COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

AK Steel Corporation June 11, 2008

Butler Works

P.O. Box 832

Butler, PA 16003

Operating Permit #: 10-00001

To: John Guth Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control Northwest Regional Office 

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to contain 

emission limitations representing Best Available Retrofit Technology (BART) for certain sources that may 

reasonably be anticipated to cause or contribute to visibility impairment at a Class 1 area. The BART 

requirements apply to units that were in existence on August 7, 1977 but were not in operation before 

August 7, 1962 that collectively, at a facility, have the potential to emit more than 250 tons per year of a 

visibility impairing pollutant. Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. 

VOC and NH3 may be visibility-impairing pollutants; however the Department has determined that 

modeling tools to assess the visibility impacts from VOC and NH3 adequately are not available at this 

time. The BART requirements only apply to sources in 26 specific categories listed in the Clean Air Act.

States are required to make a determination of BART for each source subject to BART based on an 

analysis of the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the costs of 

compliance, the energy and non-air quality environmental impacts, any pollution control equipment 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 use of the technology. 

PA DEP requested that Pennsylvania sources subject to BART conduct the BART analysis required by the 

Regional Haze rule and submit a BART proposal. 
2. Process Description:

AK Steel is an electric arc furnace steel production plant. 

The following are the Source ID numbers of the affected units. 

 TABLE 1 2002 Actual Emissions

 UNIT NOx (tpy) PM10 (tpy) SO2 (tpy) 

031 Boiler #15 (MTS) 5.2 0.3 0

102 Electric Arc Furnace #2 71.9 3.1 9.8

103 Electric Arc Furnace #3 73.5 3.1 10.1

104 Electric Arc Furnace #3 70.4 3.0 9.1

105 Shot Blast #4 0 1.6 0

114 #11 Centro Slab Grinder 0 1.6 0

115 #12 Centro Slab Grinder 0 1.1 0

118 #4 Pickle Line 4.3 1.3 0

127 #26 Carlite Acid Clean 6.8 0.5 0

136 AOD Reactor 8.5 5.4 0

137 Slab Heating Furnace #8 25.4 1.2 0

140 #2 Continuous Caster 1.2 0.3 0

142 Vacuum Degas 0 0 0

148 CRNO Line Anneal Furnace 12.9 0.9 0

160A RGO Drying Furnace 4.2 0.3 0

162 #26 Carlite Dry 0 0 0

247 Ladle Preheater #1 0 0 0

248 Ladle Preheater #2 1.8 0 0

249 Ladle Preheater #3 1.4 0 0

250 Ladle Preheater #4 1.8 0 0

Total: 289.2 20.8 29.0
3

3. NESCAUM CALPUFF modeling:

AK Steel has emission units at this facility that were originally constructed between 1962 and 1977. The 

total emissions from the date-eligible units of a single visibility impairing pollutant is over 250 tons per 

year, making all date-eligible units subject to the BART requirements that are a part of the Regional Haze 

rules specified in 40 CFR part 51, subpart P Protection of Visibility. 

Based upon the NESCAUM CALPUFF modeling, the maximum combined impact of these units on a 

Class I area was 0.079 deciviews (dv). This impact is on the Shenandoah National Park. 

The visibility impact of the units with respect to the Class I area affected is described in Tables 2 and 3. 

Table 2 contains the visibility impact modeled with the National Weather Service (NWS) platform and 

Table 3 contains the visibility impact modeled with the University of Maryland (MM5) platform. 

TABLE 2. Maximum Daily Impact NWS Platform (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

031 Shenandoah 0.001 0.000 0.000 0.000

102 Shenandoah 0.013 0.001 0.011 0.000

103 Shenandoah 0.013 0.001 0.012 0.000

104 Shenandoah 0.012 0.001 0.011 0.000

105 Shenandoah 0.000 0.000 0.000 0.000

114 Shenandoah 0.000 0.000 0.000 0.000

115 Shenandoah 0.000 0.000 0.000 0.000

118 Shenandoah 0.000 0.000 0.000 0.000

127 Shenandoah 0.001 0.000 0.001 0.000

136 Shenandoah 0.001 0.000 0.001 0.000

137 Shenandoah 0.003 0.000 0.002 0.000

140 Shenandoah 0.000 0.000 0.000 0.000

142 Shenandoah 0.000 0.000 0.000 0.000

148 Shenandoah 0.001 0.000 0.001 0.000

160A Shenandoah 0.000 0.000 0.000 0.000

162 Shenandoah 0.000 0.000 0.000 0.000

247 Shenandoah 0.000 0.000 0.000 0.000

248 Shenandoah 0.000 0.000 0.000 0.000

249 Shenandoah 0.000 0.000 0.000 0.000

250 Shenandoah 0.000 0.000 0.000 0.000

Total: 0.079

TABLE 3. Maximum Daily Impact MM5 Platform (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

031 Shenandoah N/A N/A N/A N/A

102 Shenandoah 0.017 0.001 0.016 0.000

103 Shenandoah 0.017 0.001 0.016 0.000
104 Shenandoah 0.016 0.001 0.015 0.000

105 Shenandoah N/A N/A N/A N/A

114 Shenandoah N/A N/A N/A N/A

115 Shenandoah N/A N/A N/A N/A

118 Shenandoah N/A N/A N/A N/A

127 Shenandoah N/A N/A N/A N/A

136 Shenandoah 0.001 0.000 0.001 0.000

137 Shenandoah 0.003 0.000 0.003 0.000

140 Shenandoah N/A N/A N/A N/A

142 Shenandoah N/A N/A N/A N/A

148 Shenandoah 0.001 0.000 0.001 0.000

160A Shenandoah N/A N/A N/A N/A

162 Shenandoah N/A N/A N/A N/A

247 Shenandoah N/A N/A N/A N/A

248 Shenandoah N/A N/A N/A N/A

249 Shenandoah N/A N/A N/A N/A

250 Shenandoah N/A N/A N/A N/A

Generic Stack Shenandoah 0.006 0.000 0.006 0.000

Total: 0.057

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART Determinations 

Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making BART 

determinations that States can use in implementing the regional haze BART requirements on a source-bysource basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania must follow the guidelines in making 

BART determinations on a source-by-source basis for 750 megawatt (MW) power plants, but are not 

required to use the process in the guidelines when making BART determinations for other types of 

sources. As a result, Pennsylvania retains the discretion to deviate from the guidelines as appropriate. 

 

The Department’s BART analysis took into account each of the five statutory factors required by the Clean 

Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory factors for BART were codified at 40 CFR 

51.308(e)(1)(ii).

 

In addition for each source subject to BART identified in this review memo, Pennsylvania used the BART 

determination process under the guidelines to do the following: conduct an analysis of emissions control 

alternatives, which includes the identification of available, technically feasible retrofit technologies, and 

for each technology identified, an analysis of the cost of compliance, the energy and non-air quality 

environmental impacts, and the degree of visibility improvement in affected Class I areas resulting from 

the use of the control technology. As part of the BART analysis, Pennsylvania took into account the 

remaining useful life of the source and any existing control technology present at the source. For each 

source, Pennsylvania determined a “best system of continuous emission reduction” based upon its 

evaluation of these factors. Pennsylvania also established emission limits, including a deadline for 
5

compliance, consistent with the BART determination process for each source subject to BART. Below 

is the five factor analysis, in detail, for the emissions units at this facility which had the greatest impact. 

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Electric Arc Furnaces Misc. Natural Gas Burners

SCR Ultra Low NOx Burners

SNCR

Ultra low NOx burners is the available retrofit control option with the practical potential for application 

to the miscellaneous natural gas burners for the control of NOx. 

STEP – 2: Eliminate Technically Infeasible Options Identified under Step 1

Ultra low NOx burners currently achieve a 65% reduction in NOx emissions compared to conventional 

natural gas burners. 

Since neither SCR or SNCR were found to be in use for any electric arc furnaces in the 

RACT/BACT/LAER Clearinghouse they were determined to be technically infeasible. 

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Ultra Low NOx Burner provide a 65% improvement over the conventional natural gas burner.

STEP – 4: Evaluate Impacts and Document the Results

Cost Of Compliance: Ultra Low NOx Burner $12,800/ton, the Annualized Cost is $520,000. These 

calculations are based upon information obtained from EPA’s AP42 Manual. The potential emissions 

reduction for this control was estimated to be 41 tons. 

The existing useful life of this facility was not a factor since the facility is not expected to close within 

the expected life span of the control equipment. There are no direct energy impacts or non-air quality 

impacts associated with this control. 

STEP – 5: Evaluate Visibility Impacts

The total deciview impact of this facility including all BART eligible units is 0.079 dv. The total NOx 

impact attributable to the burning of natural gas is 0.014 dv. The cost in terms of dollars per deciview 

for this facility just considering the cost of installing the ultra low NOx burner was calculated to be 

$37,143,000/dv. 

The majority of their visibility impairing emissions were associated with the emissions from their three 

electric arc furnaces. The greatest total visibility impact of each of the three individually was 0.016 dv. 

The total impact from the three electric arc furnaces was 0.047 dv. The majority of that impact is 
attributed to the NOx emissions from those furnaces. Based on a review of current NOx emissions 

reduction approaches in the RACT/BACT/LAER Clearinghouse (RBLC) there does not appear to be 

adequate alternatives available for these emissions sources. Thus, no cost effectiveness calculations were 

performed for NOx. Since the total visibility impact of SO2 from the electric arc furnaces was 0.003 dv 

no cost effectiveness calculation was deemed necessary for SO2 from the electric arc furnaces. 

5. Conclusion:

Based on the five factor analysis, the impact of this facility does not warrant additional control. I 

recommend the following determination of BART for the AK Steel facility: compliance with the 

existing operating permit for this facility. The current NOx limit for the three electric arc furnaces is 

75.0 lb/hr. The current SOx limit for the three furnaces is 500 parts per million by volume 

concentration. The current particulate matter limit for the three furnaces has three parts. The first is 

0.0036 grains per dry standard cubic feet. The second is 29.9 pounds per hour. The third is 130.8 tons 

per year. 

cc: Northwest Regional Office

Central Office

 
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

Allegheny Energy Supply Company, LLC

Hatfield’s Ferry Power Station

2907 E Roy Furman Hwy

Masontown, PA 15461- 2591

TV Operating Permit #: 30-00099

To: Mark Wayner Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Southwest Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 
BART Application Review – Allegheny Energy Supply LLC, Hatfield’s Ferry

Page 2 of 3

January 17, 2008

that an engineering analysis of VOC control options is not needed. EPA has determined that 

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

Hatfield’s Ferry Power Station consists of 3 BART affected boilers, each rated at 570 MW. The 

facility has recently received a Plan Approval for the installation of FGD. Part of the FGD Plan 

Approval’s conditions is a filterable particulate emissions rate of 0.075 lb/MMBtu. This 

filterable particulate emission rate was used by the facility to do their own CALPUFF modelling.

3. BART Analysis

The facility provided cost analysis data for a variety of filterable particulate matter control 

technologies. The retrofit technologies reviewed included fuel-related modifications, ESP 

upgrades, enhancements or replacement, replacement of the ESPs with fabric filters or compact 

hybrid particulate collectors (COHPAC). Of the technologies reviewed, COHPAC provided the 

highest filterable particulate matter removal rate with the lowest $/ton cost. This cost was

calculated to be $5,723.00/ton or $7,111,805.00 $/year per boiler. This includes an energy 

impact of 20,772 MWh/year per unit to run the booster fans required to operate the COHPAC 

device. The estimated useful life for this cost analysis was 20 years.

The facility’s CALPUFF modeling indicates that the 98th percentile delta-deciview improvement 

using this technology would be 0.177 dv at Otter Creek, 0.139 dv at Dolly Sods, 0.135 dv at 

Shenandoah and 0.053 at James River. 

The lowest levelized annual dollars per deciview visibility improvement would be 

$121,000,000/dv at the Dolly Sods Wilderness Area. This analysis indicates that it would not be 

cost effective to install this BART technology or any of the lesser ones at this facility.

A three to five percent reduction from ESP enhancement would yield a 0.006 to 0.010 delta dv 

improvement respectively. Using the facility’s three unit 3 to 5 percent annualized cost range of 

$236,492 to $1,440,000 per year yields a dollar per deciview improvement cost range of 

$39,000,000 to $144,000,000/delta dv.

4. Permit Conditions

The permit conditions listed in Plan Approval 30-00009F for filterable particulate matter along 

with the implementation of EGU CAIR requirements satisfy the BART requirements as 

demonstrated in this analysis. 
BART Application Review – Allegheny Energy Supply LLC, Hatfield’s Ferry

Page 3 of 3

January 17, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

The retrofit technologies reviewed included fuel-related modifications, ESP upgrades, 

enhancements or replacement, replacement of the ESPs with fabric filters or compact hybrid 

particulate collectors (COHPAC).

Step 2 – Eliminate Technically Infeasible Options.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

The removal of an additional 80% of filterable particulate matter emissions was assumed after 

existing controls with the installation of COHPAC. The replacement of existing ESPs with a 

fabric filter would yield a similar reduction but at an elevated cost. All other options would yield 

a progressively lower removal rate.

Step 4 – Evaluate Impacts and Document the Results.

Of the technologies reviewed, COHPAC provided the highest filterable particulate matter 

removal rate with the lowest $/ton cost. This cost was calculated to be $5,723.00/ton or 

$7,111,805.00 $/year per boiler. This includes an energy impact of 20,772 MWh/year per unit to 

run the booster fans required to operate the COHPAC device. The estimated useful life for this 

cost analysis was 20 years.

Step 5 – Evaluate Visibility Impacts.

The facility’s CALPUFF modeling indicates that the 98th percentile delta-deciview improvement 

using this technology would be 0.177 dv at Otter Creek, 0.139 dv at Dolly Sods, 0.135 dv at 

Shenandoah and 0.053 at James River. 

The lowest levelized annual dollars per deciview visibility improvement would be 

$121,000,000/dv at the Dolly Sods Wilderness Area. This analysis indicates that it would not be 

cost effective to install this BART technology or any of the lesser ones at this facility.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

Allegheny Energy Supply Company, LLC

Mitchell Power Station

50 Electric Way

New Eagle, PA 15067- 2050

TV Operating Permit #: 63-00016

To: Mark Wayner Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Southwest Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 
BART Application Review – Allegheny Energy Supply LLC, Mitchell

Page 2 of 3

January 17, 2008

that an engineering analysis of VOC control options is not needed. EPA has determined that 

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

Mitchell Power Station consists of several generating boilers but only Unit 3 is subject to BART 

rerquirements. Unit 3 is rated at 288 MW net at an input rate of 2,988 MMBTU/hr. The facility 

used an EPA Method 5 stack tested filterable particulate emission rate of 0.033 lbs/MMBTu for 

their modelling and for calculating their annual emissions at 6132 hrs/yr of year 2013 estimated 

operating capacity. Unit 3 is presently controlled by a Buell Eng. Co. ESP, an American 

Standard ESP and a Chemico FGD system in series.

3. BART Analysis

The facility provided cost analysis data for a variety of filterable particulate matter control 

technologies. The retrofit technologies reviewed included fuel-related modifications, ESP 

upgrades, enhancements or replacement, replacement of the ESPs with fabric filters or compact 

hybrid particulate collectors (COHPAC). The estimated useful life for this cost analysis was 20 

years. Of the technologies reviewed, COHPAC provided the highest filterable particulate matter 

removal rate with the lowest $/ton cost. This cost was calculated to be $20,186.00/ton or 

$4,088,691.00 $/year. This includes an energy impact of 7,395 MWh/year per unit to run the 

booster fans required to operate the COHPAC device.

The facility’s CALPUFF modeling indicates that the 98th percentile delta-deciview improvement 

using this technology would be 0.008 dv at Otter Creek, 0.006 dv at Dolly Sods and 0.007 dv at 

Shenandoah. 

The lowest levelized annual dollars per deciview visibility improvement would be 

$511,000,000/dv at the Otter Creek Wilderness Area. This analysis indicates that it would not be 

cost effective to install this BART technology at this facility. It would also not be cost effective 

if modeled at the existing permit limit of 0.1 lbs/MMBtu.

A three to five percent reduction from ESP enhancement would yield a 0.001 to 0.001 delta dv 

improvement respectively as reported by the facility in their BART analysis. Using the facility’s 

one unit 3 to 5 percent annualized cost range of $93,633 to $400,000 per year yields a dollar per 

deciview improvement cost range of $93,633,000 to $400,000,000/delta dv.

4. Permit Conditions

Title V permit # 63-00016 requires the control equipment that achieves the actual emission rates 

used in this analysis. Therefore, present permit requirements including the existing limit of 0.1 

lbs/MMbtu along with the implementation of EGU CAIR requirements satisfy BART 

requirements for this facility.
BART Application Review – Allegheny Energy Supply LLC, Mitchell

Page 3 of 3

January 17, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

The retrofit technologies reviewed included fuel-related modifications, ESP upgrades, 

enhancements or replacement, replacement of the ESPs with fabric filters or compact hybrid 

particulate collectors (COHPAC). 

Step 2 – Eliminate Technically Infeasible Options.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

The removal of an additional 67% of filterable particulate matter emissions was assumed after 

existing controls with the installation of COHPAC. The replacement of existing ESPs with a 

fabric filter would yield a similar reduction but at an elevated cost. All other options would yield 

a progressively lower removal rate.

Step 4 – Evaluate Impacts and Document the Results.

Of the technologies reviewed, COHPAC provided the highest filterable particulate matter 

removal rate with the lowest $/ton cost. This cost was calculated to be $20,186.00/ton or 

$4,088,691.00 $/year. This includes an energy impact of 7,395 MWh/year per unit to run the 

booster fans required to operate the COHPAC device. The estimated useful life for this cost

analysis was 20 years.

Step 5 – Evaluate Visibility Impacts.

The facility’s CALPUFF modeling indicates that the 98th percentile delta-deciview improvement 

using this technology would be 0.008 dv at Otter Creek, 0.006 dv at Dolly Sods and 0.007 dv at 

Shenandoah. 

The lowest levelized annual dollars per deciview visibility improvement would be 

$511,000,000/dv at the Otter Creek Wilderness Area. This analysis indicates that it would not be 

cost effective to install this BART technology at this facility.
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

Subject: Review Memo for BART Application May 4, 2009

Allegheny Ludlum Corporation

Brackenridge Facility

100 River Road

Brackenridge, PA 15014

To: Jim Thompson Air Quality Program Manager Allegheny County Health Department

From: Tom Lattner, Air Pollution Control Engineer

Erin O’Brian, Air Pollution Control Engineer

Through: Jayme Graham

Supervisor Planning Section

Air Quality Program Allegheny County Health Department 

Sandra Etzel

Chief Engineer

Air Quality Program Allegheny County Health Department

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to contain 

emission limitations representing Best Available Retrofit Technology (BART) for certain sources that may 

reasonably be anticipated to cause or contribute to visibility impairment at a Class 1 area. The BART 

requirements apply to units that were in existence on August 7, 1977 but were not in operation before 

August 7, 1962 that collectively, at a facility, have the potential to emit more than 250 tons per year of a 

visibility impairing pollutant. Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. 

VOC and NH3 may be visibility-impairing pollutants; however the PA Department of Environmental 

Protection has determined that modeling tools to assess the visibility impacts from VOC and NH3 

adequately are not available at this time. The BART requirements only apply to sources in 26 specific 

categories listed in the Clean Air Act.

States and local air agencies are required to make a determination of BART for each source subject to 

BART based on an analysis of the best system of continuous emission control technology available and 

associated emission reductions achievable. The analysis must take into consideration the technology 

available, the costs of compliance, the energy and non-air quality environmental impacts, any pollution 

control equipment 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 use of the technology. 

ACHD requested that Allegheny County sources subject to BART conduct the BART analysis required by 

the Regional Haze rule and submit a BART proposal. 
2. Process Description:

Allegheny Ludlum is an iron and steel mill plant. The ACHD had originally identified a list of 39 units as BART eligible. The 

company reviewed that list and found several of those units were not installed in the BART-eligible timeframe and several other units 

that were installed in the BART-eligible timeframe but that had not been included on the ACHD’s original list. The net result was 

actually an increase in BART eligible emissions.

The following are the Source ID numbers of the affected units. 

Table 1

ID Emission Source Installation 

Date

PM10

Potential 

To Emit 

(TPY)

PM10

Actual

(TPY)

1994

SO2

Potential 

To Emit 

(TPY)

SO2

Actual 

(TPY) 

1994

NOx 

Potential 

To Emit 

(TPY)

NOx

Actual

(TPY)

1994

VOC

Potential 

To Emit

(TPY)

VOC

Actual

(TPY)

1994

S0007A BOFs #71 and #72 

Charging

1967 0.2 0.13

S0007B BOFs #71 and #72 

Tapping

1967 0.4 0.28

S0007C BOFs #71 and #72 

Melting

1967 17.3 11.70 0.36 0.24 7.15 4.90 5.36 3.7

BOF Fugitives 1967 50.0 33.9 0.004 0.07 0.05

S008 Koppers BOF Ladle 

Preheater

1973 0.15 0.02 0.01 0 1.9 0.21 0.11 0.01

S019 Argon-Oxygen 

Decarburization 

(AOD) Vessel –

Canopy Baghouse

1977 31.30 18.60 48.2 28.6 56.9 33.8 26.3 15.6

S019 Argon-Oxygen 

Decarburization 

(AOD) Vessel –

Roof Monitor

1977 3.80 2.20 0.06 0 0.07 0 0.03 0.01

S037 BP Slab Grinder No. 

15

1968 32.40 9.80 0* unknown 0* unknown 0* unknown

S038 BP Slab Grinder No. 

16

1968 32.40 9.80 0* unknown 0* unknown 0* unknown

S039 BP Slab Grinder No. 

18

1968 32.40 9.80 0* unknown 0* unknown 0* unknown
3

S040 BP Slab Grinder No. 

19

1968 32.40 9.80 0* unknown 0* unknown 0* unknown

S041 BP Slab Grinder No. 

20

1968 32.40 9.80 0* unknown 0* unknown 0* unknown

S042 BP Slab Grinder No. 

21

1968 32.40 9.80 0* unknown 0* unknown 0* unknown

S043 BP Slab Grinder No. 

22

1968 32.40 9.80 0* unknown 0* unknown 0* unknown

S044 BP Slab Grinder No. 

23

1974 1.5 0.55 0* unknown 0* unknown 0* unknown

S045 BP Slab Grinder No. 

24

1974 1.5 0.55 0* unknown 0* unknown 0* unknown

S046 Plate Burner/Torch 

Cutter No.1 (cutting)

1973 6.30 1.30 0 0 unknown

Plate Burner/Torch 

Cutter No.1 (NG)

0.1 0.01 1.3* 0.15 0.07 0.01

S047 Plate Burner/Torch 

Cutter No.2 (cutting)

1973 6.30 1.30 0 0 unknown

Plate Burner/Torch 

Cutter No.2 (NG)

0.1 0.01 1.3* 0.15 0.07 0.01

S056 Belt Grinders #1 and 

#2

1967 0.3 0.05 0 unknown unknown

S057 Loftus Soaking Pit. 

No. 9

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S058 Loftus Soaking Pit. 

No. 10

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S059 Loftus Soaking Pit. 

No. 11

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S060 Loftus Soaking Pit. 

No. 12

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S061 Loftus Soaking Pit. 

No. 13

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S062 Loftus Soaking Pit. 

No. 14

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S063 Loftus Soaking Pit. 

No. 15

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S064 Loftus Soaking Pit. 

No. 16

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1
S065 Loftus Soaking Pit. 

No. 17

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S066 Loftus Soaking Pit. 

No. 18

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S067 Loftus Soaking Pit. 

No. 19

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S068 Loftus Soaking Pit. 

No. 20

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S069 Loftus Soaking Pit. 

No. 21

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S070 Loftus Soaking Pit. 

No. 22

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S071 Loftus Soaking Pit. 

No. 23

1970 0.84 0.14 0.07 0.01 11.1 1.8 0.61 0.1

S080 Loftus Soaking Pit. 

No. 43

1965 0.52 0.10 0.04 0 6.8 1.3 0.37 0.07

S081 Loftus Soaking Pit. 

No. 44

1965 0.52 0.10 0.04 0 6.8 1.3 0.37 0.07

S082 Loftus Soaking Pit. 

No. 45

1965 0.52 0.10 0.04 0 6.8 1.3 0.37 0.07

S083 Loftus Soaking Pit. 

No. 46

1965 0.52 0.10 0.04 0 6.8 1.3 0.37 0.07

S088 Hot Band 

Normalizing Furnace

1973 2.30 0.59 0.18 0.05 30.2 7.8 1.7 0.43

TOTAL (tpy) 363.0 142.27 50 29.04 294.1 79.21 44.3 21.55

PTE Actual PTE Actual PTE Actual PTE Actual

*Values taken from October 22, 2004 ACHD letter EJ O’Brian to SL Etzel.

Other values in the October letter were compared against those from the 9-11-2000 operating permit application and found to be nearly 

the same.
3. NESCAUM CALPUFF modeling:

Allegheny Ludlum has emission units at this facility that were originally constructed between 1962 and 

1977. The total emissions from the date-eligible units of two visibility impairing pollutants (PM10 and 

NOx) are over 250 tons per year, making all date-eligible units subject to the BART requirements that are 

a part of the Regional Haze rules specified in 40 CFR part 51, Subpart P Protection of Visibility. 

Based upon the NESCAUM CALPUFF modeling, the maximum combined impact of these units on a 

Class I area was 0.0148 deciviews (dv). This impact is on the Shenandoah National Park. 

On an individual emission unit basis, PM10 from the Basic Oxygen Furnaces #71 and 72 produces the 

maximum impact (0.0085 dv) on a Class 1 area - again Shenandoah National Park.

The visibility impact of the units with respect to the Class I area affected is described in Table II. 

TABLE II. Maximum Daily Impact (dv)

*Values for BOF #71 and 72 were not part of the NESCAUM modeling, but were ratioed from 

deciview changes for BP Slab Grinder (PM10) and Loftus Soaking Pit 14 (NOx). The BOF was 

identified as BART eligible (on the date criteria) after the modeling was performed.

4. BART Analysis:

Allegheny Ludlum did not submit a BART engineering analysis. Instead, in a September 6, 2006 letter to 

ACHD, the company proposed certain permit limitations to reduce BART eligible emissions of NOx and 

PM10 to below the 250 tpy criterion by taking throughput limitations related to some of its slab grinders 

and Loftus soaking pits. The company subsequently withdrew this proposal one year later (September 14, 

2007 letter to ACHD).” 

