New York State Department of Environmental Conservation 

Best Available Retrofit Technology Determination 

Facility Alcoa Massena Operations (West Plant) 

Location Massena, NY 

St. Lawrence County 

Permit ID 6-4058-00003 

Source Category Primary Aluminum Ore Reduction; 

Secondary Metal Production (Aluminum) 

I. Introduction 

The above referenced facility contains at least one emission source that falls under the 

requirements of the federal Best Available Retrofit Technology (BART) rule under 40 CFR Part 

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

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

1. Falls within one of 26 specific source categories, 

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

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

3. Has a potential to emit (collectively, with other emission sources at the facility which 

fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant. 

In accordance with BART requirements, each BART-eligible facility performed a BART 

analysis of controls for sulfur dioxide, nitrogen oxides and particulate matter. This analysis took 

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

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

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

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

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

including the level of controls and emission limits that constitute BART for this facility’s eligible 

emission source(s). Each analysis and BART determination was submitted to the Federal Land 

Managers (FLMs) for their review in accordance with Regional Haze State Implementation Plan 

(SIP) requirements. Comments received from the FLMs on this determination will be included 

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

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

limits. The modifications were noticed in New York State’s Environmental Notice Bulletin on 

December 28, 2011. Upon completion of this public notice period, the modified permit was 

submitted to EPA for review on January 31, 2012. The final modified permit was issued on 

March 20, 2012. This permit is now being submitted to EPA as a revision to the New York 

Regional Haze SIP. 

 

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II. BART Analysis Summary 

Alcoa submitted a BART analysis for its Massena Operations (West Plant) on September 27, 

2010. Alcoa also responded to Department questions in a letter dated October 25, 2010, and 

responded to additional EPA/FLM comments in a letter dated November 11, 2011. A 

supplemental fuel oil analysis was provided on December 15, 2011. 

The following emission sources had been identified as BART-eligible and were therefore 

included in the analysis: 

Aluminum Production Cells (Potlines) - Emission Unit S-00001; Emission Source SS198 

• Aluminum metal is produced by electrolytic reduction of alumina in these shallow 

rectangular cells, or “pots.” This potline is categorized as a center work prebake-1 

(CWPB-1) within EPA’s MACT regulations. The permit to construct was issued in 

November, 1973. The current potline control device is a fluidized bed system with a 

baghouse; the system has a 98 percent capture efficiency and a PM collection efficiency 

of greater than 95 percent. 

Anode Baking Furnace - Emission Unit S-00002; Emission Source SS78 

• Anodes are manufactured in an on-site paste production plant. Alcoa has two anode bake 

furnaces that are commonly controlled by a single dry alumina injection system and a 

pulse jet baghouse. These furnaces are fueled with natural gas. 

Four Package Boilers – Emission Unit B-00001; Emission Sources B0001 through B0004 

• These units are four virtually identical Babcock & Wilcox boilers fired by either natural 

gas or oil. (Boilers 1 and 2 are model FM2150 and boilers 3 and 4 are model FM2310.) 

Each boiler has one wall-fired burner which has a maximum rated heat capacity of 200 

mmBtu/hr for natural gas, and approximately 160 mmBtu/hr for No. 6 oil using atomized 

steam. 

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

Potlines 

• SO2

An SO2 control analysis was completed for this facility’s potlines on February 18, 2009 

by Hatch. SO2 emission controls were found to be economically infeasible. A limestone 

slurry forced oxidation scrubber (LSFO) system had a cost-effectiveness of $12,623 per 

ton of SO2 controlled, in excess of the $5,500/ton threshold established by the 

Department for BART. Two other potential SO2 controls were identified by Hatch: 

limestone slurry scrubbing with natural oxidation (LSNO) and conventional lime wet 

scrubbing. These similar technologies were reviewed and found to be even less costeffective. Other control options (e.g. sodium-based scrubbing, dry sorbent injection) 

were also ruled out based on technical or economic infeasibility. 

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Alcoa points out that BART analyses completed for its Tennessee and Washington plants 

concluded that a pollution prevention limit of 3 percent sulfur in the coke used to 

manufacture anodes satisfies BART. BART submittals for both plants have been 

accepted by their respective agencies. The Massena West Plant is already committed in 

their Title V permit to using coke with 2.5 percent sulfur content. 

