Connecticut Regional Haze 

State Implementation Plan November 2009 

ATTACHMENT W 

MANE-VU Five-Factor Analysis of BART-Eligible Sources
Five-Factor Analysis of BARTEligible Sources

Survey of Options for Conducting BART 

Determinations

Prepared by 

NESCAUM 

for the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) Regional Planning 

Organization 

June 1, 2007 
Members of Northeast States for Coordinated Air Use Management 

Anne Gobin, Acting Bureau Chief 

Connecticut Department of Environmental Protection, Bureau of Air Management 

James P. Brooks, Bureau Director 

Maine Department of Environmental Protection, Bureau of Air Quality 

Barbara Kwetz, Director 

Massachusetts Department of Environmental Protection, Bureau of Waste Prevention 

Robert Scott, Director 

New Hampshire Department of Environmental Services, Air Resources Division 

William O’Sullivan, Director 

New Jersey Department of Environmental Protection, Office of Air Quality Management 

David Shaw, Director 

New York Department of Environmental Conservation, Division of Air Recourses 

Stephen Majkut, Chief 

Rhode Island Department of Environmental Management, Office of Air Resources 

Richard A. Valentinetti, Director 

Vermont Department of Environmental Conservation, Air Pollution Control Division 

Arthur Marin, Executive Director 

Northeast States for Coordinated Air Use Management
ii

Five-Factor Analysis of BARTEligible Sources

Survey of Options for Conducting BART 

Determinations

Prepared by 

NESCAUM 

for the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) Regional Planning 

Organization 

June 1, 2007
iii

FIVE-FACTOR ANALYISIS OF BARTELIGIBLE SOURCES 

Survey of Options for Conducting BART Determinations 

Project Manager 

 Gary Kleiman, NESCAUM 

Principal Contributors

 Iyad Kheirbek and Gary Kleiman, NESCAUM 
iv

Acknowledgements 

NESCAUM acknowledges the support of its member agencies and the staff time that they 

dedicated in providing survey information on the types and level of control available for 

various source categories subject to the BART requirements of the Regional Haze Rule. 

Their insight has allowed NESCAUM to create what it hopes will be a valuable guide for 

all members of MANE-VU as they proceed to conduct source-specific BART 

determinations. NESCAUM also acknowledges the funding for this work through U.S. 

EPA agreement number XA-97318101-0 to the Ozone Transport Commission in support 

of the MANE-VU Regional Planning Organization. NESCAUM is solely responsible for 

the content of this report and any errors it may contain. 

Printed: July 2007 
v

TABLE OF CONTENTS 

Acknowledgements............................................................................................................ iv 

Executive Summary.......................................................................................................... vii 

1. Introduction................................................................................................................. 8 

1.1. The BART Rule .................................................................................................. 8 

1.2. Overview of State BART Requirements............................................................. 9

1.3. Overview of Report........................................................................................... 10 

2. Determining BART-Eligible Sources....................................................................... 11 

3. MANE-VU Approach to “Subject to BART” .......................................................... 11 

4. Regional Five Factor Analysis.................................................................................. 11 

4.1. The Degree of Visibility Improvement That May Reasonably be Anticipated 

from the Use of BART.................................................................................................. 11 

4.2. Cost and Availability of Controls and Controls Already in Place .................... 15 

4.2.1. Chemical Manufacturers........................................................................... 19 

4.2.2. Glass Fiber ................................................................................................ 19 

4.2.3. Coal Cleaning............................................................................................ 19 

4.2.4. Electric Generation Units.......................................................................... 19 

Coal-Fired Units.................................................................................................... 19 

Oil-Fired Units...................................................................................................... 20 

4.2.5. Incinerators ............................................................................................... 20 

4.2.6. Metal Production....................................................................................... 21 

4.2.7. Paper and Pulp .......................................................................................... 21 

4.2.8. Portland Cement Plants............................................................................. 21 

4.2.9. Refineries .................................................................................................. 22 

4.3. Energy and Non-Air Quality Environmental Impacts ...................................... 22 

4.4. Remaining Useful Life...................................................................................... 24 

5. Conclusions............................................................................................................... 24 

6. References................................................................................................................. 26 

Appendix A: List of BART-Eligible Sources in the MANE-VU Region ........................ 27 

Appendix B: Costs of Technologies ................................................................................. 32 

Appendix C: BART Workgroup Draft Recommendations............................................... 34 
vi

FIGURES 

Figure 4-1. Reduction potential of BART control options at EGUs and Paper and Pulp 

Sources ................................................................................................................... 23 

Figure 4-2. Reduction potential of BART control options at Cement Plants .................. 24 

TABLES 

Table 4-1. Types of BART-eligible sources modeled in the region................................ 12 

Table 4-2. Types of sources in MANE-VU region with greater than 0.1 dv impact at any 

Class I area (non year-round CAIR states). ........................................................... 14 

Table 4-3. Possible range of SO2 controls and costs based on survey of state staff........ 16 

Table 4-4. Possible range of NOX controls and costs based on survey of state staff....... 17 

Table 4-5. Possible range of PM10 controls and costs based on survey of state staff...... 18 
vii

Executive Summary 

The 1999 U.S. Environmental Protection Agency (USEPA) “Regional Haze Rule” [64 

Fed. Reg. 35714 (July 1, 1999)] requires certain emission sources that “may reasonably 

be anticipated to cause or contribute” to visibility impairment in downwind Class I areas 

to install Best Available Retrofit Technology (BART). These requirements are intended 

to reduce emissions specifically from large sources that, due to age, were exempted from 

other control requirements of the Clean Air Act. 

States are required to undertake three key steps to comply with the BART 

requirements of the Regional Haze Rule. These steps include: 

• Determining if a source is BART-eligible; 

• Determining if a source reasonably causes or contributes to visibility impairment 

in any Class I area (subject to BART); 

• Determining if additional controls or emission limits are necessary (BART 

determination). 

This report is intended to summarize one approach to satisfy the BART 

requirements of the Regional Haze Rule that member states may consider. We also 

review BART-eligible sources in the MANE-VU region and provide – on a regional basis 

– an analysis of the general applicability of the five statutory factors that states must 

consider in determining BART controls for various source categories subject to BART. 

This analysis will allow MANE-VU states to place their source-specific BART 

determinations into the regional context of similar sources within MANE-VU. This 

review includes an examination of individual units’ impacts on visibility at Class I areas 

based on CALPUFF modeling and an evaluation of existing or potential controls and 

feasibility of these controls relative to the statutory factors identified in the BART rule. 

Ultimately, the strength of the MANE-VU BART program, as determined by 

individual state control decisions and informed by this analysis, will demonstrate MANEVU’s resolve to tackle visibility and related air quality problems in its region. As 

MANE-VU enters into consultations with other regional planning organizations (RPOs), 

its willingness to seek reasonable emission reductions within its own region will help set 

expectations for the other RPOs, and the BART program represents a cornerstone of this 

process. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 8

1. INTRODUCTION 

The 1999 U.S. Environmental Protection Agency (USEPA) “Regional Haze 

Rule” [64 Fed. Reg. 35714 (July 1, 1999)] requires certain emission sources that “may 

reasonably be anticipated to cause or contribute” to visibility impairment in downwind 

Class I areas to install Best Available Retrofit Technology (BART).1

 These requirements 

are intended to reduce emissions specifically from large sources that, due to age, were 

exempted from new source performance standards (NSPS) requirements of the Clean Air 

Act. 

BART requirements pertain to 26 specified major point source categories, 

including power plants, industrial boilers, paper and pulp plants, cement kilns, and other 

large stationary sources. To be considered BART-eligible, sources from these specified 

categories must have the potential to emit at least 250 tons per year of any haze forming 

pollutant and must have commenced operation or come into existence in the 15 year 

period prior to August 7, 1977 (the date of passage of the 1977 Clean Air Act 

Amendments, which first required new source performance standards). 

Because of the regional focus of the 1999 haze rule, it is likely that BART 

requirements will be applied to a much larger number of sources across a broader 

geographic region than has been the case historically (i.e., through reasonably attributable 

visibility impairment requirements in the 1980 haze regulations). In addition, USEPA has 

for the first time introduced the possibility that source-by-source, command and control 

type BART implementation may be replaced by more flexible state initiatives (e.g. 

market-based approaches), provided such alternatives can be shown to achieve greater 

progress toward visibility objectives than the source by source BART approach. 

1.1. The BART Rule 

In June 2001, EPA released proposed guidelines on BART. This guidance 

outlined the method for determining if a facility has a BART-elgible source, if a source is 

subject to BART provisions, and methods for conducting a BART control review for 

such sources. 

In 2002, industry groups challenged the method EPA outlined in the Regional 

Haze Rule to determine the degree of visibility improvement resulting from application 

of BART controls. Under EPA’s interpretation of the statute, a state would deem sources 

subject to BART if they emitted into a geographic area or region from which pollutants 

are likely transported downwind into a protected area. In May 2002, the D.C. Circuit 

Court of Appeals agreed with industry petitioners that this interpretation impermissibly 

constrained the authority of any state that wanted to provide an exemption mechanism 

from BART requirements. The Court vacated those portions of the Regional Haze Rule 

dealing with BART. 