Nat_bgr Change in visibility (delta-deciview) Stack Name

Maxclsi Total SO4 NO3 PM10

24_01 24_01 24_01 24_01 24_01

Best Shen 2 0.0035 0.0 0.0 0.0035 BP Slab Grinder

Best Shen 2 0.0009 0.0 0.0009 0.0 Plate Burner Torch 

Cutter No. 1

Best Dolly Sods 0.0007 0.0 0.0007 0.0 Loftus Soak Pit 14

Best Dolly Sods 0.0007 0.0 0.0007 0.0 Loftus Soak Pit 18

Best Dolly Sods 0.0007 0.0 0.0007 0.0 Loftus Soak Pit 23

Best Shen 2 0.0004 0.0 0.0 0.0004 Plate Burner Torch 

Cutter 2

Best Shen 2 0.0005 0.0 0.0005 0.0 Loftus Soaking Pit 12

Best Shen 2 0.0009 0.0 0.0005 0.0005 Generic Stack

Shen 2 0.0085 0.0 0.0005*

(Dolly 

Sods)

0.0085* Basic Oxygen 

Furnaces #71 and 72
The ACHD performed a BART analysis in accordance with the Guidelines for BART Determinations 

Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making BART 

determinations that States and local agencies can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). ACHD must follow the 

guidelines in making BART determinations on a source-by-source basis for 750-megawatt (MW) or 

greater power plants, but is not required to use the process in the guidelines when making BART 

determinations for other types of sources. As a result, ACHD retains the discretion to deviate from the 

guidelines as appropriate. 

 

The ACHD’s BART analysis took into account each of the five statutory factors required by the Clean Air 

Act (CAA). These factors are: the costs of compliance; the 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. These statutory factors for BART were codified at 40 CFR 

51.308(e)(1)(ii).

 

In addition for each source subject to BART identified in this review memo, ACHD used the BART 

determination process under the guidelines to do the following: conduct an analysis of emissions control 

alternatives, which includes the identification of available, technically feasible retrofit technologies, and 

for each technology identified, an analysis of the cost of compliance, the energy and non-air quality 

environmental impacts, and the degree of visibility improvement in affected Class I areas resulting from 

the use of the control technology. As part of the BART analysis, ACHD took into account the remaining 

useful life of the source and any existing control technology present at the source. For each 

source, ACHD determined a “best system of continuous emission reduction” based upon its evaluation 

of these factors. Below is the five-factor analysis, in detail, for the emissions units at this facility, which 

had the greatest impact. 

BART Five-Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

BP Slab Grinders Plate Burner Torch 

Cutters 1 & 2

Loftus Soak Pits 12 - 23 BOFs

Existing 

controls:

None Baghouse D011 None Wet venturi 

scrubber

Retrofit 

controls:

Baghouse None Ultra low NOx burners None

Baghouses are the available retrofit control option with the practical potential for application to the slab 

grinders for the control of PM10. 

Ultra low NOx burners are the available retrofit control option with the practical potential for application 

to the natural gas burners for the control of NOx. 
7

STEP – 2: Eliminate Technically Infeasible Options Identified under Step 1

A baghouse is a technically feasible option already in use for two slab grinders at this facility.

Ultra low NOx burners achieve a 65% reduction in NOx emissions compared to conventional natural gas 

burners. 

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Baghouses can be up to 99% effective in particulate filtration.

An ultra low NOx burner provides a 65% improvement over the conventional natural gas burner.

STEP – 4: Evaluate Impacts and Document the Results

Cost Of Compliance:

(1) According to the EPA-CICA Fact Sheet, a typical baghouse could have annualized cost of $5 to $45 

per scfm (Fabric Filter, Mechanical Shaker Cleaned Type). Here, the depicted minimum annualized cost 

is $5 per scfm in 1998 dollars. This facility has two slab grinders that already exhaust to a their own 

baghouse. Based on the installation of a new baghouse for the seven BP Slab Grinders numbered 15,16, 

and 18 through 22, sized conservatively for similar operating parameters, and not correcting for 

inflation, the annualized cost is $120,000. The modeled emissions for the Slab Grinders was 9.5 tons 

per year, resulting in a cost of $12,632 per ton PM10 removed, and an cost of $34,286,000 per deciview 

change.

(2) Ultra Low NOx Burner (for Loftus Soaking Pits): $12,800/ton, the Annualized Cost is $182,000. 

These calculations are based upon information obtained from EPA’s AP42 Manual. The potential 

emissions reduction for this control was estimated to be 14 tons. 

The existing useful life of this facility was not a factor since the facility is not expected to close within 

the expected life span of the control equipment. There are no direct energy impacts or non-air quality 

impacts associated with this control. 

STEP – 5: Evaluate Visibility Impacts

Using the CALPUFF NWS platform computer modeling the total visibility impact of this facility, 

including all BART eligible units, on the Shenandoah Class 1 area was found to be 0.0148 dv. 

The costs of possible new controls in terms of dollars per deciview for this facility were calculated to be:

(1) $34,286,000 /dv for the baghouse for the BP slab grinders; and 

(2) $70,000,000/dv for the ultra low NOx Burners for the Loftus Soaking Pits.
The other two sources – the Plate Burner Torch Cutters 1 & 2 and the BOFs have existing controls.

The majority of the visibility impairing emissions was associated with the emissions from the BOFs and 

slab grinders. The greatest visibility impact of either individually was 0.0085 dv attributed to the PM10 

emissions from those BOFs. 

Based on a review of current PM10 emissions reduction approaches in the RACT/BACT/LAER 

Clearinghouse (RBLC) there does not appear to be adequate alternatives available for the two BOF 

emissions sources, beyond the currently installed wet venturi scrubbers. Thus, no cost effectiveness 

calculations were performed for PM10 from these units. 

With their existing baghouse, and low total visibility impact of 0.0009 dv due to NOx from Plate Burner 

Torch Cutter Number 1, and 0.0005 dv due to PM10 from Plate Burner Torch Cutter Number 2, no cost 

effectiveness calculation was deemed necessary for these two units.

5. Conclusion:

Based on the five-factor analysis, the impact of this facility does not warrant additional control. ACHD 

recommends the following determination of BART for the Allegheny Ludlum facility: compliance with 

the existing operating / installation permits for this facility. 

cc: Nancy Herb, PA DEP, Harrisburg

Jane Mahinske, PA DEP, Harrisburg
9

OPERATING PERMITS FOR BART ELIGIBLE SOURCES --Allegheny Ludlum

BART Eligible Units- Existing operating permits.

Installation Permit referenced where noted. Values with an asterisk signify 

Emission Limits = PTE.

ID Emission Source Permit #

S0007A BOFs #71 and #72 

Charging

0025603-000-82900

S0007B BOFs #71 and #72 

Tapping

Same

S0007C BOFs #71 and #72 Melting Same

BOF Fugitives Same

S008 Koppers BOF Ladle 

Preheater

Unknown

S019 Argon-Oxygen 

Decarburization (AOD) 

Vessel – Canopy 

Baghouse

0025603-000-92800

S019 Argon-Oxygen 

Decarburization (AOD) 

Vessel – Roof Monitor

Same

ID Emission Source Permit #

S037 BP Slab Grinder No. 15 0025603-000-65304

S038 BP Slab Grinder No. 16 Same

S039 BP Slab Grinder No. 18 Same

S040 BP Slab Grinder No. 19 Same

S041 BP Slab Grinder No. 20 Same

S042 BP Slab Grinder No. 21 Same

S043 BP Slab Grinder No. 22 Unknown

S044 BP Slab Grinder No. 23 Installation Permit 

#0059-I004

S045 BP Slab Grinder No. 24 Same
ID Emission Source Permit #

S046 Plate Burner/Torch Cutter 

No.1 (cutting)

0025603-000-1160

Plate Burner/Torch Cutter 

No.1 (NG)

Same

S047 Plate Burner/Torch Cutter 

No.2 (cutting)

Same

Plate Burner/Torch Cutter 

No.2 (NG)

Same

S056 Belt Grinders #1 and #2 Installation Permit 

#0059-I003

ID Emission Source Permit #

S057 Loftus Soaking Pit. No. 9 0025603-000-22803

S058 Loftus Soaking Pit. No. 10 Same

S059 Loftus Soaking Pit. No. 11 Same

S060 Loftus Soaking Pit. No. 12 Same

S061 Loftus Soaking Pit. No. 13 Same

S062 Loftus Soaking Pit. No. 14 Same

S063 Loftus Soaking Pit. No. 15 Same

S064 Loftus Soaking Pit. No. 16 Same

S065 Loftus Soaking Pit. No. 17 Unknown

S066 Loftus Soaking Pit. No. 18 Unknown

S067 Loftus Soaking Pit. No. 19 Unknown

S068 Loftus Soaking Pit. No. 20 Unknown

S069 Loftus Soaking Pit. No. 21 Unknown

S070 Loftus Soaking Pit. No. 22 Unknown

S071 Loftus Soaking Pit. No. 23 Unknown
11

ID Emission Source Permit #

S080 Loftus Soaking Pit. No. 43 0025603-000-22804

S081 Loftus Soaking Pit. No. 44 0025603-000-22804

S082 Loftus Soaking Pit. No. 45 0025603-000-22804

S083 Loftus Soaking Pit. No. 46 0025603-000-22804

S088 Hot Band Normalizing 

Furnace

0025603-000-71500 
 COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

Appleton Papers Inc./Spring Mill September 27, 2007

100 Paper Mill Rd.

Roaring Spring, PA 16673

Operating Permit #: 07-05001

To: William Weaver Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control Southcentral Regional Office 

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to contain 

emission limitations representing Best Available Retrofit Technology (BART) for certain sources that may 

reasonably be anticipated to cause or contribute to visibility impairment at a Class I area. The BART 

requirements apply to units that were in existence on August 7, 1977 but were not in operation before 

August 7, 1962 that collectively, at a facility, have the potential to emit more than 250 tons per year of a 

visibility impairing pollutant. Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. 

VOC and NH3 may be visibility-impairing pollutants; however the Department has determined that 

modeling tools to assess the visibility impacts from VOC and NH3 adequately are not available at this 

time. The BART requirements only apply to sources in 26 specific categories listed in the Clean Air Act.

States are required to make a determination of BART for each source subject to BART based on an 

analysis of the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the costs of 

compliance, the energy and non-air quality environmental impacts, any pollution control equipment 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 use of the technology. 

PA DEP requested that Pennsylvania sources subject to BART conduct the BART analysis required by the 

Regional Haze rule and submit a BART proposal. 
2. Process Description:

Appleton is a pulp and paper production plant. 

The following are the Source ID numbers of the affected units. 

 TABLE I 2002 Actual Emissions

 UNIT NOx (tpy) PM10 (tpy) SO2 (tpy) 

036 #3 Power Boiler 242.6 81.4 450.1

101A Batch Digesters w/incinr. 0 0 0

103A Lime Kiln 4.6 6.2 0.2

107 Starch Unloading System 0 0 0

110 Lime Storage Bins 0 2.0 0

110A Lime Slaker 0 1.2 0

111 Brown Stock Washers 0 0 0

112 Knotters 0 0 0

119 No. 2 Paper Machine 0 0 0

Total: 247.2 90.7 450.3

3. NESCAUM/CALPUFF Modeling:

Appleton Paper has emission units at this facility that were originally constructed between 1962 and 1977. 

The total emissions from the date eligible units of a single visibility impairing pollutant is over 250 tons 

per year, making all date-eligible units subject to the BART requirements that are a part of the Regional 

Haze rules specified in 40 CFR part 51, subpart P Protection of Visibility. 

Based upon NESCAUM CALPUFF modeling, the maximum combined impact of these units on a Class I 

area was 0.089 deciviews (dv). This impact is on the Shenandoah National Park. 

The visibility impact of the units with respect to the Class I area affected is described in Table II. 

TABLE II. Maximum Daily Impact (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

036 Shenandoah 0.087 0.051 0.057 0.008

101A Shenandoah 0.000 0.000 0.000 0.000

103A Shenandoah 0.000 0.000 0.000 0.000

107 Shenandoah 0.000 0.000 0.000 0.000

110 Shenandoah 0.000 0.000 0.000 0.000

110A Shenandoah 0.000 0.000 0.000 0.000
3

111 Shenandoah 0.000 0.000 0.000 0.000

112 Shenandoah 0.000 0.000 0.000 0.000

119 Shenandoah 0.000 0.000 0.000 0.000

Generic Stack* Shenandoah 0.002 0.000 0.001 0.001

Total: 0.089

* CALPUFF MM5 modeled >90% of emissions in individual stacks; remainder modeled as “generic 

stack”)

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART Determinations 

Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making BART 

determinations that States can use in implementing the regional haze BART requirements on a source-bysource basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania must follow the guidelines in making 

BART determinations on a source-by-source basis for 750 megawatt (MW) power plants, but are not 

required to use the process in the guidelines when making BART determinations for other types of 

sources. As a result, Pennsylvania retains the discretion to deviate from the guidelines as appropriate. 

 

The Department’s BART analysis took into account each of the five statutory factors required by the Clean 

Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory factors for BART were codified at 40 CFR 

51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used the BART 

determination process under the guidelines to do the following: conduct an analysis of emissions control 

alternatives, which includes the identification of available, technically feasible retrofit technologies, and 

for each technology identified, an analysis of the cost of compliance, the energy and non-air quality 

environmental impacts, and the degree of visibility improvement in affected Class I areas resulting from 

the use of the control technology. As part of the BART analysis, Pennsylvania took into account the 

remaining useful life of the source and any existing control technology present at the source. For each 

source, Pennsylvania determined a “best system of continuous emission reduction” based upon its 

evaluation of these factors. Pennsylvania also established emission limits, including a deadline for 

compliance, consistent with the BART determination process for each source subject to BART. Below 

is the five factor analysis, in detail, for the emissions unit at this facility which had the greatest impact. 

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Power Boiler #3

SO2 NOx

Wet Scrubber/Wet Flue Gas Desulfurization Selective Catalytic Reduction (SCR)

Advanced Flue Gas Desulfurization Selective Non-Catalytic Reduction (SNCR)

Dry Flue Gas Desulfurization (Spray Dryer 

Absorption)

Low NOx Burner (LNB) with SNCR

LNB with Over Fire Air (OFA) and SCR
Load Reduction

Overfire Air

Low NOx Burners

LNB with OFA 

Reburn

Low Excess Air

Burners Out of Service

Biased-Burner Firing

STEP – 2: Eliminate Technically Infeasible Options

Power Boiler #3 Technically Feasible/Infeasible

SO2

Wet Scrubber/Wet Flue Gas Desulfurization Infeasible - No known application on a unit 

this small.

Advanced Flue Gas Desulfurization Infeasible – No known application on 

industrial boilers, No application on mixed 

fuel boilers like this one. 

Dry Flue Gas Desulfurization (Spray Dryer 

Absorption)

Feasible

NOx

Selective Catalytic Reduction (SCR) Infeasible – This unit operates out of the 

effective temperature range of SCR.

Selective Non-Catalytic Reduction (SNCR) Infeasible – The NOx concentration is too 

low for effective use of this technology, This 

is a varying load boiler, thus its temperature 

swings significantly, the temperature of the 

exhaust gas is outside the effective range for 

SNCR, There is no known application of this 

technology on stoker boilers.

Overfire Air Infeasible – Operational constraints could 

cause over heating.

Low NOx Burners Infeasible – Not applicable to stoker boilers.

Reburn Infeasible – Relatively new process, No full 

scale applications on stoker boilers.

Low Excess Air Infeasible – Operational constraints could 

cause over heating. 
5

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Power Boiler #3 SO2 Control Efficiency

Dry Flue Gas Desulfurization 94% 

STEP – 4: Evaluate Impacts and Document the Results

It was determined that the cost of control for this device was not cost effective considering the 

commensurate visibility improvement. 

Power Boiler #3

(SO2)

Cost Effectiveness ($/ton) Cost of Visibility 

Improvement 

($/dv)

$3,487/ton $51,200,000/dv 

The existing useful life of this facility was not a factor since the facility is not expected to close 

within the expected life span of the control equipment. There are potentially significant energy 

impacts due to the increased energy at the facility to operate a dry scrubber. The waste stream 

from the scrubber would qualify as a non-air quality impact. This waste stream would need to be 

disposed of and would pose an additional burden to the facility. 

STEP – 5: Evaluate Visibility Impacts

The total deciview impact of this facility, including all BART eligible units, was modeled to be 

0.089 dv. The cost in terms of dollars per deciview for installing a dry flue gas desulfurization 

system at this facility was calculated to be $51,200,000/dv. 

The CALPUFF NWS platform computer modeling results show the visibility impact on the Shenandoah 

National Park Class I area from this facility to be 0.089 dv. The emissions unit which had the most 

significant impact at Appleton was the Number 3 Power Boiler. The total contribution to visibility 

impairment by this unit was 0.087 dv. The SO2 contribution was 0.051 dv and the NOx contribution 

was 0.057 dv. Upon the review of NOx control technology none were found to be feasible for this 

source.

Several control options were considered for SO2 control for the power boiler. The most cost effective 

means of control considered was an SDA system. The resulting average cost effectiveness for installing 

the SDA system based on 2002 emissions was calculated to be $3,487/ton. The corresponding visibility 

improvement based on the installation of this technology over the baseline was estimated to be 0.048 dv. 

The cost of this control equipment in terms of visibility improvement was determined to be 

$51,200,000/dv. 
5. Conclusion:

Based on the five factor analysis, the impact of this facility does not warrant additional control. I 

recommend the following determination of BART for the Appleton Paper facility: compliance with the 

existing operating permit for this facility. The following permit limits pertain to the Number 3 Power 

Boiler. The current NOx limit is 0.63 lbs/mmBTU. The current SOx limit for the power boiler is 4.0 

lbs/mmBTU. The current particulate matter limit has two parts. First, for heat input between 2.5 and 50 

mmBTU/hr, the limit is 0.4 lbs/mmBTU. Second, for heat input between 50 and 600 mmBTU/hr, the 

limit is calculated by multiplying 3.6 times the heat input raised to the –0.56 power. 

cc: Southcentral Regional Office

Central Office

 
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

February 6, 2008

Subject: Review Memo for BART Application

Carmeuse Lime Inc.

Millard Lime Plant

Route 422 W

Annville, PA 17003

Operating Permit #: 38-05003

To: William Weaver Joyce Epps

Environmental Program Manager Bureau Director

Southcentral Regional Office Bureau of Air Quality

From: Martin L. Hochhauser, P.E., Air Quality Engineering Specialist

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 
BART Application Review – Carmeuse/ Millard Lime Plant

Page 2 of 7

February 6, 2008

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment 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 use of the 

technology. 

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to 

Carmeuse/Millard indicated that an engineering analysis of VOC control options was not needed, 

because the relationship of VOC and particulate could not be quantified. In addition, the 

Department did not require an engineering analysis for pollutants with a combined potential to emit 

less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 tons per year of 

PM10, because of the small effect on visibility.

2. Process Description:

Carmeuse/Millard is a lime production plant. It has one affected lime kiln, Kiln Number 5. Kiln 

Number 5 and associated material handling units are affected units.

The primary purpose of this facility is to convert limestone into lime. It is produced in both 

quick and hydrated forms. The limestone kiln has no preheater and is a long unit. The kiln has 

one downstream control device, a fabric filter processing the kiln flue gas.

The following are the source ID numbers of the affected units.

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

107 - Number 5 Kiln 293.16 18.24 60.82

114 - Number 5 Kiln Storage Bin 0.00 2.01 0.00

116 – Chemical Hydrate Loadout 0.00 0.11 0.00

118 – Bulk Hydrate Loadout 0.00 0.11 0.00

119 – Pneu. Conv. of Quick Lime 0.00 0.58 0.00

120 – Hydration of Quick Lime 0.00 0.02 0.00
BART Application Review – Carmeuse/ Millard Lime Plant

Page 3 of 7

February 6, 2008

121 – Packing & Shipping 0.00 0.01 0.00

123 – Truck Loadout – East Silo 0.00 0.20 0.00

Total: 293.16 21.28 60.82

3. NESCAUM CALPUFF Modeling:

Carmeuse/Millard Lime Plant has eight (8) emission units at this facility originally constructed 

between the specified dates in 1962 and 1977. The total emissions from the date-eligible units of 

a single visibility impairing pollutant are over 250 tons per year, making all date-eligible units 

subject to the BART requirements that are a part of the Regional Haze rules specified in 40 CFR 

part 51, subpart P, Protection of Visibility.

Based upon NESCAUM CALPUFF modeling the maximum combined impact of this source on a 

Class I area was 0.059 deciview (dv). This impact is on the Dolly Sods Wilderness Area.

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

107 Dolly Sods 0.059 0.004 0.055 0.000

114 Dolly Sods 0.000 0.000 0.000 0.000

116 Dolly Sods 0.000 0.000 0.000 0.000

118 Dolly Sods 0.000 0.000 0.000 0.000

119 Dolly Sods 0.000 0.000 0.000 0.000

120 Dolly Sods 0.000 0.000 0.000 0.000

121 Dolly Sods 0.000 0.000 0.000 0.000

123 Dolly Sods 0.000 0.000 0.000 0.000

Total: 0.059 0.004 0.055 0.001

Upon reviewing the 2002 actual emissions of this facility it was determined that the NOx 

emissions from the Carmeuse\Millard Kiln Number 5 (Source ID #107) make up the 

preponderance of the affected visibility impairing emissions.
BART Application Review – Carmeuse/ Millard Lime Plant

Page 4 of 7

February 6, 2008

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate.

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.
BART Application Review – Carmeuse/ Millard Lime Plant

Page 5 of 7

February 6, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3 lists all available control technologies on the Carmeuse\Millard Number 5 Lime Kiln for 

control of SO2 and NOx. Visibility improvement is based on the MANE-VU analysis for the 

peak 24-hour period during 2002. Control system costs were based on a size-corrected average 

of other submittals.

Table 3 - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Carmeuse\Millard – Lime Kiln, Unit 5

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control Technology % 

Control

MANE-VU 

Maximum 

24-hour 

Visibility 

Improvement 

dv

Control Cost

$ per Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 61 Dry Injection 40% 0.004 7,045 44,443,313

SO2 61 Semi-Dry 82% 0.008 16,048 101,246,572

SO2 61 Wet Scrubber 89% 0.009 24,431 154,132,597

NOx 293 Indirect Firing 18% 0.009 33,479 211,214,331

NOx 293 Low NOx Burner 20% 0.009 1,318 8,315,467

NOx 293 SNCR 35% 0.016 1,014 6,398,357

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by a fabric filter (FF). The degree of visibility improvement that could be obtained by 

requiring additional particulate matter controls on this kiln is so small that no reasonable 

weighting of the five factors required by consideration in the BART analysis could justify 

additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a lime or cement kiln. The SDA/FF or Semi-Dry Control Technology was 

removed from consideration due to technical infeasibility.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

On long kilns, this temperature may move along the axis of the kiln with time, causing injection 

to take place outside of the temperature range. SNCR has not been used full time on long wet or 

long dry kiln systems.
BART Application Review – Carmeuse/ Millard Lime Plant

Page 6 of 7

February 6, 2008

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted. The 

USEPA RACT/BACT/LAER Clearinghouse lists no long cement kiln, either wet or dry, with 

NOx controlled by a SNCR system. It has been reported that SNCR has been proposed for NOx 

control as BART on a long cement kiln in the US. While there several technical issues 

associated with the installation of SNCR for long kilns, economic and impact analyses were 

performed for this control option. A NOx reduction of 35% was used for SNCR on long kilns 

based on the July 2006 ERG report to the Texas Commission on Environmental Quality. They 

used this reduction since SNCR control on long kilns is considered Innovative and available data 

is limited.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 40% to 

89%. Removal efficiencies of the technically feasible NOx control technologies range from 18% 

to 35%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Dry Injection system for Kiln 5 is $7,045 per ton of actual SO2 removed. 

The estimated cost of a Semi-Dry system for the kiln is $16,048 per ton of actual SO2 removed. 

The estimated cost of a Wet Scrubber system for Kiln 2 is $24,431 per ton of actual SO2 

removed. These control systems are considered too expensive to be considered as control for 

BART at the level of improvement determined for the most affected Class I area (Dolly Sods 

Wilderness Area).

The estimated cost of Indirect Firing is $33,479 per ton of NOx removed and is considered too 

expensive to be considered as control for BART at the level of improvement produced and 

determined to be Economically Infeasible. The estimated cost of Low NOx Burning is $1,318

per ton of NOx removed. The estimated cost of SNCR is $1,014 per ton of NOx removed.

In addition, a Wet Scrubber has significant energy requirements and produces a sludge that must 

be treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The technical guidance for BART analysis specified a 98th percentile maximum for the three year 

period of 2001 through 2003 be used for visibility impact. The peak 24-hour visibility impact for 

2002 was used in this analysis rather than a 98th percentile maximum for the three year period of 

2001 through 2003. This was due to a lack of company estimated visibility analysis. Estimated 

visibility impact is expected to be significantly higher due to this difference.
BART Application Review – Carmeuse/ Millard Lime Plant

Page 7 of 7

February 6, 2008

The maximum visibility improvement due to the most effective SO2 control in a Class I area 

(Dolly Sods Wilderness Area) was 0.009 dv. The minimum cost of improvement was 

$44,443,000 annually per deciview, for lesser improvement. Therefore I do not recommend any 

additional control of SO2 as a result of the BART analysis. The current operating permit 

limitation for SO2 emissions from the kiln is 500 ppm by volume.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area was 0.016 dv. The minimum cost of improvement was $8,315,000 annually per 

deciview, for lesser improvement. Therefore I do not recommend any additional control of NOx 

as a result of the BART analysis. The current operating permit limitation for NOx emissions 

from the kiln is 6.0 pounds per ton of lime produced.

5. Conclusion:

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control to meet the BART requirements. Thus, this 

reviewer concludes that no additional emission control equipment for BART is warranted at this 

location. Therefore, the existing permit limits will meet the requirements for BART.

cc: Southcentral Regional Office

Central Office
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

June 16, 2008

Subject: Review Memo for BART Application

CEMEX Inc.

2001 Portland Park

Wampum, PA 16157-3913

Operating Permit #: 37-00013

To: John Guth Joyce Epps

Environmental Program Manager Bureau Director

Northwest Regional Office Bureau of Air Quality

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 
BART Application Review – CEMEX\Wampum Facility

Page 2 of 8

February 6, 2008

equipment 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 use of the 

technology.

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to 

CEMEX/Wampum Plant indicated that an engineering analysis of VOC control options was not 

needed, because the relationship between VOC and particulate could not be quantified. In 

addition, the Department did not require an engineering analysis for pollutants with a combined 

potential to emit less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 

tons per year of PM10, because of the small effect on visibility.

2. Process Description:

CEMEX/Wampum Plant is a portland cement production plant. Kiln Number 3 at the facility 

and associated equipment are affected units. Kiln Number 3 is a long, dry kiln. Fuel is fed to 

Kiln Number 3 by a direct firing system.

The primary purpose of this facility is to convert limestone and other component materials into 

portland cement. This kiln has one downstream control device, an electrostatic precipitator 

processing the kiln flue gas.

The following are the source ID numbers of the affected units.