• NOx

Alcoa submitted a NOx RACT plan for the Massena East Plant to the Department on 

March 24, 2009. This plan, which was approved by the Department, found that no NOx

control technologies were technically feasible for potline emission control. This same 

conclusion is applicable to the Massena West Plant. All combustion modification 

techniques were eliminated because there are no conventional burners or combustion 

points to affect in an aluminum reduction cell. This plan went on to evaluate add-on NOx

control technologies. Both Selective Catalytic Reduction (SCR) and Selective NonCatalytic Reduction (SNCR) were deemed technically infeasible because exhaust gas 

temperature is well below the range required for each technology; SCR requires 650oF to 

750oF and SNCR requires 1,600oF to 2,200oF, while the West Plant potline exhaust 

temperature is approximately 170oF. 

Alcoa points out that this conclusion is consistent with the “no control” determinations 

for BART at its Tennessee and Washington plants. 

Based on available emissions data, Alcoa has proposed a 50 ton per year BART limit.

• PM 

Alcoa contends that the PM emission contribution to visibility impairment is minimal. 

NESCAUM modeling done for the “Contribution to Regional Haze in the Northeast and 

Mid-Atlantic United States” document specific to the Alcoa Massena West Plant 

indicated that its PM emissions account for a mere 0.8 percent of the facility’s visibility 

impact. Accounting for higher emission levels reported in correspondence from April, 

2010, PM contribution remains minimal. (This correspondence estimated the PM 

emissions to account for 1.5 percent of the facility’s visibility impact, though this 

assumption was based on a 1.5 percent fuel sulfur content, which is conservative; the 

facility actually burns oil with less than 1 percent sulfur content.) 

The current potline control is a shaker baghouse, which has a capture efficiency of 98 

percent and a PM removal efficiency of greater than 95 percent. Given the high 

efficiencies of the existing fluidized bed system and baghouse and the insignificant affect 

of PM on the total visibility impact, Alcoa proposes that the existing PM emissions 

control satisfies BART, with a limit of 168 tons per year, based on recent stack test data. 

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Anode Baking Furnace 

• SO2

To assess SO2 control cost, the estimate for the installation of an LSFO scrubber on the 

potline (see summary above) was scaled for installation on the bake furnace. Scaling was 

performed using ratios of exhaust flows, emission rates and economies of scale. The 

scaled cost-effectiveness for LSFO installation on the bake furnace was estimated at 

$13,795 per ton of SO2 controlled. Dry sorbent injection was cited as being technically 

infeasible. 

It is noted that—similar to the SO2 discussion for the potlines—BART proposals for 

Alcoa plants in Tennessee and Washington have been accepted by their respective 

agencies which rely on a pollution prevention limit of 3 percent sulfur in the anode coke, 

a limit which Massena West already meets. The SO2 control cost analysis completed for 

the Tennessee and Washington plants likewise concluded that bake furnace control was 

economically unreasonable. 

• NOx

Similar to the discussion on NOx controls for the potline, prospective NOx emission 

controls have been deemed technically infeasible through a prior RACT analysis. SCR 

and SNCR were again ruled out due to exhaust gas temperature; the bake furnace 

exhausts gas at 190oF, compared to the ranges of 650-750oF (SCR) and 1,600-2,200oF 

(SNCR) that are required. Cost calculations were completed for reference, and 

determined that cost-effectiveness was $30,110 per ton (SCR) and $22,860 per ton 

(SNCR). Combustion modifications were ruled out based on technical infeasibility due 

to the unique combustion system of this furnace. This “no control” conclusion is 

consistent with the approved BART determinations for the Alcoa Tennessee and 

Washington plants. 

• PM 

The current bake furnace control device is a dry alumina injection system with a pulse jet 

baghouse, which has a control efficiency greater than 95 percent. Alcoa re-asserts the 

minimal visibility impact from plant PM emissions (see pothouse PM summary). Alcoa 

proposes that the existing control equipment satisfies BART.

Package Boilers 

• SO2

Based on a fuel oil analysis submitted to the Department on December 14, 2011, Alcoa 

proposes to retain its existing 1.5 percent fuel sulfur limit. Alcoa performed a cost 

analysis which demonstrated that alternate levels of fuel sulfur content (i.e., 0.5 percent 

and 1.0 percent) were economically infeasible. 

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• NOx

The Department recently revised its NOx RACT regulations under 6 NYCRR Part 227 

and, because of the common $5,500 per ton threshold and similarity in the evaluation 

methodology, allowed BART-eligible facilities to fulfill NOx RACT and NOx for BART 

through one common demonstration. Alcoa opted for this method in analyzing controls 

for its package boilers. The revised Part 227 establishes a presumptive NOx emission 

limit for large oil/gas-fired boilers of 0.15 lb/mmBtu. 

