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 Organic Compounds for BART Purposes ..................... 11

5.1 Method ............................................................................................................................... 11 

5.2 Conclusions ........................................................................................................................ 13 

6. Treatment of Ammonia Emissions 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 Other 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 ................................................................................................. 56 

8.3.6 Degree of Visibility Improvement ............................................................................... 57 

8.4 Final BART Determination ............................................................................................... 57 

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 Visibility Protection Rule 

Appendix L.2 – Tennessee BART Eligible Sources Emissions 

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

Appendix L.4 – VISTAS BART Analysis Sensitivity Modeling 

Appendix L.5 – VISTAS Calpuff 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 Modeling 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 the State’s strategy for complying with the 

requirement to set and meet Reasonable Progress Goals (RPGs) as part of our Regional Haze SIP 

under 40 CFR 51.308(d)(1), and the requirements for establishing best available retrofit (BART) 

controls under 40 CFR 51.308(e). 

In the 1977 amendments to the Clean Air Act (CAA), Congress set a national goal for visibility 

as “the prevention of any future, and the remedying of any existing, impairment of visibility in 

mandatory Class I Federal areas which impairment results from manmade pollution”. The 

regional haze rule (RHR) at 51.308(d) requires states to demonstrate reasonable progress toward 

meeting the goal of a return to natural visibility conditions by 2064. As a guide for reasonable 

progress, the RHR directs states to graphically show 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 visibility 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 specific 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 strategy for developing those BART requirements. 

Our long term strategy contains 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 uniform rate of progress, or “glidepath” for 

each Class I area. 

III. Discussion of emissions sensitivity model runs to help determine which pollutants and 

source categories are contributing the most to visibility impairment 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 “statutory 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 visibility improvement after 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 visibility improvement expected by 2018. 

1. Background

As required by the CAA, EPA included in the final regional haze rule a requirement for Best 

Available Retrofit Technology (BART) for certain large 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 pollutant, 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 categories. Under the CAA, BART is required for any BART-eligible 

source that a State determines ‘‘emits any air pollutant which may reasonably be anticipated to 

cause or contribute to any impairment of visibility in any such area.’’ Accordingly, for stationary 

sources meeting these criteria, States must address the BART requirement when they develop 

regional haze SIPs. 1 EPA has set guidance for identifying BART-eligible sources in 40 CFR 

Part 51 Appendix Y. 

A BART-eligible source that is responsible for a 1.0 deciview (dv) change or more is considered 

to “cause” visibility impairment. Although the appropriate 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 responsible for a 0.5 dv change or more is 

considered to “contribute” to visibility impairment. 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 direct particulate matter (PM) 

emissions, including both PM10 and PM2.5, in determining whether sources cause or contribute 

to visibility impairment. States may use their 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 subject to BART, states have several options. A 

state may consider all BART-eligible sources subject 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 contribute to any visibility impairment in any Class I areas; or may 

consider the individualized contribution 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 determination. Section 169A(g)(7) of 

the CAA requires that States must consider 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 pollution 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 result from the use of such technology. 1 

To demonstrate the degree of improvement in visibility from various BART control options, the 

States may run CALPUFF or another appropriate dispersion model to predict visibility impacts. 

Scenarios would be run for the pre-controlled and post-controlled emission rates for each of the 

BART control options under review. The maximum 24-hour emission rates 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 years of meteorological data. States have the flexibility to develop 

their own methods to evaluate model results. 1 

2. Approach to Implementation 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, concurrent adoption of a framework rule to establish a process for 

conducting BART determinations, use of a permitting 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 spanning states in the VISTAS region, and ongoing consultation with 

affected sources, and EPA and FLMs 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 not 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 pollutant, 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 guidelines. The rule allows affected sources to 

demonstrate that the source does not contribute to visibility impairment and should be exempted. 

Non-exempt sources are required to undergo a determination of best available retrofit 

technology. Accordingly, non-exempt sources are required to submit a permit application 

proposing BART by November 1, 2006. The rule requires that BART controls be installed and 

begin operation as expeditiously as practicable but 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-eligible 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 determine the population of potential BART-eligible 

sources. The data were initially queried for any sources emitting SO2, NOx, PM-10, VOC, or 

ammonia. The data set was refined based on emissions, whether emission units fit in any of the 

twenty-six listed source categories for BART, and available date information obtained through 

review of permit and inspection reports and discussion with permits section and regional office 

staff familiar with the facilities. 

