# BART Modeling Protocol:

Plant Scherer

Prepared by:

Southern Company Services and ENSR Corporation

for Georgia Power Company

May 2006May 2006 i 050106 Scherer BART Modeling Protocol.doc 

# Contents

1.0 Introduction...................................

................................................... ................................................... ...... 1-1

1.1 Objectives .........................................

................................................... ............................................ 1-1

1.2 Location of source vs. relevant Class I Areas ......

................................................... ....................... 1-1

1.3 Organization of protocol document..................

................................................... ............................ 1-1

2.0 Source description and emissions data ..........

................................................... .................................. 2-1

2.1 Unit-specific source data..........................

................................................... .................................... 2-1

3.0 Input data to the CALPUFF model ................

................................................... ...................................... 3-1

3.1 General modeling procedures: .......................

................................................... ............................. 3-1

3.2 Air quality database (background ozone and ammonia)

................................................... ............ 3-1

3.3 Natural conditions and monthly f(RH) at Class I Are as ................................................. ................ 3-1

4.0 Air quality modeling procedures ................

................................................... ........................................ 4-1

4.1 Model selection and features.......................

................................................... ................................ 4-1

4.2 Modeling domain and receptors ......................

................................................... ............................ 4-1

4.3 Technical options used in the modeling .............

................................................... ......................... 4-1

4.4 Light extinction and haze impact calculations ......

................................................... ....................... 4-2

5.0 Presentation of modeling results...............

................................................... ......................................... 5-1

Appendix A Basis for Source-Specific Sulfuric Acid Emissions for BART Baseline Case..............A-1

Appendix B Field Observational Information for Seco ndary Organic Aerosols ............................. ...B-1May 2006 ii 050106 Scherer BART Modeling Protocol.doc 

# List of Tables

Table 2-1 Plant Scherer modeling emission parameters.........

................................................... ............. 2-2



# List of Figures

Figure 1-1 Location of PSD Class I Areas in relation to Plant Scherer ............................................ ........ 1-2May 2006 1-1 050106 Scherer BART Modeling Protocol.doc 

# 1.0 Introduction

1.1 Objectives

The Regional Haze Rule requires Best Available Retr ofit Technology (BART) for any BART-eligible source that ‘‘emits any air pollutant which may reasonably be a nticipated to cause or contribute to any impairment of visibility” in any mandatory Class I federal area. Pursuant to federal regulations, states have the o ption of exempting a BART-eligible source from the BART requ irements based on dispersion modeling demonstrating that the source cannot reasonably be anticipated to cause or contribute to visibility impairment in a Class I area. In addition, the Environmental Protection Ag ency (EPA) has promulgated a rule allowing states s ubject to the Clean Air Interstate Rule (CAIR) to determin e that CAIR satisfies the BART requirements for SO 2 and
NO

x for electric generating units (EGUs). Preliminary feedback from the Georgia Environmental Protection Division indicates that they anticipate making the decision that CAIR satisfies BART for SO 2 and NO

x for EGUs. Therefore, this modeling protocol focuses on performing the BART modeling analysis for particul ate matter (PM) only.

Units 1, 2, 3, and 4 at Plant Scherer, located near Smyrna, which is operated by Georgia Power Company

, has been identified as a BART-eligible source. The purpose of this document is to summarize the proce dures by which a modeling analysis will be conducted for this source. The modeling procedures outlined wil l be used to determine whether the source is subject to BART requirements (exemption modeling). If it is determined that the source is subject to BART, then the procedures will be used to evaluate the visibi lity improvement factor in the BART determination step ( determination modeling). The modeling procedures a re consistent with those outlined in the updated final VISTAS common BART modeling protocol (dated Decemb er 22, 2005, revision 2 – 3/9/06), available at http://www.vistassesarm.org/BART/BARTModelingProtocol_rev2_9Mar2006. pdf . This source-specific BART modeling protocol references relevant portions of the common VISTAS m odeling protocol.