The Massena West Plant currently operates with low NOx burners and flue gas 

recirculation (FGR) to control NOx emissions. Recent testing led to the establishment of 

emission rates of 0.08 lb/mmBtu for gas and 0.27 lb/mmBtu for oil. Alcoa therefore 

analyzed additional NOx control equipment to help potentially meet the presumptive NOx

RACT limit of 0.15 lb/mmBtu. 

SCR and SNCR add-on controls were evaluated for the package boilers. The estimated 

cost of retrofitting these four boilers was $9,950 per ton and $12,226 per ton for SCR and 

SNCR, respectively. These costs were under the assumption of a single add-on control 

system that would be sized appropriately to be used to control all four boilers; individual 

boiler add-on control was considered, but was determined to be less cost-effective. 

The current permitted NOx limit for the Massena West Plant is 0.30 lb/mmBtu. Alcoa 

proposes that this limit be retained as BART in light of no technically and economically 

feasible options. 

• PM 

A PM compliance test conducted on March 28, 2006 resulted in an emission rate of 0.045 

lb/mmBtu burning No. 6 fuel oil. Additionally, the “Five-Factor Analysis of BART 

Eligible Sources – Survey of Options for Conducting BART Determinations” prepared 

by NESCAUM on June 1, 2007 indicates that presumptive PM control levels for 

industrial boilers is a range of 0.02 to 0.07 lb/mmBtu. The Alcoa Massena emission rate 

of 0.045 lb/mmBtu falls within this presumptive range. 

Accordingly, given the low PM emission rate and the insignificant effect of PM on the 

total visibility impact, Alcoa proposes that existing PM emissions satisfy BART. 

III. BART Determination 

The Department finds that the following shall constitute BART for the Alcoa Massena (West 

Plant) emission sources: 

 

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Potlines 

• SO2

The Department accepts Alcoa’s proposal that no further controls be required as BART 

for SO2. The control options identified proved to be cost-prohibitive. The sulfur level in 

coke is limited to 2.5 percent by weight. 

• NOx

The Department accepts Alcoa’s proposal that no further controls be required as BART 

for NOx. The recent NOx RACT plan submitted for the East Plant demonstrated the 

technical infeasibility of NOx control options. The existing limit of 3.0 lb/hr will be 

enforced, and an additional 50 ton per year BART limit has been established. 

• PM 

The Department accepts the existing baghouse as representing BART for PM. This unit 

has very high emission control rates, and the effect of PM from the potlines on downwind 

visibility is minimal. A particulate emission limit of 168 tons per year has been 

established. 

Anode Baking Furnace 

• SO2

The Department accepts Alcoa’s proposal that no further controls be required as BART 

for SO2. Alcoa demonstrated the economic infeasibility of additional control. This 

decision is consistent with previous BART determinations by other states. The existing 

limit of 2.5 percent sulfur-in-coke (by weight) will be retained as BART. 

• NOx

The Department accepts Alcoa’s proposal that no further controls be required as BART 

for NOx. A previous NOx RACT plan demonstrated the technical infeasibility of NOx

control options. A BART limit of 203 tons per year is being established based on 

projected actual emissions. 

• PM 

The Department accepts the existing dry alumina injection system and baghouse as 

representing BART for PM. This unit has very high emission control rates, and the effect 

of PM from the potlines on downwind visibility is minimal. The unit currently has a 

solid particulate emission limit of 0.050 grains/dscf pursuant to 6 NYCRR Part 212.4(c). 

An additional BART limit of 24 tons per year is being established based on projected 

actual emissions. 

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Package Boilers 

• SO2

The Department will retain the existing 1.5 percent fuel sulfur limit on residual oil burned 

in the package boilers. Alcoa adequately demonstrated the economic infeasibility of 

burning oil with a lower sulfur content. 

It should also be noted that the Department is pursuing a regulatory revision to 6 NYCRR 

Part 225-1 to lower the acceptable fuel sulfur limit to 0.5 percent statewide (not including 

the New York City and lower Hudson Valley areas, which are already subject to more 

stringent limits). This revision is tentatively scheduled to be effective for 2014, and 

would supersede Alcoa’s current limit of 1.5 percent. 

• NOx

The Department accepts the current controls (low NOx burners, FGR) as representing 

BART for NOx. Additional control options were demonstrated as economically 

infeasible. The existing limit of 0.30 lb/mmBtu will be retained as BART. 

• PM 

The Department accepts Alcoa’s recommendation that current operation with no control 

be considered BART for PM. The existing limit of 0.10 lb/mmBtu will be retained as 

BART.