An information packet on BART was sent to and additional information was collected from the 

remaining sources regarding potential emissions and BART eligibility from the standpoint of 

source category and date criteria. Through this iterative review process, the list of potential 

BART-eligible sources was pared down to the fifteen BART-eligible sources listed below. The 

facilities are scattered throughout the state with closest facility proximity to Class I areas ranging 

from 16 km to 312 km. The facilities include one primary aluminum facility, one pulp and paper 

facility, one military ordinance facility, two electric utilities, nine chemical manufacturers, and 

one nitrogen fertilizer 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 Company – Tennessee Operations 

E I DuPont de Nemours and Company, 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-eligible sources. Since 

the time that the BART-eligible sources were identified, Liberty Fibers Corporation has 

permanently shut down, and the BART-eligible boilers 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 nitrogen 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 potential emissions above 250 TPY at this facility were either built 

before August 1962 or were built or modified after 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 Company – Tennessee Operations 

E I DuPont de Nemours and Company, 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 source 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 demonstrations showing that they did not contribute to visibility 

impairment, i.e., had less than 0.5 deciviews (dv) 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 Rule1

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 ‘contributes’ to visibility impairment should not be higher than 0.5 

deciviews.” The rationale for these instructions is provided in the preamble to the BART 

guidance, in the statement, “If ‘causing’ visibility 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 rise to the level of human perception.”2

 The guidance document 

itself also states that, “States remain free to use a threshold lower than 0.5 deciviews if they 

conclude that the location of a large number of BART-eligible sources within the State and in 

proximity to a Class I area justify this approach.” 

The EPA’s documents strive to set these thresholds in the context of the human perception of 

visibility change. As noted above, the EPA considers a 1.0-deciview change in visibility to be 

humanly perceptible “in virtually all situations.” Also, the preamble to the BART guidance3

 cites 

 

1

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

2

 70 FR 39120. Footnote 31 

3

 70 FR 39119. Footnote 28 

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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 Subject SourceOld 

IMPROVE Equ. 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 Exempt SourcesOld 

IMPROVE Equ. 12 Km. 

Facility Distances to Class I Areas (Km)

BART Subject SourcesNew 

IMPROVE Equ.
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 (National Acid Precipitation Assessment Program) 

report, which asserts that “changes in light extinction 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 perceptibility is not a prerequisite for choosing a contribution threshold. 

Putting all this together, it appears 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 having 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 impact 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, visibility impacts are calculated as 24-hr averages of 1-hr plume 

impacts, so if the plumes from the various sources 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 within 32 km from each other and the rest at 

over 100 km from one another with respect to these Class I areas. Similairly, Tennessee BART 

sources near the Memphis area (i.e., DuPont-Shelby, Lucite International and PCS Nitrogen) are 

all located greater than 180 km from the MING/SIPS/MACA Class I areas and they would not 

constitute a cluster of sources near a Class I area for plume convergence considerations. 

TDEC-APC concluded that the EPA suggested contribution 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. Appendix D in Acidic Deposition: State of Science and 

Technology, Report 24, Visibility: Existing and Historical 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 Volatile Organic Compounds for BART 

Purposes 

The State of Tennessee has determined through regional modeling that Volatile Organic 

Compounds (VOC) from point sources are not anticipated to cause or contribute significantly to 

any impairment of visibility in Class I areas and should be exempt for BART purposes. 

5.1 Method 

The State of Tennessee determined through regional modeling that VOCs from point sources are 

not anticipated to cause or contribute significantly to any impairment of visibility in Class I 

areas. 

Modeling was conducted through The Visibility Improvement State and Tribal Association of 

the Southeast (VISTAS). VISTAS is a collaborative effort of state governments, tribal 

governments, and various federal agencies established 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 contracted with Georgia Institute 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, point 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 point 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 below 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 for 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 controlling VOCs from a BART source 

would be much less than the 0.5 dv threshold. VISTAS 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 for 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-eligible 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 analysis for BART is not needed. 

Maximum Point VOC Impact

Maximum VOC Impact

0.0

0.1

0.2

0.3

0.4

0.5

0.6

BRET

BRIG

CACRCHAS

COHU

DOSO

EVER

GRSM

HEGL

JARI

LIGO

MACA

MING

OKEF

ROMA

SAMA

SHEN

SHRO

SIPS

SWAN

UPBU

WOLF

∆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 modeling that with one exception (PCS Nitrogen 

facility near Memphis, TN) ammonia (NH3) emissions from point sources are not anticipated to 

cause or contribute significantly to any impairment of visibility in Class I areas and should be 

exempt for BART purposes. 