 

1

 There are seven designated Class I areas in the Northeast and Mid-Atlantic States. They include Acadia 

National Park and Moosehorn Wilderness Area in Maine; Roosevelt Campobello International Park in New 

Brunswick and Maine; the Lye Brook Wilderness Area in Vermont; the Great Gulf and Presidential RangeDry River Wilderness Areas in New Hampshire; and the Brigantine Wilderness Area in New Jersey. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 9

In June 2005, EPA released the final BART guidelines that also addressed the remanded 

portions of the Regional Haze Rule dealing with BART. Under the final rule, the BART 

program requires states to develop an inventory of sources within each state or tribal 

jurisdiction that could be subject to control. Specifically, the rule: 

• Outlined methods to determine if a source is “reasonably anticipated to cause or 

contribute to haze;” 

• Defined the methodology for conducting a BART control analysis; 

• Provided presumptive control limits for electricity generating units (EGUs) larger 

than 750 Megawatts; 

• Provided a justification for the use of the Clean Air Interstate Rule (CAIR) as 

BART for CAIR state EGUs. 

Beyond the specific elements listed above, EPA provided the states with a great 

degree of flexibility in how they choose to implement the BART program. The following 

section summarizes the core requirements for state compliance with BART regulations. 

1.2. Overview of State BART Requirements 

As finally promulgated, States are required to undertake three key steps to comply with 

the BART requirements of the Regional Haze Rule. These steps include: 

• Determining if a source is BART-eligible; 

• Determining if a source reasonably causes or contributes to visibility impairment 

in any Class I area (subject to BART); 

• Determining if additional controls or emission limits are necessary (BART 

determination). 

As stated earlier, eligibility is limited to sources in one of 26 source categories 

that have units installed and operating between 1962 and 1977 with the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Once a source is found to 

be “eligible” for the BART program, states must determine if that source is “subject to 

BART,” that is, if it causes haze or contributes to the formation of haze at any Class I 

area. EPA’s 2005 rule outlines three options to determine if a source is subject to BART. 

These options include: 

• Individual source assessment (Exemption Modeling) – This assessment uses 

CALPUFF or other EPA approved modeling methods. Results of modeling 

would be compared to natural background conditions. EPA defined “cause” as an 

impact of 1.0 deciview or more and “contribute” as an impact of 0.5 deciview or 

more.2

 The rule, however, gave states discretion to set lower thresholds for 

contribution. 

 

2

 Impacts are based on the difference in deciviews (delta deciview) calculated between the best twenty 

percent natural visibility conditions (states have the option to use annual average conditions as an 

alternative) at a Class I site with and without individual source contributions included. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 10

• Cumulative assessment of all BART "eligible sources” – Under this method, a 

state can choose to find that all eligible sources within a geographic area or region 

are subject to BART. This method could also be used to analyze an area’s 

contribution to visibility impairment and demonstrate that no sources are subject, 

based on cumulative modeling. 

• Assessment based on model plants – This method provides a mechanism to 

exempt sources with common characteristics that are found not to impair visibility 

at Class I areas. 

Once a source has been identified as BART-eligible and “subject” to BART, it must 

conduct an engineering review to determine if the installation of new control 

requirements is appropriate.3

 This review takes into consideration five factors: 

• Cost of controls 

• Energy and non-air quality environmental impacts 

• Existing controls at source 

• Remaining useful life of source 

• Visibility improvement reasonably expected from application of the controls. 

1.3. Overview of Report 

This report is intended to summarize an approach to satisfy the BART 

requirements of the Regional Haze Rule based on the “cumulative assessment of 

contribution” option for determining if eligible sources are subject to BART. We also 

review BART-eligible sources in the MANE-VU region and provide – on a regional basis 

– an analysis of the general applicability of the five factors for various source categories 

subject to BART. This analysis should not be viewed as preventing states from 

exercising their flexibility in structuring their own approach to BART or in applying the 

five factors to that approach. Rather, this analysis will allow MANE-VU states to place 

their source-specific BART determinations into the regional context of similar sources 

within MANE-VU. This review includes an examination of individual units’ impacts on 

visibility at Class I areas, based on CALPUFF modeling and an evaluation of existing or 

potential controls and feasibility of these controls relative to the statutory factors 

identified in the BART rule4

. 

To that end, Section 2 of this report first develops a list of all BART-eligible 

sources in the MANE-VU region. Section 3 provides an overview of the region’s 

approach to determining BART eligibility. Finally, Section 4 presents observations on 

the regional and sectoral differences among control options and the applicability of the 

five-factor analysis. 

 

3

 A possible exception to this requirement would exist in the case where a state has adopted a “better than 

BART” alternative program that would take the place of a source-specific BART determination. The RPO 

is not aware of any MANE-VU states that are adopting such programs at this time. 

4

 Throughout this report we refer to the collection of sources at a stationary facility potentially subject to 

BART as a “BART-eligible source.” Individual emitting units at these BART-eligible sources will be 

referred to as “units” when emissions are modeled and descriptions of possible control strategies are 

offered. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 11

2. DETERMINING BART-ELIGIBLE SOURCES 

 To assist MANE-VU states and tribes with BART implementation efforts, 

MANE-VU developed a list of BART-eligible sources in the region (NESCAUM, 2001; 

NESCAUM, 2003). Since then, the preliminary list developed in these documents was 

refined through consultation with state permitting staff to verify completeness and 

accuracy of the list. Emissions of SO2, NOX, and PM10 as well as stack information were 

compiled through either consultation with state permitting staff or the 2002 MANE-VU 

emissions inventory. The final list of sources (as well as associated 2002 emissions and 

stack parameters) was developed in consultation with state staffs (see Appendix A for a 

complete list of BART-eligible sources and units in the MANE-VU region). 

3. MANE-VU APPROACH TO “SUBJECT TO BART” 

Based on the MANE-VU contribution assessment (NESCAUM, 2006b), every 

MANE-VU state with BART-eligible sources contributes to visibility impairment at a 

Class I area to a significant degree. Therefore, MANE-VU staff continues to support the 

policy decision made by the MANE-VU Board in June 2004, that if a source is eligible 

for BART, it is subject to BART. (i.e., no exemption test will be used). The reasons why 

MANE-VU has chosen to pursue this option for demonstrating its sources are reasonably 

anticipated to cause or contribute to visibility impairment at Class I areas are threefold: 

(1) the BART sources represent an opportunity to achieve greater reasonable progress, 

(2) additional public health and welfare benefits will accrue from resulting decreases in 

fine particulate matter, and (3) to demonstrate its commitment to federal land managers 

(FLMs) and other RPOs as it seeks emissions reductions wherever it is reasonable to do 

so. 

This recommendation is not equivalent, however, to the statement that every 

BART-eligible source must install controls. The approach presented for MANE-VU state 

consideration – starting with this document and continuing with their own source specific 

analyses – requires the consideration of each of the five factors required by statute before 

determining whether or not controls are warranted. 

4. REGIONAL FIVE FACTOR ANALYSIS 

4.1. The Degree of Visibility Improvement That May Reasonably be 

Anticipated from the Use of BART 

BART emission limits must be determined subject to an evaluation of the five statutory 

factors. These factors include: 

(a) the costs of compliance, 

(b) the energy and non-air quality environmental impacts of 

compliance, 

(c) any existing pollution control technology in use at the source, 

(d) the remaining useful life of the source, and 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 12

(e) the degree of visibility improvement which may reasonably be 

anticipated from the use of BART. 

To begin its regional analysis of these factors, MANE-VU staff first considered 

the degree of visibility improvement that could result from the installation of BART 

controls. This is slightly different than the statutory language and is meant to reflect our 

first-order approach to estimating the maximum visibility benefit that could be achieved 

by eliminating all emissions from the source. While this is not a realistic approach to 

fully satisfying the intent of factor (e) above, it does provide the states a useful metric for 

determining which sources are unlikely to warrant BART controls based on consideration 

of this factor. 

This analysis was achieved by first modeling 2002 emissions of SO2, NOX, and 

PM10 from all BART-eligible units in the region.5 A total of 136 BART-eligible sources 

were identified in the MANE-VU region and modeled on the two CALPUFF platforms. 

Table 4-1 displays the types and numbers of sources modeled in the region. 

Table 4-1. Types of BART-eligible sources modeled in the region 

Source Type Number of Sources 

Number of 

Units/MM5* 

Number of 

Units/NWS 

Chemical Manufacturer 12 48 107 

Chemical Plant 1 4 18 

Coal Cleaning 1 1 1 

EGU 59 139 296 

Glass Fiber 3 14 33 

Incinerator 1 2 2 

Industrial Boilers 2 6 8 

Lime Plant 2 4 14 

Metal Production 13 64 140 

Mineral Products 1 4 13 

Paper and Pulp 14 39 63 

Petroleum Storage 4 6 10 

Portland Cement 13 49 228 

Refinery 9 70 497 

Total 136 455 1449 

* Units with very small emissions were grouped together and modeled as one stack for the MM5-based 

CALPUFF runs. 