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

228 – Kiln Number 3 351.00 14.10 799.80

158 – #3 Shale Belt to #3 Raw Mill Feed Belt 0.00 0.01 0.00

159 – #3 Raw Mill Feed Belt 0.00 0.59 0.00

168 – 3101 Belt to Clinker Pile Transfer 0.00 2.60 0.00

169 – Removal from Clinker Pile 0.00 0.00 0.00

171 – #3 Kiln Dust Refeed 0.00 0.00 0.00

179 – Clinker Dome Feeder Transfer 0.00 0.00 0.00
BART Application Review – CEMEX\Wampum Facility

Page 3 of 8

February 6, 2008

199 – 3101 Belt & 3102 Belt 0.00 2.60 0.00

200 – Gravel Bed Filter Dust Silo 0.00 2.60 0.00

202 – 3104 Belt & 3105 Belt 0.00 2.60 0.00

204 – Clinker Dome and Tunnel 0.00 21.90 0.00

207 – #5 Homogenizing Silo 0.00 7.00 0.00

217 – New Truck Loading 0.00 1.80 0.00

225 – #3 Clinker Cooler 0.00 4.50 0.00

231 – #3 Kiln Auxiliary Motor 0.00 0.00 0.00

Total: 351.00 60.30 799.80

3. NESCAUM CALPUFF Modeling:

The CEMEX Wampum Plant has fifteen (15) sources at this facility originally constructed 

between the specified dates in 1962 and 1977. The total emissions from the date-eligible units of 

a single visibility impairing pollutant are over 250 tons per year, making all date-eligible units 

subject to the BART requirements that are a part of the Regional Haze rules specified in 40 CFR 

part 51, subpart P, Protection of Visibility.

Based upon NESCAUM CALPUFF modeling the combined impact on a Class I area was 0.161

deciview (dv). This impact is on the Dolly Sods Wilderness Area.

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

228 Dolly Sods 0.159 0.081 0.077 0.001

158

159

168

169

171

179

199
BART Application Review – CEMEX\Wampum Facility

Page 4 of 8

February 6, 2008

200

202

204 Dolly Sods 0.001 0.000 0.000 0.001

207

217

225

231

Total: 0.161 0.081 0.077 0.003

Upon reviewing actual emissions of this facility it was determined that the emissions from the 

Cement Kiln Number 3 (Source ID #228) make up the preponderance of the affected visibility 

impairing emissions.

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate.

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 
BART Application Review – CEMEX\Wampum Facility

Page 5 of 8

February 6, 2008

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3 lists all available control technologies on the CEMEX\Wampum Unit 3 Cement Kiln for 

control of SO2 and NOx. CEMEX proposed evaluation of Selective Mining without estimation 

of costs. Visibility improvement is based on the MANE-VU analysis for the peak 24-hour period 

during 2002. Control system costs were based on a size-corrected average of other submittals.

Table 3 - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – CEMEX\Wampum Kiln Number 3

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control Technology % 

Control

MANE-VU 

Maximum 

24-hour 

Visibility 

Improvement 

dv

Control Cost

$ per Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 800 Dry Injection 40% 0.032 7,045 70,759,062

SO2 800 Semi-Dry 82% 0.066 16,048 159,538,000

SO2 800 Wet Scrubber 89% 0.072 24,431 240,786,792

SO2 800 Selective Mining 70% 0.057

NOx 351 SNCR 35% 0.027 1,014 4,678,401

NOx 351 Water Injection 7% 0.005 1,849 9,095,000

NOx 351 Low NOx Calciner w/ 

indirect firing 40% 0.031 10,517 47,632,258

NOx 351 Low NOx Burner w/ 

indirect firing 20% 0.015 10,873 50,886,667

NOx 351 Mid Kiln TDF 5% 0.0038 11,062 51,236,842

NOx 351 Indirect Firing 18% 0.014 33,479 245,282,864

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by an electrostatic precipitator (ESP). The degree of visibility improvement that could 

be obtained by requiring additional particulate matter controls on this kiln is so small that no 

reasonable weighting of the five factors required by consideration in the BART analysis could 

justify additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.
BART Application Review – CEMEX\Wampum Facility

Page 6 of 8

February 6, 2008

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a cement kiln. The SDA/FF or Semi-Dry Control Technology was removed 

from consideration due to technical infeasibility.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

On long kilns, this temperature may move along the axis of the kiln with time, causing injection 

to take place outside of the temperature range. SNCR has not been used full time on long wet or 

long dry kiln systems.

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted. The 

USEPA RACT/BACT/LAER Clearinghouse lists no long cement kiln, either wet or dry, with 

NOx controlled by a SNCR system. It has been reported that SNCR has been proposed for NOx 

control as BART on a long cement kiln in the US. While there several technical issues 

associated with the installation of SNCR for long kilns, economic and impact analyses were 

performed for this control option. A NOx reduction of 35% was used for SNCR on long kilns 

based on the July 2006 ERG report to the Texas Commission on Environmental Quality. They 

used this reduction since SNCR control on long kilns is considered innovative and there is 

limited available data.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 40% to 

89%. Removal efficiencies of the technically feasible NOx control technologies range from 5% 

to 40%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Dry Injection system for Kiln 3 is $7,045 per ton of actual SO2 removed. 

The estimated cost of a Semi-Dry system for the kiln is $16,048 per ton of actual SO2 removed. 

The estimated cost of a Wet Scrubber system for Kiln 3 is $24,431 per ton of actual SO2 

removed. These SO2 control systems are considered too expensive to be considered as control 

for BART at the level of improvement determined for the most affected Class I area (Dolly Sods 

Wilderness Area). Selective mining of limestone was also proposed by CEMEX, with cost only 

estimated as “significant”.

The estimated cost of indirect firing is $33,479 per ton of NOx removed. The estimated cost of 

mid kiln TDF is $11,062 per ton of NOx removed. The estimated cost of low NOx burner with 

indirect firing is $10,873 per ton of NOx removed. The estimated cost of low NOx calciner with 

indirect firing is $10,517 per ton of NOx removed. These NOx control systems are considered 

too expensive to be considered as control for BART at the level of improvement produced and 
BART Application Review – CEMEX\Wampum Facility

Page 7 of 8

February 6, 2008

was determined to be economically infeasible. The estimated cost of water injection is $1,849

per ton of NOx removed. The estimated cost of SNCR is $1,014 per ton of NOx removed.

Also, a Wet Scrubber has significant energy requirements and produces a sludge that must be 

treated and disposed of.

Selective mining of limestone would lower the concentration of iron pyrite in limestone entering 

the kiln. Pyrites are the primary source of sulfur in SO2 emitted from the cement kiln. To mine 

purer limestone, the top portion of the limestone seam would have to be mined and discarded. 

The bottom portion of the seam would have to be left in place. Strata with impurities within the 

seam may also have to be mined and discarded. Portions of the seam determined by core drilling 

to have a high concentration of pyrite would not be mined. This would increase both the amount 

of limestone quarried and overburden removed. Less limestone would be available for the kin 

from a defined land area.

Step 5 – Evaluate Visibility Impacts.

The technical guidance for BART analysis specified a 98th percentile maximum for the three year 

period of 2001 through 2003 be used for visibility impact. The peak 24-hour visibility impact for 

2002 was used in this analysis rather than a 98th percentile maximum for the three year period of 

2001 through 2003. This was due to a lack of company estimated visibility analysis. Estimated 

visibility impact is expected to be significantly higher due to this difference.

The maximum visibility improvement due to the most effective SO2 control in a Class I area was 

0.072 dv. The minimum cost of improvement was $70,759,062 annually per deciview, for lesser 

improvement. Therefore, I do not recommend any additional control of SO2 as a result of the 

BART analysis. The current operating permit limitation for SO2 emissions from the kiln is 500 

ppm by volume.

The maximum visibility improvement due to the most effective NOx control, SNCR, in the most 

affected Class I area (Brigantine Wilderness Area) was 0.027 dv. The minimum cost of 

improvement was $4,678,401 annually per deciview. Given the uncertainties associated with the 

effectiveness of SNCR with kilns, and its cost effectiveness, I do not recommend the use of 

SNCR for control of NOx as a result of the BART analysis. The next most cost effective NOx 

control was water injection at $9,095,000 annually per deciview. This cost effectiveness 

combined with its overall expected visibility improvement of, 0.005 dv, renders it an 

inappropriate BART control option. The current operating permit NOx emission limitation from 

Kiln Number 3 is 6.0 pounds per ton of clinker produced during the period from May 1 through 

September 30, and 6.2 pounds per ton of clinker produced during the period from October 1 

through April 30.

5. Conclusion:
BART Application Review – CEMEX\Wampum Facility

Page 8 of 8

February 6, 2008

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control to meet the BART requirements. The 

determination for the BART affected sources at this facility is consistent with the determination 

for other similar cement manufacturing facilities. Thus, this reviewer concludes that no 

additional emission control equipment for BART is warranted at this location. Therefore, the 

existing permit limits will meet the requirements for BART.

cc: Northwest Regional Office

Central Office
- 1 -

 COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

ConocoPhillips Trainer Refinery June 10, 2008

4101 Post Road

Trainer, PA 19061

Operating Permit #: 23-00003

To: Francine Carlini Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control Southeast Regional Office 

From: Dan Husted, Air Quality Engineer

Through: Krish Ramamurthy

Chief, Permits Division

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to contain 

emission limitations representing Best Available Retrofit Technology (BART) for certain sources that may 

reasonably be anticipated to cause or contribute to visibility impairment at a Class I area. The BART 

requirements apply to units that were in existence on August 7, 1977 but were not in operation before 

August 7, 1962 that collectively, at a facility, have the potential to emit more than 250 tons per year of a 

visibility impairing pollutant. Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. 

VOC and NH3 may be visibility-impairing pollutants; however the Department has determined that 

modeling tools to assess the visibility impacts from VOC and NH3 adequately are not available at this 

time. The BART requirements only apply to sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of the best 

system of continuous emission control technology available and associated emission reductions

achievable. The analysis must take into consideration the technology available, the costs of compliance, 

the energy and non-air quality environmental impacts, any pollution control equipment 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 use of the technology. 

PA DEP requested that Pennsylvania sources subject to BART conduct the BART analysis required by the 

Regional Haze rule and submit a BART proposal. 

2. Process Description:
- 2 -

ConocoPhillips Trainer Refinery is an oil refinery located in Trainer, PA. It has twenty-one affected units. 

The following are the Source ID numbers of the affected units. 

 TABLE I 2002 Actual Emissions

 UNIT NOx (tpy) PM10 (tpy) SO2 (tpy) 

102 Claus Sulfur Recovery Plant 5.6 0.1 34.8

103 Main Flare 43.6 0.1 15.1

105 Marine Vessel Loading 0 0 0

111 Cooling Towers 0 16.0 0

125 #68 Ext. Float. 43M BBLS 0 0 0

137 #152 Int. Float 61M BBL 0 0 0

140 #155 Int. Float 63M BBLS 0 0 0

142 #157 Ext. Float 77M BBLS 0 0 0

143 #159 Ext. Float 79M BBLS 0 0 0

150 #168 Int. Float 79M BBLS 0 0 0

151 #169 Ext. Float 78M BBLS 0 0 0

163 #185 Ext. Float 150M BBLS 0 0 0

164 #186 Ext. Float 151M BBLS 0 0 0

184 #63 Fixed Roof TK 8M BBLS 0 0 0

193 #158 Fixed Roof TK 56M BBLS 0 0 0

737 Naphtha HDS Heater 27.0 0.5 0.1

738 Platformer Feed Heater 429.4 5.0 1.3

739 Isocracker 1st Stage Heater 10.5 0.2 0.8

740 Isocracker Splitter RBLR 26.2 0.5 2.1

741 VGO HDS Charge Heater 18.9 0.4 0.1

CO1 CO Boiler 536.9 113.4 2062.9

Total: 1098.1 136.2 2117.2
- 3 -

The ConocoPhillips Trainer Facility is currently under an EPA consent decree that will produce significant 

emission reductions for the CO Boiler (Source ID number CO1). Of the BART affected units, this unit 

contributed approximately 49% of the actual 2002 NOx emissions and 97% of the 2002 actual SO2 

emissions. The consent decree mandated the installation of a wet scrubber and enhanced SNCR on the 

Fluidized Catalytic Cracking Unit/CO Boiler. As a result, SO2 emissions will not exceed 25 ppmvd based 

on a 365-day rolling average or 50 ppmvd based on a 7-day average, each at 0% oxygen. Additionally, 

PM emissions from the FCCU must meet the NSPS limit of 0.5 lb/1000 lb coke burn or lower. 

ConocoPhillips is in the process of conducting an ESNCR optimization study required under the consent 

decree. This will evaluate the effects of operating parameters on NOx emissions from the FCCU to 

evaluate the optimal operating levels to minimize NOx emissions. When the optimization study is 

completed, ConocoPhillips is required to propose an emission limit for NOx emissions from the FCCU by 

May 2009.

3. NESCAUM CALPUFF modeling:

The ConocoPhillips Trainer Refinery has emission units at this facility that were originally constructed 

between 1962 and 1977. The total emissions from the date-eligible units of a single visibility impairing 

pollutant is over 250 tons per year, making all date-eligible units subject to the BART requirements that 

are a part of the Regional Haze rules specified in 40 CFR part 51, subpart P, Protection of Visibility. 

Based upon NESCAUM CALPUFF modeling, the maximum combined impact of these units on a Class I 

area was 1.104 deciviews (dv). This impact is on the Brigantine wilderness area. 

Two of the BART affected units were determined to be the most significant sources of concern for 

regional haze at this facility. These two units are Source ID numbers 738 (Platformer Feed Heater) and 

CO1 (CO Boiler). 

The visibility impact of the units with respect to the Class I area affected is described in Tables 2 and 3. 

Table 2 contains the visibility impact modeled with the National Weather Service (NWS) platform and 

Table 3 contains the visibility impact modeled with the University of Maryland (MM5) platform. 

Table 2 – Maximum Daily Impact NWS Platform (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

102 Brigantine 0.006 0.004 0.002 0.000

103 Brigantine 0.017 0.002 0.016 0.000

105 Brigantine 0.000 0.000 0.000 0.000

111 Brigantine 0.000 0.000 0.000 0.000

125 Brigantine 0.000 0.000 0.000 0.000

137 Brigantine 0.000 0.000 0.000 0.000

140 Brigantine 0.000 0.000 0.000 0.000

142 Brigantine 0.000 0.000 0.000 0.000

143 Brigantine 0.000 0.000 0.000 0.000

150 Brigantine 0.000 0.000 0.000 0.000
- 4 -

151 Brigantine 0.000 0.000 0.000 0.000

163 Brigantine 0.000 0.000 0.000 0.000

164 Brigantine 0.000 0.000 0.000 0.000

184 Brigantine 0.000 0.000 0.000 0.000

193 Brigantine 0.000 0.000 0.000 0.000

737 Brigantine 0.018 0.000 0.018 0.000

738 Brigantine 0.160 0.000 0.159 0.001

739 Brigantine 0.008 0.000 0.008 0.000

740 Brigantine 0.018 0.000 0.018 0.000

741 Brigantine 0.013 0.000 0.013 0.000

CO1 Brigantine 0.253 0.232 0.085 0.021

Total: 0.369

*NOTE: Total CALPUFF impact may not equal the sum of unit level impacts due to the non-linear nature 

of the deciview index.

Table 3 – Maximum Daily Impact MM5 Platform (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

102 Brigantine 0.015 0.013 0.002 0.000

103 Brigantine 0.022 0.005 0.017 0.000

105 Brigantine N/A N/A N/A N/A

111 Brigantine N/A N/A N/A N/A

125 Brigantine N/A N/A N/A N/A

137 Brigantine N/A N/A N/A N/A

140 Brigantine N/A N/A N/A N/A

142 Brigantine N/A N/A N/A N/A

143 Brigantine N/A N/A N/A N/A

150 Brigantine N/A N/A N/A N/A

151 Brigantine N/A N/A N/A N/A

163 Brigantine N/A N/A N/A N/A

164 Brigantine N/A N/A N/A N/A

184 Brigantine N/A N/A N/A N/A

193 Brigantine N/A N/A N/A N/A

737 Brigantine 0.017 0.000 0.017 0.000

738 Brigantine 0.190 0.000 .0189 0.002

739 Brigantine N/A N/A N/A N/A

740 Brigantine 0.017 0.001 0.017 0.000

741 Brigantine N/A N/A N/A N/A

CO1 Brigantine 0.857 0.681 0.156 0.032

Total: 1.104

4. BART Analysis
- 5 -

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making 

BART determinations that States can use in implementing the regional haze BART requirements on a 

source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania must follow the guidelines in 

making BART determinations on a source-by-source basis for 750 megawatt (MW) power plants but are 

not required to use the process in the guidelines when making BART determinations for other types of 

sources. As a result, Pennsylvania retains the discretion to deviate from the guidelines as appropriate. 

 

The Department’s BART analysis took into account each of the five statutory factors required by the 

Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory factors for BART were codified at 

40 CFR 51.308(e)(1)(ii).

 

In addition for each source subject to BART identified in this review memo, Pennsylvania used the 

BART determination process under the guidelines to do the following: conduct an analysis of emissions 

control alternatives, which includes the identification of available, technically feasible retrofit 

technologies, and for each technology identified, an analysis of the cost of compliance, the energy and 

non-air quality environmental impacts, and the degree of visibility improvement in affected Class I areas 

resulting from the use of the control technology. As part of the BART analysis, Pennsylvania took into 

account the remaining useful life of the source and any existing control technology present at the source. 

For each source, Pennsylvania determined a ``best system of continuous emission reduction'' based upon 

its evaluation of these factors. Pennsylvania also established emission limits, including a deadline for 

compliance, consistent with the BART determination process for each source subject to BART

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Platformer Feed Heater (ID 738)

NOx SO2 PM

Water/Steam Injection Fuel Specification Good Combustion Practice

SNCR Wet Scrubbing Wet Scrubbing

ULNB Cyclone

ULNB and SNCR ESP

ULNB and SCR FF

The above chart identifies the available retrofit control option with the practical potential for application 

to the Platformer Feed Heater for NOx, SOx, and PM. 
- 6 -

CO Boiler (ID CO1)

NOx SO2 PM

None None None

The above chart identifies that there are no available retrofit control options that have practical potential 

for application to the CO Boiler for NOx, SOx, and PM. 

STEP – 2: Eliminate Technically Infeasible Options

Platformer Feed Heater Technically 

Feasible/Infeasible

NOx

Water/Steam Injection Infeasible

SCR Feasible

SNCR Infeasible 

ULNB Feasible

ULNB and SNCR Infeasible

ULNB and SCR Feasible

SO2

Fuel Specification Feasible

Wet Scrubbing Infeasible

PM

Wet Scrubbing Infeasible

Cyclone Infeasible

ESP Infeasible

FF Infeasible

SCR, ULNB, ULNB with SCR, and fuel specification are all considered technically feasible options 

because these control options have all been demonstrated as effective for process heaters.

Water/Steam Injection is considered technically infeasible because it reduces thermal efficiency in 

process heaters, and there are few full-scale retrofit or test trials of this technology in Platformer Feed 

Heater.

SNCR and ULNB with SNCR are both technically infeasible for the Platformer Feed Heater because the 

exhaust temperatures of the process heater would allow significant ammonia slip from SNCR. 
- 7 -

Wet scrubbing is not feasible because it has not been installed and operated successfully for process 

heaters and is therefore considered technically infeasible.

PM10 will serve as a surrogate for PM2.5. The degree of visibility improvement that could be obtained 

by requiring additional particulate matter controls on the affected units is so small that no reasonable 

weighing of the five factors required by consideration in the BART analysis could justify additional 

controls under BART.

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Platformer Feed Heater Control Effectiveness

NOx Controls

SCR 80%

ULNB 71%

ULNB and SCR 93.5%

SO2 Controls

Fuel Specification Not considered further because the NSPS 

standard already meets BACT.

A control efficiency of 71% for an Ultra Low NOx Burner is representative of the achievable level for 

that particular control device. A control efficiency of 93.5% for an Ultra Low NOx Burner and SCR is 

representative of the achievable level for that particular combination of control devices. 

SCR alone is economically inferior to SCR in combination with combustion controls because it would 

require larger amounts of ammonia. Therefore, SCR will be removed from consideration.

Fuel specification is not considered a feasible option because current NSPS standards already meet 

BACT for SO2 reduction. 

STEP – 4: Evaluate Impacts and Document the Results

Platformer Feed Heater Cost Effectiveness 

($/ton)

Cost of Visibility 

Improvement 

($/dv)

NOx Controls

ULNB 16,042 34,443,040

ULNB and SCR 74,488 316,482,090

Using SCR would cause amounts of unreacted ammonia to be emitted into the atmosphere. Ammonia is 

a PM10 precursor. Also, ammonia emissions would create ammonia salts to be emitted into the 

atmosphere as PM10. There are also safety issues associated with transporting and handling aqueous 
- 8 -

and anhydrous ammonia. There are also space issues with installing SCR, which would make this 

control option infeasible.

There are no energy or non-air quality impacts associated with ULNB at this unit. The remaining useful 

life of the unit was not calculated because there are no plans to shutdown the Platformer feed Heater in 

the foreseeable future.

STEP – 5: Evaluate Visibility Impacts

The Department analyzed installing ultra low NOx burners (ULNB) on Platformer Feed Heater 738. The 

facility estimated that the cost effectiveness of this technology would be approximately $16,042/ton of 

NOx removed (on an actual basis) or $34,443,040/dv improvement. The visibility improvement from 

this installation would be approximately 0.025 deciviews. The basis of the visibility impact is the 

modeling conducted by ConocoPhilips which was performed in accordance with NESCAUM’s 

procedures and utilized the maximum daily impact. In addition, ConocoPhillips has already replaced a 

number of the Platformer Feed Heater burners with ULNBs. The remaining burners would be 

technically infeasible to replace with ULNBs because of the burner configurations. 

5. Conclusion:

After careful review of the facility’s engineering analysis, I recommend the following determination of 

BART for the ConocoPhillips Trainer Refinery: compliance with the terms of the EPA consent decree for 

the FCCU/CO Boiler (Source ID number CO1). The consent decree mandated the installation of a wet 

scrubber and enhanced SNCR on the Fluidized Catalytic Cracking Unit/CO Boiler. As a result, SO2 

emissions will not exceed 25 ppmvd based on a 365-day rolling average or 50 ppmvd based on a 7-day 

average, each at 0% oxygen. Additionally, PM emissions from the FCCU must meet the NSPS limit of 

0.5 lb/1000 lb coke burn or lower. ConocoPhillips is also required to propose an emission limit for NOx

emissions from the FCCU by May 2009. These controls are the most stringent available and all possible 

improvements to these control devices will be made.

I further recommend compliance with the existing operating permit for the Platformer Feed Heater 

(Source ID number 738). The current NOx emission limitation for the Platformer Feed Heater is 0.12 

lbs/MMBtu and 394.2 tons in any 12 consecutive month period. The current SO2 emission limitation for 

the Platformer Feed Heater is 0.011 lbs/mmBtu on an annual basis calculated quarterly.

cc: Southeast Regional Office

Central Office
 COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

Dyno Nobel Inc. September 27, 2007

1320 Galiffa Dr.

Donora, PA 15033

Operating Permit #: 63-00070 

To: Mark Wayner Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control Southwest Regional Office 

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to contain 

emission limitations representing Best Available Retrofit Technology (BART) for certain sources that may 

reasonably be anticipated to cause or contribute to visibility impairment at a Class 1 area. The BART 

requirements apply to units that were in existence on August 7, 1977 but were not in operation before 

August 7, 1962 that collectively, at a facility, have the potential to emit more than 250 tons per year of a 

visibility impairing pollutant. Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. 

VOC and NH3 may be visibility-impairing pollutants; however the Department has determined that 

modeling tools to assess the visibility impacts from VOC and NH3 adequately are not available at this 

time. The BART requirements only apply to sources in 26 specific categories listed in the Clean Air Act.

States are required to make a determination of BART for each source subject to BART based on an 

analysis of the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the costs of 

compliance, the energy and non-air quality environmental impacts, any pollution control equipment 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 use of the technology. 

PA DEP requested that Pennsylvania sources subject to BART conduct the BART analysis required by the 

Regional Haze rule and submit a BART proposal. 
2. Process Description:

Dyno Nobel is a nitric acid production plant. 

The following are the Source ID numbers of the affected units. 

 TABLE I 2002 Actual Emissions

 UNIT NOx (tpy) PM10 (tpy) SO2 (tpy) 

031 Murray No.2 8.0 0.8 0

035 AOP Cooling Tower 0 3.5 0

101 Ammonia Oxidation Plant 224.7 0.6 0

103B Prill Handling 0 1.0 0

104 Ammonium Nitrate Cooler 0 0.9 0

105 Ammonium Nitrate Predrier 0 1.6 0

106 Ammonium Nitrate Drier 0 1.1 0

107 Ammonium Nitrate Evaporate 0 1.8 0

108 Ammonia Nitrate Solvent Tank 0 11.6 0

109 Ammonia Nitrate Solvent Tank 0 0.8 0

Total: 232.7 23.7 0

3. NESCAUM CALPUFF modeling:

Dyno Nobel has emission units at this facility that were originally constructed between 1962 and 1977. 

The total emissions from the date-eligible units of a single visibility impairing pollutant is over 250 tons 

per year, making all date-eligible units subject to the BART requirements that are a part of the Regional 

Haze rules specified in 40 CFR part 51, subpart P Protection of Visibility. 

Based upon NESCAUM CALPUFF modeling, the maximum combined impact of this source on a Class I 

area was 0.100 deciviews (dv). This impact is on the Dolly Sods wildlife area. 

The visibility impact of the units with respect to the Class I area affected is described in Table II 

TABLE II. Maximum Daily Impact (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

031 Dolly Sods 0.003 0.000 0.003 0.000

035 Dolly Sods 0.001 0.000 0.000 0.001

101 Dolly Sods 0.096 0.000 0.096 0.000

103B Dolly Sods 0.000 0.000 0.000 0.000
3

104 Dolly Sods 0.000 0.000 0.000 0.000

105 Dolly Sods 0.000 0.000 0.000 0.000

106 Dolly Sods 0.000 0.000 0.000 0.000

107 Dolly Sods 0.000 0.000 0.000 0.000

108 Dolly Sods 0.000 0.000 0.000 0.000

109 Dolly Sods 0.000 0.000 0.000 0.000

Total: 0.100

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART Determinations 

Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making BART 

determinations that States can use in implementing the regional haze BART requirements on a source-bysource basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania must follow the guidelines in making 

BART determinations on a source-by-source basis for 750 megawatt (MW) power plants, but are not 

required to use the process in the guidelines when making BART determinations for other types of 

sources. As a result, Pennsylvania retains the discretion to deviate from the guidelines as appropriate. 

 

The Department’s BART analysis took into account each of the five statutory factors required by the Clean 

Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory factors for BART were codified at 40 CFR 

51.308(e)(1)(ii).

 

In addition for each source subject to BART identified in this review memo, Pennsylvania used the BART 

determination process under the guidelines to do the following: conduct an analysis of emissions control 

alternatives, which includes the identification of available, technically feasible retrofit technologies, and 

for each technology identified, an analysis of the cost of compliance, the energy and non-air quality 

environmental impacts, and the degree of visibility improvement in affected Class I areas resulting from 

the use of the control technology. As part of the BART analysis, Pennsylvania took into account the 

remaining useful life of the source and any existing control technology present at the source. For each 

source, Pennsylvania determined a “best system of continuous emission reduction” based upon its 

evaluation of these factors. Pennsylvania also established emission limits, including a deadline for 

compliance, consistent with the BART determination process for each source subject to BART. Below is 

the five factor analysis, in detail, for the emissions unit at this facility which was found to have the greatest 

impact. 