### 1.2 Location of source vs. relevant Class I Areas

The Georgia Environmental Protection Division, whic h is in charge of the state’s BART program, has determined that units 1, 2, 3, and 4 at Plant Scher er are BART-eligible for PM. Figure 1-1 shows a pl ot of Plant Scherer relative to nearby Class I Areas. Th ere are six Class I areas within 300 km of the plan t: Cohutta, Great Smoky Mountains, Joyce Kilmer, Okefenokee, Sh inning Rock, and Wolf Island. The BART exemption modeling will be conducted for each of these Class I areas in accordance with the referenced VISTAS common BART modeling protocol and the procedures de scribed in this source-specific BART modeling protocol. If necessary, visibility improvement mod eling for the BART determination step will be perfo rmed for those Class I areas where the exemption modeling sh ows a greater than 0.5 deciview impact.



### 1.3 Organization of protocol document

Section 2 of this protocol describes the source emi ssions that will be used as input to the BART exemp tion modeling and, if necessary, the BART determination modeling. Section 3 describes the input data to be used for the modeling including the modeling domain, ter rain and land use, and meteorological data. Sectio n 4 describes the air quality modeling procedures and S ection 5 discusses the presentation of modeling res ults.
Since all of the references cited are also included in the VISTAS common BART modeling protocol (Secti on 7.), no additional references section is included i n this document. Appendix A and B provide addition al

information on the baseline source emissions.May 2006 1-2 050106 Scherer BART Modeling Protocol.doc Figure 1-1 Location of Class I Areas in Relation to Plant SchererMay 2006 2-1 050106 Scherer BART Modeling Protocol.doc 

# 2.0 Source description and emissions data

2.1 Unit-specific source data

The emissions data used to assess the visibility im pacts at the Class I areas within 300 km of Plant S cherer is discussed in this section. As noted earlier, indic ations from the Georgia Environmental Protection Di vision are that they will issue rules stating that CAIR will s uffice for EGU BART for SO 2 and NO

x . Therefore, this protocol focuses only on PM 10 . Since various components of PM 10 emissions have different visibility extinction efficiencies, the PM 10 emissions are divided, or “speciated,” into severa l components (VISTAS common protocol Sections 4.3.3 and 4.4.2). The VISTAS pro tocol (Section 5.) allows for the use of source-spe cific emissions and speciation factors or default values from AP-42. The PM 10 emissions and speciation approach to be used for the modeling described in this proto col is indicated in the bullets below. Where defau lt speciation values are used, the data represents a u nit where current (baseline) emission controls incl ude electrostatic precipitators (ESPs), but no post-com bustion NO

x or SO 2 control equipment exists.

• Total PM 10 is comprised of filterable and condensable emissio ns.

• Baseline filterable PM 10 emissions are based on the highest stack test for t he most recent 3-year period (2003-2005). This stack test is combined wi th the highest 24 hour heat input value for this period from CEMS data to calculate the “maximum 24 hour average emission rate” as required by the VISTAS protocol.

• Filterable PM 10 will be subdivided by size category consistent wit h the default approach from AP-42 Table 1-1.6, and as noted on pages 41 and 42 of the VISTAS common BART modeling protocol. The AP-42 Table 1-1.6 specifies for the emission contro ls indicated above that 55.6% of filterable PM 10 emissions is coarse (greater than 2.5 microns in si ze) and 44.4% is fine. Of the fine portion, 3.7% i s elemental carbon and the remainder is inorganic fin e particulates (soil).

• Condensable PM 10 consists of inorganic and organic compounds. The inorganic portion is by default

assumed to be H 2 SO 4 , although other non-sulfate inorganic condensables could be present. The organic portion is modeled as secondary organic aer osols.

• Baseline H 2 SO 4 emissions are calculated consistent with the metho d used by Southern Company to derive these emissions for TRI purposes. This appr oach assumes that the H 2 SO 4 emissions released from the stack are proportional to SO 2 emissions from combustion and are dependent on the fuel type

and the removal of H 2 SO 4 by downstream equipment (i.e., ESP and air heater) . For eastern

bituminous coal the baseline H 2 SO 4 release rate is in the range of 0.3 to 0.4% of the SO 2 emissions. Appendix A will provide the basis for the site-spec ific value used.

