disposal are included within the estimated O&M cost estimates. As indicated above, the ad ditional waste would be dry, so it would likely be disposed of in a landfill. Additional purchased electricity would be required for operation of the scrubber and baghouse, including, for exampl e, lime transport, sl urry preparation and injection, baghouse pulse air, ash and spent so rbent handling, and increased fan power to compensate for increased flue gas pressure drop. Increased purchased electricity would result in increased emissions of SO 2 

### , NOx, CO 2 

### , and other emissions from th e electric utility generators providing that power, which could in fact, be units that themselves impact Class I areas with their SO 2 

### and NOx emissions. Water would also be consumed for slurry preparation.

Use of a sodium wet scrubber would require use of caustic as the reagent. Liquid waste disposal would increase for disposal of the scrubber blow down stream. The existing plant waste water treatment facility likely does not have adequate ca pacity for that waste stream directly, but some form of neutralization and oxidati on would be required prior to tr ansfer to the waste treatment system. Costs for that disposal are included within the estimated O&M cost estimates. Additional purchased electricity would be required for operation of the scrubber, including, for example, liquid pumping power and increased fan power to compensate for increased flue gas pressure drop. Increased purch ased electricity would result in increased emissions of SO 2 

### , NOx, CO 2 

### , and other emissions from the electric utility generators providing th at power, which could in fact, be units that themselves impact Class I areas with their SO 2 

### and NOx emissions. Water would also be consumed for the scrubber solution.

Use of Low NOx Burners (LNB) w ould result in increased unburned carbon in the flyash due to lower flame temperatures. This could impact the me thod of disposal of flya sh in that beneficial reuse might not be possible, and landfill disposal might be the only option. The associated efficiency loss with increased unburned carbon woul d result in incremental increase in coal consumption and the associated electricity for pul verization and fan power, as well as increased ash disposal overall.

Selective Non Catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR) technologies would utilize ammonia or urea as reagents. Ammonia slip would occur with either control technology. Ammonia slip reacts with sulfur and chloride species in the flue gas forming ammonium salts which increase the concentration of fine particulat es (PM2.5) in the flue gas, potentially increasing stack opacity. On-site stor age of ammonia would cr eate its own set of safety issues. Disposal of spent catalyst w ould be a long term solid waste issue for SCR.

8.3.4 Existing Control

### BART Related Documentation Appendix L - 

### 56 Regional Haze SIP for TN Class I Areas April 4, 2008 

### For Alcoa , existing controls on the BART subject s ources are described in Table 8.1.1.1 (above). They comprise of primary control system of flui d-bed reactor type system with fabric filtration downstream of the reactor beds (Potlines 1 and 2, and Anode Baking Furnace). The rest of the BART subject units are contro lled by fabric filteration.

For Eastman Chemical , existing controls on the BART subj ect sources are described in Table 8.1.1.2 (above). There are no existing add-on SO2 controls for the Co al-fired Boilers, only sulfur content limitation in the fuel. For NOx control, LNB is applied for the ozone season for Boilers #25-#29 only. Cracking furnaces are natural-gas fired only. General Purpose Batch Chemical Manufacturing (OC-BATCH) SO2 and NOx emi ssions are controlled by Scrubbers. PM emissions for each boiler are controlled by ESPs.

For TVA-Cumberland, the facilty has two pulverized-coal-fired steam generators that are considered BART eligible. Units 1 and 2 are nominally rated at about 1325 MW each. Both units are equipped with flue gas desulfuri zation (FGD) systems for sulfur dioxide (SO 2 

### ) control, selective catalytic reduction systems for controlling nitrogen oxides (NO x 

### ), and electrostatic precipitators (ESPs) to control particulate matte r (PM) emissions. In addition, CUF currently uses hydrated lime injection on both units to mitigate stack opacity.

The two units at CUF are subject to the EPA Clean Air Interstate Rule (CAIR). Based on guidance from EPA and TDEC-APC, compliance w ith CAIR satisfies BART requirements for SO 2 

### and NO x 

### emissions at electric generating units.

For DuPont-Old Hickory, as discussed in Section 8.1.1.3 earlie r, the two Industrial Boilers #20 and #24 have the following permit limitations:

• Boilers 20 and 24 are subject to MC L 10.56.200 (Davidson County-Local Program) which limits the maximum sulfur content of any solid or liquid fuel to 2.0% sulfur by weight. The above standards are based on a maximum sulfur content of 0.05% by weight for No.2 Fuel Oil.

• Boilers 20 and 24 are subject to 40 CFR 75, Subpart H, NOx Budget Trading Program.

• All boilers are subject to 40 CFR 63, S ubpart DDDDD, Industrial, Commercial, and Institutional Boilers and Process Heaters with a compliance date of September 13, 2007.

8.3.5 Remaining Useful Life

For Alcoa , the facility has been in operation si nce 1913 and it intends to be in operation throughout the period of th e regional Haze Program.

For Eastman Chemical , the remaining useful life is not expected to affect the BART determination.

For TVA-Cumberland , the remaining useful life is not expected to affect the BART determination.

### BART Related Documentation Appendix L - 

### 57 Regional Haze SIP for TN Class I Areas April 4, 2008 

### For DuPont-Old Hickory , the remaining useful life is not expected to affect the BART determination.

8.3.6 Degree of Visibility Improvement

Already discussed earlier for each facility.