6.1 Method 

The State of Tennessee determined through modeling that ammonia emissions from point 

sources are not anticipated to cause or contribute significantly to any 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 model sensitivity runs to 

determine the impact of point 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 emissions. 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 maximum 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 Class I areas within the VISTAS domain. 2 

Maximum NH3 Impact

0.0

0.5

1.0

1.5

BRET

BRIG

CACRCHAS

COHU

DOSO

EVER

GRSM

HEGL

JARI

LIGO

MACA

MING

OKEF

ROMA

SAMA

SHEN

SHRO

SIPS

SWAN

UPBU

WOLF

∆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 NH3 point sources in the VISTAS region 

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

The chart shows the largest haze impact in delta dv over the two timeframes at each Class I area. 

These delta dv changes represent the haze contribution 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 East and monthly-varying “climatologically 

representative” relative humidity at each Class I area. 

During the periods modeled the ammonia emissions from all BART-eligible sources contributed 

more than 0.5 dv to haze at Mammoth Cave National Park (MACA), Kentucky; Mingo 

Wilderness (MING), Missouri, Cape Romain National Wildlife Refuge Area (ROMA) South 

Carolina, and Swanquarter National Wildlife 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 NH3 Sources in the VISTAS Region 

Facility State NH3 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 concentrations 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 few BART sources. Removal of the large NH3 

emission sources results in minimal impact on visibility at Class I areas in the VISTAS region. 

At their discretion states may ask those few large sources to evaluate NH3 impacts and potential 

controls for NH3. Based on the CMAQ sensitivity analyses 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 BART purposes. PCS Nitrogen has the potential to 

emit more than 250 tons per year of ammonia from three of its BART eligible units and it is 

located less than 300 km from both Mingo and Sipsey. Thus these emissions were included in 

the PCS Nitrogen BART determination 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-eligible sources can be excluded from BART 

determinations by demonstrating that the source cannot be reasonably expected to cause or 

contribute to visibility impairment in a Class I area. The threshold 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 propose that the threshold at which a source may 

“contribute” to visibility impairment 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 preferred approach for determining cause or 

contribution is an assessment with an air quality model such as CALPUFF or other appropriate 

model followed by comparison of the estimated 24-hour visibility impacts against a threshold 

above estimated natural conditions to be determined by the State. EPA recommends that the 98th

percentile value from the modeling be compared to the State’s chosen contribution threshold to 

determine if a source does not contribute to visibility impairment and thus is not subject to 

BART. Comparison of the 98th percentile value to the threshold must be made for each Class I 

area. For an annual period, this implies the 8th highest 24-hr value at a particular Class I area is 

compared to the contribution threshold. For a 3-year modeling period, the 98th percentile value 

may be interpreted as the highest of the three annual 98th percentile values at a particular Class I 

area or the 22nd highest value in the combined three year record, whichever is more conservative. 

Tennessee worked with the regional planning organization (RPO) VISTAS on development of 

the VISTAS Protocol for the Application of the CALPUFF Model for Analyses of Best Available 

Retrofit Technology (BART) (Appendix L-5). The common protocol was established to provide 

the basis for a common understanding among the organizations performing BART analyses or 

reviewing BART modeling results in the VISTAS region. 

The VISTAS protocol describes common procedures for carrying out air quality modeling to 

support BART determinations that are consistent with the 40 CFR Part 51 Appendix Y 

guidelines. The protocol provides a consistent model, CALPUFF, and modeling guidelines for 

BART determinations, clearly delineated modeling steps, a common CALPUFF configuration, 

guidance for site-specific modeling, 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 application for BART purposes are found in Chapter 4, and specific 

information that should be included in site-specific protocols is found in Chapter 5. 

VISTAS contracted EarthTech to develop a version of the CALPUFF model appropriate for 

BART purposes. The VISTAS version of the CALPUFF model is CALPUFF 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 publicly available 12-km CALMET output files 

for the entire VISTAS modeling domain (eastern United States) and provided CALMET output 

files for five 4-km grid subdomains covering the 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 provided 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 available, continuous emission data, permit allowable emissions, 

potential emissions, and emission factors 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 facility, NO3 should be repartitioned in 

POSTUTIL. 

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

• The Pasquill-Gifford dispersion method should be used. 