• Baseline emissions of secondary organic aerosols (t he remaining portion of condensable PM 10 ) are derived based on the supporting field observational information in Appendix A and will be a function o f
SO 2 emitted.

In practice, CALPUFF allows for the user to input c ertain components of PM 10 as separate species and separate sizes, which will result in more accurate wet and dry deposition velocity results and also mo re accurate effects on light scattering. As noted abo ve, the particle size distribution information is p rovided in AP-42 Table 1-1.6, and will be used for the BART ex emption modeling as well as the BART determination modeling, if needed.

Table 2-1 provides a summary of the modeling emissi on parameters to be used in the BART CALPUFF modeling, consistent with the source emissions data presented in Appendix A for the baseline. All of the
emissions in Table 2-1 were extracted from CEMS dat a for the 2003 to 2005 period and represent the maximum 24-hour average lb/hr rates (excluding days where startup, shutdown, or malfunctions occurred)

. For NO

x and SO 2 the values are directly from CEMS. Filterable PM 10 emissions were calculated using theMay 20062-2050106 Scherer BART Modeling Protocol.docTable 2-1 Plant Scherer modeling emission parametersLocation UTM(Zone 17 NAD-83)Emissions1Particle Speciation2CaseSource /UnitUTMEastUTMNorthStackHtBaseElev.DiameterGasExitVel.Stack GasExitTemp.SO2NOXPM10Filt.PM10FinePMECCond.PM10H2SO4Organickm km m ft m m/s deg K lbs/hrlbs/hrlbs/hr lbs/hr lbs/hrlbs/hrlbs/hr lbs/hrlbs/hrPlant Scherer currentBaseline Unit 1 237,891 3,661,258 308.4 467 8.2 23.2 409.7 8780 3557 122.1 117.6 52.2 1.90Note3 4.50Note3Baseline Unit 2 237,891 3,661,258 308.4 467 8.2 23.2 409.7 8716 2460 130.3 125.8 55.9 2.10Note3 4.50Note3Baseline Unit 3 237,891 3,661,258 308.4 467 8.2 24.2 400.8 8473 1472 80.4 76.0 33.8 1.20Note3 4.40Note3Baseline Unit 4 237,891 3,661,258 308.4 467 8.2 24.2 400.8 8663 1519 57.6 53.2 23.6 0.90Note3 4.50Note3Plant Scherer future, if BART is required4Control 1 Unit 1Unit 1Control n Unit 1Control 1 Unit 4Unit 4Control n Unit 41SO2and NOxemissions are not BART-applicable for EGU sourcesin CAIR states, if the state agency agrees with EPA’s interpretation of the BART finalrule. The emissions for SO2and NOxare provided for information purposes, and for reference in the computation of certain particle species such as H2SO4.2Elemental carbon (EC) and Fine PM are a part of Filterable PM10and H2SO4and Organics are a part of Condensable PM10.3Total Condensable PM10= H2SO4+ Organic. The Organic emission value will be provided later.4This data will be provided later if a BART determination analysis is required.May 2006 2-3 050106 Scherer BART Modeling Protocol.doc highest stack test over the 2003 to 2005 period and multiplying these value times the maximum 24-hour average heat input derived from CEMS. These values were then adjusted using AP-42 factors from Table 1.1-

6 that indicate that PM 10 is 67% of total PM for a PC unit with an ESP. PM 10 speciation was then performed as

indicated above.

