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 Retrofit Technology (BART) rule under 40 CFR Part 

51 and Appendix Y, and the New York State BART regulation as codified under 6 NYCRR Part 

249. These requirements affect an emission source which fulfills the following criteria: 

1. Falls within one of 26 specific 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 other 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 particulate matter. This analysis took 

into account such factors as the cost of controls, energy and non-air quality environmental 

impacts of compliance, any existing pollution control technology in use at the source, the 

remaining useful life of the source, and the degree of improvement in visibility which may 

reasonably be anticipated to result from the use of such technology. 

This document summarizes the reasoning behind the Department’s BART determination, 

including the level of controls 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 public 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 submitted 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 emission 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 burns 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 does not produce electricity, and 

follows steam load which results in limited operation and significant unused capacity. 

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

• SO2

Under the low-sulfur fuel oil standards 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 Boiler 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 

SO2. 

• NOx

Con Ed identified seven potential BART control technologies for NOx for Boiler No. 2. 

The following table lists the options identified, with technically infeasible options crossed 

out. For the options that remain feasible, the expected control efficiency has been 

provided along with the cost-effectiveness values under full 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 for Boiler No. 2 are deemed economically infeasible when 

considering the $5,500 per ton threshold established by the Department for BART, 

whether under full operation or anticipated operation. Aside from being cost-prohibitive 
on a dollar-per-ton basis, Con Ed also includes 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 NOx reduction. 

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

NOx for Boiler No. 2. 

• PM 

Con Ed identified three potential add-on control technologies for PM at the Ravenswood 

Steam Plant: an electrostatic precipitator (ESP), a fabric filter/baghouse, and a cyclone. 

In each case, Con Ed notes that the control technology does not appear to be 

demonstrated in practice for a utility boiler that burns oil as the primary fuel. Con Ed 

therefore deems each as technically infeasible. 

Con Ed requests that current 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 shall constitute BART for Ravenswood Steam Plant 

Boiler No. 2: 

• SO2

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

for SO2. This is in line with the guidance provided by EPA for sulfur in fuel of 1.0 

percent or less by weight (Appendix Y, Section IV.E.4, “SO2 limits for Utility Boilers”). 

EPA also notes in the BART rule that “the most appropriate control 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). 

• NOx

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

on technical and/or economic infeasibility and the negligible visibility improvement that 

would have resulted from their implementation. 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 necessary for BART for PM based on technical 

infeasibility. The existing 0.1 lb/mmBtu particulate emission limit will remain in place.