• In CALPOST Method 6 with monthly average RH for calculating extinction as 

recommended by EPA should be used. 

• EPA default calculations of light extinction under current and natural background 

conditions should be used. In addition a source may also calculate visibility using the 

recently revised IMPROVE algorithm. 

Additional discussion of the CALPUFF model and VISTAS recommended settings can be found 

in the VISTAS protocol in Appendix L-5. 

7.2 Tennessee BART Sources Exemption Modeling 

TDEC-APC requested that its sources 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 three years of pre-processed MM5 meteorological data was used 

to evaluate the deciview change compared to natural 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-deciview (dv) value was 

applied, and for the 4 km refined runs, the 98th percentile dv value was determined similarly at 

each Class 1 area and compared to the 0.5 dv contribution threshold. For a source located within 

50 km from a Class I area (i.e., the Alcoa facility) 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 modeling protocol. Modeling of the other six BARTeligible sources – DuPont-Humphreys, DuPont-Shelby, Lucite International, Owens Corning, 

PCS Nitrogen, and Zinifex-Clarksville, were conducted by VISTAS 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 (BART exempt demonstrations) and Appendix L-8 

(BART non-exempt demonstrations). The protocols and demonstrations were reviewed by 

Tennessee’s Air Pollution Control Division and also 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 resolve many of the issues 

and concerns reflected in their comments. TDEC-APC staff reviewed the demonstrations to 

determine whether the sources have less than 0.5 deicview (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 subject to BART and required to 

proceed to an analysis of what control measures, if any, constitute BART for the source. 

Review of the demonstrations submitted led to the 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 Table 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 summary 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 SO2, 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 SO2, 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 SO2, 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 SO2, NOx, NH3 and PM10) 

 Mingo Wildlife Refuge 186 0.166 

 Sipsey Wilderness Area 253 0.074 

 Zinifex – Clarksville 

 (for SO2, 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 Results 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 SO2, 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-eligible sources are electric generating units (EGUs). These are 

TVA-Bull Run and TVA-Cumberland. Consistent with BART regulation requirements and EPA 

guidance, BART-eligible sources at electric utilities complying with EPA’s Clean Air Interstate 

Rule (CAIR) that wished to demonstrate exemption 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 individual sources in states affected by CAIR. A 

State that opts to participate in the CAIR program under 40 CFR 96.201-.224 (Subpart AAA 

through EEE) need not require affected BART-eligible 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 participating 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 demonstrations for PM emissions only. TVA-Bull Run 

demonstrated that it does not contribute to visibility impairment in any Class I area. 

In total, eight (8) of Tennessee’s twelve (12) BART-eligible sources were able to demonstrate 

that they did not cause or contribute to visibility impairment in any 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 SO2, 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 SO2, 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-1st to 8th-high value, 3% sulfur coal using New Improve Equation. 

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

(3) DuPont BART base case Mammoth Cave (MACA) modeling, refined 4-km runs, 8th 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 emission rate, 

which is more representative of the firing patterns for the Boilers. Revised summer time 24-hour maximum emission rates resulted 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, 8th highest value, SDA/FF Controls, using New Improve Equation. 

(5) TVA-Cumberland BART base case, refined 4-km runs, 8th 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 Smoky 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 Smoky 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 summer 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 impacts 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 contributed 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 km 

 GRSM Fraction of AOI (%) JOKI Fraction 

of 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 Areas

COHU Fraction of AOI JARI Fraction of AOI LIGO Fraction of AOI MACA Fraction of AOI SHRO Fraction of AOI SIPS Fraction of AOI MING Fraction

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 Class 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 the 2018 total SO2 emissions in the AOI, modeled 

impacts at Sipsey. Three TN sources, representing % 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 Linville Gorge. The modeled impacts ranged from 

0.033 dv to 0.712 dv at Mammoth Cave. Only two Tennessee BART-eligible sources, Alcoa and 

TVA-Cumberland, modeled a contribution in access of 0.5 dv at two out-of-state Class I areas 

(i.e., SHRO and MACA) respectively. 

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

At this time the VISTAS states are at various points in their processes for addressing BART. 