If the BART exemption modeling indicates that a BAR T determination is required, then one or more parti culate matter control options will be considered for the m odeling to determine visibility improvement from th e baseline case. The BART engineering analysis will provide t he justifications for the selected, technically fea sible options and the species-specific control efficienci es. Table 2-1 will be updated to provide the model ing parameters for these feasible options and resubmitt ed to the Georgia Environmental Protection Division for review. Any site-specific deviations from the defa ult particulate matter speciation guidance would be outlined

at that time.May 2006 3-1 050106 Scherer BART Modeling Protocol.doc 

# 3.0 Input data to the CALPUFF model

3.1 General modeling procedures:

VISTAS has developed five sub-regional 4-km CALMET meteorological databases for three years (2001- 2003) (VISTAS common protocol Section 4.4.2). The sub-regional modeling domains are strategically designed to cover all potential BART eligible sourc es within VISTAS states and all PSD Class I areas w ithin 300 km of those sources (to the nearest edge). The extents of the 4-km sub-regional domains are shown in Figure 4-4 of the VISTAS common BART modeling proto col. The BART modeling for Plant Scherer will be done using the 4-km subdomain 4.

USGS 90-meter Digital Elevation Model (DEM) files w ere used by VISTAS to generate the terrain data at 4-km resolution for input to the 4-km sub-regional CALME T run. Likewise, USGS 90-meter Composite Theme Gri d (CTG) files were used by VISTAS to generate the lan d use data at 4-km resolution for input to the 4-km subregional CALMET run.

Three years of MM5 data (2001-2003) were used by VI STAS to generate the 4-km sub-regional meteorological datasets. See Sections 4.3.2 and 4. 4.2 in the VISTAS common BART modeling protocol for

more detail on these issues.

It is intended that all of the modeling for Plant S cherer will use the 4-km subdomain 4. However, if the results indicate that the modeling could be improved with a CALPUFF run using a finer grid, then refinements i n the modeling procedures will be considered and the Geor gia Environmental Protection Division will be asked to approve these refinements.

In the event that a finer grid resolution is used, CALMET must be rerun. Other modifications to input s of CALMET would include the extent of the modeling dom ain, the resolution of the terrain and land use dat a, and other relevant settings. The same MM5 data and ob servations as used for the 4-km sub-regional CALMET

simulations would be used. The extent of the model ing domain may need to be changed because of disk space restrictions. The size of the CALMET output is directly proportional to the grid resolution of the run. The

domain would be limited to the source and the exclu sive Class I area(s) being assessed with a higher g rid resolution, including a 50-km buffer in all directi ons.

If CALMET needs to be run at even a finer grid reso lution, then the appropriate model setting/files (s pecifically the GEO.DAT file) will be modified. A summary of t hese modifications would be provided to the Georgia Environmental Protection Division for review and ap proval.



### 3.2 Air quality database (background ozone and ammo nia)

Hourly measurements of ozone from all non-urban mon itors, as generated by VISTAS and available on the VISTAS CALPUFF page on the Earth Tech web site (htt p://www.src.com/verio/download/sample_files.htm), will be used as input to CALPUFF. For ammonia, the approach recommended by VISTAS will be followed. However, since only PM emissions are being modeled, ozone and ammonia data is not really needed given
that this data has no affect on PM results in CALPU FF.



### 3.3 Natural conditions and monthly f(RH) at Class I Areas

For each of the applicable Class I areas, natural b ackground conditions must be established in order t o determine a change in natural conditions related to a source’s emissions. The modeling described by t his protocol document intends to use annual average nat ural background light extinction (EPA 2003 values).May 2006 3-2 050106 Scherer BART Modeling Protocol.doc To determine the input to CALPUFF, it is first nece ssary to convert the deciviews to extinction using the equation:

Extinction (Mm-1) = 10 exp(deciviews/10).

For example, the EPA guidance document indicates fo r Great Smoky Mountains National Park that the deciview value for the average of the days is 7.60. This is equivalent to an extinction of 21.38 inve rse megameters (Mm-1).