The two CALPUFF modeling platforms are described in greater detail elsewhere 

(NESCAUM, 2006b) and are driven by two respective meteorological datasets: 1) a 

wind field based on National Weather Service (NWS) observations and 2) a wind field 

based on output from the MM5 meteorological model (MM5, 2006). Environmental 

Resources Management (ERM) developed CALMET-processed meteorology on a large 

domain (extending from Oklahoma City, OK up to Prince Edward Island, Canada). The 

CALMET meteorology was processed directly from the MM5 model output developed 

 

5

 Emissions information was gathered from the MANE-VU 2002 Version 2 (Base A) emissions inventory. 

Since then, the MANE-VU 2002 Version 3 (Base B) emissions inventory has been developed which 

includes several changes made by the OTC modeling committee. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 13

on a 12-km horizontal grid by the University of Maryland for the OTC modeling 

committee and MANE-VU. The Vermont Department of Environmental Conservation 

(VT DEC) developed CALMET meteorology (for the identical domain) driven by the 

NWS’s surface observation network, rawinsonde network, and supplemented by the 

Airport Surface Observation System (ASOS) network. This observation-based dataset 

provides an alternative to the gridded wind fields generated by the diagnostic model 

MM5. 

Modeling results from both NWS and MM5 platforms have been made available 

to the states involved in this process. Results include each BART-eligible unit’s 

maximum 24-hr, 8th highest 24-hr, and annual average impact at the Class I area most 

heavily impacted, as well as the total impact from all BART sources on each Class I area. 

These visibility impacts were modeled relative to 20 percent best, 20 percent worst, and 

annual average natural background conditions. For the purposes of this analysis, we 

examined the 24-hr maximum visibility impact relative to the 20 percent best days. On 

July 19, 2006, EPA provided clarification to guidance that states may use either estimates 

of 20 percent best or annual average natural background visibility conditions as the basis 

for calculating the deciview difference that individual sources would contribute for 

BART exemption modeling purposes. MANE-VU has opted to use the best conditions 

estimates for their consideration of the “degree of visibility improvement” modeling 

because it is more protective to the region. 

Given that no modeling of 2018 “post-BART” emission levels has been 

conducted yet, the 2002 modeling, in essence, provides MANE-VU with an estimate of 

the maximum improvement in visibility that could result from installation of BART 

controls at Class I areas in the region (i.e., if the source was zeroed out). In virtually all 

instances, the installation of BART controls would result in less visibility improvement 

than what is represented by a source’s 2002 impact, but this does provide a consistent 

means of identifying those sources whose emissions represent a more significant 

contribution to visibility impairment than others. 

In July of 2004, MANE-VU submitted comments to EPA that included visibility 

impact analysis of a representative sample of EGUs across the country. Based on that 

representative sample, MANE-VU determined that the value of the maximum 24-hour 

impact relative to natural conditions that would include 98 percent of the cumulative 

visibility impact on MANE-VU sites was likely between 0.1 and 0.2 dv. However, this 

dataset was limited in that it only explored the relationship of EGUs and did not provide 

an indication of how the total frequency impact might change with numerous smaller, 

non-EGU, BART-eligible sources. With this new CALPUFF modeling data, we were 

able to repeat this analysis for the dataset that included all BART-eligible units in the 

region. This analysis remains limited that in that it includes only MANE-VU sources. It 

is likely that the additional sources from VISTAS and MWRPO would add to the total 

visibility impairment experienced at MANE-VU class I areas and, to some extent, to the 

top 98 percent of the visibility impacts. Without knowing the exact contribution of extraregional BART sources to impairment at our Class I sites, it is impossible to determine 

the cumulative 98th percentile frequency precisely. 

Notwithstanding this limitation, the results of this new analysis showed that 98 

percent of the cumulative frequency visibility impact from all MANE-VU BART-eligible 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 14

sources corresponds to a maximum 24-hr impact of 0.22 dv from the NWS-driven data 

and 0.29 dv from the MM5 data. We therefore concluded that a range of 0.2 to 0.3 dv 

would represent a “significant” impact at MANE-VU Class I areas on an average basis. 

Given the analysis and the limitation due to exclusion of sources outside of MANE-VU, 

we decided to place increased weight on sources with an individual visibility impact 

greater than 0.1 dv for this 1st order regional 5-factor analysis. This threshold is overly 

inclusive relative to exemption processes being conducted by other RPOs, but still 

provides MANE-VU states flexibility in choosing the weight to be given to the first of 

the five factors considered (i.e., the degree of visibility improvement that could result 

from BART). 

As an additional demonstration that sources whose impact were below the 0.1 dv 

level were too small to warrant BART controls, the entire MANE-VU population of these 

units was modeled together to examine their cumulative impacts on each Class I site. 

The result of this simulation showed that the maximum 24-hr impact at any Class I area 

of all modeled sources with individual impacts below 0.1 dv was only a 0.35 dv change 

relative to the estimated best days natural conditions at Acadia National Park. This value 

is below the 0.5 dv impact recommended by EPA for exemption modeling and we can be 

fairly certain that sources below the 0.1 dv level have very small individual impacts on 

visibility at Class I areas. 

Among the sources with a greater than 0.1 dv total impact at any Class I area were 

29 EGUs with 95 BART-eligible units that are located in states subject to CAIR. These 

CAIR-eligible EGU units may use the CAIR program to satisfy BART for SO2 and in 

most cases NOX BART. We did not consider these sources further with the exception of 

the three EGU sources (eight units) that had greater than 0.1 dv contribution for PM 

alone. These three EGU sources, along with 14 additional EGU sources in states that are 

not subject to CAIR (17 EGUs total), and 36 additional non-EGU sources with visibility 

impacts that may warrant BART controls are listed in Table 4-2 by type. 

Table 4-2. Types of sources in MANE-VU region with greater than 0.1 dv 

impact at any Class I area (non year-round CAIR states). 

Source Type Number of Sources

Number of 

Units/MM5* 

Chemical 

Manufacturer 1 3 

Coal Cleaning 1 1 

EGU 17 30 

Glass Fiber 1 6 

Incinerator 1 2 

Metal Production 2 7 

Paper and Pulp 12 30 

Portland Cement 12 25 

Refinery 5 37 

Total 53 142 

*Only MM5 Data were used for this analysis. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 15

4.2. Cost and Availability of Controls and Controls Already in Place 

The second and third steps of the MANE-VU five-factor analysis involved 

evaluating current controls at sources and costs of additional controls at these sources – 

factors (a) and (c) above. To address these factors, the list of these 53 highest impacting 

sources, including all the BART-eligible units at these sources (142 units), was sent out 

to state permitting staff for feedback on possible controls recommendations for these 

types of units and cost information for typical installation of these controls. Several 

states informed us that some of the eligible sources are subject to future controls under 

existing state regulations that will achieve “BART-like” levels of control. In these cases, 

we have listed the control level where applicable, or designated the control as “Currently 

Controlled” if the controls are already in place. Other states are considering a cost 

threshold to determine whether controls are feasible. If potential additional controls are 

above any known cost thresholds, then it is likely that a state would not feel that 

additional controls beyond those currently in place are warranted and we have therefore 

designated such units as “No Further Controls Warranted.” In situations where we did 

not have sufficient information to assess current or potential future controls, the unit has 

been designated as “No Known Further Controls.” In cases where other control programs 

such will satisfy BART, the control program is listed. Finally, we have listed the control 

technology as “No Known Further Controls” for BART-eligible sources where no 

information was available on possible control options. 

 NESCAUM compiled the available survey results provided by state staffs on 

expected or potential controls on these units and projected 2018 emissions from these 

units. Summaries of these results are found in Table 4-3 to Table 4-5. Cost information 

for various control options was obtained from a variety of sources including individual 

states, previous NESCAUM reports (NESCAUM, 2005), and other RPO analyses. Cost 

estimates from NESCAUM (2005) as well as the low, medium, and high cost 

designations described in the Tables 4.3-4.5 are summarized in Appendix B. Obviously, 

more detailed analysis of the cost of various control options will have to be conducted at 

the source-specific level by the states as they conduct source-specific BART 

determinations. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 16

Table 4-3. Possible range of SO2 controls and costs based on survey of state staff 

Type of 

Source 

Number 

of 

Sources Control Strategies 

Number of 

Emission Units 

Control Strategy 

May Apply 

Total 2002 

SO2 

Emissions 

Total 

Estimated 

Decrease in 

SO2 (tons/yr) 

Estimated Cost 

($/Ton SO2) Notes 

Chemical SO2 Scrubber 1 24000 9600 400-8000 Mid Range (1) 

Manufacturer 3 Currently Controlled 2 80 NA 0 

Glass Fiber 6 Currently Controlled 6 17 0 0 

Coal 

Cleaning 1 

No Known Further 

Controls 1 68 0 0 

Dry Scrubber 4 58000 52600 200-500 

Mid Range, 

assume 90% 

scrubber efficiency 

EGU/Coal 5 0.33 lb/MMBtu 1 4000 1200 NA 

0.3% fuel sulfur limit 3 1400 340 0 

Switch to 0.3% has 

already occurred 

for 3 boilers. 