Tennessee intends to provide a summary of the BART 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 hearing. 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, 

YATES 

STEAMELECT SG07 14,024 16,530 0 229.18 72.13 0.31 16.05 1157.69 0.0188 

GA 07700001 

GEORGIA 

POWER 

COMPANY, 

YATES 

STEAMELECT 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, 

BOWEN 

STEAMELECT 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, 

BOWEN 

STEAMELECT 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 sea 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 develop a post processor to allow CALPOST outputs to 

be used with the new IMPROVE equation. TDEC-APC submitted to US EPA Region 4 a request 

for approval to use the new IMPROVE equation and postprocessor developed by Dr. Tombach 

in BART modeling. A discussion of the rationale for use of the new IMPROVE equation 

follows. The new IMPROVE postprocessor and instructions are included in the request to EPA 

for approval of its use in Appendix L-9. 

Rationale for Need for Use of New IMPROVE Equation 

The new IMPROVE equation is a much better representation of the effects of particulate matter 

on light extinction than the old equation 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 comparing the measured light extinction from 

nephelometers at Class I areas to light extinction calculated using each of the equations. 

2. The new algorithm recognizes spatial and temporal variation in light extinction as size 

distribution of the aerosol changes by increasing 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 increasing relative humidity recognizing research findings 

showing that fine sea salt can be an important 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 greater than represented by the old equation. 

5. The new algorithm includes a NO2 term to represent times when light absorption by 

NO2 is a meaningful contributor to light extinction. 

6. The new algorithm incorporates site-specific 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 IMPROVE equation, the resulting apportionment of 

extinction to various components is more accurate on the haziest and clearest days. This is 

important for development of emission control strategies since the benefits of control of 

concentrations of each species will be represented 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 represent the contribution of sea salt for BART 

sources is important in determining their contribution 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-specific 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 equation 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 for use with CALPUFF contains a modification 

of CALPOST that calculates the light extinction from the CALPUFF output. In their review of 

the spreadsheet and supporting documentation, EPA Region 4 staff commented that the VISTAS 

methodology contained in the spreadsheet developed 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 addition of their recommendation for addressing the 

NO2 term, the VISTAS methodology to incorporate the new IMPROVE equation is acceptable 

on a case-by-case basis upon consultation 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 impairment in any Class I area within 300 km of the 

source. Six sources used the old IMPROVE equation 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, were able to demonstrate exemption using the 

old IMPROVE equation and a refined 4 km CALMET assessment. 

Four sources, Alcoa in Alcoa, TN, Eastman Chemical in Kingsport, TN, DuPont-Old Hickory in 

Old Hickory, TN and TVA-Cumberland 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 considered “subject to BART”. These four sources 

were required to submit permit applications containing their evaluation of potential BART 

options and proposed BART determination. Discussion 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 with 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 IMPROVE equation used and difference in results, 

whether a BART determination was required, the facilities’ 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 conducted the modeling, existing controls, and 

proposed controls resulting from BART determinations 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 various control options and selecting the best alternative taking into 

consideration any pollution control equipment in use at the source, 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 degree of improvement in visibility that may 

reasonably be anticipated to result from the use of such technology. Under Tennessee’s 

approach, facilities that are subject 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 Tennessee that emit any air 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 facilities submitted permit applications proposing 

BART for their sources (Appendix L-8). Upon receipt, 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 the permit applications proposing BART. 

8.1.1 BART-eligible Units and Existing Control 

8.1.1.1 Alcoa - BART-eligible Units and Existing Control

Alcoa has twenty-four BART-eligible emission units that comprise the BART-eligible source. 

The majority of these units are currently controlled. 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, SO2 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, SO2 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, SO2, NOX 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 into 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, SO2 Fabric Filter 

05-0008-19 Ball Mill This emission 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 recycled 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 soda 

storage 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 and 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 mixes 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 SO2 and particulate matter (PM), and the anode bake furnace emits 

lesser amounts of SO2, nitrogen oxides (NOX), and PM. These three emission units are already 

equipped with sophisticated emission control equipment for PM, so the BART determination for 

these emission units focuses primarily on potential reductions for SO2 and NOX. 

The remaining 21 emission units identified in Table 8.1.1.1 are material handling and 

transfer operations that support the potlines and 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 filters effectively remove >99% of particulate emissions and, based 

on a control technology review, represent the best available control 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 analysis. Based on visibility modeling results for the aluminum 

reclamation melting furnaces, which have a comparable PM emission rate, visibility impacts 

from individual fabric filters 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-eligible 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. Specific information on stack parameters and 

maximum daily emissions of the emission units 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 CEM

02 B-83-1 C Boiler 24 (overfeed 

stoker, 500 MBtu/hr) 

569 CEMS N/A None 1,494 Fuel

Usag

Sulfu

Cont

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

Fuel

Usag

16 B-6C-1 B Furnace 28 (18 

MBtu/hr) 

6.5 AP-42, 

Fuel 

Usage 

10.6 tpy None 0.16 AP-4

Fuel

Usag

Others 

25 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 boilers are Combustion Engineering 

tangentially-fired pulverized coal boilers started up between 1966 

and 1972. They are rated at a maximum heat input capacity of 655 

MBtu/hr. Eastern Kentucky and western Virginia type bituminous 

coal is the only fuel burned in these units (other than natural gas 

for startups). 