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Ammonia Oxidation Plant

Extended Absorption

Nonselective Catalytic Reduction (NSCR)

Selective Catalytic Reduction (SCR)

STEP – 2: Eliminate Technically Infeasible Options Identified under Step 1
All options are technically feasible. 

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Ammonia Oxidation Plant NOx Control Effectiveness

Extended Absorption 95.8% (1)

Nonselective Catalytic Reduction (NSCR) 97% to 99.1% (1)

Selective Catalytic Reduction (SCR) 80% to 90% (2)

(1) EPA AP-42 Document, Volume 1 Fifth Edition

(2) EPA Document Number EPA-450/3-91-026

STEP – 4: Evaluate Impacts and Document the Results

Since the facility already employs NSCR to control NOx no additional control is necessary to 

meet BART. 

STEP – 5: Evaluate Visibility Impacts

Since existing control is the best available technology this step is NA. 

The primary purpose of this facility is to produce nitric acid. The CALPUFF NWS platform computer 

modeling found the total visibility impact of this facility to be 0.1 dv on the Dolly Sods Class 1 area. 

Upon reviewing the 2002 actual emissions of that facility it was determined that the NOx emissions from 

the ammonia oxidation plant make up the preponderance of the visibility impairing emissions from this 

facility. The ammonia oxidation plant currently uses non-selective catalytic reduction (NSCR) to control 

NOx emissions. This is the state of the art control technology for NOx from this type of source. 

According to AP-42 NSCR provides 97 to 99.1 percent NOx control efficiency over uncontrolled nitric 

acid plant NOx emissions. Since NSCR was found to be state of the art control technology for this type of 

source no cost effectiveness calculations were performed.

5. Conclusion:

Based on the five factor analysis, the impact of this facility does not warrant additional control. I 

recommend the following determination of BART for the Dyno-Nobel facility: compliance with the 

existing operating permit for this facility. The following emission limitations pertain to the ammonia 

oxidation plant. The current NOx limit is 396 tons in any 12 month period. Additionally, the current NO2

limit is 5.5 lbs/ton of acid production with the acid product expressed as 100% HNO3.

cc: Southwest Regional Office

Central Office

 
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

EME Homer City Generation LP

EME Homer City Generating Station

1750 Power Plant Road

Homer City, PA 15748-8009

TV Operating Permit #: 32-00055

To: Mark Wayner Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Southwest Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 
BART Application Review – EME Homer City Generating Station

Page 2 of 4

January 17, 2008

that an engineering analysis of VOC control options is not needed. EPA has determined that 

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

EME Homer City Generating Facility is an 1884 MW power plant with three BART affected coal

fired boilers, Units 1, 2 and 3. All three units have ESPs and Unit 3 has FGD. Unit 1 has a 

partially rebuilt ESP while the Unit 2 ESP is scheduled for the same rebuild in 2007. The facility 

used 2002 stack testing results for Unit 1 filterable PM10 emissions calculations and projected 

the same emission rate for Unit 2 calculations. The recalculated facilty wide filterable PM10 

emissions are as summarized below:

Unit 1 230.93 lbs/hr

Unit 2 230.93 lbs/hr

Unit 3 174.24 lbs/hr

631.1 lbs/hr = 2764 TPY @ 8760

3. BART Analysis

The facility did not use the NESCAUM provided PM10 filterable emmission visibility impact 

analysis based upon actual 2001 through 2003 emissions but instead substituted the above most 

current recalculated PM10 filterable emissions and reran the modelling using the BART-specific 

versions of CALMET and CALPUFF that were posted at http://www.src.com . The results of the 

facility conducted modelling are as summarized below:

 2001 2002 2003

Max 8th Max 8th Max 8th

24 hr highest 24 hr highest 24 hr highest

PSD Class 1 Area impact impact impact

Dolly Sods Wilderness Area dv 0.10 0.04 0.07 0.03 0.08 0.04

Otter Creek Wilderness Area dv 0.09 0.04 0.12 0.03 0.07 0.03

Shenandoah National Park dv 0.17 0.09 0.16 0.09 0.10 0.07

 

The facility expressed the opinion that these results as tabulated above are minimal and that no 

action should be required. The facilty did not do a technical feasibility or economic analysis for 

PM10 control technology options based on this opinion.

The Department considered a variety of filterable PM10 control technologies for use at all of 

Pennsylavania’s EGUs for BART purposes. These technologies included fuel related changes, 

ESP upgrades and enhancements, replacement of ESPs with fabric filters and the addition of 

Compact Hybrid Particualte Collectors (COHPAC)s. It was determined that where technically 

feasible, COHPAC would provide the most significant percent reduction of filterable PM10 

emissions at a cost that is significantly less than replacement of existing ESPs with enhanced 

ESPs or fabric filters. Other options provide lesser percent reductions at costs that do not justify 

the associated possible reductions. Since this facility did not do a technical feasibility study it is 
BART Application Review – EME Homer City Generating Station

Page 3 of 4

January 17, 2008

assummed that COHPAC is technically feasible and a basic cost analysis for this option has been 

performed. COHPAC installations will require the use of booster fans which will consume 

energy. The estimated useful life for this cost analysis was 20 years. The minimal representative 

costs used for this analysis to represent the applicable COHPAC annualized costs were derived 

from EPA-CICA Fact Sheet, Fabric Filter, Mechanical Shaker Cleaned Type. Here, the depicted 

minimum annualized cost is $5 per scfm in 1998 dollars and this is adjusted to $6 for 2007. This 

value is then reduced to $4 per scfm assumming that COHPAC annualized costs are 

approximately two thirds of fabric filter annualized costs due basically to the variance in air to 

cloth ratios. Using the facility provided facility-wide current annual filterable PM10 emission 

rate of 631.1 lbs/hr after existing or projected ESP control and assumming 8760 hrs/yr of 

operation, a COHPAC estimated efficiency of 80% and an annualized COHPAC cost of 

$18,800,000 for the three boiler total AIMS listed scfm of 4,700,000, the cost of additional 

filterable PM10 removed calculates to approximately $8,502 per ton. This cost is not justified 

where the maximum theoretical visibilty reduction would be approximately 0.17 deciview for the 

maximum 24 hr impact at Shenandoah National Park due to PM10 filterable emissions. The 

annualized cost of $18,800,000 translates to a minimum cost of $110,588,235/delta dv at the 

Shenandoah National Park. It also would not be cost effective at a modeled emission rate of 0.1 

lbs/MMBtu, the existing permit limit.

A three to five percent reduction from ESP enhancement would yield a 0.0051 to 0.0085 delta dv 

improvement respectively. Using a three unit 3 to 5 percent annualized cost range of $225,000 to 

$1,200,000 per year yields a dollar per deciview improvement cost range of $44,117,647 to 

$141,176,470/delta dv.

4. Permit Conditions

TV Permit # 32-00055 together with the planned ESP upgrade for the Unit 2 requires the control 

equipment that achieves the actual emission rates used for this analysis. Therefore, the present 

permit condition of 0.1 lb/MMBtu along with the implementation of EGU CAIR requirements 

satisfy BART requirements for this facility. 
BART Application Review – EME Homer City Generating Station

Page 4 of 4

January 17, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

The Department considered a variety of filterable PM10 control technologies for use at all of 

Pennsylavania’s EGUs for BART purposes. These technologies included fuel related changes, 

ESP upgrades and enhancements, replacement of ESPs with fabric filters and the addition of 

Compact Hybrid Particualte Collectors (COHPAC)s. 

Step 2 – Eliminate Technically Infeasible Options.

It was determined that where technically feasible, COHPAC would provide the most significant 

percent reduction of filterable PM10 emissions at a cost that is significantly less than 

replacement of existing ESPs with enhanced ESPs or fabric filters. Other options provide lesser 

percent reductions at costs that do not justify the associated possible reductions.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

A COHPAC efficiency of 80% of the remaining filterable particulate matter after existing 

controls was assumed.

Step 4 – Evaluate Impacts and Document the Results.

COHPAC installations will require the use of booster fans which will consume energy. The 

estimated useful life for this cost analysis was 20 years. The minimal representative costs used 

for this analysis to represent the applicable COHPAC annualized costs were derived from EPACICA Fact Sheet, Fabric Filter, Mechanical Shaker Cleaned Type. Here, the depicted minimum 

annualized cost is $5 per scfm in 1998 dollars and this is adjusted to $6 for 2007. This value is 

then reduced to $4 per scfm assumming that COHPAC annualized costs are approximately two 

thirds of fabric filter annualized costs due basically to the variance in air to cloth ratios. Using 

the facility provided facility-wide current annual filterable PM10 emission rate of 631.1 lbs/hr 

after existing or projected ESP control and assumming 8760 hrs/yr of operation, a COHPAC 

estimated efficiency of 80% and an annualized COHPAC cost of $18,800,000 for the three boiler 

total AIMS listed scfm of 4,700,000, the cost of additional filterable PM10 removed calculates to 

approximately $8,502 per ton. 

Step 5 – Evaluate Visibility Impacts.

This cost is not justified where the maximum theoretical visibilty reduction would be 

approximately 0.17 deciview for the maximum 24 hr impact at Shenandoah National Park due to 

PM10 filterable emissions. The annualized cost of $18,800,000 translates to a minimum cost of 

$110,588,235/delta dv at the Shenandoah National Park.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

June 13, 2008

Subject: Review Memo for BART Application

Essroc Cement Corporation

P.O. Box 779

Bessemer, PA 16112

Operating Permit #: 37-00003

To: John Guth Joyce Epps

Environmental Program Manager Bureau Director

Northwest Regional Office Bureau of Air Quality

From: Daniel C. Husted, P.E., Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 
BART Application Review – Essroc/Bessemer Facility

Page 2 of 7

February 6, 2008

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment 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 use of the 

technology. 

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to Essroc 

Cement/Bessemer Plant indicated that an engineering analysis of VOC control options was not 

needed, because the relationship of VOC and NOx could not be quantified. In addition, the 

Department did not require an engineering analysis for pollutants with a combined potential to emit

less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 tons per year of 

PM10, because of the small effect on visibility.

2. Process Description:

Essroc Cement/Bessemer Plant is a portland cement production plant. Clinker Kiln Number 5 

kiln is a long, wet, cement kiln. This kiln and associated equipment are affected units. Fuel is 

fed to the kiln by a direct firing system.

The primary purpose of this facility is to convert limestone and other component materials into 

portland cement. Clinker Kiln Number 5 has one downstream control device, an electrostatic 

precipitator, processing the kiln flue gas.

The following are source ID numbers of the affected units.

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

502 – Clinker Kiln Number 5 1,604.50 118.03 516.60

212 – Stone Storage Building 0.00 4.92 0.00

225 – Crane Transfer System 0.00 1.32 0.00

504 – #5 Clinker Cooler 0.00 38.13 0.00

511 – #5 Clinker Storage Tank 0.00 2.04 0.00

512 – #5 Clinker Loadout 0.00 2.04 0.00
BART Application Review – Essroc/Bessemer Facility

Page 3 of 7

February 6, 2008

604 – #14 Clinker and Gypsum Bins 0.00 9.14 0.00

605 – #16 Clinker and Gypsum Bins 0.00 8.90 0.00

Total: 1,604.50 184.52 516.60

3. NESCAUM CALPUFF Modeling:

Essroc Cement/Bessemer Plant has eight (8) emission units at this facility originally constructed 

between the specified dates in 1962 and 1977. The total emissions from the date-eligible units of 

a single visibility impairing pollutant are over 250 tons per year, making all date-eligible units 

subject to the BART requirements that are a part of the Regional Haze rules specified in 40 CFR 

part 51, subpart P, Protection of Visibility.

Based upon NESCAUM CALPUFF modeling the maximum combined impact on a Class I area 

was 0.301 deciview (dv). This impact is on the Shenandoah National Park.

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

502 Shenandoah 0.296 0.073 0.218 0.007

212 0.000 0.000 0.000 0.000

225 0.000 0.000 0.000 0.000

504 Shenandoah 0.003 0.000 0.000 0.000

511 0.000 0.000 0.000 0.000

512 0.000 0.000 0.000 0.000

604 0.000 0.000 0.000 0.000

605 0.000 0.000 0.000 0.000

Total: 0.301 0.073 0.218 0.012

Upon reviewing actual emissions of this facility it was determined that the emissions from the 

Clinker Kiln Number 5 (Source ID #502) make up the preponderance of the affected visibility 

impairing emissions.
BART Application Review – Essroc/Bessemer Facility

Page 4 of 7

February 6, 2008

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate.

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.
BART Application Review – Essroc/Bessemer Facility

Page 5 of 7

February 6, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3 lists all available control technologies on the Essroc\Bessemer Clinker Kiln Number 5 

for control of SO2 and NOx. Essroc Cement Company conducted ambient modeling and 

visibility analysis for the period 2001 through 2003 at Class 1 areas affected by this facility. 

Visibility improvement is based on the company analysis. Emission control system costs, other 

than the Wet Scrubber, were based on size-corrected averages of other company submittals.

Table 3 - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Essroc\Bessemer Clinker Kiln Number 5

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control 

Technology

% 

Control

Maximum 

Visibility 

Improvement 

dv

Control Cost

$ per Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 517 Dry Injection 40% 0.029 7,045 50,432,103

SO2 517 Semi-Dry 82% 0.060 16,048 113,352,167

SO2 517 Wet Scrubber 80% 0.058 32,370 230,649,690

NOx 1,605 Indirect Firing 18% 0.039 33,479 253,224,410

NOx 1,605 Low NOx Burner 20% 0.044 1,318 9,612,931

NOx 1,605 SNCR 35% 0.076 1,014 7,494,026

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by an electrostatic precipitator (ESP). The degree of visibility improvement that could 

be obtained by requiring additional particulate matter controls on this kiln is so small that no 

reasonable weighting of the five factors required by consideration in the BART analysis could 

justify additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a cement kiln. The SDA/FF or Semi-Dry Control Technology was removed 

from consideration due to technical infeasibility.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

On long kilns, this temperature may move along the axis of the kiln with time, causing injection 
BART Application Review – Essroc/Bessemer Facility

Page 6 of 7

February 6, 2008

to take place outside of the temperature range. SNCR has not been used full time on long wet or 

long dry kiln systems.

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted. The 

USEPA RACT/BACT/LAER Clearinghouse lists no long cement kiln, either wet or dry, with 

NOx controlled by a SNCR system. It has been reported that SNCR has been proposed for NOx 

control as BART on a long cement kiln in the US. While there several technical issues 

associated with the installation of SNCR for long kilns, economic and impact analyses were 

performed for this control option. A NOx reduction of 35% was used for SNCR on long kilns 

based on the July 2006 ERG report to the Texas Commission on Environmental Quality. They 

used this reduction since SNCR control on long kilns is considered Innovative and available data 

is limited.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 40% to 

82%. Removal efficiencies of the technically feasible NOx control technologies range from 18% 

to 35%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Wet Scrubber system for Kiln 5 is $32,370 per ton of actual SO2 

removed. The estimated cost of a Semi-Dry system for the kiln is $16,048 per ton of actual SO2 

removed. The estimated cost of a Dry Injection system for Kiln 5 is $7,045 per ton of actual SO2 

removed. These SO2 control systems are considered too expensive to be considered as control 

for BART at the level of improvement determined for the most affected Class I area (Shenandoah 

National Park).

The estimated cost of Indirect Firing is $33,479 per ton of NOx removed and is considered too 

expensive to be considered as control for BART at the level of improvement produced and was 

determined to be economically infeasible. The estimated cost of Low NOx Burning is $1,318 per 

ton of NOx removed. The estimated cost of SNCR is $1,014 per ton of NOx removed.

In addition, a Wet Scrubber has significant energy requirements and produces a sludge that must 

be treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area was 

0.060 dv. The minimum cost of improvement was $50,432,103 annually per deciview. 

Therefore, I do not recommend any additional control of SO2 as a result of the BART analysis. 

The current operating permit limitation for SO2 emissions from the kiln is 500 ppm by volume.
BART Application Review – Essroc/Bessemer Facility

Page 7 of 7

February 6, 2008

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Shenandoah National Park) was 0.076 dv. The minimum cost of improvement was 

$7,494,026 annually per deciview. Therefore, I do not recommend any additional control of 

NOx as a result of the BART analysis. The current operating permit limitation for NOx 

emissions from Clinker Kiln Number 5 is 476 pounds per hour.

5. Conclusion:

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control to meet the BART requirements. Thus, this 

reviewer concludes that no additional emission control equipment for BART is warranted at this 

location. Therefore, the existing permit limits will meet the requirements for BART.

cc: Northwest Regional Office

Central Office
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

June 27, 2008

Subject: Review Memo for BART Application

Exelon Power

Eddystone Generating Station

1 Industrial Highway

Eddystone, PA 19022-1524

TV Operating Permit #: 23-00017

To: James Rebarchak Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Southeast Regional Office

From: Joseph R. White, Environmental Engineer Manager

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 
BART Application Review – Exelon Power, Eddystone Generating Station

Page 2 of 3

June 27, 2008, 2008

that an engineering analysis of VOC control options is not needed. EPA has determined that 

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

Eddystone Generating Station has identified two BART affected boilers, Units 3 and 4, rated at 

an input capacity of 4,116 MMBTU/hr each, both fired on #6 oil, #2 oil, natural gas or waste 

derived fuel. Neither unit presently has any control devices. Both units presently operate using 

good combustion pratcies and low sulfur fuels.

3. BART Analysis

The facility provided cost analysis data for the only technically feasible option for removal of 

filterable PM10 emissions from #6 oil-fired boilers, an ESP. Fabric Filters are not desirable for 

use on oil-fired boilers. The estimated useful life for this cost analysis was 20 years. The facility 

assumed a 98% filterable PM10 control efficiency reducing the filterable PM10 emission rate 

from 299.1 lbs/hr to 2.1 lbs/hr for a total filterable PM10 emissions reduction of 1,300.9 tons per 

year resulting in a cost of $9,985.2/ton reduction for both boilers. The annualized cost was 

calculated to be $12,989,308 for two ESPs with one common stack.

The facility’s NESCAUM CALPUFF modeling results indicate a 0.146 delta deciview 

improvement for the maximum 24-hr impact at the Brigantine Wilderness area. 

At an annualized cost of $12,989,308 the cost per deciview decrease is $88,967,863/delta dv at 

the Brigantine Wilderness Area utilizing the maximum 0.19 delta deciview effect controlled to a 

98 % efficiency as displayed in Tables 6-1 and 6-2 of their submittal. This analysis indicates that 

it would not be cost effective to require this control option to achieve the modeled delta deciview 

impact. It would also not be cost effective at the permit emission level of 0.1 lb/MMBTU. 

4. Permit Conditions

TV Permit # 23-00017 that requires the use of low sulfur fuels along with the implementation of 

EGU CAIR requirements and the existing permit level of 0.1 lbs/MMBtu meet the requirements 

for BART at this facility.
BART Application Review – Exelon Power, Eddystone Generating Station

Page 3 of 3

June 27, 2008, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Electrostatic Precipitators, Fabric Filters, Mechanical Collectors, Wet Scrubbers

Step 2 – Eliminate Technically Infeasible Options.

Fabric Filters not compatible with oil-fired boilers, Mechanical Collectors designed for larger 

particulate matter.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

The facility assumed a 98% filterable PM10 control efficiency reducing the filterable PM10 

emission rate from 299.1 lbs/hr to 2.1 lbs/hr for a total filterable PM10 emissions reduction of 

1,300.9 tons per year

Step 4 – Evaluate Impacts and Document the Results.

The estimated useful life for this cost analysis was 20 years. The facility assumed a 98% 

filterable PM10 control efficiency reducing the filterable PM10 emission rate from 299.1 lbs/hr 

to 2.1 lbs/hr for a total filterable PM10 emissions reduction of 1,300.9 tons per year resulting in a 

cost of $9,985.2/ton reduction for both boilers. The annualized cost was calculated to be 

$12,989,308 for two ESPs with one common stack.

Step 5 – Evaluate Visibility Impacts.

The facility’s CALPUFF modeling results indicate a 0.092 delta deciview impact for the 

maximum 24-hr impact over a 3-year period, 22nd highest at the Brigantine WA and 0.016 delta 

deciview impact for the maximum 24-hr impact over a 3-year period, 22nd highest at the 

Shenandoah NP. The uncontrolled impact is 0.119 dv at Brigantine and 0.021dv at Shenandoah. 

However, these results are based upon one year's worth of modeling data

At an annualized cost of $12,989,308 / (0.190 dv - 0.044 dv) the cost per deciview decrease is 

$88,967,863/delta dv at the Brigantine Wilderness Area utilizing the maximum 0.19 worst day 

delta deciview effect controlled to a 98 % efficiency as displayed in Tables 6-1 and 6-2 of the 

Exelon submittal. This analysis indicates that it would not be cost effective to require this 

control option to achieve the modeled delta deciview impact improvement for the single worst 

day. 

 
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

First Energy Generation Corp., Bruce Mansfield

SR 168 S

Shippingport, PA 15077

TV Operating Permit #: 04-00235

To: Mark Wayner Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Southwest Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 

that an engineering analysis of VOC control options is not needed. EPA has determined that 
BART Application Review – First Energy Generation Corp., Bruce Mansfield

Page 2 of 3

January 17, 2008

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

First Energy Generation Corporation, Bruce Mansfield is an 2741 MW power plant with three 

BART affected coal fired boilers, Units 1, 2 and 3. Units 1 and 2 have scrubber trains rated at 

99% PM10 efficiencies and 92.1 % SO2 efficiencies. Unit 3 has 95 % PM10 control ESPs in 

series with 92% PM10 and 96 % SO2 absorbers. The facility has installed low NOx burners and 

SCR which is presently operated during the ozone season. The facility reported the 2005 PM10 

filterable emissions as reflective of their latest configurations. They are as follows:

Unit 1 179.4 tpy

Unit 2 237.3 tpy

Unit 3 298.7 tpy

3. BART Analysis

The facility performed the following feasibility and cost analysis: Due to space constraints an 

add-on wet ESP is the only feasible control technology. There would be some pressure drop 

which may require the use of booster fans to overcome and this would consume some power. 

Assumming 90 % PM10 efficiency and an annual cost of 73.12 million dollars per unit, for Unit 

1 the cost would be $453,036 per ton of PM10 removed, for Unit 2 the cost would be $343,322 

per ton and for Unit 3 the cost would be $271,993. The annual cost calculates to $219,360,000 

for all three units. The estimated useful life for this cost analysis was 20 years.

The facility indicated that the CALPUFF data show that the maximum 24-hour deciview impact 

from Bruce Mansfield’s combined PM10 filterable emissions from Units 1, 2 and 3 is 0.011 

deciview for Otter Creek and 0.006 deciview for Dolly Sods as reported by NESCAUM. The 

lowest cost dv estimate is $2,215,757,576/delta dv at Otter Creek.

This analysis indicates that it would not be cost effective to require this control option to achieve 

this modeled delta deciview impact. This would also be true at the existing permit limit of 0.1 

lbs/MMBtu.

Unit 3 is the only unit where ESP upgrade or enhancement could be considered. The existing dv 

impact from Unit 3 alone would be 0.005 dv. A three to five percent reduction from ESP 

enhancement would yield a 0.00015 to 0.00025 delta dv improvement respectively. Using a 3 to 

5 percent annualized cost range of $75,000 to $400,000 per year yields a dollar per deciview 

improvement cost range of $ 500,000,000 to 1,600,000,000/delta dv.

4. Permit Conditions

The control equipment described in this analysis is required by TV Permit # 04-00235. The 

conditions of this permit, including the permit limit of 0.1 lbs/MMBtu, along with the 

implementation of EGU CAIR requirements, satisfy BART requirements for this facility.
BART Application Review – First Energy Generation Corp., Bruce Mansfield

Page 3 of 3

January 17, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Fuel-related modifications, ESP upgrades, enhancements or replacement, replacement of the 

ESPs with fabric filters or compact hybrid particulate collectors (COHPAC)

Step 2 – Eliminate Technically Infeasible Options.

Due to space constraints a wet ESP is the only feasible control technology. 

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

A 90% Wet ESP control device efficiency was assummed for this analysis.

Step 4 – Evaluate Impacts and Document the Results.

There would be some pressure drop which may require the use of booster fans to overcome and 

this would consume some power. Assumming 90 % PM10 efficiency, for Unit 1 the cost would 

be $453,036 per ton, for Unit 2 the cost would be $343,322 per ton and for Unit 3 the cost would 

be $271,993. The annual cost calculated to $219,360,000 for all three units. The estimated 

useful life for this cost analysis was 20 years. 

Step 5 – Evaluate Visibility Impacts.

The facility indicated that the CALPUFF data show that the maximum 24-hour deciview impact 

from Bruce Mansfield’s combined PM10 filterable emissions from Units 1, 2 and 3 is 0.011 

deciview for Otter Creek and 0.006 deciview for Dolly Sods. The lowest cost estimate is 

$1,994,181,818/delta dv at Otter Creek. This analysis indicates that it would not be cost 

effective to require this control option to achieve this modeled delta deciview impact.

 
 COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

ISG Plate Llc/Coatesville June 11, 2008

139 Modena Rd.

Coatesville, PA 19320

Operating Permit #: 15-00010

To: Francine Carlini Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control Southeast Regional Office 

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to contain 

emission limitations representing Best Available Retrofit Technology (BART) for certain sources that may 

reasonably be anticipated to cause or contribute to visibility impairment at a Class I area. The BART 

requirements apply to units that were in existence on August 7, 1977 but were not in operation before 

August 7, 1962 that collectively, at a facility, have the potential to emit more than 250 tons per year of a 

visibility impairing pollutant. Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. 

VOC and NH3 may be visibility-impairing pollutants; however the Department has determined that 

modeling tools to assess the visibility impacts from VOC and NH3 adequately are not available at this 

time. The BART requirements only apply to sources in 26 specific categories listed in the Clean Air Act.

States are required to make a determination of BART for each source subject to BART based on an 

analysis of the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the costs of 

compliance, the energy and non-air quality environmental impacts, any pollution control equipment 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 use of the technology. 

PA DEP requested that Pennsylvania sources subject to BART conduct the BART analysis required by the 

Regional Haze rule and submit a BART proposal. 
2. Process Description:

ISG Plate is an electric arc furnace steel production plant. 

The following are the Source ID numbers of the affected units. 

 TABLE I 2002 Actual Emissions

 UNIT NOx (tpy) PM10 (tpy) SO2 (tpy) 

033 Br. Boilers: BH-B&W #3&4 3.9 0.1 0

034 Brandy Boiler: BH-B&W #4 0 0 0

104 /D/ Electric Furnace 82.1 67.4 207.8

142 #8 Batch heat Treat Furnace 0 0 0

159 Soaking Pit #35 0 0 0

160 Soaking Pit #36 0 0 0

161 37 Soaking Pit 140-206M 0 0 0

174 Green Anneal Grit Blaster & Baghouse 0 4.5 0

176 Vert. Blast Cont. Fin. & Baghouse 0 0.1 0

181 South Steel Yard & Baghouse 0 0.3 0

182 ACA Powder Cutting & Baghouse 0 6.2 0

183 Misc. Processes & Gas Use (10) 32.5 1.0 0.2

207 ICA Hot Top Cut Station & Baghouse 0 0.5 0

256 Steel Plate Acid Wash and Scrubber 0.2 0 0

270 Continuous Casting Spray Chamber 0 0 0

Total: 118.7 80.1 208

3. NESCAUM/CALPUFF Modeling:

ISG Plate has emission units at this facility that were originally constructed between 1962 and 1977. The 

total emissions from the date-eligible units of a single visibility impairing pollutant is over 250 tons per 

year, making all date-eligible units subject to the BART requirements that are a part of the Regional Haze 

rules specified in 40 CFR part 51, subpart P Protection of Visibility. 