0.56 lb/MMBtu 1 85 NA NA 

2.0 % Fuel Sulfur Limit 1 600 300 NA 

1.5% Fuel Sulfur Limit 1 5200 3900 NA 

0.33 lb/MMBtu 1 4000 3100 NA 

3.0 lb/MWh 5 31000 NA NA 

1.1-1.2 lb/MMBtu 2 480 NA NA 

EGU/Oil 

(Resid and 

Dist) 17 Currently Controlled 3 1200 0 0 

Incinerator 2 Currently Controlled 2 84 0 0 

No Further Controls 

Warranted 5 2200 0 0 

Metal 

Production 7 

Increased efficiency of 

the facility's wet 

scrubber 2 3000 300 Limited Cost Low Range 

FGD (SO2 Scrubber) 3 13000 11000 400-8000 Mid Range (1) 

1.8% Fuel Oil 2 6050 3000 NA 

2.0% Fuel Oil 1 2800 1400 NA 

No Known further 

controls 3 10000 0 0 Paper and 

Pulp 30 Currently Controlled 21 4000 0 0 

Fuel switching: CE of 

SOx 10% 3 2300 230 NA 

No Further Controls 

Warranted 5 3700 0 0 

No Known Further 

Controls 7 300 0 0 Portland 

Cement 25 SO2 Scrubber 10 26000 19000 400-8000 Mid Range (1) 

Refinery RACT 9 5400 NA 0 

SO2 Scrubber 3 NA NA 400-8000 Mid Range (1) 

Refinery 37 

No Known Further 

Controls 25 NA NA 0 

(1) Cost estimate from NESCAUM 2005 for Industrial Boilers 

NA- No information currently available.
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 17

Table 4-4. Possible range of NOX controls and costs based on survey of state staff 

Type of 

Source 

Number 

of 

Sources 

Control 

Strategies 

Number of 

Emission 

Units Control 

Strategy May 

Apply 

Total 2002 

NOx

Emissions 

Total 

Estimated 

Decrease in 

NOx (tons/yr) 

Estimated 

Cost ($/Ton 

NOx) Notes 

SCR 1 4900 3400 1300-10000 (2) 

Chemical 

Manufacturer 3 

Currently 

Controlled 2 5000 0 0 

Glass Fiber 6 

Currently 

Controlled 6 180 0 0 

Coal Cleaning 1 

Low NOx burners, 

CE of 15% 1 160 25 

1-2 Million 

(capital cost) Low Range 

Currently 

Controlled 2 2900 820 0 

SCR and 1.5 

lb/MWh 2 9800 NA 1000-1500 Mid Range (1) 

EGU/Coal 5 

NOx Budget & 1.5 

#/MWh 1 2300 NA NA 

Currently 

Controlled 6 3200 0 0 

No Known Controls 3 390 0 0 

NOx Budget 3 700 NA NA 

NOx Budget and 

1.5 lb/MWh 4 5300 NA NA 

EGU/Oil 17 SNCR, 1.5 lb/MWh 1 2400 NA 500-700 Mid Range (1) 

Incinerator 1 

Currently 

Controlled 2 720 0 NA 

2 

Currently 

Controlled 2 0 0 0 

Metal 

Production 5 

No Further 

Controls Warranted 5 110 0 0 

SCR or SNCR 2 710 430 1300-10000 

Mid to High Range 

(2) 

No Known Further 

Controls 13 4500 0 0 

Paper and Pulp 30 

Currently 

Controlled 15 4600 0 0 

Low NOx burners 3 2800 430 200-3000 Mid Range (3) 

Low NOx Burners 

and Mid Kiln Firing, 

40% Reduction 2 8500 3400 1200-10000 Mid Range (2)

SCR, 65% Red. 1 740 480 1300-10000 (2) 

No Known Further 

Controls 9 2000 0 0 

Currently 

Portland Controlled 1 1700 0 0 

Cement 25 SNCR 9 7100 2900 900-1200 Mid Range (3) 

Refinery RACT 9 2300 NA NA 

No Known Further 

Controls 25 0 0 0 

SCR 2 460 40 1300-10000 (2) 

Refinery 37 SNCR 1 1000 560 1300-10000 (2) 

(1) Cost estimate from NESCAUM 2005, EGU controls 

(2) Cost estimate from NESCAUM 2005, Industrial Boiler controls 

(3) Cost estimate from NESCAUM 2005, Portland Cement Kilns 

NA-No information currently available. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 18

Table 4-5. Possible range of PM10 controls and costs based on survey of state staff 

Type of 

Source 

Number of 

Sources 

Control 

Strategies 

Number of 

Emission Units 

Control Strategy 

May Apply 

Total 2002 

PM10 

Emissions 

Total 

Estimated 

Decrease in 

PM10 

(tons/yr) 

Estimated 

Cost ($/Ton 

PM10 ) Notes 

Chemical 

Manufacturer 3 

Currently 

Controlled 3 200 0 0 

Coal Cleaning 1 

No Known Further 

Controls 1 46 0 0 

Currently 

Controlled ESP 7 2000 0 0 

PM co-benefit 

reductions 

expected due to 

FGD-25-50% 

reduction 2 1500 370 0 

EGU/Coal 10 Baghouse 1 1500 NA $50 M Capital Cost 

EGU/Natural 

Gas 2 

Controls 

information 

included with 

oil/coal boilers 2 13 NA NA 

Currently 

Controlled 13 410 42 0 

EGU/Oil 18 

No Known Further 

Controls 5 50 0 0 

Incinerator 2 

Currently 

Controlled Fabric 

Filter 2 0 0 0 

Glass Fiber 6 

Currently 

Controlled 6 190 0 0 

Metal Production 7 

Currently 

Controlled 7 41 0 0 

Upgrade from ESP 

to baghouse, CE of 

4% estimate 2 180 7 $15 M Capital Cost 

No Known Further 

Controls 7 280 0 0 

Currently 

Controlled (ESP, 

Venturi Scrubbers, 

Demister, or 

MultiCyclones) 9 690 0 0 

Paper and Pulp 30 Current Controls 7 670 0 NA 

Upgrade on current 

ESP, CE of 5% 3 210 11 Limited Cost 

No Known Further 

Controls 15 300 0 0 

Currently 

Controlled 6 370 0 0 

Portland Cement 25 

Baghouse or 

electric precipitator 1 4 NA NA 

No Known Further 

Controls 28 NA 0 0 

Refinery 37 Refinery RACT 9 270 NA NA 

NA-No information currently available. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 19

Table 4-3 through Table 4-5 display general summary information from state 

surveys on possible BART control efforts as well as cost information gathered from 

several sources. The sections below will describe the contents of these tables in further 

detail. 

4.2.1. Chemical Manufacturers 

In the MANE-VU region, one chemical manufacturing source showed visibility 

impacts greater than 0.1 dv at a Class I area. At this source the state is considering SO2

scrubber installation at one boiler unit (emission unit containing three oil and coal fired 

boilers) that could result in a decrease of 9600 tons of SO2 emitted from this source 

annually. The State is also considering an installation of an SCR (Selective Catalytic 

Reduction) at this unit that could result in a decrease of 3400 tons of NOx emissions 

annually from the three boilers. This unit currently has an ESP installed for PM control 

which is expected to satisfy BART. 

4.2.2. Glass Fiber 

There is one glass fiber source in the region with a significant visibility impact on 

a Class I area in MANE-VU. Recent conversion from air/natural gas firing to 

oxygen/natural firing in 2000 has led to to an 85% reduction from the previous 

configuration which adequately satisfies BART. 

4.2.3. Coal Cleaning 

One coal cleaning source in the region showed a significant visibility impact at 

Class I areas. Low NOX burners for NOX control are considered a low-cost option for the 

thermal coal dryer unit at this source (Appendix B).. Additional control options for SO2

and PM may not be warranted based on a survey of state staff. Low NOX burners could 

result in approximately 24 tons of NOX reduced annually. 

4.2.4. Electric Generation Units 

Of the 58 EGUs modeled in the region, 40 sources are located in states 

implementing a year-round CAIR program, while 15 sources are located in states 

implementing an ozone season CAIR program. Units covered in a year-round CAIR 

program were removed from further SO2 and NOX analysis because BART would likely 

be satisfied through CAIR requirements. Visibility modeling was conducted for all 

EGUs in the region and of the 18 EGU sources in MANE-VU states without a year-round 

CAIR program under development, 13 showed a significant impact at Class I areas in the 

region. In addition, three sources in states with a year-round CAIR program showed a 

significant PM impact, and were included in the PM control and cost analysis. 