These units are used for co-production of steam and electricity in 

support of manufacturing operations at the Kingsport plant. A 

high level of reliability and the ability 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 precipitators are located at ground level. These 

precipitators were installed 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 overfire-air (separates the upper 

end auxiliary air from the fire creating a mini-SOFA within the 

windbox) with modified coal tips that provide for flame attachment 

closer to the burners. When fired 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 load. 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 strategy know as Burner Out of 

Service (BOOS) and results in significantly 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 load demands dictated by unplanned 

outages or site steam load requirements. 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 lower 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 Plant Title V Air Permit includes the following information 

relative to the two BART-eligible 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 standby 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 standby fuel- No.2 Fuel 

Oil 

Mass and Visible Emission Standards and Operating Schedule Limitations

• Boilers 20 and 24- visible 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 

PM10 77.4 1858 339.1 

SO2 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 

PM10 54.8 1315 240.1 

SO2 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 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, 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 Plant 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 emissions 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 are 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 (SO2) control, selective catalytic 

reduction systems for controlling nitrogen oxides (NOx), and electrostatic precipitators 

(ESPs) to control particulate matter (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 with CAIR satisfies BART 

requirements for SO2 and NOx emissions at electric generating units. As a result, the 

BART analysis only considerd PM10 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 (oK) 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 visibility 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 impairment 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 determinations: (1) The costs of compliance, (2) The energy and nonair quality environmental impacts of compliance, (3) Any existing pollution control 

technology in use at the source, (4) The remaining useful life of the source, and (5) The 

degree of improvement in visibility which may reasonably be anticipated to result from 

the use of such technology. These 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 weighted in making their 

determinations regarding what constitutes BART. (See 70 FR 39170, 1st col., July 6, 

2005.) 

8.3.1 Control Scenarios Considered 

Each facility reviewed several potential control alternatives. These control alternatives 

considered and the associated visibility improvement that would result are summarized in 

Tables 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 - SO2 Post-Control Emission Ratesa

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 potential 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 Evaluation 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 Evaluation 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 & 240.605 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 0.039 

B3. 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 Hickory – MACA Visibility Assessment 

Summary of the Control Scenario Visibility & 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

Average 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

SO2 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 

Cofiring on Both Boilers 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 estimate range). The costs for the (Wet Scrubber 

scenario 1)are summarized in Table 8-3.2.1 below taken from the Alcoa BART determination 

permit application submittal (Appendix L-8). The facility proposed that BART is taking a 

pollution prevention limit of 3% sulfur in the calcined petroleum coke used to manufacture 

anodes. 

Table 8.3.2.1 Alcoa - Summary of the Impacts Analysis for SO2 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 5,234a $217,000 $39,000 $7,500 33,200 4

P

2 3.0% Sulfur 

Coke with 

Anode Bake 

Furnace Wet 

Scrubber 

4,830 687b 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 from 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 removed 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 desulfurization using a SDA followed by a fabric filter 

(scenario 2 in the demonstration) for the five Coal-fired Boilers #25-#29 (powerhouse B-253). 

Table 8.3.2.2 – SO2 Costs Effectiveness Summary (5 Boilers) 

Technology Capital 

Cost 

$M 

Annual O/M 

Cost 

$M 

Assumed 

Percent 

Control 

Efficiency 

Annual 

SO2 

Reduced 

(tons) 

CostEffectiveness 

($/ton) 

Incremental 

CostEffectiveness 

($/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 ponds, 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 

Incremental 

CostEffectiveness 

$/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 SIPS to 0.472 dv at MACA with costs at over 

$85,000/ton of SO2 removed for each boiler The costs 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 proposed 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 ft2/1000 cfm, 4.5 million cfm 

 Material $ 787,610 1% of PEC 

Utilities 

 Electricity-fan $ 599,342 2" H2O ∆p, $0.06/kWh 

 