Based upon the NESCAUM CALPUFF modeling, the maximum combined impact of these units on a 

Class I area was 0.055 deciviews (dv). This impact is on the Brigantine wildlife area. 
3

The visibility impact of the units with respect to the Class I area affected is described in Tables 2 and 3. 

Table 2 contains the visibility impact modeled with the National Weather Service (NWS) platform and 

Table 3 contains the visibility impact modeled with the University of Maryland (MM5) platform. 

TABLE 2. Maximum Daily Impact NWS Platform (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

033 Brigantine 0.002 0.000 0.002 0.000

034 Brigantine 0.001 0.000 0.001 0.000

104 Brigantine 0.031 0.012 0.022 0.000

142 Brigantine 0.000 0.000 0.000 0.000

159 Brigantine 0.001 0.000 0.001 0.000

160 Brigantine 0.002 0.000 0.002 0.000

Brigantine 0.001 0.000 0.001 0.000

161 Brigantine 0.001 0.000 0.001 0.000

Brigantine 0.001 0.000 0.001 0.000

174 Brigantine 0.000 0.000 0.000 0.000

176 Brigantine 0.000 0.000 0.000 0.000

181 Brigantine 0.000 0.000 0.000 0.000

182 Brigantine 0.000 0.000 0.000 0.000

183 Brigantine 0.010 0.000 0.010 0.000

207 Brigantine 0.000 0.000 0.000 0.000

256 Brigantine 0.004 0.000 0.004 0.000

270 Brigantine 0.000 0.000 0.000 0.000

Total: 0.053

TABLE 3. Maximum Daily Impact MM5 Platform (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

033 Brigantine N/A N/A N/A N/A

034 Brigantine N/A N/A N/A N/A

104 Brigantine 0.050 0.033 0.018 0.000

142 Brigantine N/A N/A N/A N/A

159 Brigantine N/A N/A N/A N/A

160 Brigantine N/A N/A N/A N/A

Brigantine N/A N/A N/A N/A

161 Brigantine N/A N/A N/A N/A

Brigantine N/A N/A N/A N/A

174 Brigantine N/A N/A N/A N/A

176 Brigantine N/A N/A N/A N/A

181 Brigantine N/A N/A N/A N/A

182 Brigantine N/A N/A N/A N/A

183 Brigantine 0.006 0.000 0.006 0.000

207 Brigantine N/A N/A N/A N/A

256 Brigantine 0.002 0.000 0.002 0.000

270 Brigantine N/A N/A N/A N/A

Generic Stack 0.006 0.000 0.006 0.000
Total: 0.055

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART Determinations 

Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making BART 

determinations that States can use in implementing the regional haze BART requirements on a source-by- source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania must follow the guidelines in making 

BART determinations on a source-by-source basis for 750 megawatt (MW) power plants, but are not 

required to use the process in the guidelines when making BART determinations for other types of 

sources. As a result, Pennsylvania retains the discretion to deviate from the guidelines as appropriate. 

 

The Department’s BART analysis took into account each of the five statutory factors required by the Clean 

Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory factors for BART were codified at 40 CFR 

51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used the BART 

determination process under the guidelines to do the following: conduct an analysis of emissions control 

alternatives, which includes the identification of available, technically feasible retrofit technologies, and 

for each technology identified, an analysis of the cost of compliance, the energy and non-air quality 

environmental impacts, and the degree of visibility improvement in affected Class I areas resulting from 

the use of the control technology. As part of the BART analysis, Pennsylvania took into account the 

remaining useful life of the source and any existing control technology present at the source. For each 

source, Pennsylvania determined a “best system of continuous emission reduction” based upon its 

evaluation of these factors. Pennsylvania also established emission limits, including a deadline for 

compliance, consistent with the BART determination process for each source subject to BART. Below 

is the five factor analysis, in detail, for the emissions unit at this facility which had the greatest impact. 

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Electric Arc Furnace

SO2 NOx

Wet Scrubber Selective Catalytic Reduction

Selective Non-Catalytic Reduction

STEP – 2: Eliminate Technically Infeasible Options Identified under Step 1

Both NOx options were technically infeasible. Based on the RACT/BACT/LAER Clearinghouse 

(RBLC) no other steel making facilities utilize these controls technologies. Thus, neither of 

these technologies are in use on full scale operational electric arc furnaces. 

Wet scrubbing was determined to be technologically feasible.
5

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Electric Arc Furnace Control Effectiveness

Wet Scrubbing 90% 

STEP – 4: Evaluate Impacts and Document the Results

It was determined that the cost of control for this device was not cost effective considering the 

commensurate visibility improvement. 

Electric Arc Furnace

(SO2)

Cost Effectiveness ($/ton) Cost of Visibility 

Improvement 

($/dv)

$9,023/ton to

$173,243/ton

$250,545,000/dv to 

$4,818,181,818/dv

The existing useful life of this facility was not a factor since the facility is not expected to close 

within the expected life span of the control equipment. There are potentially significant energy 

impacts due to the increased energy at the facility to operate a wet scrubber. The waste stream 

from the scrubber would qualify as a non-air quality impact. This waste stream would need to be 

treated and would pose an additional burden to the facility. 

STEP – 5: Evaluate Visibility Impacts

The total deciview impact of the electric arc furnace attributable to SO2 was modeled to be 0.033 

dv. The cost in terms of dollars per deciview for installing a dry flue gas desulfurization system 

at this facility was calculated to be from $250,545,454/dv to $4,818,181,818/dv. 

The CALPUFF NWS platform computer modeling found the total visibility impact of this facility to be 

0.055 dv on the Brigantine Class I area. 

Cost effectiveness calculations were not generated for NOx controls since none were found to be 

technically feasible for electric arc furnaces. No application of NOx control for electric arc furnaces was 

found in the RBLC. A wet scrubber is technically feasible for the control of SO2 emissions from this 

source. The cost effectiveness numbers for SO2 control in this memo were calculated using information 

from EPA’s Air Pollution Control Fact Sheet (EPA-452/F-03-016) for wet scrubbers. I estimated the 

cost effectiveness for installing a wet scrubber system to control S02 to be from $9,022/ton to 

$173,244/ton. These calculations are based on 2004 actual emissions. Thus, the dollars per deciview 

cost would range from 250 million dollars per deciview to 4,818 million dollars per deciview. Even at 

the low cost end of this range this control was determined not to be cost effective. 
5. Conclusion:

Based on the five factor analysis, the impact of this facility does not warrant additional control. I 

recommend the following determination of BART: compliance with the existing operating permit for 

this facility. The current SO2 limit from the electric arc furnace is 500 parts per million dry 

concentration based on volume. The current particulate matter limit from this unit through the main 

Baghouse E is 0.0052 grains per dry standard cubic feet. The current particulate matter limit from this 

unit through Baghouses A, B, and D is 0.02 grains per dry standard cubic foot. 

cc: Southeast Regional Office

Central Office

.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

February 5, 2008

Subject: Review Memo for BART Application

Keystone Cement Company

Route 329, Drawer A

Bath, PA 18014

Operating Permit #: 48-00003

To: Mark Wejkszner Joyce Epps

Environmental Program Manager Bureau Director

Northeast Regional Office Bureau of Air Quality

From: Martin L. Hochhauser, P.E., Air Quality Engineering Specialist

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 
BART Application Review – Keystone/East Allen Facility

Page 2 of 7

February 5, 2008

equipment 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 use of the 

technology. 

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to Keystone 

Portland Cement/East Allen Plant indicated that an engineering analysis of VOC control options 

was not needed, because the relationship of VOC and particulate could not be quantified. In 

addition, the Department did not require an engineering analysis for pollutants with a combined 

potential to emit less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 

tons per year of PM10, because of the small effect on visibility.

2. Process Description:

The Keystone Portland Cement/East Allen Plant is a portland cement production plant. Kiln 

Number 2 at the facility is a long, wet, cement kiln. Kiln Number 2 and associated equipment 

are affected units. Fuel is fed to this kiln by a direct firing system. 

The primary purpose of this facility is to convert limestone and other component materials into 

portland cement. This kiln has one downstream control device, a fabric filter, processing the kiln 

flue gas.

The following are the source ID numbers of the affected units.

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

102 – Cement Kiln Number 2 1,315.60 122.60 2,027.30

127 – Stone Plant 0.00 9.70 0.00

Total: 1,315.60 132.30 2,027.30
BART Application Review – Keystone/East Allen Facility

Page 3 of 7

February 5, 2008

3. NESCAUM CALPUFF Modeling:

Keystone Portland Cement/East Allen Plant has two (2) emission units at this facility originally 

constructed between the specified dates in 1962 and 1977 that may continue operating after 

January 1, 2013. The total emissions from the date-eligible units of a single visibility impairing 

pollutant are over 250 tons per year, making all date-eligible units subject to the BART 

requirements that are a part of the Regional Haze rules specified in 40 CFR part 51, subpart P, 

Protection of Visibility.

Based upon NESCAUM CALPUFF modeling the maximum combined impact on a Class I area 

was 0.378 deciview (dv). This impact is on the Brigantine Wilderness Area.

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

102 Brigantine 0.378 0.226 0.181 0.009

127 Brigantine 0.001 0.001 0.000 0.001

Total: 0.378 0.226 0.181 0.009

Upon reviewing actual emissions of this facility it was determined that the emissions from the 

Cement Kiln Number 2 (Source ID #102) make up the preponderance of the affected visibility 

impairing emissions.
BART Application Review – Keystone/East Allen Facility

Page 4 of 7

February 5, 2008

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate.

The Department’s BART analysis took into account each of the five statutory factors required by

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.
BART Application Review – Keystone/East Allen Facility

Page 5 of 7

February 5, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3 lists all available control technologies on the Keystone Unit 2 Cement Kiln for control of 

SO2 and NOx. Keystone Cement Company conducted ambient modeling and visibility analysis 

for the period 2001 through 2003 at Class 1 areas affected by this facility. Visibility 

improvement is based on the company analysis. SNCR costs were based on a size-corrected 

average of other submittals.

Table 3 - Available Retrofit Control Technologies for BART Evaluation

Emission Unit - Keystone - Unit 2

Pollutant

Uncontrolled 

Emission 

Rate TPY 

(2002EI)

Control Technology

Emission 

Control 

%

98th 

Percentile 

Maximum 

Visibility 

Improvement 

dv

Control Cost

$ per Ton 

Controlled

Annual $ per 

dv 

Improvement

SO2 2,027 Dry Injection 50% 0.044 8,894 205,490,868

SO2 2,027 Semi-Dry 90% 0.079 5,404 124,847,548

SO2 2,027 Wet Scrubber 90% 0.079 2,224 51,380,361

NOx 1,316 Indirect Firing 20% 0.011 2,796 64,590,816

NOx 1,316 Low NOx Burner 20% 0.011 874 20,196,626

NOx 1,316 Staged Air Combustion 20% 0.011 1,066 24,635,624

NOx 1,316 SNCR 35% 0.020 1,014 23,431,248

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by a fabric filter (FF). The degree of visibility improvement that could be obtained by 

requiring additional particulate matter controls on this kiln is so small that no reasonable 

weighting of the five factors required by consideration in the BART analysis could justify 

additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a cement kiln. The SDA/FF or Semi-Dry Control Technology was removed 

from consideration due to technical infeasibility.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

On long kilns, this temperature may move along the axis of the kiln with time, causing injection 
BART Application Review – Keystone/East Allen Facility

Page 6 of 7

February 5, 2008

to take place outside of the temperature range. SNCR has not been used full time on long wet or 

long dry kiln systems.

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted. The 

USEPA RACT/BACT/LAER Clearinghouse lists no long cement kiln, either wet or dry, with 

NOx controlled by a SNCR system. It has been reported that SNCR has been proposed for NOx 

control as BART on a long cement kiln in the US. While there several technical issues 

associated with the installation of SNCR for long kilns, economic and impact analyses were 

performed for this control option. A NOx reduction of 35% was used for SNCR on long kilns 

based on the July 2006 ERG report to the Texas Commission on Environmental Quality. They 

used this reduction since SNCR control on long kilns is considered Innovative and available data 

is limited.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 50% to 

90%. Removal efficiencies of the technically feasible NOx control technologies range from 20% 

to 35%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Dry Injection system for Kiln 2 is $8,894 per ton of actual SO2 removed. 

The estimated cost of a Semi-Dry system for Kiln 2 is $5,404 per ton of actual SO2 removed. 

The estimated cost of a Wet Scrubber system for Kiln 2 is $2,224 per ton of actual SO2 removed. 

These control systems are considered too expensive to be considered as control for BART at the 

level of improvement determined for the most affected Class I area (Brigantine Wilderness 

Area).

The estimated cost of Indirect Firing is $2,796 per ton of NOx removed and is considered too 

expensive to be considered as control for BART at the level of improvement produced and 

determined Economically Infeasible. The estimated cost of Low NOx Burning is $874 per ton of 

NOx removed. The estimated cost of Staged Air Combustion is $1,066 per ton of NOx removed.

The estimated cost of SNCR is $1,014 per ton of NOx removed.

In addition, a Wet Scrubber has significant energy requirements and produces a sludge that must 

be treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area was 

0.079 dv. The minimum cost of improvement was $51,380,000 annually per deciview. 
BART Application Review – Keystone/East Allen Facility

Page 7 of 7

February 5, 2008

Therefore I do not recommend any additional control of SO2 as a result of the BART analysis. 

The current operating permit limitation for SO2 emissions from the kiln is 500 ppm by volume.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Brigantine Wilderness Area) was 0.020 dv. The minimum cost of improvement was 

$20,197,000 annually per deciview, for lesser improvement. Therefore I do not recommend any 

additional control of NOx as a result of the BART analysis. The current operating permit NOx 

emission limitation from the kiln is 529.0 pounds per hour.

5. Conclusion:

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control to meet the BART requirements. Thus, this 

reviewer concludes that no additional emission control equipment for BART is warranted at this 

location. Therefore, the existing permit limits will meet the requirements for BART.

cc: Northeast Regional Office

Central Office
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

February 5, 2008

Subject: Review Memo for BART Application

Lafarge Corp/Whitehall Plant

5160 Main St.

Whitehall, PA 18052-1827

Operating Permit #: 39-00011

To: Mark Wejkszner Joyce Epps

Environmental Program Manager Bureau Director

Northeast Regional Office Bureau of Air Quality

From: Martin L. Hochhauser, P.E., Air Quality Engineering Specialist

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 
BART Application Review – Lafarge Corp/Whitehall Facility

Page 2 of 10

February 5, 2008

equipment 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 use of the 

technology. 

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to Lafarge 

Corp./Whitehall Plant indicated that an engineering analysis of VOC control options was not 

needed, because the relationship of VOC and particulate could not be quantified. In addition, the 

Department did not require an engineering analysis for pollutants with a combined potential to emit 

less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 tons per year of 

PM10, because of the small effect on visibility.

2. Process Description:

Lafarge Corp./Whitehall Plant is a portland cement production plant. Kilns K-2 and K-3 at the 

facility and associated equipment are affected units. These kilns are dry kilns with preheaters. 

Each kiln has fuel fed to it by a direct firing system.

The primary purpose of this facility is to convert limestone and other component materials into 

portland cement. Each of these kilns, K-2 and K-3, has a downstream control device, a fabric 

filter processing the kiln flue gas. 

The following are the source ID numbers of the affected units.

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

101 – Kiln K-2 692.10 1.60 813.20

114 – Kiln K-3 410.70 0.9 496.60

103 – K-2 Cooler 0.00 2.60 0.00

112 – H3/H4 Silo 0.00 1.90 0.00

113 – K-2 Dust Return System 0.00 0.70 0.00

115 – K-3 Cooler 0.00 1.90 0.00

118 – C-1 Clinker Silo 0.00 0.40 0.00
BART Application Review – Lafarge Corp/Whitehall Facility

Page 3 of 10

February 5, 2008

119 – C-2 Clinker Silo 0.00 0.40 0.00

120 – C-5 Clinker Silo 0.00 0.40 0.00

121 – C-6 Clinker Silo 0.00 0.40 0.00

122 – #2 Finish Mill OSEPA 0.00 3.00 0.00

123 – Clinkers Silos Collector 0.00 3.00 0.00

124 – K-3 Clinker Tower 0.00 1.70 0.00

125 – K-3 Clinker Transfer Tower 0.00 1.70 0.00

127 – #1 Finish Grinding Mill 0.00 2.80 0.00

128 – #2 Finish Grinding Mill 0.00 5.40 0.00

129 – #2 Finish Mill Auxiliaries 0.00 3.70 0.00

135 – H5/H6 Silo 0.00 4.00 0.00

137 – #1 Finish Mill Auxiliaries 0.00 3.10 0.00

140 – Bulk Silos Lane #1 0.00 0.03 0.00

141 – Bulk Silos Lane #2 0.00 0.03 0.00

143 – Coal Mill #2 0.00 3.40 0.00

144 – Coal Mill #3 0.00 3.70 0.00

Total: 1,102.80 46.76 1,309.80

3. NESCAUM CALPUFF Modeling:

LaFarge Corp./Whitehall has twenty-three (23) emission units at this facility originally 

constructed between the specified dates in 1962 and 1977. The total emissions from the dateeligible units of a single visibility impairing pollutant are over 250 tons per year, making all dateeligible units subject to the BART requirements that are a part of the Regional Haze rules 

specified in 40 CFR part 51, subpart P, Protection of Visibility.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 4 of 10

February 5, 2008

Based upon NESCAUM CALPUFF modeling the combined impact of these units on a Class I 

area was 0.231 deciview (dv). This impact is on the Brigantine Wilderness Area.

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

101 Brigantine 0.140 0.074 0.099 0.000

114 Brigantine 0.091 0.048 0.066 0.000

103 0.00 0.00 0.00 0.00

112 0.00 0.00 0.00 0.00

113 0.00 0.00 0.00 0.00

115 0.00 0.00 0.00 0.00

118 0.00 0.00 0.00 0.00

119 0.00 0.00 0.00 0.00

120 0.00 0.00 0.00 0.00

121 0.00 0.00 0.00 0.00

122 0.00 0.00 0.00 0.00

123 0.00 0.00 0.00 0.00

124 0.00 0.00 0.00 0.00

125 0.00 0.00 0.00 0.00

127 0.00 0.00 0.00 0.00

128 0.00 0.00 0.00 0.00

129 0.00 0.00 0.00 0.00

135 0.00 0.00 0.00 0.00

137 0.00 0.00 0.00 0.00

140 0.00 0.00 0.00 0.00

141 0.00 0.00 0.00 0.00

143 0.00 0.00 0.00 0.00

144 0.00 0.00 0.00 0.00

Total: 0.231 0.121 0.159 0.003

Upon reviewing actual emissions of this facility it was determined that the emissions from the 

Kilns K-2 (Source ID #101) and K-3 (Source ID #114) make up the preponderance of the 

affected visibility impairing emissions.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 5 of 10

February 5, 2008

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate, for the Lafarge Corp./Whitehall Facility.

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.

The BART determination process will be performed on Kilns K-2 and K-3 separately.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 6 of 10

February 5, 2008

A. BART Analysis of Kiln K-2:

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3a lists all available control technologies on the Lafarge Corp/Whitehall Plant Kiln K-2 for 

control of SO2 and NOx. Lafarge Corp. conducted ambient modeling and visibility analysis for 

the period 2001 through 2003 at Class 1 areas affected by this facility. Visibility improvement is 

based on the company analysis.

Table 3a - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Lafarge\Whitehall – Kiln K-2

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control Technology % 

Control

98th 

Percentile 

Maximum 

Visibility 

Improvement 

dv

Control Cost

$ per Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 813 Dry Injection 25% 0.013 3,636 54,784,228

SO2 813 Semi-Dry 50% 0.027 31,722 478,020,997

SO2 813 Wet Scrubber 81% 0.044 6,412 96,628,145

NOx 692 Low NOx Burner 20% 0.009 1,318 24,591,254

NOx 692 SNCR 25% 0.011 1,804 27,177,065

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by a fabric filter (FF). The degree of visibility improvement that could be obtained by 

requiring additional particulate matter controls on this kiln is so small that no reasonable 

weighting of the five factors required by consideration in the BART analysis could justify 

additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter system, operating full time, on the 

exhaust of a cement kiln. The SDA/FF Control Technology was removed from consideration 

due to technical infeasibility, for this reason.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 7 of 10

February 5, 2008

However this technology has been used to control NOx emissions from other cement kilns with 

preheaters in the United States. While there are technical issues associated with the installation 

of SNCR for cement kilns, economic and impact analyses were performed for this control option.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 25% to 

81%. Removal efficiencies of the technically feasible NOx control technologies range from 20% 

to 25%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Dry Injection system for Kiln K-2 is $3,636 per ton of actual SO2 

removed. The estimated cost of a Semi-Dry control system for Kiln K-2 is $31,722 per ton of 

actual SO2 removed. The estimated cost of a Wet Scrubber system for Kiln K-2 is $6,412 per 

ton of actual SO2 removed. These control systems are considered too expensive to be considered 

as control for BART at the level of improvement determined for the most affected Class I area 

(Brigantine Wilderness Area).

The estimated cost of LNB is $1,318 per ton of NOx removed. The estimated cost of SNCR is 

$1,804 per ton of NOx removed. 

Also, a Wet Scrubber has significant energy requirements and produces a sludge that must be 

treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area 

(Brigantine Wilderness Area) was 0.044 dv. The minimum cost of improvement was 

$54,784,000 annually per deciview, for lesser improvement. Therefore I do not recommend any 

additional control of SO2 on Kiln K-2 as a result of the BART analysis. The current operating 

permit SO2 emission limitation from Kiln K-2 is 362.0 pounds per hour.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Brigantine Wilderness Area) was 0.011 dv. The minimum cost of improvement was 

$24,177,000 annually per deciview, for lesser improvement. Therefore I do not recommend any 

additional control of NOx on Kiln K-2 as a result of the BART analysis. The current operating 

permit NOx emission limitation from Kiln K-2 is 260.5 pounds per hour, when burning Tire 

Derived Fuel (TDF) and 297.7 pounds per hour when not burning TDF.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 8 of 10

February 5, 2008

B. BART Analysis of Kiln K-3:

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3b lists all available control technologies on the Lafarge Corp.\Whitehall Kiln K-3 for 

control of SO2 and NOx. Lafarge Corp. conducted ambient modeling and visibility analysis for 

the period 2001 through 2003 at Class 1 areas affected by this facility. Visibility improvement is 

based on the company analysis.

Table 3b - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Lafarge\Whitehall – Kiln K-3

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control Technology % 

Control

98th 

Percentile 

Maximum 

Visibility 

Improvement 

dv

Control Cost

$ per Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 497 Dry Injection 25% 0.011 5,076 57,621,139

SO2 497 Semi-Dry 50% 0.022 37,538 426,151,544

SO2 497 Wet Scrubber 81% 0.035 7,948 90,234,180

NOx 411 Low NOx Burner 20% 0.007 2,750 31,219,928

NOx 411 SNCR 25% 0.009 2,144 24,336,753

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by a fabric filter (FF). The degree of visibility improvement that could be obtained by 

requiring additional particulate matter controls on this kiln is so small that no reasonable 

weighting of the five factors required by consideration in the BART analysis could justify 

additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter system, operating full time, on the 

exhaust of a cement kiln. The SDA/FF Control Technology was removed from consideration 

due to technical infeasibility, for this reason.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 9 of 10

February 5, 2008

However this technology has been used to control NOx emissions from other cement kilns with 

preheaters in the United States. While there are technical issues associated with the installation 

of SNCR for cement kilns, economic and impact analyses were performed for this control option.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 25% to 

81%. Removal efficiencies of the technically feasible NOx control technologies range from 20% 

to 25%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Dry Injection system for Kiln K-3 is $5,076 per ton of actual SO2 

removed. The estimated cost of a Semi-Dry control system for Kiln K-3 is $37,538 per ton of 

actual SO2 removed. The estimated cost of a Wet Scrubber system for Kiln K-3 is $7,948 per 

ton of actual SO2 removed. These control systems are considered too expensive to be considered 

as control for BART at the level of improvement determined for the most affected Class I area 

(Brigantine Wilderness Area).

The estimated cost of LNB is $2,750 per ton of NOx removed. The estimated cost of SNCR is 

$2,144 per ton of NOx removed. 

Also, a Wet Scrubber has significant energy requirements and produces a sludge that must be 

treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area 

(Brigantine Wilderness Area) was 0.035 dv. The minimum cost of improvement was 

$57,621,000 annually per deciview, for lesser improvement. Therefore I do not recommend any 

additional control of SO2 on Kiln K-3 as a result of the BART analysis. The current operating 

permit SO2 emission limitation from Kiln K-3 is 362.0 pounds per hour.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Brigantine Wilderness Area) was 0.009 dv. The minimum cost of this improvement 

was $24,337,000 annually per deciview, for lesser improvement. Therefore I do not recommend 

any additional control of NOx on Kiln K-3 as a result of the BART analysis. The current 

operating permit NOx emission limitation from Kiln K-3 is 166.0 pounds per hour, when burning 

TDF and 202.3 pounds per hour when not burning TDF.
BART Application Review – Lafarge Corp/Whitehall Facility

Page 10 of 10

February 5, 2008

5. Conclusion:

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control on these units to meet the BART requirements. 

Thus, this reviewer concludes that no additional emission control equipment for BART is 

warranted at this location. Therefore, the existing permit limits will meet the requirements for 

BART.

cc: Northeast Regional Office

Central Office
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

June 18, 2008

Subject: Review Memo for BART Application

Lehigh Cement/Evansville Cement Plant

537 Evansville Rd.

Fleetwood, PA 19522

Operating Permit #: 06-05002

To: William Weaver Joyce Epps

Environmental Program Manager Director

Southcentral Regional Office Bureau of Air Quality

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 
BART Application Review – Lehigh Cement/Evansville Plant

Page 2 of 11

January 15, 2008

equipment 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 use of the 

technology. 

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to Lehigh 

Cement/Evansville Cement Plant indicated that an engineering analysis of VOC control options 

was not needed, because the relationship of VOC and particulate could not be quantified. In 

addition, the Department did not require an engineering analysis for pollutants with a combined 

potential to emit less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 

tons per year of PM10, because of the small effect on visibility.

2. Process Description:

Lehigh Cement/Evansville Cement Plant is a portland cement production plant. Kilns Number 1 

and 2 at the facility and associated equipment are affected units. These kilns are dry cement kilns 

with preheaters. Each kiln has fuel fed to it by a direct firing system.

The primary purpose of this facility is to convert limestone and other component materials into 

portland cement. The plant has two cement kilns, Kilns Number 1 and 2 with associated material 

handling units. Each kiln has a downstream control device, a fabric filter processing the kiln flue 

gas.