Coal-Fired Units 

States with coal-fired EGU units are considering two options for SO2 control; dry 

scrubber installation (a mid level cost option) and a 0.33 lb/mmBTU capacity limit. A 

dry scrubber could result in over 90 percent SO2 decrease while a capacity limit of 0.33 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 20

lb/mmBTU could result in a decrease of 1200 tons SO2 at one unit considering this 

option. 

In terms of NOX control, two boilers in the region have current controls of LowNOx concentric firing systems and SCR that are being considered sufficient for BART. 

Two units are looking at SCR controls to achieve a 1.5 lb/MWh emission rate, a mid 

level cost option for this source. One unit’s control level under the NOX Budget Program 

will simultaneously control for BART. 

The majority of coal-fired units at EGUs in the region are currently fit with ESPs 

and further PM control recommendations are not warranted. For the units without ESPs, 

one state was looking at baghouse installation as a possible option and another expects 

sufficient reductions due to a PM co-benefit from the installation of an FGD (Fluid Gas 

Desulfurization) scrubber for SO2 control. 

Oil-Fired Units 

The majority of BART-eligible oil-fired EGU boilers in the region were found in 

one state. For these units, input- and output-based capacity limits established under other 

programs for which the BART-eligible units were covered may satisfy SO2 BART 

control requirements. The levels of those programs are 0.56 and 1.1 lb/MMBtu for two 

different EGUs respectively, and 3.0 lb/MWh output-based limit for several other EGUs. 

Another control option being considered by other states is a fuel sulfur limit (0.3 

percent) or an equivalent 0.33 lb/MMBtu emissions rate. Four BART-eligible units in 

the region have been controlled at this level since 2002 and would consider this level of 

control appropriate for BART. This BART control option has reduced total SO2

emissions by 3100 tons annually at the one controlled sources, but is not anticipated to 

achieve as great a reduction at the other three BART-eligible sources, which are smaller. 

One unit is considering a 1.5 percent fuel sulfur limit that could result in approximately 

3900 tons (or approximately 75 percent reduction) of SO2 emissions from the one 

candidate for this option. We have no information on potential controls for two other 

BART-eligible units in the region. 

Regarding NOX controls on oil-fired boilers, possible technologies being 

considered for BART include SNCR (Selective Non-Catalytic Reduction) installation. 

Several units in the region are either currently controlled, with further controls considered 

unwarranted, or are under a NOX budget program that would serve as BART. Current 

controls on oil-fired boilers at EGUs include SNCR, boiler excess air control, and LowNOx burners. For several of these units, information on BART recommendations was 

unavailable. 

As with the coal-fired units, the majority of oil-fired boilers in the region have 

existing PM control technologies like ESPs, multicyclones, and mechanical collectors. 

4.2.5. Incinerators 

The lone BART-eligible incinerator source in the region has already achieved an 

approximately 75 percent reduction in SO2 emissions through the installation of a dry 

scrubber. This source already has SNCR NOX controls and reverse air fabric filters for 

PM controls and therefore further controls are not warranted. The air pollution controls 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 21

on this source are the same controls required by new municipal waste combustion 

facilities MACT requirements. 

4.2.6. Metal Production 

Two metal production sources consisting of seven BART eligible units showed 

significant visibility impact on the region For one source, the state was looking at low 

cost, better efficiency measures for the SO2 scrubber that would result in an increase of 

SO2 control efficiency by 10 percent at two aluminum ore reduction units. A preliminary 

cost analysis conducted by the state at another source showed that SO2 controls were not 

warranted at the sources BART eligible units (baking furnaces and potlines). The survey 

of state staff indicated that current controls for PM would likely satisfy BART for 

all metal production units in the region. Two units in the region are currently controlled 

for NOx while a cost analysis for NOx controls at 5 units indicated that no further 

controls were warranted. 

4.2.7. Paper and Pulp 

There are 30 eligible units at paper and pulp sources with significant visibility 

impact in the region. While the majority of these units are industrial boilers, this category 

also contains lime kilns, smelt tanks, and other process units. States are contemplating 

FGD scrubber installations for SO2 control for at least three industrial boiler units as 

possible BART control options. This is a mid-range cost technology for typical 

installations that could result in an estimated 20,000 fewer tons of SO2 for these three 

units alone. At three industrial boiler units, a fuel switching option is being considered 

by the state. Two boilers switching to 1.8% Sulfur fuel oil could result in 3000 tons of 

SO2 being reduced while one boiler switching to 2.0% sulfur fuel oil could result in 1400 

tons of SO2 reduced. Twenty-one units are currently controlled at a level such that 

existing controls are likely to satisfy BART, while no known further controls are 

expected for three units in this category. Current controls on these boiler units are 

generally wet scrubbers. 

For the majority of paper and pulp units, either the existing Low NOX burner 

controls or current capacity limits may satisfy BART or we did not have information 

about possible controls for units. Possible control options being considered for 

uncontrolled sources include SCR or SNCR technologies on boilers that could achieve 60 

to 80 percent NOX control. This is a mid to high cost control option, depending on the 

source. Installation of these technologies is estimated to result in a decrease of 430 tons 

of NOX emissions at two units considering this option. 

Most of the units at paper and pulp sources with significant visibility impacts in 

the region have existing PM controls including ESPs, baghouses, multicyclones, and 

venturi scrubbers and were therefore not viewed as candidates for further controls. One 

state is considering upgrading ESPs on two coal fired industrial boilers to baghouses that 

would result in a decrease of 7 tons of PM emitted per year. 

4.2.8. Portland Cement Plants 

Twenty-five Portland cement units in MANE-VU are located at BART-eligible 

sources with significant visibility impacts on Class I areas in the region. At these 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 22

sources, states are considering installation of SO2 scrubbers at 10 cement kilns at these 

sources, which would significantly reduce the amount of SO2 emitted from this sector. If 

installed, scrubbers at these kilns would result in a decrease in emissions of 19,000 tons 

of SO2 annually. 

Another BART control option being considered for cement kilns in the region is 

fuel switching. Units considering this option for kilns could decrease annual SO2

emissions by 230 tons. Twelve units in this sector either have existing controls that will 

likely satisfy BART, or control information for SO2 is currently unknown. 

Control technologies under consideration for NOX at cement plants were varied 

according to our survey information. Low NOX burners are a possible control option for 

uncontrolled cement kilns. This is a mid range cost option that could result in an annual 

decrease of 430 tons of NOX emitted from three units. Another possible control option is 

Low NOX burners with mid-kiln firing. At a mid level cost, this technology could result 

in a decrease of 3400 annual tons of NOX emissions at units where this option is 

applicable. SCR installation is being considered at one unit, also a mid level cost option 

that could decrease emissions from unit by 480 tons annually. SNCR control technology 

is a mid level cost option, which if in place at units considering this option, could result 

in a decrease of 2900 tons of NOX emissions. Ten of the 25 units in this category either 

have existing controls that will likely satisfy BART or controls for NOX are currently 

unknown. 

Most of the units at these Portland cement plants either have existing PM controls 

or potential control information is unknown. Where no controls exist, possible control 

options include installation of a baghouse or an ESP. One state is considering a 

recommendation of upgrading ESPs at three units, a low cost option that would reduce 

annual emissions of PM by 11 tons. 

4.2.9. Refineries 

At this time, for the majority of the units in this category, control information is 

unknown. One possible control option for SO2 is installation of a scrubber on fluid 

catalytic cracking units, a mid range cost option being considered for three units in the 

region. Nine of these units are currently subject to refinery RACT (Reasonably Available 

Control Technology) controls for 8-hour ozone and these control levels for SO2, NOX, 

and PM are likely to satisfy BART requirements. States are also considering SCR or 

SNCR controls for three fluid catalytic cracking units in the region for possible NOX

control, also a mid level cost option. 

4.3. Energy and Non-Air Quality Environmental Impacts 

While there are certain to be several issues that arise on a source-specific basis 

with respect to individual control technologies (e.g., water quality impacts or solid waste 

disposal issues), we are unable to address these issues in a regional analysis. One 

environmental benefit that should be considered in weighing control options for BART is 

the regional impact on acid deposition in MANE-VU. 

An analysis of combined SO2 and NOX reduction potential of BART control 

options by sector showed similar results for EGUs and paper and pulp sources. Figure 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 23

4-1 shows the amount of SO2 and NOX that could be reduced if BART control options 

were implemented at the units for which likely control options are known. Figure 4-1 

shows that generally, when emission reduction options are known, the emissions 

reduction potential is evenly distributed across the range of sources in the region. This is 

important as states are weighing whether controls are warranted or not for EGUs or paper 

and pulp boilers. However, for the majority of units with significant visibility impact in 

these sectors, the amount of SO2 and NOX reduction potential is currently unknown, 

limiting the power of this analysis. 