Electricityoperating $ 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 Hickory visibility improvement resulting from the nine (9) control scenarios 

considered of SO2 reductions ranged from 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 summarized 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 feasible controls and a proposed BART control 

determination for the two boilers. This additional information is a compliment to their BART 

determination permit application submittal (Appendix 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 stated 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 On

Control Option --> No FGD No FGD No FGD 95% WSS 95% WSS 95% WSS 50% Gas Cofiring 95% WS

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/-30

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 $364,24

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 $1,988

Cost Effectiveness Relative to Coal 2, $/Ton Removed: $526 $2,962 $2,823 $4,102 $5,827 $2,170

Cost Effectiveness Relative to Coal 3, $/Ton Removed: $4,244 $4,064 $6,075 $49,997 $3,252

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 As

FACTORED ESTIMATE FROM RTP DATABASE using current Coal Boiler 20 Only w/ Boiler 20 Only w/ Boiler 20 On

Control Option --> CC LNB SNCR LNB+SCR 50% Gas Cofiring LNB SNCR LNB+SC

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 $816,96

Range: +50/-30 +50/-30 +50/-30 +50/-30 +50/-30 +50/-30

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 $182,12

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 $3,380

Incremental Cost Effectiveness Relative to LNB on Boiler 20 Only, $/Ton Removed: $3,803 $5,189 $6,490 $132,585 $4,974

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 DuPont Old Hickory Boiler 20 at Combined 

Maximum Daily Emissions 

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

CF as annual 

operating rate= 80%

BASES --->

CF as annual

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 Bo

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 cu

Control Option --> No FGD No FGD No FGD 85% SDA+FF 95% WSS 85% SDA+FF 95% WSS 85% SDA+FF 95% WSS 50% Ga

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 Incremental 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 Incremental 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 Annualinterestrate (fractional): 0.07

Cost Effectiveness: $226 $882 $560 C ontrolsystem life (years): 15

Annual Emissions Reduction: 391 391 859 Capitalrecovery factor(system ): 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 

operating rate= 20%

BASES --->

CF as annual

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 curren

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 Co

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 $4,031

Cost Effectiveness Relative to Coal 2: $526 $8,165 $5,563 $8,429 $5,469 $12,235 $8,500 $5,827

Cost Effectiveness Relative to Coal 3: $12,659 $8,215 $13,528 $8,141 $20,388 $12,900 $49,99

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 Annualinterestrate (fractional): 0.07

Cost Effectiveness: $610 $2,375 $1,699 C ontrolsystem life (years): 15

Annual Emissions Reduction: 103 103 226 C apitalrecovery factor(system ): 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 & 24

 

P. 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 & 24 

B3. 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 Control Determination–Proposed Emission 

Limitations 

Operating Limits SO2 (lb/day) NOx (lb/day) 

Summer Months (May-September) 32260 6120 

NON-Summer Months (October -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 SO2 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 scrubber 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, instrumentation, and miscellaneous items (e.g., lighting). The total energy 

required, based on an average of the two proposals, 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 whether the gypsum would have commercial value or 

whether there would be any demand 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 estimated that 180 million gallons of water will be 

required annually to operate the potline wet 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 relatively no impact due to water discharge, at 

approximately 4 gallons/minute. It is also estimated that 36 million kWh would be needed to 

operate the scrubbers annually. 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 changes, positive or negative, on energy 

consumption. For non-air quality environmental 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 Eastman's on-site nonhazardous waste landfill. Eastman 

has estimated this additional waste would shorten the landfill life by about 5 years (15 percent 

reduction in remaining life). Since the SDAs would 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 lost. We have estimated this loss of flyash sales at 11,000 tons 

per year and that this volume would shorten the landfill life by an additional year or two. Loss of 

this volume of flyash to the concrete industry would mean that much more cement would be 

required resulting in consumption of additional energy (natural gas) and raw materials to produce 

the cement along with the associated air emissions. It would also result in an increased 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 environmental impact as the landfill has liners and 

leachate collection systems and should 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. However, 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 result in other community impacts such as noise and scenic concerns. 

The caustic scrubber option would generate a scrubber blowdown stream containing dissolved 

salts which would require discharge to the South 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 Solids (TDS) loading to the river by approximately 

238,000 lb/day. 

The worst-case maximum TDS loading could increase 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 Tennessee Department of Environment 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, the discharge of the scrubber 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 standard and within the range of values currently 

measured in the river. A worst-case evaluation of the impact of the blowdown discharge was 

performed based on low flow in the river combined 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 increasing the level of TDS in the SFHR, would not 

result in an exceedence of the 500 mg/L water 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 annual 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 ESPs on both units at CUF 

would consume over 16 billion gallons per year of additional water and require treatment of an 

equivalent volume of wastewater. 