The following are the source ID numbers of the affected units.

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

121 – Kiln Number 1 1,275.20 53.10 181.30

122– Kiln Number 2 1,333.80 53.30 215.90

125 – Clinker Cooler Number 1 0.00 30.30 0.00

126 – Clinker Cooler Number 2 0.00 15.00 0.00

112 – Raw Mill Grinder & Heater 0.00 27.40 0.00

159 – Finish Mill Number 1 0.00 10.30 0.00
BART Application Review – Lehigh Cement/Evansville Plant

Page 3 of 11

January 15, 2008

160 – Finish Mill Number 2 0.00 12.30 0.00

162 – Finish Mill Number 3 0.00 40.10 0.00

103 – Limestone Crushing 0.00 3.20 0.00

105 – Rock Silo West & Heater 0.00 1.40 0.00

106 – Rock Silo East & Heater 0.00 1.40 0.00

107 – Raw Mill 1 & 2 Belt Circuit 0.00 2.00 0.00

108 – Raw Mill 3 Belt Circuit 0.00 2.10 0.00

113 – Kiln Feed Blending Number 1 0.00 6.70 0.00

114 – Kiln Feed Blending Number 2 0.00 6.70 0.00

115 – Kiln Feed Silo 1 & 3 0.00 1.25 0.00

116 – Kiln Feed Silo 2 & 4 0.00 1.25 0.00

117 – Kiln Feed Pump 0.00 4.90 0.00

127 – Clinker Handling 0.00 5.70 0.00

128 – Clinker Handling 0.00 3.40 0.00

129 – Clinker Handling 0.00 3.00 0.00

130 – Clinker Handling 0.00 6.00 0.00

144 – Bulk Loading Number 1 0.00 2.40 0.00

145 – Bulk Loading Number 2 0.00 2.40 0.00

163 – Cement Storage 0.00 0.00 0.00

164 – Cement Storage 0.00 5.30 0.00

165 – Cement Storage 0.00 6.20 0.00

166 – Cement Storage 0.00 6.20 0.00
BART Application Review – Lehigh Cement/Evansville Plant

Page 4 of 11

January 15, 2008

167 – Clinker Handling 0.00 1.80 0.00

168 – Clinker Handling 0.00 4.00 0.00

170 – Bulk Loading 0.00 7.80 0.00

172 – Clinker Silos 0.00 3.50 0.00

179 – Plant Roadways 0.00 44.70 0.00

440 – Wash House Boiler 0.00 0.02 0.00

Total: 2,609.00 375.12 397.20

3. NESCAUM CALPUFF Modeling:

Lehigh Cement/Evansville has thirty-four (34) emission units at this facility originally 

constructed between the specified dates in 1962 and 1977. The total emissions from the dateeligible units of a single visibility impairing pollutant are over 250 tons per year, making all dateeligible units subject to the BART requirements that are a part of the Regional Haze rules 

specified in 40 CFR part 51, subpart P, Protection of Visibility.

Based upon NESCAUM CALPUFF modeling the combined impact of these units on a Class I 

area was 0.617 deciview (dv). This impact is on the Brigantine Wilderness Area.

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

121 Brigantine 0.292 0.014 0.280 0.002

122 Brigantine 0.317 0.015 0.306 0.000

125 Brigantine 0.00 0.00 0.00 0.00

126 Brigantine 0.001 0.000 0.000 0.001

112 Brigantine 0.001 0.000 0.000 0.001

159 Brigantine 0.00 0.00 0.00 0.00

160 Brigantine 0.00 0.00 0.00 0.00

162 Brigantine 0.001 0.000 0.000 0.001

103 Brigantine 0.00 0.00 0.00 0.00

105 Brigantine 0.00 0.00 0.00 0.00

106 Brigantine 0.00 0.00 0.00 0.00

107 Brigantine 0.00 0.00 0.00 0.00
BART Application Review – Lehigh Cement/Evansville Plant

Page 5 of 11

January 15, 2008

108 Brigantine 0.00 0.00 0.00 0.00

113 Brigantine 0.00 0.00 0.00 0.00

114 Brigantine 0.00 0.00 0.00 0.00

115 Brigantine 0.00 0.00 0.00 0.00

116 Brigantine 0.00 0.00 0.00 0.00

117 Brigantine 0.00 0.00 0.00 0.00

127 Brigantine 0.00 0.00 0.00 0.00

128 Brigantine 0.00 0.00 0.00 0.00

129 Brigantine 0.00 0.00 0.00 0.00

130 Brigantine 0.00 0.00 0.00 0.00

144 Brigantine 0.00 0.00 0.00 0.00

145 Brigantine 0.00 0.00 0.00 0.00

163 Brigantine 0.00 0.00 0.00 0.00

164 Brigantine 0.00 0.00 0.00 0.00

165 Brigantine 0.00 0.00 0.00 0.00

166 Brigantine 0.00 0.00 0.00 0.00

167 Brigantine 0.00 0.00 0.00 0.00

168 Brigantine 0.00 0.00 0.00 0.00

170 Brigantine 0.00 0.00 0.00 0.00

172 Brigantine 0.001 0.000 0.000 0.001

179 Shenandoah 0.004 0.000 0.000 0.004

440 Brigantine 0.00 0.00 0.00 0.00

Total: 0.617 0.029 0.586 0.010

Upon reviewing actual emissions of this facility in Table 2, it was determined that the NOx 

emissions from Kilns 1 (Source ID #121) and 2 (Source ID #122) make up the preponderance of 

the affected visibility impairing emissions.

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate, for the Lehigh Cement/Evansville Plant.
BART Application Review – Lehigh Cement/Evansville Plant

Page 6 of 11

January 15, 2008

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.

The BART determination process will be performed on Kilns 1 and 2 separately.
BART Application Review – Lehigh Cement/Evansville Plant

Page 7 of 11

January 15, 2008

A. BART Analysis of Kiln 1:

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3a lists all available control technologies on the Lehigh Cement/Evansville Cement Plant

Kiln 1 for control of SO2 and NOx. Lehigh Cement conducted ambient modeling and visibility 

analysis for the period 2001 through 2003 at Class 1 areas affected by this facility. Visibility 

improvement is based on the company analysis.

Table 3a - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Lehigh\Evansville – Kiln 1

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control Technology % 

Control

98th 

Percentile 

Maximum 

Visibility 

Improvement 

dv

Control Cost

$ per 

Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 181 Semi-Dry 90% 0.004 1,856 171,079,211

SO2 181 Wet Scrubber 95% 0.005 13,592 1,253,151,622

NOx 1,275 Indirect Firing 15% 0.005 34,640 1,332,162,809

NOx 1,275 Low NOx Burner 20% 0.007 1,166 50,880,783

NOx 1,275 SNCR 60% 0.020 627 14,267,800*

• Costs calculated for common system for kilns 1 and 2

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by a fabric filter (FF). The degree of visibility improvement that could be obtained by 

requiring additional particulate matter controls on this kiln is so small that no reasonable 

weighting of the five factors required by consideration in the BART analysis could justify 

additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a cement kiln. The SDA/FF SO2 control technology was removed from 

consideration due to technical infeasibility, for this reason.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted.
BART Application Review – Lehigh Cement/Evansville Plant

Page 8 of 11

January 15, 2008

However, this technology has been used to control NOx emissions from other cement kilns with 

preheaters in the United States. While there are technical issues associated with the installation 

of SNCR for cement kilns, economic and impact analyses were performed for this control option.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 90% to 

95%. Removal efficiencies of the technically feasible NOx control technologies range from 15% 

to 60%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Wet Scrubber system for Kiln 1 is $ 13,592 per ton of actual SO2 

removed. This control system is too expensive to be considered as control for BART at the level 

of improvement determined for the most affected Class I area (Brigantine Wilderness Area). The 

estimated cost of a Semi-Dry system for Kiln 1 is $ 1,856 per ton of actual SO2 removed.

The estimated cost of Indirect Firing is $ 34,640 per ton of NOx removed and is considered too 

expensive to be considered as control for BART at the level of improvement produced and 

determined Economically Infeasible. The estimated cost of Low NOx Burners is $ 1,166 per ton 

of NOx removed. The estimated cost of SNCR is $ 627 per ton of NOx removed.

Also, a Wet Scrubber has significant energy requirements and produces a sludge that must be 

treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area 

(Brigantine Wilderness Area) was 0.005 dv. The minimum cost of improvement was 

$ 171,079,000 annually per deciview, for lesser improvement. Therefore I do not recommend 

any additional control of SO2 on Kiln 1 as a result of the BART analysis. The current operating 

permit limitation for SO2 emissions from Kiln 1 is 59.4 pounds per hour.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Brigantine Wilderness Area) was 0.020 dv. The minimum cost this improvement 

was $ 47,910,000 annually per deciview. Therefore I do not recommend any additional control 

of NOx on Kiln 1 as a result of the BART analysis. The current NOx emission permit limitation 

is 367.7 pounds per hour from Kiln Number 1.
BART Application Review – Lehigh Cement/Evansville Plant

Page 9 of 11

January 15, 2008

B. BART Analysis of Kiln 2:

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3b lists all available control technologies on the Lehigh Cement/Evansville Cement Plant

Kiln 2 for control of SO2 and NOx. Lehigh Cement conducted ambient modeling and visibility 

analysis for the period 2001 through 2003 at Class 1 areas affected by this facility. Visibility 

improvement is based on the company analysis.

Table 3b - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Lehigh\Evansville – Kiln 2

Pollutant

Uncontrolled 

emission rate 

TPY 

(2002EI)

Control Technology % 

Control

98th 

Percentile 

Maximum 

Visibility 

Improvement 

dv

Control Cost

$ per 

Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 216 Semi-Dry 90% 0.005 2,937 150,988,971

SO2 216 Wet Scrubber 95% 0.005 21,703 1,115,868,499

NOx 1,334 Indirect Firing 15% 0.005 40,772 1,352,435,404

NOx 1,334 Low NOx Burner 20% 0.007 1,540 51,275,899

NOx 1,334 SNCR 60% 0.040 627 14,267,800* 

• Costs calculated for common system for kilns 1 and 2

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by a fabric filter (FF). The degree of visibility improvement that could be obtained by 

requiring additional particulate matter controls on this kiln is so small that no reasonable 

weighting of the five factors required by consideration in the BART analysis could justify 

additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a cement kiln. The SDA/FF SO2 control technology was removed from 

consideration due to technical infeasibility, for this reason.

For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be injected into the 

rotating kiln at a location where the gas is within the temperature range of 1600 to 2000 Deg. F. 

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted.
BART Application Review – Lehigh Cement/Evansville Plant

Page 10 of 11

January 15, 2008

However, this technology has been used to control NOx emissions from other cement kilns with 

preheaters in the United States. While there are technical issues associated with the installation 

of SNCR for cement kilns, economic and impact analyses were performed for this control option.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 90% to 

95%. Removal efficiencies of the technically feasible NOx control technologies range from 15% 

to 60%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Wet Scrubber system for Kiln 2 is $ 21,703 per ton of actual SO2 

removed. The estimated cost of a Semi-Dry system for Kiln 2 is $ 2,937 per ton of actual SO2 

removed. These control systems are considered too expensive to be considered as control for 

BART at the level of improvement determined for the most affected Class I area (Brigantine 

Wilderness Area).

The estimated cost of Indirect Firing is $ 40,772 per ton of NOx removed and is considered too 

expensive to be considered as control for BART at the level of improvement produced and 

determined Economically Infeasible. The estimated cost of LNB is $ 1,540 per ton of NOx 

removed. The estimated cost of SNCR is $ 627 per ton of NOx removed.

Also, a Wet Scrubber has significant energy requirements and produces a sludge that must be 

treated and disposed of.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area 

(Brigantine Wilderness Area) was 0.005 dv. The minimum cost of improvement was 

$ 150,989,000 annually per deciview, for lesser improvement. Therefore I do not recommend 

any additional control of SO2 on Kiln 2 as a result of the BART analysis. The current operating 

permit limitation for SO2 emissions from Kiln 2 is 59.4 pounds per hour.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Brigantine Wilderness Area) was 0.020 dv. The minimum cost of this improvement 

was $ 48,640,000 annually per deciview. Therefore I do not recommend any additional control 

of NOx on Kiln 2 as a result of the BART analysis. The current NOx emission operating permit 

limitation is 367.7 pounds per hour from Kiln Number 2.
BART Application Review – Lehigh Cement/Evansville Plant

Page 11 of 11

January 15, 2008

5. Conclusion:

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control on these units to meet the BART requirements. 

Thus, this reviewer concludes that no additional emission control equipment for BART is 

warranted at this location. Therefore, the existing permit limits will meet the requirements for 

BART.

cc: Southcentral Regional Office

Central Office
January 10, 2008 

Mr. Krishnan Ramamurthy 

Pennsylvania Department of 

Environmental Protection 

Rachel Carson Building 

P.O. Box 8468 

Harrisburg, PA 17105-8468 

Re: Lehigh Cement Company – Evansville and York Pennsylvania Facilities 

Supplemental Best Available Retrofit Technology (BART) Information 

Dear Mr. Ramamurthy, 

On behalf of the Lehigh Cement Company (Lehigh), All4, Inc. (ALL4) is submitting 

supplemental information related to Lehigh’s Best Available Retrofit Technology 

(BART) proposals that were prepared for the Lehigh Evansville and York, Pennsylvania 

facilities and submitted to the Pennsylvania Department of Environmental Protection (PA 

DEP) in January, 2007. The supplemental information was initially discussed during our 

conference call of November 6, 2007 with you and Martin Hochhauser and during several 

supplemental telephone conversations and e-mail communications between Lehigh, 

ALL4, and PA DEP. 

There are several issues concerning the visibility modeling that was conducted in support 

of the BART proposals that should be considered in conjunction with the control 

technology cost evaluations. These issues include the low visibility impacts, the 

conservatism of the visibility analysis, and the necessity of out-of-state emission 

reductions to demonstrate future acceptable progress at the Shenandoah Class I area. This 

letter includes a brief discussion of the background leading up to this letter, a 

supplemental visibility modeling discussion, a supplemental NOX control cost/feasibility 

discussion, a response to a Federal Land Manager comment, and a conclusion. 

Background 

In separate April 2006 letters to each Lehigh facility in Pennsylvania, the PA DEP 

identified two potential options for addressing the BART requirements of the Federal 

Regional Haze Program. These options were: 

1. Establish a permit limit to restrict the combined emissions from BART eligible 

sources to below 250 tons per year for each visibility impairing pollutant; or 

2. Conduct and submit a BART proposal based on an engineering analysis of control 

options for each BART eligible unit at the facility for each visibility impairing 

pollutant. 

Since neither the Evansville nor York facilities could accept emission limits that would 

be necessary under Option 1 to avoid the BART applicability, Lehigh prepared BART 
Mr. Krishnan Ramamurthy

Pennsylvania Department of 

Environmental Protection 

Page 2 of 6

proposals for each facility to satisfy Option 2. In the April 2006 letters, PA DEP 

specified that the BART proposals should be prepared in accordance with United States 

Environmental Protection Agency (U.S. EPA) guidance published in Appendix Y of 40 

CFR Part 51 (Guidelines for BART Determinations under the Regional Haze Rule). In 

accordance with Appendix Y, Lehigh completed BART analyses for the BART eligible 

emission units at Evansville and York facilities taking the following statutory 

requirements from Section 169A(g) of the CAA into account for each control option: 

1. The cost of compliance; 

2. The energy and non-air quality impacts of compliance; 

3. Any existing air pollution control technology in use at the source; 

4. The remaining useful life of the source; and 

5. The degree of visibility improvement which may reasonably be anticipated from 

the use of BART. 

The final BART proposals, prepared in accordance with the Part 51 Appendix Y 

guidance, were submitted to PA DEP in January 2007. The results of the BART analyses 

indicated that the baseline visibility impacts due to the Evansville BART eligible sources 

were no greater than 0.16 deciview (dV) for either the Brigantine or Shenandoah Class I 

areas on a 98th percentile basis. The visibility impacts due to BART eligible sources at 

the York facility were less than 0.05 dV at either the Brigantine or Shenandoah Class I 

areas using the 98th percentile. These visibility impacts are well below the level at which 

a human can distinguish a “just noticeable change”, which is defined as a 1 to 2 dV 

change per “Development and Application of a Standard Visual Index” (Pitchford and 

Malm 1994). The visibility improvement due to the use of BART controls at either the 

Evansville or York facilities did not result in significant improvement in visibility at the 

Shenandoah or Brigantine Class I areas. Using the 98th percentile, the greatest change in 

visibility due to BART NOX or SO2 controls at Evansville was 0.08 dV while the 98th

percentile change due to BART NOX or SO2 controls at York was 0.02 dV. The most 

stringent technically feasible NOX control option for either kiln at Evansville was the use 

of selective non-catalytic reduction (SNCR). The most stringent technically feasible 

NOX control for the York cement kiln was determined to be staged air combustion. 

While the use of certain retrofit controls may be considered cost effective based upon 

BART cost criteria developed by PA DEP, the installation of those controls will not 

result in a noticeable improvement in visibility. 

Lehigh understands that PA DEP had agreed to use the BART protocol developed by the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) regional planning organization 

(RPO). The MANE-VU protocol does not include provisions for the use of the Appendix 

Y suggested 0.5 deciview visibility impairment contribution threshold. As a result, 

facility exemption modeling in the MANE-VU region was not an available option for the 

Lehigh facilities. Rather, all BART affected facilities in the MANE-VU region were 

required to prepare and submit complete BART analyses. A facility exemption modeling 

option was a part of the BART protocol developed by the Visibility Improvement State 

and Tribal Association of the Southeast (VISTAS) RPO which includes Virginia. 

However, Lehigh also understands that PA DEP must consider all five of the statutory 
Mr. Krishnan Ramamurthy

Pennsylvania Department of 

Environmental Protection 

Page 3 of 6

factors identified above when making a BART determination and not focus solely on the 

cost effectiveness of a given control technology to determine BART. Given the 

imperceptible visibility improvements predicted for the most stringent technically 

feasible NOX controls at the Lehigh Evansville and York cement kilns and the excessive 

capital and on-going operational costs associated with implementing those controls, 

Lehigh reasserts that the use of the existing air pollution controls at the Evansville and 

York facilities represents BART for each facility. 

Supplemental Visibility Modeling Discussion

During the BART proposal development process, PA DEP advised Lehigh and other 

BART eligible sources throughout the state that PA DEP would be providing visibility 

impairment modeling results to each facility. An analysis of the visibility improvement 

associated with each control option is a required component of a BART proposal. Lehigh 

understands that the MANE-VU modeling was conducted by a contractor working for the 

Northeast States for Coordinated Air Use Management (NESCAUM). PA DEP provided 

the NESCAUM modeling results to Lehigh on November 17, 2006 along with 

information intended to assist the BART eligible sources in completing the requisite 

BART proposals. In the transmittal letter that accompanied the NESCAUM modeling 

results, PA DEP acknowledged that the NESCAUM visibility modeling had not been 

conducted in accordance with the Part 51 Appendix Y visibility modeling guidelines. As 

a result, Lehigh conducted independent visibility impairment modeling as part of each 

facility’s BART proposal in accordance with modeling protocols submitted to PA DEP in 

November of 2006. The visibility impacts due to emissions from the BART eligible 

sources at the Lehigh facilities are extremely low at the Shenandoah Class I area. The 

difference between the pre-control and post control visibility impacts are below the level 

at which human perception can detect a difference in visibility improvement. 

Since the original visibility modeling was conducted, the National Park Service (NPS) in 

conjunction with the IMPROVE Steering Committee identified deficiencies in the 

original IMPROVE equation and recommended changes (i.e., the new IMPROVE 

equation). The IMPROVE equation is the algorithm that uses pollutant concentration 

levels to determine the amount of light that is scattered or absorbed (i.e., beta extinction – 

bext). The new IMPROVE equation correlates more closely with actual measurements 

than the old IMPROVE equation. The recommended changes to the old IMPROVE 

equation reflect large and small size fractions for ammonium sulfate and nitrate 

compounds, new hydroscopic growth terms, and new f(RH) terms for large and small 

size fractions. The new IMPROVE equation also reflects site specific Rayleigh 

scattering and includes an approach to factor in the presence of sea salt and ambient 

levels of nitrogen dioxide (NO2). The impact of the new IMPROVE equation has been to 

increase the background levels of light extinction and thus decrease the deciview change 

from BART eligible sources. 
Mr. Krishnan Ramamurthy

Pennsylvania Department of 

Environmental Protection 

Page 4 of 6

Supplemental NOX Technical Feasibility/Control Cost Discussion

Lehigh Evansville 

The BART analysis that was prepared for the Lehigh Evansville facility included an 

evaluation of the retrofit costs for a common selective non-catalytic reduction (SNCR) 

system for both of the dry, preheater kilns to abate NOX emissions. SNCR was found to 

be technically feasible with a cost effectiveness of $627 per ton of NOX reduced 

(combined), a total capital cost of $1,500,000, and annual operating costs of 

$970,712/year. At the request of PA DEP, Lehigh reviewed the costs associated with 

retrofitting the two Evansville long dry cement kilns with SNCR. Lehigh has determined 

that the SNCR capital and operating costs that were provided with the January 2007 

BART proposal for the facility remain valid. 

Lehigh York 

The BART analysis that was prepared for the Lehigh York facility included an evaluation 

of the retrofit costs for staged combustion via a mid-kiln air injection fan for the white 

cement kiln to abate NOX emissions. Staged combustion using a mid-kiln air injection 

fan provided by Cadence Environmental Energy, Inc. (Cadence) was found to be 

technically feasible with a capital cost of $295,293, annual operating costs of $132,476, 

and a cost effectiveness value of $1,046 per ton of NOX reduced. At the request of PA 

DEP, Lehigh reviewed both the technical feasibility and the costs associated with 

retrofitting the York kiln with a mid-kiln air injection system. Lehigh has confirmed that 

mid-kiln air injection via a Cadence fan system is technically feasible. The capital and 

operating costs have been revised slightly based on a recent cost proposal provided by 

Cadence dated December 7, 2007 for the retrofit of the Lehigh York white cement kiln 

with a mid-kiln air injection system. The revised annual operating cost was calculated to 

be $1,118 per ton of NOX reduced. 

The BART analysis that was prepared for the Lehigh York facility included an evaluation 

of the technical feasibility of retrofitting a SNCR system on the white cement kiln at 

York. At the time of the BART proposal, Lehigh had determined that SNCR was not 

technically feasible for use on a wet, white cement kiln due to concerns with product 

quality (color) and very limited use of SNCR systems on wet cement kilns in the world. 

At the request of PA DEP, Lehigh re-evaluated the technical feasibility of using SNCR 

on a wet, white cement kiln. Lehigh has determined that the use of an ammonia or urea 

based reagent in an SNCR system will not likely impact the quality (color) of the white 

cement produced by the York wet kiln. 

At Lehigh’s request, All4 Inc. (ALL4) contacted FuelTech, a well-known provider of 

SNCR systems. Upon evaluation of the logistics associated with injecting their reagent at 

the appropriate temperature “window” within the wet cement kiln, FuelTech declined to 

provide a cost estimate. Upon further evaluation of the limited application of SNCR 

domestically on wet cement kilns, ALL4 discovered that the SNCR system installed on 

the Ash Grove Cement Company kiln in Midlothian, Texas was not a “typical” SNCR 

system, but a proprietary combination of mid-kiln air injection via a Cadence fan and 

ammonia/urea injection directly into the mid-kiln air injection “tubes.” By injecting 
Mr. Krishnan Ramamurthy

Pennsylvania Department of 

Environmental Protection 

Page 5 of 6

reagent directly into the Cadence mixing fan manifold or air injection tubes, the 

installation of a reagent pipeline along the length of the kiln is avoided. 

Lehigh has determined that the use of a combined mid-kiln air/reagent injection system is 

technically feasible at the Lehigh York wet, white cement kiln. A Cadence representative 

visited the Lehigh York facility in late November 2007, but never provided a cost 

quotation for retrofitting a SNCR system at the Lehigh York kiln. Therefore, Lehigh 

evaluated the cost effectiveness of SNCR at the York facility based on a cost quotation 

provided to Lehigh by Cadence dated October 26, 2007 for a comparable Lehigh white 

cement kiln in Waco, Texas. Based on the analysis presented in Attachment A, the cost 

effectiveness for SNCR was determined to be $3,314/ton at 40% efficiency, with a total 

capital cost of $1,154,880, and annual operating costs of $559,588/year. Based on this 

analysis and using PA DEP’s BART control cost criteria, SNCR is not a cost-effective 

retrofit option at the Lehigh York facility. A copy of the cost analysis spreadsheet is 

provided in Attachment A. 

Federal Land Manager Comments

In an e-mail dated September 7, 2007, Don Sheppard of the National Park Service quoted 

an excerpt from the preamble to the Appendix Y BART Guidelines: 

It is incorrect to dismiss a control strategy on the basis that the resulting 

improvement is not perceptible or significant. EPA states in the preamble to its 

BART Guidelines that, “Even though the visibility improvement from an individual 

source may not be perceptible, it should still be considered in setting BART because 

the contribution to haze may be significant relative to other source contributions in 

the Class I areas. Thus, we disagree that the degree of impairment should be 

contingent upon perceptibility. Failing to consider less-than-perceptible 

contributions to visibility impairment would ignore the CAA’s intent to have BART 

requirements apply to sources that contribute to, as well as cause, such impairment.” 

Mr. Sheppard’s comment addresses the scenario where many small sources with minor 

visibility impacts combine to have a noticeable impact on visibility. It has not been 

demonstrated to either the York or Evansville facilities that they are part of a group of 

insignificant sources adversely impacting visibility. Further, it is Lehigh’s understanding 

that for the Shenandoah Class I area, the State of Virginia regional haze state 

implementation plan (SIP) is not requiring any sources outside of Virginia to commit to 

controls for improving visibility at Shenandoah. Thus it appears that the Evansville and 

York facilities are not part of a group of singularly insignificant sources that collectively 

are adversely contributing to visibility impairment. 

Conclusion

Lehigh reasserts the findings of the BART proposals prepared for the Lehigh Evansville 

and York facilities that the use of the existing air pollution controls at each facility 

represents BART. This conclusion is based on the following: 
Mr. Krishnan Ramamurthy

Pennsylvania Department of 

Environmental Protection 

Page 6 of 6

 In accordance with the guidance presented in Appendix Y, baseline visibility 

impairing pollutant (VIP) emissions from the Evansville or York facilities do not 

cause or contribute to visibility impairment at Shenandoah National Park. 

 The difference between the pre-control and post control visibility impacts due to 

emissions from the BART eligible sources at the Lehigh facilities are below the 

level at which human perception can detect a difference in visibility improvement. 

 The use of the new IMPROVE equation would further reduce the visibility 

impacts associated with baseline facility emissions and would reduce the visibility 

improvements associated with the use of retrofit control technology. 

 Regardless of the cost-effectiveness of a given retrofit technology, the PA DEP 

must sufficiently consider the visibility impacts of the BART analyses in 

conjunction with the retrofit control costs to meet the statutory BART 

requirements. 