Figure 4-1. Reduction potential of BART control options at 

EGUs and Paper and Pulp Sources 

0

2

4

6

8

10

12

14

16

18

20

Unknown <1000 1000-3000 3000-5000 >5000

Combined Tons SO2 and NOx Reduced by BART Control Options

Number of Units

EGUs

Paper and Pulp

For Portland cement plants, possible emissions reduction data were more 

complete and allowed for a clearer analysis of SO2 and NOX control. Figure 4-2 shows 

the emissions reduction potential that would be achieved by BART if the survey control 

options were implemented for units in this sector. While several units would benefit 

from BART control options with emissions being reduced by greater than 3,000 tons of 

combined SO2 and NOX, the majority of the cement plant units would reduce emissions 

by less than 1,000 tons. As states weigh whether additional controls are warranted for 

cement plants, this non air-quality environmental factor may play less of a role for these 

sources. 

For other source categories, the statistics are generally too small to make an 

analysis meaningful, but as a general rule, the remaining source categories tend to have 

lower overall emissions and lower overall reduction potential, which may factor into 

control decisions accordingly. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 24

Figure 4-2. Reduction potential of BART control options at Cement Plants 

0

2

4

6

8

10

12

Unknown <1000 1000-3000 3000-5000 >5000

Combined Tons SO2 and NOx Reduced by BART Control Options

Number of Units

Cement Plants

4.4. Remaining Useful Life 

The MANE-VU BART Workgroup has considered what weight to give to this 

factor in conducting BART determinations and has recommended that remaining useful 

life of a source will be addressed in the following way. A BART-eligible source that is 

found to have reasonable control options available to it should either control emissions 

from that BART-eligible source prior to 2013 or accept a federally enforceable permit 

limitation or retirement date prior to each state’s public notice and hearing processes and 

FLM review of BART SIP elements.

5. CONCLUSIONS 

As MANE-VU states prepare to conduct source-specific BART determinations 

for the eligible units in their jurisdictions, this report provides a regional assessment of 

the five factors that must be considered in determining whether additional controls are 

warranted for an individual BART source. This information is intended to lay out a 

regional approach and provide regional context for individual control decisions that will 

be made by the MANE-VU member states. This information may also serve as an 

important regional basis for dialogue and internal MANE-VU consultations as states 

consider what level of stringency is justified and reasonable based on consideration of the 

five factors. 

Important findings of this analysis include the identification of BART-eligible 

sources in the region, the numbers of units in various categories subject to BART 

consideration, BART control technology options being considered in the region, and 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 25

estimates of the total emissions and reduction potential from units contributing to 

potentially significant visibility impacts at Class I areas. 

Table 4-1 and Table 4-2 indicate that 136 BART-eligible sources exist in the 

region with 53 contributing to potentially significant visibility impairment at a Class I 

area. The majority of BART-eligible sources in the region are EGUs, however, most of 

these sources fall under a year-round CAIR program that will satisfy BART. 

Of the BART-eligible source categories with potentially significant visibility 

impacts, the non-CAIR EGU sector was the largest emitter of SO2, NOX, and PM10 in 

2002. BART-eligible EGUs with significant visibility impacts included 17 sources with 

30 units emitting 110,000 tons SO2, 28,000 tons NOX, and 7,000 tons PM10 in 2002. The 

majority of these units are anticipating controls for SO2 and NOX to satisfy BART 

requirements. Although the amount of expected reductions is currently unknown, we can 

expect significant reductions in emissions from this sector given widely available control 

technologies for SO2 and NOX with proven cost-effectiveness. Most of these units are 

currently controlled for particulate matter and further controls are not expected. 

Portland cement plants and paper and pulp sources are sectors with many BARTeligible units that made significant contributions to visibility impairment and total 

pollutant emissions in the region. Paper and pulp sources with significant visibility 

impacts emitted 36,000 tons SO2, 10,000 tons NOX, and 2,000 ton PM10 at 30 units in 

2002. Although information on controls is currently unknown for many of these units, 

information from units considering controls indicates that significant reductions can be 

achieved from this sector (19,000 tons SO2 reduced if scrubbers are installed at 13 units 

and 400 tons NOX reduced if SCR controls are introduced to two units). Portland cement 

sources with significant visibility impacts emitted 32,000 tons SO2, 23,000 tons NOX, and 

850 tons PM10 at 25 units in the region. With more complete information for cement 

plants, we estimated a reduction of 19,000 tons SO2 at 13 units and 7,000 tons NOX at 15 

units when considering controls that would satisfy BART. 

Ultimately, the strength of the MANE-VU BART program, as determined by 

individual state control decisions and informed by this analysis, will demonstrate MANEVU’s resolve to tackle visibility and related air quality problems in its region. As 

MANE-VU enters into inter-RPO consultations, its willingness to seek reasonable 

emission reductions within its own region will help set expectations for the other RPOs, 

and the BART program represents a cornerstone of this process. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 26

6. REFERENCES 

MM5 website http://www.mmm.ucar.edu/mm5/

NESCAUM. 2005. Assessment of Control Technology Options for BART-Eligible 

Sources. Available at: http://www.nescaum.org/documents/bart-control-assessment.pdf/

NESCAUM. 2006a. BART Resource Guide. Available at: 

http://www.nescaum.org/documents/bart-resource-guide/bart-resource-guide-08-23-06-

final.pdf/

NESCAUM. 2003. Technical Memorandum #6. Development of a List of BARTEligible Sources in the MANE-VU Region: Interim Report. Available at: 

http://www.nescaum.org/documents/memo6-bart.pdf/

NESCAUM. 2006b. Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States. Appendix D: Development of Parallel CALPUFF Dispersion Modeling 

Platforms for Sulfate Source Attribution Studies in the Northeast U.S. Available at: 

http://www.nescaum.org/documents/contributions-to-regional-haze-in-the-northeast-andmid-atlantic--united-states/appendixd--2006-0831.pdf/

NESCAUM. 2001. A Basis for Control of BART-Eligible Sources. Available at: 

http://www.nescaum.org/documents/a-basis-for-control-of-bart-eligiblesources/basis.pdf/
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 27

Appendix A: List of BART-Eligible Sources in the 

MANE-VU Region 

State Plant Type 

Number 

of Units 

CT Middletown Power LLC (NRG) EGU 2

CT Montville Power LLC (NRG) EGU 1

CT Norwalk Power LLC (NRG) EGU 1

CT PSEG Power CT Bridgeport Harbor Station EGU 1

CT PSEG Power CT New Haven Harbor Station EGU 1

CT Sprague Paperboard Caraustar 

Fossil Fuel Boiler 

(>250 MMBtu 1

DC Benning (PEPCO -15) EGU 1

DC Benning (PEPCO -16) EGU 1

DE City of Dover - Mckee Run EGU 1

DE Connectiv Edgemore EGU 2

DE NRG- Indian River EGU 1

MA Exxon Mobil Everett Petroleum Storage 1

MA Global Petroleum Revere Petroleum Storage 1

MA Gulf Oil Chelsea Petroleum Storage 1

MA Solutia 

Chemical Process 

Plant 3

MA Braintree Electric EGU 1

MA Brayton Point EGU 4

MA Eastman Gelatin (boilers only) 

Chemical Process 

Plant/Industrial 

Boilers 4

MA General Electric Lynn EGU 1

MA Harvard U (Blackstone) EGU 2

MA Mirant Kendall LLC EGU 3

MA Mirant-Canal Electric EGU 2

MA Mystic EGU 1

MA New Boston EGU 1

MA Salem Harbor EGU 1

MA TMLP - Cleary Flood EGU 3

MA Trigen - Kneeland St EGU 1

MA Wheelabrator -Saugus 

Municipal 

Incinerator 2

MD CONSTELLATION POWER SOURCE GENERATION CP CRANE EGU 7

MD 

CONSTELLATION POWER SOURCE GENERATION HERBERT 

WAGNER EGU 2

MD EASTALCO ALUMINUM 

Primary Aluminum 

Ore Reduction Plant 2

MD INDEPENDENT CEMENT ST LAWERENCE Portland Cement 1

MD LEHIGH PORTLAND CEMENT Portland Cement 3
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 28

