New York State Department of Environmental Conservation

Best Available Retrofit Technology Determination

Facility Ravenswood Steam Plant

Location Queens, NY
Queens County

Permit ID 2-6304-01378

Source Category Fossil-fuel boilers of more than 250 mmBtu/hr heat input

I. Introduction

The above referenced facility contains at least one emission source that falls under the requirements of the federal Best Available Retr ofit Technology (BART) rule under 40 CFR Part 51 and Appendix Y, and the New York State BA RT regulation as codified under 6 NYCRR Part 249. These requirements affect an emission s ource which fulfills the following criteria:

1. Falls within one of 26 sp ecific source categories,

2. Was not in operation prior to August 7, 1962 and was in existence on August 7, 1977, or

underwent reconstruction between August 7, 1962 and August 7, 1977, and

3. Has a potential to emit (collectively, with ot her emission sources at the facility which fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant.

In accordance with BART requirements, each BART-eligible facility performed a BART analysis of controls for sulfur dioxide, nitrogen oxides and particul ate matter. This analysis took

into account such factors as the cost of c ontrols, energy and non-air quality environmental impacts of compliance, any existing pollution co ntrol technology in use at the source, the remaining useful life of the source, and the de gree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

This document summarizes the reasoning be hind the Department’s BART determination, including the level of cont rols and emission limits that constitute BART for this facility’s eligible emission source(s). Each analysis and BART determination was submitted to the Federal Land Managers (FLMs) for their review in accordance with Regional Haze State Implementation Plan (SIP) requirements. Comments received from the FLMs on this determination will be included

with its official submission to the U.S. Environmental Protection Agency (EPA).

The Department has modified this facility’s Title V permit to include the enforceable BART

limits. The modifications were noticed in New York State’s Environmental Notice Bulletin on December 28, 2011. Upon completion of this pub lic notice period, the modified permit was submitted to EPA for review on January 31, 2012. The final modified permit was issued on March 20, 2012. This permit is now being submitt ed to EPA as a revision to the New York Regional Haze SIP.II. BART Analysis Summary

Consolidated Edison (Con Ed) conducted the BART analysis, dated September, 2010, for the Ravenswood Steam Plant. The following emissi on source had previously been identified as BART-eligible and was therefore included in the analysis:

Steam Plant Boiler No. 2 – Emission Unit UBLR24; Emission Source ESAH2

• This unit is a front wall-fired Babcock & Wilcox boiler with a design maximum heat input capacity of 424 mmBtu/hr. This unit bu rns low sulfur No. 6 fuel oil (0.3 percent sulfur by weight) as the primary fuel, with natural gas being used for ignition. It was

installed in 1962. This boiler is a steam-only boiler that doe s not produce electricity, and

follows steam load which results in limite d operation and signifi cant unused capacity.

A summary of the analysis’ findings for each pollutant follows:

• SO 2

Under the low-sulfur fuel oil standard s contained in 6 NYCRR Part 225-1, the Ravenswood Steam Plant has a permit condition that limits the maximum sulfur content of the fuel oil to 0.3 percent by weight for Boile r No. 2. Con Ed notes that this low-sulfur fuel is below the 1.0 percent sulfur limit in oil referenced by the Appendix Y guidance. Con Ed therefore requests that the current use of low-sulfur fuel be considered BART for

SO 2

.

• NO

x

Con Ed identified seven potential BART control technologies for NO

x for Boiler No. 2. The following table lists the options identified, with technically infeas ible options crossed out. For the options that remain feasible, the expected control efficiency has been provided along with the cost -effectiveness values under fu ll operation and expected operation.

NOx Control Option Control Efficiency Cost Effectiveness, 8,760hr/yr ($/ton) Cost Effectiveness,
Expected Operation ($/ton)

Ultra Low NOx Burners N/A N/A N/A

Water Injection N/A N/A N/A

Low NOx Burners 15% $24,763 $151,828

Flue Gas Recirculation (FGR) 10% $12,218 $74,910

Selective Catalytic Reduction (SCR) 47% $14,403 $88,310

Selective Non

‐ Catalytic Reduction (SNCR) 20% $21,464 $131,600

Overfire Air (OFA) 25% $30,295 $185,743

All potential control options fo r Boiler No. 2 are deemed economically infeasible when considering the $5,500 per ton threshold es tablished by the Department for BART, whether under full operation or anticipated operation. Aside from being cost-prohibitiveon a dollar-per-ton basis, Con Ed also incl udes visibility modeling results for the Ravenswood Steam Plant (Tables 3-3 and 3-4) which indicate minimal improvement in downwind visibility conditions, in the range of 0.01 to 0.02 deciviews, resulting from an assumed 30 percent NO

x reduction.

Con Ed therefore recommends that no further controls are necessary to fulfill BART for

NO

x for Boiler No. 2.

• PM

Con Ed identified three potential add-on cont rol technologies for PM at the Ravenswood Steam Plant: an electrostatic precipitator (ESP) , a fabric filter/baghous e, and a cyclone. In each case, Con Ed notes that the c ontrol technology does not appear to be demonstrated in practice for a utility boiler th at burns oil as the primary fuel. Con Ed therefore deems each as technically infeasible.

Con Ed requests that curren t operations be determined as BART for PM. Good combustion practices and the use of low sulfur fuel serve to minimize PM emissions from

Ravenswood Steam Plant Boiler No. 2.

III. BART Determination

The Department finds that the following sha ll constitute BART for Ravenswood Steam Plant

Boiler No. 2:

• SO 2

The Department accepts the current fuel sulfur limit of 0.3 percent by weight as BART

for SO 2 . This is in line with the guidance pr ovided by EPA for sulfur in fuel of 1.0 percent or less by weight (A ppendix Y, Section IV.E.4, “SO 2 limits for Utility Boilers”).

EPA also notes in the BART rule that “the most appropriate contro l option for oil-fired EGUs, regardless of capacity, is to set limits on the sulfur content of the fuel oil burned in the unit” (70 FR 39133).

• NO

x

The Department accepts the finding that no controls are required as BART for NO

x based

on technical and/or economic in feasibility and the negligible visibility improvement that would have resulted from their implementa tion. The unit will continue to employ offstoichiometric firing. Boiler No. 2 will be subject to a 0.32 lb/mmBtu limit, based on a 30-day rolling average.

• PM

The Department accepts that no control is ne cessary for BART for PM based on technical infeasibility. The existing 0.1 lb/mmBtu pa rticulate emission limit will remain in place.