By not sufficiently considering the visibility impacts analysis (a statutory requirement) 

provided with each BART analysis, the BART evaluation process becomes a retrofit 

control technology cost analysis by default, focusing solely on the cost effectiveness of a 

given retrofit technology rather than the five statutory requirements identified above. We 

believe that this approach is both inconsistent with the intent of the BART regulations 

and with the guidance provided by U.S. EPA in Appendix Y. Furthermore, based upon 

the modeling conducted by Lehigh, any additional costs incurred by Lehigh to retrofit 

NOX controls on the York and/or Evansville cement kilns will have no perceptible impact 

on visibility in the Class I areas. 

Please contact Tim Matz at (610) 366-4752 or me at (610) 933-5246 if you have any 

questions or require additional information. 

Sincerely, 

All4, Inc. 

Roy Rakiewicz 

Senior Consultant 

cc: Timothy L. Matz, Director of Environmental Affairs - Lehigh Cement Company 

Martin Hochhauser – PA DEP
ATTACHMENT A

CAPITAL AND ANNUALIZED COSTS FOR INSTALLATION OF A CADENCE FAN/SNCR SYSTEM FOR NOX CONTROL

LEHIGH CEMENT YORK FACILITY

WHITE CEMENT KILN

CAPITAL COSTS(a) ANNUALIZED COSTS

COST ITEM COST ($) COST ITEM COST FACTOR RATE 

Direct Costs Direct Annual Costs

Purchased Equipment Costs Operating Labor 

Operator, two employees(b) 0.5 hours/shift $36.74 per 

Purchased Equipment Costs Subtotal $198,000 Supervisor 15% of operator labor Ammonia Storage Tank (estimate) $250,000 Maintenance 

Freight 0.05 A $22,400 Maintenance Labor and Material 5% of sum of direct installation costs, engine

contingencies 

Total Purchased Equipment Cost B $470,400

Utilities

Direct Installation Costs Electricity 47 kW $0.05 per 

Direct Installation Cost $399,840 Reagent Consumption

Aqueous ammonia 0.85 lb NH3/lb NO $0.065 per 

Total Direct Costs 1.85 B $870,240 Surcharges $47.40 per delivery 92 del

Total Direct Annual Costs 

Cadence License Agreement Fee $120,000

Indirect Annual Costs

Indirect Costs Spare Parts 60% of Maintenance Labor & Materials 

Engineering 0.10 B $47,040 Administrative charges 2% of TCI Construction Management 0.10 B $47,040 Property taxes 1% of TCI Contractor fees 0.10 B $47,040 Insurance 1% of TCI Start-up 0.01 B $4,704 Capital recovery 0.142 x TCI Performance test 0.01 B $4,704 Life of the control: 10 years at 7.0% inteContingencies 0.03 B $14,112

Total Indirect Annual Costs 

Total Indirect Costs $164,640

Total Annual Costs 

Total Capital Investment (TCI) $1,154,880

Cost Effectiveness ($/ton)

NOX Control Efficiency 40% (f)

Potential NOX Emissions 422.2 tpy Total Annual Costs/C

Controlled NOX Emissions 168.9 tons of NOX removed annually 

(a) Capital costs are estimated based on a quotation provided by Cadence Environmental Energy, Inc. (Cadence) for the Lehigh White Cement kiln in Waco Texas dated October 26, 2007 which specified $198,000 for a SNCR sy

 $120,000 licensing fee. Installation costs were estimated using U.S.EPA control cost algorithms. The quotation for the Waco kiln is representative of the costs that would be experienced at the York facility since the Waco and Y are similarly sized and are both white cement kilns. The capital cost includes an estimated cost provided by Cadence for the purchase and installation of an aqueous ammonia storage tank at York.

(b) Based on 8,760 hours of operation per year. (c) Facility specific cost.(d) Utility costs for electricity represent the electrical consumption of an air mixing cadence fan and other ancillary equipment.(e) A site specific quote for 19.5% aqueous ammonia delivered to York was not received as of 1/10/08. The aqueous ammonia cost used in the cost analysis represents the delivered cost of 19.5% aqueous ammonia delivered to 

The ammonia injection rate is based on 1.5:1 NH3 to NO molar ratio. 

(f) The NOX control efficiency resulting from the installation of an air mixing cadence fan and SNCR is conservatively assumed to be 40 percent.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

January 15, 2008

Subject: Review Memo for BART Application

Lehigh Cement/York Operations

200 Hokes Mill Rd.

York, PA 17404-5540

Operating Permit #: 67-05024

To: William Weaver Joyce Epps

Environmental Program Manager Director

Southcentral Regional Office Bureau of Air Quality

From: Martin L. Hochhauser, P.E., Air Quality Engineering Specialist

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a Class 

I area. The BART requirements apply to units that were in existence on August 7, 1977 but were 

not in operation before August 7, 1962 that collectively, at a facility, have the potential to emit 

more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each source subject to BART based on an analysis of 

the best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 
BART Application Review – Lehigh Cement/York Plant

Page 2 of 8

January 15, 2008

equipment 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 use of the 

technology. 

The Pennsylvania Department of Environmental Protection (Department) requested that 

Pennsylvania sources subject to BART conduct the BART analysis required by the Regional Haze 

rule and submit a BART proposal. The Department’s November 17, 2006 letter to Lehigh 

Cement/York Plant indicated that an engineering analysis of VOC control options was not needed, 

because the relationship of VOC and particulate could not be quantified. In addition, the 

Department did not require an engineering analysis for pollutants with a combined potential to emit 

less than US EPA’s de minimis levels of 40 tons per year for NOx and SO2 or 15 tons per year of 

PM10, because of the small effect on visibility.

2. Process Description:

Lehigh Cement/York is a portland cement production plant. It produces “White” cement. The 

plant has one cement kiln, known as the White Cement Kiln. The White Cement Kiln and 

associated material handling units are affected units. This kiln has one downstream control 

device, an electrostatic precipitator processing the kiln flue gas.

The primary purpose of this facility is to convert limestone and other component materials into 

“white” cement. Unlike kilns used for other Portland Cement production, the White Cement 

Kiln and its operations are designed to prevent formation of color changing iron oxides.

The following are the source ID numbers of the affected units:

TABLE 1 - 2002 Actual Emissions

UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

200 – White Cement Kiln (2003 EI data) 391.30 21.70 56.90

031 – York Shipley Boiler 0.41 0.05 0.08

121A – Limestone Silo Pneumatic 0.00 0.01 0.00

122 – Raw Clay Stockpiling 0.00 1.27 0.00

123 – Clay Silo Loading 0.00 0.00 0.00

124 – Gypsum Silo Loading 0.00 0.01 0.00
BART Application Review – Lehigh Cement/York Plant

Page 3 of 8

January 15, 2008

135 – Clay Wash Mill 0.00 1.29 0.00

140 – Raw Mill Feed System 0.00 1.47 0.00

150 – Raw Mill (All Wet) 0.00 0.00 0.00

205 – CKD Return Bin 34 Ton 0.00 0.40 0.00

210 – Cement Cooler/Steam Exhaust 0.00 1.45 0.00

220 – Clinker Discharge System 0.00 1.36 0.00

230A – 8th Floor Bldg. Transfer 0.00 1.45 0.00

231 – Yard Filling Operations 0.00 0.11 0.00

300 – Finish Mill Grinding System 0.00 5.31 0.00

380 – Three Truck Loadout 0.00 0.66 0.00

400 – Packhouse (Backup) 0.00 0.00 0.00

450 – 1956 Silos Receiving 0.00 1.53 0.00

Total: 391.71 38.07 56.98

3. NESCAUM CALPUFF Modeling:

Lehigh Cement/York has eighteen (18) emission units at this facility originally constructed 

between the specified dates in 1962 and 1977. The total emissions from the date-eligible units of 

a single visibility impairing pollutant are over 250 tons per year, making all date-eligible units 

subject to the BART requirements that are a part of the Regional Haze rules specified in 40 CFR 

part 51, subpart P, Protection of Visibility.

Based upon NESCAUM CALPUFF modeling the maximum combined impact of these units on a 

Class I area was 0.128 deciview (dv). This impact is on the Shenandoah National Park.
BART Application Review – Lehigh Cement/York Plant

Page 4 of 8

January 15, 2008

The visibility impact of the units with respect to the Class I area affected is described in Table 2.

Table 2 – Maximum Daily Impact (dv)

Source ID Class I Area Total SO4 NO3 PM10

200 (2003 EI) Shenandoah 0.128 0.011 0.117 0.001

031 Shenandoah 0.000 0.000 0.000 0.000

121A Shenandoah 0.000 0.000 0.000 0.000

122 Shenandoah 0.000 0.000 0.000 0.000

123 Shenandoah 0.000 0.000 0.000 0.000

124 Shenandoah 0.000 0.000 0.000 0.000

121 Shenandoah 0.000 0.000 0.000 0.000

135 Shenandoah 0.000 0.000 0.000 0.000

140 Shenandoah 0.000 0.000 0.000 0.000

150 Shenandoah 0.000 0.000 0.000 0.000

205 Shenandoah 0.000 0.000 0.000 0.000

210 Shenandoah 0.000 0.000 0.000 0.000

220 Shenandoah 0.000 0.000 0.000 0.000

230A Shenandoah 0.000 0.000 0.000 0.000

231 Shenandoah 0.000 0.000 0.000 0.000

300 Shenandoah 0.000 0.000 0.000 0.000

380 Shenandoah 0.000 0.000 0.000 0.000

400 Shenandoah 0.000 0.000 0.000 0.000

450 Shenandoah 0.000 0.000 0.000 0.000

Total: 0.128 0.011 0.117 0.001

(Source 2002 SO4 impact adjusted for 2003 SO2 emissions since the EI 2002 SO2 estimate is considered inaccurate.)

Upon reviewing actual emissions of this facility in Table 2, it was determined that the NOx 

emissions from the White Cement Kiln (Source ID #200) make up the preponderance of the 

affected visibility impairing emissions.

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for 

making BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania 

must follow the guidelines in making BART determinations on a source-by-source basis for 750 

megawatt (MW) power plants but are not required to use the process in the guidelines when 
BART Application Review – Lehigh Cement/York Plant

Page 5 of 8

January 15, 2008

making BART determinations for other types of sources. As a result, Pennsylvania retains the 

discretion to deviate from the guidelines as appropriate, for the Lehigh Cement/York Plant.

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition for each source subject to BART identified in this review memo, Pennsylvania used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, 

the energy and non-air quality environmental impacts, and the degree of visibility improvement 

in affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, Pennsylvania took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, Pennsylvania determined a ``best 

system of continuous emission reduction'' based upon its evaluation of these factors. 

Pennsylvania also established emission limits, including a deadline for compliance, consistent 

with the BART determination process for each source subject to BART.
BART Application Review – Lehigh Cement/York Plant

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January 15, 2008

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Table 3 lists all available control technologies on the Lehigh\York White Cement Kiln for 

control of SO2 and NOx. Lehigh Cement conducted ambient modeling and visibility analysis for 

the period 2001 through 2003 at Class 1 areas affected by this facility. Visibility improvement is 

based on the company analysis.

Table 3 - Available Retrofit Control Technologies for BART Evaluation

Emission Unit – Lehigh\York – White Cement Kiln

Pollutant

Uncontrolled 

emission rate 

TPY 

(2003EI)

Control Technology % 

Control

98th 

Percentile 

Maximum 

Impact 

Visibility 

Improvement 

dv

Control Cost

$ per 

Ton 

Removed

Annual $ per 

dv 

Improvement

SO2 57 Semi-Dry 90% 0.005 54,178 562,845,137

SO2 57 Wet Scrubber 95% 0.006 104,577 917,180,124

NOx 399 Indirect Firing 15% 0.006 97,769 991,394,772

NOx 399 Cadence Fan 30% 0.012 1,118 10,605,754

NOx 399 Cadence Fan+SNCR 40% 0.017 2,623 26,596,064

PM10 will serve as a surrogate for PM2.5. The particulate emissions from this kiln are 

controlled by an electrostatic precipitator (ESP). The degree of visibility improvement that could 

be obtained by requiring additional particulate matter controls on this kiln is so small that no 

reasonable weighting of the five factors required by consideration in the BART analysis could 

justify additional controls under BART.

Step 2 – Eliminate Technically Infeasible Options.

There is presently no Spray Dryer Absorber/Fabric Filter (SDA/FF) system, operating full time, 

on the exhaust of a cement kiln. The SDA/FF SO2 control technology was removed from 

consideration due to technical infeasibility, for this reason.

For Selective Non-Catalytic Reduction (SNCR) with a Cadence fan, ammonia or urea would be 

injected into the rotating kiln at a specific location. The location would be fixed, since a 

Cadence, non-rotating, injection system would be used. SNCR operates properly when flue gas 

at the injection location is within the temperature range of 1600 to 2000 Deg. F. On long kilns, 

this temperature range may move along the axis of the kiln with time, causing injection to take 

place outside of the temperature range. SNCR has not been used full time on long wet or long 

dry kiln systems.
BART Application Review – Lehigh Cement/York Plant

Page 7 of 8

January 15, 2008

Reagent injection outside of this range does not cause a reaction with NOx and makes ammonia 

available to react with HCl and sulfur oxides downstream of the particulate control device. This 

reacted material is emitted as fine particulate. Unreacted ammonia may also be emitted. The 

USEPA RACT/BACT/LAER Clearinghouse lists no long cement kiln, either wet or dry, with 

NOx controlled by a SNCR system. It has been reported that SNCR has been proposed for NOx 

control as BART on a long cement kiln in the US. While there several technical issues 

associated with the installation of SNCR for long kilns, economic and impact analyses were 

performed for this control option. A NOx reduction of 35% was used for SNCR on long kilns 

based on the July 2006 ERG report to the Texas Commission on Environmental Quality. They 

used this reduction since SNCR control on long kilns is considered Innovative and available data 

is limited.

The Cadence air injection system has been operated on other cement kilns owned by Lehigh 

Cement. However, they have experienced lower NOx reductions than the predicted 30% at these 

units.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Removal efficiencies of the technically feasible SO2 control technologies range from 90% to 

95%. Removal efficiencies of the technically feasible NOx control technologies range from 15% 

to 40%.

Step 4 – Evaluate Impacts and Document the Results.

The estimated cost of a Semi-Dry system for the White Cement Kiln is $ 54,178 per ton of actual 

SO2 removed. The estimated cost of a Wet Scrubber system for the White Cement Kiln is 

$ 104,577 per ton of actual SO2 removed. These control systems are considered too expensive to 

be considered as control for BART at the level of improvement determined for the most affected 

Class I area (Shenandoah National Park).

In addition, a Wet Scrubber has significant energy requirements and produces a sludge that must 

be treated and disposed of.

The estimated cost of Indirect Firing is $ 97,769 per ton of NOx removed and is considered too 

expensive to be considered as control for BART. The estimated cost of a Cadence fan combined 

with a SNCR system is $ 2,623 per ton of NOx removed and also determined to be Economically 

Infeasible. The estimated cost of a Cadence fan system is $ 1,118 per ton of NOx removed.

Step 5 – Evaluate Visibility Impacts.

The maximum visibility improvement due to the most effective SO2 control in a Class I area 

(Shenandoah National Park) was 0.006 dv. The minimum cost of improvement was 

$ 562,845,000 annually per deciview, for lesser improvement. Therefore, I do not recommend 
BART Application Review – Lehigh Cement/York Plant

Page 8 of 8

January 15, 2008

any additional control of SO2 as a result of the BART analysis. The current operating permit 

limitation for SO2 emissions from the kiln is 500 ppm by volume.

The maximum visibility improvement due to the most effective NOx control in the most affected 

Class I area (Shenandoah National Park) was 0.017 dv. The minimum cost of improvement was 

$ 10,606,000 annually per deciview, for lesser improvement. Therefore, I do not recommend any 

additional control of NOx as a result of the BART analysis. The current operating permit 

limitation for NOx emissions from the kiln is 8.2 pounds per ton of cement clinker produced.

5. Conclusion:

The estimated visibility improvement is too low and the cost of additional air emission control 

too high to warrant additional emission control to meet the BART requirements. Thus, this 

reviewer concludes that no additional emission control equipment for BART is warranted at this 

location. Therefore, the existing permit limits will meet the requirements for BART.

cc: Southcentral Regional Office

Central Office
ATTACHMENT B

REVISED CAPITAL AND ANNUALIZED COSTS FOR INSTALLATION OF AN AIR MIXING CADENCE FAN FOR NOX CONTRO

LEHIGH CEMENT YORK FACILITY

WHITE CEMENT KILN

CAPITAL COSTS(a) ANNUALIZED COSTS

COST ITEM COST ($) COST ITEM COST FACTOR 

Direct Costs Direct Annual Costs

Purchased Equipment Costs Operating Labor 

Operator, two employees(b) 0.5 hours/shift $36.74 

Purchased Equipment Costs Subtotal $102,600 Supervisor 15% of operator labor Freight 0.05 A $5,130 Maintenance 

Total Purchased Equipment Cost B $107,730 Maintenance Labor and Material 5% of sum of direct installation costs, e

contingencies 

Direct Installation Costs Utilities

Electricity 47 kW 0.053 

Direct Installation Cost $91,571

Total Direct Costs 1.85 B $199,301 Total Direct Annual Costs 

Cadence License Agreement Fee $120,000

Indirect Annual Costs

Indirect Costs Spare Parts 60% of Maintenance Labor & Materials 

Engineering 0.10 B $10,773 Administrative charges 2% of TCI Construction Management 0.10 B $10,773 Property taxes 1% of TCI Contractor fees 0.10 B $10,773 Insurance 1% of TCI Start-up 0.01 B $1,077 Capital recovery 0.142 x TCI Performance test 0.01 B $1,077 Life of the control: 10 years at 7.0% Contingencies 0.03 B $3,232

Total Indirect Annual Costs 

Total Indirect Costs $37,706

Total Annual Costs 

Total Capital Investment (TCI) $357,006

Cost Effectiveness ($/ton)

NOX Control Efficiency 30% (e)

Potential NOX Emissions 422.2 tpy Total Annual Co

Controlled NOX Emissions 126.7 tons of NOX removed annually 

(a) Capital costs are estimated based on a quotation provided by Cadence Environmental Energy for the Lehigh York White Cement kiln dated December 7, 2007 which specified $102,600 for a mid kiln air injection fan syste

fee. Installation costs were estimated using U.S.EPA control cost algorithms.

(b) Based on 8,760 hours of operation per year. (c) Facility specific cost.(d) Utility costs for electricity represent the electrical consumption of an air mixing cadence fan and other ancillary equipment.(e) Control efficiency of NOX emissions from installing an air mixing cadence fan is assumed to be at least 30 percent.



COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

Reliant Energy, New Castle

120 Champion Way, Suite 200

Canonsburg, PA 15317-5817

TV Operating Permit #: 37-00023

To: John Guth Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Northwest Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 

that an engineering analysis of VOC control options is not needed. EPA has determined that 
BART Application Review – Reliant Energy, New Castle

Page 2 of 4

January 17, 2008

DRAFT

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

Reliant Energy, New Castle is an 353 MW power plant with one BART affected coal fired boiler,

Unit 5. This unit has an ESP. The facility used source specific emission factors used in the 2005 

AIMS submittal and the maximum daily heat input recorded during a four and one-half rear 

period from May 2, 2002 through October 30, 2006 using certified continious emissions 

monitoring (CEM) data. The recalculated facilty wide filterable PM10 emissions for purposes of 

this determination are as summarized below:

Unit 1 49.4 lbs/hr = 216.2 TPY @ 8760

3. BART Analysis

The facility did not use the NESCAUM provided visibility impact analysis based upon actual 

2001 through 2003 emissions but instead substituted the above recalculated PM10 filterable 

lbs/hr emissions rates and reran the modelling using the BART-specific versions of CALMET 

and CALPUFF that were posted at http://www.src.com . The results of the facility conducted 

modelling are as summarized below:

 2001 2002 2003

Max 8th Max 8th Max 8th

24 hr highest 24 hr highest 24 hr highest

PSD Class 1 Area impact impact impact

Dolly Sods Wilderness Area dv 0.01 0.00 0.01 0.00 0.01 0.00

Otter Creek Wilderness Area dv 0.01 0.01 0.01 0.00 0.01 0.01

Shenandoah National Park dv 0.02 0.01 0.01 0.01 0.01 0.00

 

The facility expressed the opinion that these results as tabulated above are minimal and that no 

action should be required. The facilty did not do a technical feasibility or economic analysis for 

PM10 control technology options based on this opinion.

The Department considered a variety of filterable PM10 control technologies for use at all of 

Pennsylavania’s EGUs for BART purposes. These technologies included fuel related changes, 

ESP upgrades and enhancements, replacement of ESPs with fabric filters and the addition of 

Compact Hybrid Particualte Collectors (COHPAC)s. It was determined that where technically 

feasible, COHPAC would provide the most significant percent reduction of filterable PM10 

emissions at a cost that is significantly less than replacement of existing ESPs with enhanced 

ESPs or fabric filters. Other options provide various percent reductions at costs that do not 

justify the associated possible reductions. Since this facility did not do a technical feasibility 

study the Department assummed that COHPAC is technically feasible and performed a basic cost 

analysis for this option. The estimated useful life for this cost analysis was 20 years. COHPAC 

installations would require the use of booster fans which will consume energy. The minimal 

representative costs used for this analysis to represent the applicable COHPAC annualized costs 

were derived from EPA-CICA Fact Sheet, Fabric Filter, Mechanical Shaker Cleaned Type. Here, 
BART Application Review – Reliant Energy, New Castle

Page 3 of 4

January 17, 2008

DRAFT

the depicted minimum annualized cost is $5 per scfm in 1998 dollars and this is adjusted to $6 

for 2007. This value is then reduced to $4 per scfm assumming that COHPAC annualized costs 

are approximately two thirds of fabric filter annualized costs due basically to the variance in air 

to cloth ratios. Using the facility provided unit annual filterable PM10 emission rate of 49.4 

lbs/hr after existing control and assumming 8760 hrs/yr of operation, a COHPAC estimated 

efficiency of 80% and an annualized COHPAC cost of $6,756,000 for the two boiler total AIMS 

listed scfm of 1,689,000 the cost of additional filterable PM10 removed calculates to 

approximately $39,030 per ton. 

($4/scfm x 1689000 scfm) / (0.80 x (49.4 lbs/hr x 8760 hrs/yr x 1 ton/2000lbs)) = $39,030/ton 

annualized

This analysis shows that this additional cost is not cost effective where the maximum theoretical 

visibilty reduction would be approximately 0.02 deciview for the maximum 24 hr impact at the 

Shenandoah National Park. With the annualized cost of $6,756,000, the cost of additional 

control for filterable PM10 emissions on Unit 1 calculates to $337,800,0000/delta dv at 

Shenandoah National Park. It would also not be cost effective at the existing permit limit of 0.1 

lbs/MMBtu

The existing dv impact from Unit 5 is 0.02 dv maximum 24 hr at Shenandoah. A three to five 

percent reduction from ESP enhancement would yield a 0.0006 to 0.0010 delta dv improvement 

respectively. Using a 3 to 5 percent annualized cost range of $75,000 to $400,000 per year yields 

a dollar per deciview improvement cost range of $ 125,000,000 to $400,000,000/delta dv.

4. Permit Conditions

TV Permit # 37-00023 requires the control equipment that achieves the actual emissions rate that 

was used in this analysis. Therefore, present permit conditions including the 0.1 lbs/MMBtu 

emission rate along with the implementation of EGU CAIR requirements satisfy BART 

requirements for this facility. 
BART Application Review – Reliant Energy, New Castle

Page 4 of 4

January 17, 2008

DRAFT

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

The Department considered a variety of filterable PM10 control technologies for use at all of 

Pennsylavania’s EGUs for BART purposes. These technologies included fuel related changes, 

ESP upgrades and enhancements, replacement of ESPs with fabric filters and the addition of 

Compact Hybrid Particualte Collectors (COHPAC)s. 

Step 2 – Eliminate Technically Infeasible Options.

It was determined that where technically feasible, COHPAC would provide the most significant 

percent reduction of filterable PM10 emissions at a cost that is significantly less than

replacement of existing ESPs with enhanced ESPs or fabric filters. Other options provide an 

various percent reductions at costs that do not justify the associated possible reductions. 

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

The COHPAC control efficiency was assumed to be 80% for this analysis.

Step 4 – Evaluate Impacts and Document the Results.

Since this facility did not do a technical feasibility study the Department assummed that 

COHPAC is technically feasible and performed a basic cost analysis for this option. The 

estimated useful life for this cost analysis was 20 years. COHPAC installations would require 

the use of booster fans which will consume energy. The minimal representative costs used for 

this analysis to represent the applicable COHPAC annualized costs were derived from EPACICA Fact Sheet, Fabric Filter, Mechanical Shaker Cleaned Type. Here, the depicted minimum 

annualized cost is $5 per scfm in 1998 dollars and this is adjusted to $6 for 2007. This value is 

then reduced to $4 per scfm assumming that COHPAC annualized costs are approximately two 

thirds of fabric filter annualized costs due basically to the variance in air to cloth ratios. Using 

the facility provided unit annual filterable PM10 emission rate of 49.4 lbs/hr after existing 

control and assumming 8760 hrs/yr of operation, a COHPAC estimated efficiency of 80% and an 

annualized COHPAC cost of $6,756,000 for the two boiler total AIMS listed scfm of 1,689,000 

the cost of additional filterable PM10 removed calculates to approximately $39,030 per ton. 

Step 5 – Evaluate Visibility Impacts.

This analysis shows that this additional cost is not cost effective where the maximum theoretical 

visibilty reduction would be approximately 0.016 deciview for the maximum 24 hr impact at the 

Shenandoah National Park. With the annualized cost of $6,756,000, the cost of additional 

control for filterable pm emissions on Unit 1 calculates to $422,250,000/delta dv at Shenandoah 

National Park.
COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

P.H. Glatfelter Company FebruaryMay 58, 2008

Spring Grove Mill

228 S. Main St.

Spring Grove, PA 17362

Operating Permit #: 67-05004

To: William Weaver Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Bureau of Air Quality

 Southcentral Regional Office 

From: Daniel C. Husted, Air Quality Engineer

Through: Krishnan Ramamurthy

Chief, Division of Permits

Bureau of Air Quality 

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limitations representing Best Available Retrofit Technology (BART) for certain 

sources that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

sources in 26 specific categories listed in the Clean Air Act.

States are required to make a determination of BART for each source subject to BART based on an 

analysis of the best system of continuous emission control technology available and associated 

emission reductions achievable. The analysis must take into consideration the technology 

available, the costs of compliance, the energy and non-air quality environmental impacts, any 

pollution control equipment 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 use of the 

technology. 

Pennsylvania Department of Environmental Protection (Department) requested that Pennsylvania 

sources subject to BART conduct the BART analysis required by the Regional Haze rule and 

Formatted: Right: 0"

Formatted: Right: 1"
2

submit a BART proposal. The Department’s November 17, 2006 letter to P.H. Glatfelter indicated 

that an engineering analysis of VOC control options was not needed. This was due to the technical 

inability to determine the extent of contribution by individual sources of VOCs. In addition, the 

Department did not require an engineering analysis for pollutants with a combined potential to 

emit less than the U.S. Environmental Protection Agency’s (EPA) de minimis levels of 40 tons per 

year for NOx and SO2 or 15 tons per year of PM10.