MD METTIKI COAL CORPORATION Coal Cleaning 1

MD MILLENIUM INORGANIC CHEMICALS 

Chemical Process 

Plants 5

MD MIRANT MID ATLANTIC LLC MORGANTOWN EGU 2

MD MIRANT MID ATLANTIC DICKERSON EGU 1

MD PEPCO CHALK POINT EGU 3

MD TRIGEN LEADENHALL STREET 

Fossil Fuel Boiler 

(>250 MMBtu 4

MD VIENNA GENERATING STATION EGU 1

MD WESTVACO FINE PAPERS 

Kraft Pulp Mill/Fossil 

Fuel Boiler (>250 

MMBtu 3

ME Domtar Ind 

Industrial 

Boiler/Kraft Pulp Mill 2

ME Dragon Products Portland Cement 1

ME Georgia Pacific Old Town 

Industrial 

Boiler/Kraft Pulp Mill 2

ME IP Bucksport 

Fossil Fuel Boiler 

(>250 MMBtu 1

ME IP Jay 

Industrial Boiler/ 

Kraft Pulp Mill 9

ME Katahdin Paper Millinocket 

Fossil Fuel Boiler 

(>250 MMBtu 1

ME Lincoln Paper and Tissue 

Industrial 

Boiler/Kraft Pulp Mill 2

ME Rumford Paper Industrial Boiler 1

ME SAPPI Somerset 

Industrial 

Boiler/Kraft Pulp Mill 4

ME Wyman Station EGU 2

NH PSNH Merrimack Station EGU 1

NH PSNH Newington Station EGU 1

NJ Amerada Hess Corporation-Port Reading Re Petroleum Refinery 13

NJ Bayway Refinery Petroleum Refinery 257

NJ Chevron Products Company Petroleum Refinery 22

NJ COASTAL EAGLE POINT OIL COMPANY Petroleum Refinery 145

NJ Hudson Generation Station EGU 4

NY 3M TONAWANDA 

Chemical Process 

Plants/Industrial 

Boilers 4

NY ALCAN ALUMINUM CORPORATION 

Primary and 

Secondary 

Aluminum 

Production 9

NY ALCOA MASSENA OPERATIONS (WEST PLANT) 

Primary and 

Secondary 

Aluminum 

Production 25

NY ARTHUR KILL GENERATING STATION EGU 2

NY ASTORIA GENERATING STATION EGU 2

NY BOWLINE POINT GENERATING STATION EGU 5
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 29

NY BUFFALO COLOR CORP - LEE ST PLANT 

Chemical Process 

Plants/Industrial 

Boilers 5

NY CON ED-59TH ST STA EGU 4

NY DANSKAMMER GENERATING STATION EGU 2

NY EF BARRETT POWER STATION EGU 44

NY ERWIN MANUFACTURING COMPLEX 

Glass Fiber 

Processing Plants 3

NY GENERAL ELECTRIC SELKIRK PLASTICS PLT 

Chemical Process 

Plants/Industrial 

Boilers 16

NY GLENS FALLS LEHIGH CEMENT COMPANY Portland Cement 46

NY INTERFACE SOLUTIONS INC 

Kraft Pulp 

Mill/Industrial 

Boilers 9

NY INTERNATIONAL PAPER TICONDEROGA MILL 

Kraft Pulp 

Mill/Industrial 

Boilers 11

NY KODAK PARK DIVISION 

Chemical Process 

Plants/Industrial 

Boilers 20

NY LACKAWANNA PLANT- REPUBLIC ENG PROD INC 

Primary Metal 

Production/Industrial 

Boilers 3

NY LAFARGE BUILDING MATERIALS INC Portland Cement 31

NY LOVETT GENERATING STATION EGU 4

NY NORTHPORT POWER STATION EGU 17

NY OSWEGO HARBOR POWER EGU 3

NY OWENS-CORNING DELMAR PLANT 

Glass Fiber 

Processing Plants 27

NY RAVENSWOOD GENERATING STATION EGU 60

NY REVERE SMELTING & REFINING CORP 

Primary Metal 

Production/Industrial 

Boilers 8

NY RIVERBAY CORP-CO-OP CITY Industrial Boilers 4

NY RIVERHEAD TERMINAL-CONOCOPHILLIPS 

Petroleum 

Storage/Industrial 

Boilers 7

NY ROSETON GENERATING STATION EGU 4

NY SAMUEL A CARLSON GENERATING STATION EGU 2

NY SCHENECTADY INTERNATIONAL ROTT JCT FAC 

Chemical 

Plant/Industrial 

Boilers 18

NY ST LAWRENCE CEMENT CORP-CATSKILL QUARRY Portland Cement 37

NY WASHINGTON MILLS ELECTRO MINERALS 

Glass Fiber 

Processing Plants 3

PA ALLEGHENY_LUDLUM_CORP_BRACKENRIDGE EGU 8

PA EASTMAN_CHEMICAL_RESINS_INC 

Chemical Process 

Plants/Industrial 

Boilers 2

PA ESSROC/BESSEMER Portland Cement 14
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 30

PA NEVILLE_CHEMICAL_COMPANY 

Chemical Process 

Plants 5

PA ORION_POWER_MIDWEST_CHESWICK_STATION EGU 2

PA USS_CLAIRTON_WORKS 

Metal 

Production/Industrial 

Boilers 4

PA AK STEEL CORP BUTLER WORKS 

Iron and Steel Mill 

Plants 16

PA ALLEGHENY ENERGY SUPPLY CO HATFIELDS FER EGU 5

PA ALLEGHENY ENERGY SUPPLY CO MITCHELL POWE EGU 19

PA AMER REF GROUP BRADFORD Petroleum Refinery 4

PA APPLETON PAPERS SPRING MILL 

Kraft Pulp 

Mill/Industrial 

Boilers 9

PA CARMEUSE LIME INC MILLARD LIME PLT Lime Plant 8

PA CEMEX INC WAMPUM CEMENT PLT Portland Cement 9

PA CONOCOPHILLIPS CO TRAINER REF Petroleum Refinery 10

PA DUFERCO FARRELL CORP FARRELL PLT 

Iron and Steel Mill 

Plants 1

PA DYNO NOBEL INC DONORA 

Chemical Process 

Plants 9

PA ESSROC NAZARETH LOWER CEMENT PLT 1 Portland Cement 1

PA EXELON GENERATION CO EDDYSTONE EGU 6

PA EXIDE TECH READING SMELTER 

Secondary Metal 

Production 9

PA HOMER CITY OL HOMER CITY GEN STA EGU 6

PA HORSEHEAD CORP MONACA SMELTER 

Primary Zinc 

Smelter 25

PA INDSPEC CHEM CORP PETROLIA 

Chemical Process 

Plants 17

PA INMETCO ELLWOOD CITY 

Iron and Steel Mill 

Plants 6

PA ISG PLATE LLC COATESVILLE 

Iron and Steel Mill 

Plants 20

PA KEYSTONE PORTLAND CEMENT EAST ALLEN Portland Cement 4

PA LAFARGE CORP WHITEHALL PLT Portland Cement 28

PA LEHIGH CEMENT CO EVANSVILLE CEMENT PLT Portland Cement 42

PA LEHIGH CEMENT CO YORK OPERATIONS Portland Cement 11

PA LWB REFRACTORIES CO W MANCHESTER Mineral Products 13

PA MERCER LIME & STONE BRANCHTON Lime Plant 6

PA NEW CASTLE POWER PLT EGU 2

PA PA POWER CO BRUCE MANSFIELD PLT EGU 18

PA PH GLATFELTER CO SPRING GROVE 

Paper and 

Pulp/Industrial 

Boilers 8

PA PPL BRUNNER ISLAND L BRUNNER ISLAND EGU 4

PA PPL MARTINS CREEK LLC MARTINS CREEK EGU 2

PA PPL MONTOUR LLC MONTOUR SES EGU 4

PA RELIANT ENERGY NORTHEAST CONEMAUGH PLT EGU 6

PA RELIANT ENERGY NORTHEAST MGMT KEYSTONE POWER PLT EGU 2

PA RELIANT ENERGY PORTLAND GENERATING STATION EGU 2

PA SUNOCO CHEMICALS (FORMER ALLIED SIGNAL) Chemical Process 17
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 31

Plants 

PA SUNOCO INC (R&M) MARCUS HOOK REFINERY Refinery 10

PA SUNOCO INC (R&M) Refinery 26

PA TRIGEN - EDISON EGU 4

PA TRIGEN - SCHUYLKILL EGU 1

PA UNITED REFINING CO WARREN PLT Refinery 10

PA VICTAULIC CO AMER FORKS FACILITY 

Secondary Metal 

Production 12
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 32

Appendix B: Costs of Technologies 

From NESCAUM, 2005. 