For DuPont – Old Hickory, this analysis does not provide detailed quantification of energy and 

non-air quality environmental impacts for each compliance option since this is a high level 

analysis. However, those impacts 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 condition by the quantity of calcium sulfite/sulfate 

formed in the scrubber. This can be estimated based on removal percent and expected 

calcium/sulfur stoichiometric ratio. Costs for that disposal are included within the estimated 

O&M cost estimates. As indicated above, the additional 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 example, lime transport, slurry preparation and 

injection, baghouse pulse air, ash and spent sorbent handling, and increased fan power to 

compensate for increased flue gas pressure drop. Increased purchased electricity would result in 

increased emissions of SO2, NOx, CO2, and other emissions from the electric utility generators 

providing that power, which could in fact, be units that themselves impact Class I areas with 

their SO2 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 blowdown stream. The existing plant waste water 

treatment facility likely does not have adequate capacity for that waste stream directly, but some 

form of neutralization and oxidation would be required prior to transfer 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 purchased electricity would result in increased emissions of SO2, NOx, 

CO2, and other emissions from the electric utility generators providing that power, which could 

in fact, be units that themselves impact Class I areas with their SO2 and NOx emissions. Water 

would also be consumed for the scrubber solution. 

Use of Low NOx Burners (LNB) would result in increased unburned carbon in the flyash due to 

lower flame temperatures. This could impact the method of disposal of flyash in that beneficial 

reuse might not be possible, and landfill disposal might be the only option. The associated 

efficiency loss with increased unburned carbon would result in incremental increase in coal 

consumption and the associated electricity for pulverization 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 particulates (PM2.5) in the flue gas, 

potentially increasing stack opacity. On-site storage of ammonia would create its own set of 

safety issues. Disposal of spent catalyst would 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 sources are described in Table 8.1.1.1 (above). 

They comprise of primary control system of fluid-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 controlled by fabric filteration. 

For Eastman Chemical, existing controls on the BART subject sources are described in Table 

8.1.1.2 (above). There are no existing add-on SO2 controls for the Coal-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 emissions 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 desulfurization (FGD) systems for sulfur dioxide (SO2) control, 

selective catalytic reduction systems for controlling nitrogen oxides (NOx), and electrostatic 

precipitators (ESPs) to control particulate matter (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 with CAIR satisfies BART requirements for 

SO2 and NOx emissions at electric generating units. 

For DuPont-Old Hickory, as discussed in Section 8.1.1.3 earlier, the two Industrial Boilers #20 

and #24 have the following permit limitations: 

• 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 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, Subpart 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 since 1913 and it intends to be in operation 

throughout the period of the 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 determinations and considering the factors, TDEC-APC 

permitting staff concluded that 

BART for Alcoa is limiting the sulfur in the calcined petroleum coke used to manufacture 

anodes to 3%. 

TDEC-APC concluded that BART for Eastman Chemical is the application 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-Cumberland 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 following operating limits stated in Table 8.4 

below. 

 

Table 8.4 DuPont-Old Hickory BART Control Determination–Emission Limitations 

Operating Limits SO2 (lb/day) NOx (lb/day) 

Summer Months (May-September) 32260 6120 

NON-Summer Months (October -April) 38570 6770 

TDEC-APC plans to notice draft permits after approval of the Tennessee Regional Haze SIP by 

EPA and issue final permits as expeditiously as possible but no later than five years after the date 

of the SIP approval. The permits will be issued following Tennessee’s standard permitting 

process. The BART specific permit conditions for 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 the 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 Class I areas were subject to BART. # of these 

sources are installing controls/reducing emissions to comply with BART requirements. The 

resulting visibility improvement at TN Class 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 state 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 DuPont-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 requirements. There are limited additional costeffective control options available. Based on review of the available control options, associated 

costs and visibility benefits BART is determined to be no additional 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 improvement 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 

 

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1. Boylan Ph.D., James, 2006, VISTAS Joint Tech 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 Monitoring Networks in the Southeastern United States. J Air and Waste 

Management Association, 55, 1663-1674. 

3. Federal Register / Vol. 70, No. 128 / Wednesday, 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 (IMPROVE), Colorado State 

University, Cooperative Institute for Research 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.