8.4 Final BART Determination

After reviewing the proposed BART determinatio ns and considering the factors, TDEC-APC permitting staff concluded that

BART for Alcoa is limiting the sulfur in th e calcined petroleum coke used to manufacture anodes to 3%.

TDEC-APC concluded that BART for Eastman Chem ical is the applicati on of SDA/FF-dry fluegas desulfurization using a Spray Dryer Absorber (SDA) followed by a fabric filter for the five Coal-fired Boilers #25-#29 (B-253).

TDEC-APC concluded that BART for TVA-Cu mberland is no additional controls.

TDEC-APC concluded that BART for DuPont-Old Hickory is limiting the total combined daily emissions for Boilers 20 and 24 based upon the fo llowing operating limits stated in Table 8.4 below.

Table 8.4 DuPont-Old Hickory BART Contro l Determination–Emission Limitations Operating Limits SO2 (lb/day) NOx (lb/day) Summer Months (May-September) 32260 6120 NON-Summer Months (O ctober -April) 38570 6770

TDEC-APC plans to notice draf t permits after approval of the Tennessee Regional Haze SIP by EPA and issue final permits as expeditiously as po ssible but no later than fi ve years after the date of the SIP approval. The permits will be issued following Tennessee’s standard permitting process. The BART specific permit conditions fo r those sources are included as Appendix L-12.

8.5 BART Subject Sources in Other States Within 300 km of Tennessee Class I Areas

Tennessee intends to provide a summary of th e BART decisions to date for any BART subject sources that fall into the AOI of any of Tennessee’s Class I areas later in the review

process.

# sources outside Tennessee impacting Tennessee Cl ass I areas were subject to BART. # of these sources are installing controls/r educing emissions to comply with BART requirements. The resulting visibility improvement at TN Cl ass I areas is provided in Table 8.5 below.

### BART Related Documentation Appendix L - 

### 58 Regional Haze SIP for TN Class I Areas April 4, 2008 Insert table of out of st ate BART Sources, Class I Areas impacted and resulting visibility improvement.



### Relative impacts/contribution?

8.6 Conclusions

Only four sources in Tennessee out of twelve , Alcoa in Alcoa, TN, Eastman Chemical in Kingsport, TN, TVA-Cumberland in Stewart county, TN, and DuP ont-Old Hickory in Davidson county, TN were subject to BART. Based on review of the available control options, associated costs and visibility benefits, BART for Alcoa is determined to be limiting the sulfur content in the coke to 3% from an allowable of 3.5%.

At TVA-Cumberland all of its BART subject units have some form of existing control to comply with various CAIR, NSPS, MACT, and other requ irements. There are limited additional costeffective control options available. Based on revi ew of the available control options, associated costs and visibility benefits BART is de termined to be no a dditional controls.

For Eastman Chemical, there will be 1.19 dv of visibility improvement at Linville Gorge, 1.56 dv of visibility improvement at Great Smokys, 0.90 dv of visibility improvement at Shinning Rock, 1.20 dv visibility improvement at Joyce Kilmer–Slickrock , 0.72 dv visibility improvement at Cohutta, and 0.50 dv visibility im provement at James River Face as a result of BART requirements.

For DuPont-Old Hickory, there will be 0.033 dv of visibility improvement at Mammoth Cave (New Improve Equation) as a result of BART requirements.

### BART Related Documentation Appendix L - 

### 59 Regional Haze SIP for TN Class I Areas April 4, 2008 

## REFERENCES:

1. Boylan Ph.D., James, 2006, VISTAS Joint T ech Analysis-Planning Call. Power Point Presentation: Summary BART_VOC_NH3_PM.ppt. 2. Brewer, P.F.; and Adloch, J.P., 2005, Trends in Speciated Fine Particulate Matter and Visibility across Monito ring Networks in the Southeastern United States . J Air and Waste Management Association , 55, 1663-1674. 3. Federal Register / Vol. 70, No. 128 / Wedne sday, July 6, 2005 / Rules and Regulations. 4. Hand, J.L.; and Malm, W.C.,2006, Review of the IMPROVE Equation for Estimating Ambient Light Extinction Coefficients - Final Report. March 2006. Prepared for Interagency Monitoring of Protected Visual Environments (IMPR OVE), Colorado State University, Cooperative Institute for Resear ch in the Atmosphere, Fort Collins, CO. 5. MACTEC, 2006, Documentation of the Base G 2002 Base Year, 2009 and 2018, Emissions Inventory VISTAS. 6. Pechan, E.H., and Associates, Inc., 2005, AirControlNET User Guide. 7. Pitchford, Marc., 2006, Natural Haze Levels II: Application of the New IMPROVE Alogrithm to Natural Species Concentrations Estimates. Final Report of the Natural Haze Levels II Committee to the RPO Monitoring/Data Analysis Workgroup. Sep 2006. 8. Sorrels, Larry, 2006, AirControlNET 4.1 Software ; US EPA, OAQPS, Research Triangle Park, NC. 9. U.S. Environmental Protection Agency. (2003). Guidance for Tracking Progress under the Regional Haze Program; EPA-54/B-03-004, 2003.