 

EGU Cost Effectiveness 

Pollutant Control Cost Units Cost Bin 

SO2 Wet/Dry Scrubbers (FGD) 200-500 Dollars per ton SO2 Low 

NOx Gas Reburn 500-2000 Dollars per ton NOx Mid 

NOx Low-NOx Burners 200-500 Dollars per ton NOx Low 

NOx Overfire Air 250-600 Dollars per ton NOx Low 

NOx SCR 1000-1500 Dollars per ton NOx Mid 

NOx SNCR 500-700 Dollars per ton NOx Mid 

PM ESP 15-40 Dollars per Actual Cubic Feet per 

Minute 

PM Fabric Filters 12-40 Dollars per Actual Cubic Feet per 

Minute 

 

Industrial Boilers Cost Effectiveness 

Pollutant Control Cost Units Cost Bin 

NOx Low NOx-Burners 200-3000 Dollars per ton NOx Mid 

NOx SNCR 1300-

10000 

Dollars per ton NOx Mid to 

High 

NOx SCR 4000-

15000 

dollars per MMBtu/hr 

High 

SO2 Wet/Dry Scrubbers 400-4000 Dollars per ton SO2 (coal) Mid 

SO2 Wet/Dry Scrubbers 800-8000 Dollars per ton SO2 (oil) Mid to 

High 

PM ESP 15-40 Dollars per Actual Cubic Feet per 

Minute 

PM Reverse Air Fabric Filter 15-40 Dollars per Actual Cubic Feet per 

Minute 

PM Pule Jet Fabric Filter 17-40 Dollars per Actual Cubic Feet per 

Minute 

PM Venturi Scrubber 12-40 Dollars per Actual Cubic Feet per 

Minute 

PM Cyclone 1-5 Dollars per Actual Cubic Feet per 

Minute 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 33

 

Portland Cement Kilns Cost Effectiveness 

Pollutant Control Cost Units Cost Bin 

SO2 Spray Dryer 10.96-54.67 dollars/ton Clinker 

SO2 Wet Scrubber 10.83-47.00 dollars/ton Clinker 

NOx Process Modifications 3100-8800 Dollars per ton NOx Mid to High 

NOx Low NOx Burners 

w/Indirect Firing 

5800-8100 Dollars per ton NOx High 

NOx Low NOx Burners 

w/Indirect Firing and MidKiln Tire Injection 

1-1800 Dollars per ton NOx Low to Mid 

NOx Mid-Kiln Injection of Fuel 5100-11500 Dollars per ton NOx Mid to High 

NOx CemStar 0-600 Dollars per ton NOx Low 

NOx Low NOx Precalciner 2700-3600 Dollars per ton NOx Mid 

NOx SNCR 900-1200 Dollars per ton NOx Mid 

NOx Biosolids Injection 100-1800 Dollars per ton NOx Low to Mid 

PM ESP 3.33-41.00 dollars/ton clinker 

PM Baghouse 4.00-16.67 dollars/ton clinker 

 

Paper and Pulp 

Cost Effectiveness Not Available 

 

Cost levels SO2 NOx 

Low <800 <500 

Mid 800-2000 500-10000 

High >2000 >10000 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 34

Appendix C: BART Workgroup Draft 

Recommendations 

Draft BART Recommendations 

to MANE-VU Air Directors 

September 7, 2006

Under the U.S. Environmental Protection Agency’s (USEPA) 1999 “regional 

haze rule” [64 Fed. Reg. 35714 (July 1, 1999)], certain emission sources that “may 

reasonably be anticipated to cause or contribute” to visibility impairment in downwind 

Class I areas are required to install Best Available Retrofit Technology (BART).6 These 

requirements are intended to reduce emissions specifically from large sources that, due to 

age, were exempted from other control requirements of the Clean Air Act (CAA). 

BART requirements pertain to 26 specified major point source categories, 

including power plants, industrial boilers, paper and pulp plants, cement kilns and other 

large stationary sources. To be considered BART-eligible, sources from these specified 

categories must have the potential to emit at least 250 tons per year of any haze forming 

pollutant and must have commenced operation in the fifteen year period prior to August 

7, 1977 (the date of passage of the 1977 Clean Air Act Amendments (CAAA), which first 

required new source performance standards). 

 MANE-VU formed the BART workgroup as part of an effort to assist states and 

tribes as they prepare to comply with the Best Available Retrofit Technology 

Requirements (BART) of the Regional Haze Rule. To date states have made substantial 

progress in identifying sources that are BART-eligible, however that is only the first step 

in the process. Once a source is identified as “BART eligible”, an analysis must be 

conducted to determine what will constitute BART control levels. The Haze Rule 

requires states to determine the most stringent technologically feasible system of controls 

that can reasonably be installed at each source eligible for BART. The BART workgroup 

has developed a list of draft recommendations for the BART control process that will be 

submitted to the MANE-VU Directors. Feedback on these recommendations will be 

useful to assist the Air Directors in their review. The recommendations include overall 

BART policies and specific “presumptive” levels and types of control. These 

recommendations will serve as a regional foundation for conducting BART engineering 

reviews on a state-by-state basis. The workgroup recommendations are presented below: 

1. Any BART-eligible facility may “cap-out” of BART via a permit emission limit, 

however all permit modifications must be finalized prior to December 16, 2006* 

in order to eliminate BART-eligibility. Caps must limit emissions from BART 

eligible units below 250 tons per year of any visibility impairing pollutant 

 

6

 There are seven designated Class I areas in the Northeast and Mid-Atlantic States. They include Acadia 

National Park and Moosehorn Wilderness Area in Maine; Roosevelt-Campobello International Park in New 

Brunswick and Maine; the Lye Brook Wilderness Area in Vermont; the Great Gulf and Presidential RangeDry River Wilderness Areas in New Hampshire; and the Brigantine Wilderness Area in New Jersey. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 35

 * It is not clear from the final rule when a federally enforceable permit limitation 

 would need to be in place in order to avoid BART-eligibility. We are 

 recommending to EPA that they allow permit limits which go into place prior to 

 December 16, 2006. This will enable states to take action to get permit 

 limitations in place and achieve emission limits (though probably not reductions) 

 prior to SIP submission avoiding the need for formal BART determinations. The 

 2006 date will give states one full year prior to the submission deadline for public 

 notice and hearing processes on a final SIP package. 

2. MANE-VU staff continues to support the policy decision made by the MANEVU Board in June 2004, that if a source is eligible for BART, it is subject to 

BART. (i.e. no exemptions will be given). 

3. Regional performance standards or cost thresholds are appropriate for many 

individual categories of BART eligible sources. The attachment contains an 

initial round of recommended presumptive levels of control for EGUs, industrial 

boilers and cement kilns. The workgroup may develop additional presumptive 

levels in the future. 

4. Remaining useful life of a source will be considered in the following way:

Sources have the option to either control a BART-eligible facility prior to 2013 

or accept federally enforceable permit limitation or retirement date prior to 

December 16, 2006. 

5. Control technology in place (other than for source categories covered by the 

attached list of presumptive control levels) will likely have to be dealt with on a 

source by source basis. (i.e. no regional recommendation) 

6. Energy and non-air quality environmental impacts will likely have to be dealt 

with on a source by source basis. (i.e. no regional recommendation) however the 

workgroup is still considering regional recommendations for non-air quality 

environmental impacts. 

7. If data does not exist to accurately determine the installation date for emission 

unit(s)within a facility then the unit will be treated as though it IS within the 

BART date range unless the facility can provide proof otherwise (i.e., proof that 

the unit was in operation prior to 1962). Many states are having difficulty 

identifying installation dates for pre-1977 units. All states felt they could easily 

identify post-1977 units. Therefore, the workgroup supported a policy position 

that when the state could not accurately determine the "in existence" date, the 

burden of proof lay with the facility in proving that the unit was installed prior to 

1962. 
DRAFT – Five-Factor Analysis of BART-Eligible Sources Page 36

MANE-VU BART Workgroup Recommendations 

DRAFT Presumptive Control Levels 

*Updated September 7, 2006* 

Non-CAIR EGUs:

• SO2 – Coal - 95% control or 0.15 lb/MMBtu* 

 Oil - 95% control or 0.33 lb/MMBtu (0.3% sulfur content)* 

• NOX 

o in NOX SIP call area, extend use of controls to year-round 

o 0.1 – 0.25 lb/MMBtu, depending on boiler and fuel type 

• PM – 0.02 – 0.04 lb/MMBtu** 

 

CAIR EGUs:

• SO2 – CAIR requirements 

• NOX – CAIR requirements 

• PM – 0.02- 0.04 lb/MMBtu** 

If an EGU is only enrolled in CAIR for one or two pollutants, it still must complete an 

analysis for the remaining visibility impairing pollutants such as particulate matter. 

Industrial Boilers 

• SO2 – 90% control, MACT acid gas control level, ICI-RACT, or 0.55 lb/MMBtu 

(0.5% fuel sulfur limit) 

• NOX 

o 0.1 – 0.4 lb/MMBtu, depending on boiler and fuel type*** 

• PM – 0.02 - 0.07 lb/MMBtu 

Cement Kilns

No common emission threshold has been identified. The following lists, however, 

recommend control technologies to evaluate. 

• SO2 

o in process removal 

o wet or dry scrubbers 

o conversion from wet kiln to dry kiln 

• NOX 

o Combustion optimization 

o Low NOX burners 

o Secondary combustion control (SNCR/SCR) 

o Mid-Kiln firing 

o Flame shape adjustment 

• PM 

o baghouse 

o electrostatic precipitator 

o baghouse/ESP upgrades of existing controls 

*Consistent with EPA presumptive BART for EGUs and OTC Control Strategy 

** PM measures are based on front-half (Method 5) particulate matter measures 

*** Consistent with OTC Control Strategies and NOX SIP call emission limits