2. Process Description:

P.H. Glatfelter is a pulp and paper production plant. 

The following are the Source ID numbers of the affected units. 

 TABLE I

 2002 Actual Emissions

 UNIT NOx (tpy) PM10 (tpy) SO2 (tpy)

 

035 #1 Power Boiler 576.0 48.3 3583.5

103 Fluo –Solids Calciner 102.7 28.3 0

111 Softwood Pulp Vents 0 0 0

113A Pulp Bleaching System Vents 0 0 0

115 Paper Machines 0 0 0

117 Blade Coater 0 0 0

119 Black Liquor Collection System 0 0 0

120 Cooking Liquor Preparation 0 0 0

130 Material Handling 0 58.0 0

Total: 678.7 134.6 3583.5

3. NESCAUM/CALPUFF Modeling:

P.H. Glatfelter has emission units at this facility that were originally constructed between 1962 and 

1977. The total emissions from the date eligible units of a single visibility impairing pollutant is 

over 250 tons per year, making all date-eligible units subject to the BART requirements that are a 

part of the Regional Haze rules specified in 40 CFR part 51, subpart P Protection of Visibility. 

Based upon NESCAUM CALPUFF modeling, the maximum combined impact of these units on a 

Class I area was 0.694 deciviews (dv). This impact is on the Shenandoah National Park. 

Modeling data provided by P.H. Glatfelter showed the total 98th percentile impact of all BART 

affected units at the facility to be 0.3 dv. The P.H. Glatfelter modeling utilized the three years 

worth of meteorological data needed for this modeling analysis. 

The visibility impact of the units with respect to the Class I area affected is described in Table II. 
3

TABLE II. 

Maximum Daily Impact (dv)

Source ID Class 1 Area Total SO4 NO3 PM10

035 Shenandoah 0.661 0.554 0.124 0.002

103 Shenandoah 0.026 0.000 0.024 0.003

111 Shenandoah 0.000 0.000 0.000 0.000

113A Shenandoah 0.000 0.000 0.000 0.000

115 Shenandoah 0.000 0.000 0.000 0.000

117 Shenandoah 0.000 0.000 0.000 0.000

119 Shenandoah 0.000 0.000 0.000 0.000

120 Shenandoah 0.000 0.000 0.000 0.000

130 Shenandoah 0.000 0.000 0.000 NA

Total: 0.694

4. BART Analysis:

The Department performed a BART analysis in accordance with the Guidelines for BART 

Determinations Under the Regional Haze Rule issued by the EPA and available at 

http://www.epa.gov/air/visibility/actions.html#bart1. The guidelines provide a process for making 

BART 

determinations that States can use in implementing the regional haze BART requirements on a 

source-by-source basis, as provided in 40 CFR 51.308(e)(1). Pennsylvania must follow the 

guidelines in making BART determinations on a source-by-source basis for 750 megawatt (MW) 

power plants, but are not required to use the process in the guidelines when making BART 

determinations for other types of sources. As a result, Pennsylvania retains the discretion related 

to the units at P.H. Glatfelter to deviate from the guidelines as appropriate. 

 

The Department’s BART analysis took into account each of the five statutory factors required by 

the Clean Air Act (CAA). These factors are: the costs of compliance; the 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. These statutory 

factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

In addition, for each source subject to BART identified in this review memo, the Department used 

the BART determination process under the guidelines to do the following: conduct an analysis of 

emissions control alternatives, which includes the identification of available, technically feasible 

retrofit technologies, and for each technology identified, an analysis of the cost of compliance, the 

energy and non-air quality environmental impacts, and the degree of visibility improvement in 

affected Class I areas resulting from the use of the control technology. As part of the BART 

analysis, the Department took into account the remaining useful life of the source and any existing 

control technology present at the source. For each source, the Department determined a “best 

system of continuous emission reduction” based upon its evaluation of these factors. The 

Department also established emission limits, consistent with the BART determination process. 
4

Below is the five factor analysis, in detail, for the emissions unit at this facility which had the 

greatest impact. 

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Power Boiler #1

SO2 NOx

Wet Scrubbing Selective Catalytic Reduction (SCR)

Dry Scrubbing Switch from Coal to Ultra Low Sulfur Diesel 

with Low NOx Burner

Switch from Coal to Natural Gas Switch from Coal to Natural Gas with Low 

NOx Burner 

Switch from Coal to Ultra Low Sulfur Diesel Oxygen-Enhanced Combustion (OEC)

Semi-dry Scrubbing Selective Non-catalytic Reduction (SNCR)

Switch from Coal to Lower Sulfur, 0.7%, Coal Low NOx Burners (LNB) with Secondary 

Overfire Air (SOFA)

Flue Gas Recirculation

STEP – 2: Eliminate Technically Infeasible Options Identified under Step 1

Power Boiler #1 Technically Feasible/Infeasible

SO2

Wet Scrubbing Feasible

Dry Scrubbing Feasible

Switch from Coal to Natural Gas Feasible

Switch from Coal to Ultra Low Sulfur Diesel Feasible

Semi-dry Scrubbing Feasible

Switch from current Coal and No. 6 Fuel Oil 

with Lower Sulfur Coal and No. 6 Fuel Oil

Feasible

Switch from Current Coal to Lower Sulfur 

Coal

Feasible

NOx

Selective Catalytic Reduction (SCR) Feasible

Switch from Coal to Ultra Low Sulfur Diesel 

with Low NOx Burner

Feasible

Switch from Coal to Natural Gas with Low 

NOx Burner 

Feasible

OEC Feasible

Selective Non-catalytic Reduction (SNCR) Feasible

Low NOx Burners (LNB) with Secondary Feasible
5

Overfire Air (SOFA)

Flue Gas Recirculation Feasible

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Power Boiler #1 Control Effectiveness

NOx Controls

SCR 90%

Switch from Coal to Ultra Low Sulfur Diesel 

with Low NOx Burner

82%

Switch from Coal to Natural Gas with Low 

NOx Burner 

68%

OEC 37%

SNCR 30% - Not considered further because it would 

provide a lesser level of control and would be 

more expensive than OEC.

Low NOx Burners (LNB) with Secondary 

Overfire Air (SOFA)

Not considered further because it is already 

installed and in operation.

Flue Gas Recirculation Not considered further since this technology is 

not expected to reduce NOx further than 

currently installed controls.

SO2 Controls

Wet Scrubbing 90%

Dry Scrubbing 90%

Switch from Coal to Natural Gas 92%

Switch from Coal to Ultra Low Sulfur Diesel 90%

Semi-dry Scrubbing 90%

Switch from Current Coal and No. 6 Fuel Oil 

with Lower Sulfur Coal and No. 6 Fuel Oil

57%

Switch from Current Coal to Lower Sulfur 

Coal

56%

STEP – 4: Evaluate Impacts and Document the Results

It was determined that the cost of control for this unit was not cost effective considering the 

commensurate visibility improvement. 

Power Boiler #1 Cost Effectiveness 

($/ton)

98th Percentile

Modeled

Visibility 

Improvement 

(dv)

Cost of Visibility Improvement 

($/dv)
6

NOx

SCR 10,627 0.013 423,458,923

Switch from Coal to 

Ultra Low Sulfur 

Diesel with Low 

NOx Burner

75,056 0.012 2,952,215,333

Switch from Coal to 

Natural Gas with 

Low NOx Burner 

35,689 0.012 1,165,839,250

OEC 1,954 0.010 41,629,300

SO2

Wet Scrubbing 1,667 0.219 24,545,196

Dry Scrubbing 2,824 0.219 41,589,982

Switch from Coal to 

Natural Gas

4,255 0.223 62,735,744

Switch from Coal to 

Ultra Low Sulfur 

Diesel

10,975 0.219 161,765,224

Semi-dry Scrubbing 1,724 0.219 25,394,352

Switch from Current 

Coal and No. 6 Fuel 

Oil with Lower 

Sulfur, 0.7%, Coal 

and 0.5% Sulfur No. 

6 Fuel Oil

2,304 0.141 33,212,212

Switch to Lower 

Sulfur Coal, (0.7%)

2,310 0.138 33,400,000

The existing useful life of this facility was not a factor since the facility is not expected to close 

within the expected life span of the control equipment. There are potentially significant energy 

impacts due to the increased energy needs at the facility to operate a wet scrubber. The waste 

stream from the scrubber would qualify as a non-air quality impact. This waste stream would 

need to be treated and would pose an additional burden on the facility. 

STEP – 5: Evaluate Visibility Impacts
7

The 98th percentile deciview improvement expected by the installation of a wet scrubber system 

on the Number 1 Power Boiler was found to be 0.219 dv. The cost in terms of dollars per 

deciview at this facility for the installation of the wet scrubber was calculated to be 

$24,545,196/dv. The 98th percentile deciview improvement expected by operating the Number 

One Power Boiler existing OEC year round was found to be 0.010 dv. The cost in terms of 

dollar per deciview for this control approach was calculated to be $41,629,300/dv. 

Discussion

The two main BART affected units that generated the most significant emissions were the 

Number 1 Power Boiler and the Fluo-Solids Calciner. The feasibility of three types of NOx

control options for the Calciner was evaluated. The options were low-NOx burner technology, 

selective catalytic reduction, and selective non-catalytic reduction. None of these options were 

found to be technically feasible. Therefore, the BART 5 Factor Analysis for this source was 

stopped at Step 2. The Calciner currently utilizes a cyclone and two scrubbers to remove 

particulate matter and total reduced sulfide emissions. 

The Number 1 Power Boiler is the source at P.H. Glatfelter that was found to have the most 

significant impact on visibility at the Shenandoah National Park. This unit’s 98th percentile

modeled impact was 0.284 dv. The two pollutants that generated the greatest impact from this 

source were SO2 and NOx. 

Seven control technologies for NOx from this emissions unit were evaluated. The most effective 

option considered in terms of emission reduction was selective catalytic reduction (SCR). The 

cost effectiveness of this technology was calculated to be $10,627/ton. The least effective 

technology considered in terms of emission reduction was operating the existing OEC system 

year round. However, considering visibility impacts combined with technology costs this 

approach was found to be the most cost effective NOx control strategy. The average cost 

effectiveness of OEC year round was $1,954/ton and $41,629,300/dv. 

Seven potential SO2 control technologies for the Number 1 Power Boiler were evaluated. Wet 

scrubbing was found to be the most cost effective means of SO2 control. Its control efficiency 

was estimated at 90%. The 98th percentile P.H. Glatfelter estimated visibility improvement 

attributed to installing a wet scrubber was modeled to be 0.219 dv. Although the cost 

effectiveness of wet scrubbing was calculated to be $1,667/ton, the cost effectiveness in terms of 

visibility improvement was $24,545,196/dv. The most effective option considered in terms of 

control efficiency was switching from coal to natural gas. The control efficiency of this 

approach was estimated to be 92% and its associated cost effectiveness was calculated to be 

$4,255/ton. Despite this option having the highest control efficiency it was not chosen as the 

best control option due to its high cost in terms of visibility improvement. 

Based on a series of inquiries this reviewer made about the basis of their BART analysis, P.H. 

Glatfelter provided two revisions to their cost data and the basis of their cost calculations. Their 

most current cost analysis breakdown for the wet scrubber is in Table 4 of the third version of 

their cost analysis. 
8

P.H. Glatfelter provided supporting data for the purchased equipment costs that would be 

associated with installing a wet scrubber. This included the cost of the scrubber itself and of the 

ancillary systems associated with the scrubber. Under direct installation costs their costs for 

everything, except the demolition and clean up of the building in the intended scrubber site, was 

$9,815,256. This is approximately 1.6 times their total purchased equipment costs.

Due to lack of available space for installing a wet scrubber at the existing locations P.H. 

Glatfelter estimated the cost of dismantling and removing existing structures where they would 

install the wet scrubber system to be approximately $4,000,000. P.H. Glatfelter provided an 

itemized breakdown for what that cost included. The breakdown is $1.4 million for asbestos 

abatement; $0.6 million for the clean-up of dead birds, bird feces, peeling paint, etc; $1.5 million 

for steel and concrete demolition; and $0.5 million for contingencies. 

The initial P.H. Glatfelter BART analysis was based on a caustic scrubber system. However, it 

was determined that a caustic scrubber would cause the facility to exceed Pennsylvania water 

quality standards with respect to total dissolved solids. Thus, the revised cost analyses were 

based on using a lime-based scrubbing system. 

The Number 1 Power Boiler shares a stack with three other boilers. Neither of the other two 

boilers that share that stack is BART eligible. 

P.H. Glatfelter initially used an interest rate of 10% and ten years to determine their capital 

recovery factor for use in their cost calculations. Based on questions raised by the Department,

P.H. Glatfelter revised their cost calculations using an amortization period of 15 years. This 

revision resulted in a decrease in the cost effectiveness value for the wet scrubber SO2 control 

option. 

Upon initial review of the BART cost analysis it appeared that the costs of the induced draft (ID)

fan and the new stack were counted twice. They appeared in both the Purchased Equipment Cost 

section and the Direct Installation Cost section under Capital Costs. The mention of the ID Fan 

and the stack in the Direct Installation Costs section referred to the costs associated with 

installing these components, not the hardware a second time. 

Based upon the data supplied, this reviewer finds P.H. Glatfelter’s cost analysis to be 

representative of the reasonably expected costs for installing a wet scrubber system. 

Since none of the other BART eligible sources were found to generate a modeled visibility 

impact the existing control technologies and emission limits were found to be BART.

Table III.

Summary of Power Boiler No. 1 Cost Effectiveness Calculations for NOx and SO2 Control 

Unit Pollutant 2002 

Emissions 

(tons)

NESCAUM 

Impact 

(dv)

Control 

Option

Annualized 

Cost of 

Control

Tons 

Removed

(Actual)

Cost 

Effectiveness 

(Actual) 

P.H. 

Glatfelter

Estimated 

Visibility 

Improvement

(dv) (Highest 

Day and 98th

Dollar/(dv)

Cost 

98th% Day
9

% Day)

No. 1 

Power 

Boiler 

SO2 3584 0.554 Install a wet 

scrubber 

system. 90% 

Control

$5,375,398 3,225 $1,667/ton 0.458 / 0.219 24,545,196

NOx 576 0.124 Year-round 

OEC. 37% 

Control

$416,293 213 $1,954/ton 0.016 //0.010 41,629,300

5. Conclusion:

The cost effectiveness of installing a wet scrubber system for SO2 control on Number 1 Power 

Boiler, taking into account visibility improvement, was $24,545,196/dv. The cost effectiveness of 

operating the OEC system year-round for NOx control on the Number 1 Power Boiler, taking into 

account visibility improvement, was $41,629,300/dv. This data, in addition to cost effectiveness 

values for emissions reduced and modeled visibility impacts, are shown in Table III. 

Based on the five factor analysis, the impact of this facility does not warrant additional control. I 

recommend the following determination of BART for the P.H. Glatfelter facility: compliance with 

the existing operating permit for this facility. The following permit conditions pertain to the 

Number 1 Power Boiler. The current NOx emission limitation is 0.66 lbs/mmBTU, based upon a 

30 day rolling average. The current PM10 limitation for heat input between 50 and 600 mmBTU/hr 

is calculated by multiplying 3.6 times the heat input in terms of lbs/mmBTU raised to the –0.56 

power. The current SOx limitation has three provisions: the SOx limit based on a thirty day 

running average is 3.7 lbs/mmBTU; the SOx limit daily average not to be exceeded more than 2 

days in any running 30 day period is 4.0 lbs/mmBTU; and the SOx daily average not to be 

exceeded at any time is 4.8 lbs/mmBTU. 

cc: Southcentral Regional Office

Central Office
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

PPL Generation LLC, Brunner Island

Brunner Island

York Haven, PA 17370

TV Operating Permit #: 67-05005

To: William Weaver Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Southcentral Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 

that an engineering analysis of VOC control options is not needed. EPA has determined that 
BART Application Review – PPL Generation LLC, Brunner Island

Page 2 of 3

January 17, 2008

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

Brunner Island is a 1,483 Megawatt coal fired power plant. The facility has identified two BART 

affected boilers, Units 2 and 3. Unit 2 is rated at 3,790 MMBtu/hr heat input, 390 megawatt 

output and Unit 3 is rated at 7,239 MMBtu/hr heat input, 759 megawatt output. Both units are 

equiped with ESPs. The ESP was replaced in 2006 on Unit 3, the ESP on Unit 2 is scheduled for 

replacement by 2009. Unit 2 is expected to have FGD by 2009 while Unit 3 will have FGD by 

2008. The Unit 2 FGD will also serve Unit 1 which is not a BART affected unit.

3. BART Analysis

The facility provided cost analysis data for a pulse jet fabric filter addition to the existing or 

planned ESPs. The retrofit technologies reviewed by the Department included fuel-related 

modifications, ESP upgrades, enhancements or replacement, replacement of the ESPs with fabric 

filters or compact hybrid particulate collectors (COHPAC). Of the technologies reviewed, 

COHPAC provided the highest filterable particulate matter removal rate with the lowest $/ton 

cost. The Department concurs with the facility’s choice. 

This cost analysis indicates that it would cost $208,732/ton of additional filterable PM10 

removed on Unit 2 and $211,561/ton on Unit 3. There would be a pressure drop from the use of 

this technology that would require the use of booster fans to overcome and this would consume 

some energy. The estimated useful life for this cost analysis was 20 years.

The facility’s CALPUFF modeling results based on maximum hourly throughput and the 

removal of additional filterable PM10 indicate a 0.038 delta deciview impact improvement for 

the maximum 98th percentile deciview impact for the Brigantine WA, a 0.021 delta deciview 

impact improvement for the maximum 98th percentile deciview impact for the Dolly Sods WA, a 

0.022 delta deciview impact improvement for the maximum 98th percentile deciview impact for 

the Otter Creek WA and a 0.034 delta deciview impact improvement for the maximum 98th

percentile deciview impact for the Shenandoah NP. This results in a lowest cost of 

$1,250,139,553/delta dv at the Brigantine Wilderness Area.

 

This analysis indicates that it would not be cost effective to require this additional control option 

for filterable particulate emissions to achieve this modeled delta deciview impact. It would also 

not be cost effective to install this control equipment if the facility were to emit at the existing 

permit limit of 0.1 lb/MMBtu for filterable PM emissions.

Since both BART affected units will have brand new state of the art ESPs, improvement and 

enhancement options have not been evaluated. 

4. Permit Conditions
BART Application Review – PPL Generation LLC, Brunner Island

Page 3 of 3

January 17, 2008

TV Permit # 67-05005 and Plan Approval # 67-05005F for installation of the Unit 2 ESP along 

with the implementation of EGU CAIR requirements and the existing permit limit of 0.1 

lbs/MMBtu satisfy BART requirements for this facility.

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

The retrofit technologies reviewed by the Department included fuel-related modifications, ESP 

upgrades, enhancements or replacement, replacement of the ESPs with fabric filters or compact 

hybrid particulate collectors (COHPAC). 

Step 2 – Eliminate Technically Infeasible Options.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

Of the technologies reviewed, COHPAC provided the highest filterable particulate matter 

removal rate with the lowest $/ton cost. The Department concurs with the facility’s choice. The 

addition of COHPAC would remove an additional 50% to 80% of the remaining filterable 

particulate matter after the existing controls.

Step 4 – Evaluate Impacts and Document the Results.

This cost analysis indicates that it would cost $208,732/ton of additional filterable PM10 

removed on Unit 2 and $211,561/ton on Unit 3. There would be a pressure drop from the use of 

this technology that would require the use of booster fans to overcome and this would consume 

some energy. The estimated useful life for this cost analysis was 20 years.

Step 5 – Evaluate Visibility Impacts.

The facility’s CALPUFF modeling results based on maximum hourly throughput and the 

removal of additional filterable PM10 indicate a 0.038 delta deciview impact improvement for 

the maximum 98th percentile deciview impact for the Brigantine WA, a 0.021 delta deciview 

impact improvement for the maximum 98th percentile deciview impact for the Dolly Sods WA, a 

0.022 delta deciview impact improvement for the maximum 98th percentile deciview impact for 

the Otter Creek WA and a 0.034 delta deciview impact improvement for the maximum 98th

percentile deciview impact for the Shenandoah NP. This results in a lowest cost of 

$1,250,139,553/delta dv at the Brigantine Wilderness Area.

 

This analysis indicates that it would not be cost effective to require this additional control option 

for filterable particulate emissions to achieve this modeled delta deciview impact.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

PPL Generation, LLC

Martins Creek Generating Station

Foul Rift Road

Martins Creek, PA 18063

TV Operating Permit #: 48-00011

To: Mark Wejkszner Joyce Epps

Environmental Program Manager Bureau Director

Bureau of Air Quality Control Bureau of Air Quality Control

Northeast Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

Central Office

1. Background:

The Regional Haze regulation in 40 CFR 51.308(e) requires state implementation plans (SIPs) to 

contain emission limits representing Best Available Retrofit Technology (BART) for certain 

facilities that may reasonably be anticipated to cause or contribute to visibility impairment at a 

Class I area. The BART requirements apply to units that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the potential to 

emit more than 250 tons per year of a visibility impairing pollutant. Visibility impairing pollutants 

include: NOx, SO2, PM10, and PM2.5. VOC and NH3 may be visibility-impairing pollutants; 

however the Department has determined that modeling tools to assess the visibility impacts from 

VOC and NH3 adequately are not available at this time. The BART requirements only apply to 

facilities in 26 specific categories listed in the Clean Air Act. 

States are required to determine BART for each unit subject to BART based on an analysis of the 

best system of continuous emission control technology available and associated emission 

reductions achievable. The analysis must take into consideration the technology available, the 

costs of compliance, the energy and non-air quality environmental impacts, any pollution control 

equipment in use at the units, the remaining useful life of the units, and the degree of improvement 

in visibility which may reasonably be anticipated to result from use of the technology. 

PA DEP requested that Pennsylvania facilities subject to BART conduct the BART analysis 

required by the Regional Haze rule and submit a BART proposal. The Department has determined 
BART Application Review – PPL Generation, LLC, Martins Creek

Page 2 of 4

January 17, 2008

that an engineering analysis of VOC control options is not needed. EPA has determined that 

BART requirements for EGUs (Electric Generating Units) covered by CAIR are satisfied by the 

CAIR requirements for NOx and SOx so an engineering analysis is not required for these 

pollutants. For Pennsylvania EGUs the only pollutant requiring an engineering analysis is 

filterable PM10. 

2. Process Description:

Martins Creek Generating Station is a 1970 Megawatt power plant operating two BART affected 

boilers, Units 3 and 4, rated at 835 megawatts each, fired on either natural gas, residual oil or 

both.

3. BART Analysis

The facility provided cost analysis data for the only two technically feasible options for removal 

of filterable PM10 emissions. These two options were ESPs or Venturi Scrubbers where 

Mechanical Collectors were considered to be ineffective and Fabric Filters were considered 

inappropriate due to the oily consistency of oil fired fly ash. The estimated useful life for this 

cost analysis was 20 years.

The results are $247,383/ton of filterable PM10 emissions removed for ESP control using a 

PM10 filterable emission rate of 0.03 lbs/MMBTU, a unit capacity of 7,721 MMBTU/hr, 1, 840 

hrs/yr of operation, 80% ESP efficiency with 170.45 tons per year of filterable PM10 removed. 

It was assumed that no condensable PM would be removed.

The second option results are $151,335/ton of filterable PM10 emission removed for Venturi 

Scrubber control at the same emission rate, capacity, hours per year of operation, efficiency and

removal rate.

The facility used the CALPUFF modeling procedures with three years of meteorological data to 

evaluate the impact of their units’ visibility effects with and without control of filterable PM10 

emissions only. The results (based on the 98th percentile modeled impact) are as follows:

Brigantine WA, Base Case 0.667 dv, 80% control 0.046 dv, improvement 0.037 dv

Lye Brook WA, Base Case 0.406 dv, 80% control 0.028 dv, improvement 0.022 dv

The 0.667 and 0.406 existing deciview impacts listed above include the condensable portion of 

the PM10 emissions from these emission units. The filterable PM10 portions of these impact 

amounts are 0.046 and 0.028 deciviews respectively. The remaining portions of the existing 

deciview impacts are due to condensable emissions, mostly SO3, and are covered by the CAIR. 

Using the most effective Venturi Scrubber annualized cost of $25,794,902 the visibility 

improvement cost calculates to $697,159,514/delta dv at the Brigantine Wilderness Area. This 

analysis indicates that it would not be cost effective to require this control option to achieve this 

modeled delta deciview impact. It would also not be cost effective at the existing permit level of 

0.1 lb/MMBtu.

4. Permit Conditions
BART Application Review – PPL Generation, LLC, Martins Creek

Page 3 of 4

January 17, 2008

TV Permit # 48-00011 requires good combustion practice and the use of low sulfur fuels. These 

permit requirements including the permit limit of 0.1 lbs/MMBtu along with the implementation 

of EGU CAIR requirements meet BART requirements for this facility. 

The Five Basic Steps of a Case-by-Case BART Analysis

Step 1 – Identify All Available Retrofit Control Technologies.

Electrostatic Precipitators, Fabric Filters, Mechanical Collectors, Wet Scrubbers

Step 2 – Eliminate Technically Infeasible Options.

Fabric Filters not compatible with oil-fired boilers, Mechanical Collectors designed for larger 

particulate matter.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

An 80% filterable particulate matter removal rate was assumed for this analysis.

Step 4 – Evaluate Impacts and Document the Results.

The facility provided cost analysis data for the only two technically feasible options for removal 

of filterable PM10 emissions. These two options were ESPs or Venturi Scrubbers where 

Mechanical Collectors were considered to be ineffective and Fabric Filters were considered 

inappropriate due to the oily consistency of oil fired fly ash. The estimated useful life for this 

cost analysis was 20 years.

The results are $247,383/ton of filterable PM10 emissions removed for ESP control using a 

PM10 filterable emission rate of 0.03 lbs/MMBTU, a unit capacity of 7,721 MMBTU/hr, 1, 840 

hrs/yr of operation, 80% ESP efficiency with 170.45 tons per year of filterable PM10 removed. 

It was assumed that no condensable PM would be removed.

The second option results are $151,335/ton of filterable PM10 emission removed for Venturi 

Scrubber control at the same emission rate, capacity, hours per year of operation, efficiency and 

removal rate.

Step 5 – Evaluate Visibility Impacts.

The facility used the CALPUFF modeling procedures to evaluate the impact of their units’ 

visibility effects with and without control of filterable PM10 emissions only. The results are as 

follows:

Brigantine WA, Base Case 0.667 dv total PM, 80% control 0.046 dv, improvement 0.037 dv

Lye Brook WA, Base Case 0.406 dv total PM, 80% control 0.028 dv, improvement 0.022 dv
BART Application Review – PPL Generation, LLC, Martins Creek

Page 4 of 4

January 17, 2008

Using the Venturi Scrubber annualized cost of $25,794,902 the impact cost calculates to 

$697,159,514/delta dv at the Brigantine Wilderness Area. This analysis indicates that it would 

not be cost effective to require this control option to achieve this modeled delta deciview impact.