This extinction includes the default 10 Mm-1 for Ra yleigh scattering. The remaining extinction is due to naturally occurring particles, and should be held c onstant for the entire year’s simulation. Therefor e, the data provided to CALPOST for Great Smoky Mountains would be the total natural background extinction minus 1 0 (expressed in Mm-1), or 11.38. This is most easily input as fine soil concentrations (11.38 μ g/m3) in CALPOST, since the extinction efficiency of soil (P M-fine) is 1.0 and there is no f(RH) component. Th e concentration entries for all other particle consti tuents would be set to zero, and the fine soil conc entration would be kept the same for each month of the year. The monthly values for f(RH) that CALPOST needs wi ll be taken from "Guidance for Tracking Progress Under the Regional Haze Rule" (EPA, 2003) Appendix A,

Table A-3.May 2006 4-1 050106 Scherer BART Modeling Protocol.doc 

# 4.0 Air quality modeling procedures

This section provides a summary of the modeling pro cedures outlined in the VISTAS protocol that will b e used for the refined CALPUFF analysis to be conducted fo r Plant Scherer.



### 4.1 Model selection and features

As noted in the VISTAS protocol (Summary, Recommend ations Section II.), VISTAS will use CALPUFF Version 5.754 and CALMET Version 5.7, which can be obtained at http://www.src.com/verio/download/download.htm#VIST AS_VERSION . These versions contain enhancements funded by the Minerals Management Serv ice (MMS) and VISTAS. They were developed by Earth Tech, Inc. and they are maintained on Earth T ech’s Atmospheric Studies Group CALPUFF website for public access. This release includes CALMET, CALPU FF, CALPOST, CALSUM, and POSTUTIL as well as

CALVIEW.

The major features of the CALPUFF modeling system, including those of CALMET and the post processors (CALPOST and POSTUTIL), are referenced in Section 3 of the VISTAS protocol.



### 4.2 Modeling domain and receptors

The initial Plant Scherer BART runs will use the su b-domain 4, 4-km CALMET data to be supplied by VIST AS,

as discussed above. This domain includes all Class I areas within 300 km of the source, plus a 50-km buffer. If there is the need for a refined analysis with a finer grid, a supplement to this modeling protocol will be provided describing the proposed procedures.

The receptors used for each of the Class I areas ar e based on the NPS database of Class I receptors, a s recommended by the VISTAS common protocol (Section 4.3.3).

The BART exemption modeling will be conducted for S cherer units 1 thru 4 (BART eligible units) for eac h
Class I area within 300 km of the source. If neces sary, units 1 thru 4 will each be modeled separatel y for the visibility improvement modeling for the BART determ ination step for the Class I areas where exemption modeling shows a greater than 0.5 deciview impact.



### 4.3 Technical options used in the modeling

CALMET modeling for the VISTAS-provided 4-km subdom ains will be performed per the procedures specified in the VISTAS common BART modeling protocol. If it is decided to conduct additional modeling with a f iner grid than 4 km, this modeling protocol will be upda ted to specify the technical options to be used in the CALMET run, in order to allow for state agency revi ew and approval .

For CALPUFF model options, Plant Scherer will follo w the VISTAS common BART modeling protocol (Section 4.4.1), which states that we should use IWAQM (EPA, 1998) guidance. The VISTAS protocol (Section 4.3. 3) also notes that building downwash effects are not r equired to be included unless the state directs the source to
include these effects. Since Plant Scherer is more than 50 km from the nearest Class I area, building

downwash effects will not be included in the CALPUF F modeling.

The POSTUTIL utility program (VISTAS common protoco l Section 4.4.2) will be used to repartition HNO3 a nd NO3 using VISTAS-provided ammonia concentrations de rived from previous 2002 CMAQ modeling conducted by EPA or the alternate ammonia concentrations appr oach recommended by VISTAS, if the CMAQ data is unavailable. As indicated earlier, since only PM e missions are being modeled, the treatment of ammoni a should not have an affect on PM results from CALPUF F.May 2006 4-2 050106 Scherer BART Modeling Protocol.doc 

### 4.4 Light extinction and haze impact calculations

The CALPOST postprocessor will be used as prescribe d in the VISTAS protocol for the calculation of the impact from the modeled source’s primary and second ary particulate matter concentrations on light exti nction. The formula that is used is the existing (not the N ovember 2005 revised) IMPROVE/EPA formula, which is applied to determine a change in light extinction d ue to increases in the particulate matter component concentrations. Using the notation of CALPOST, the formula is the following:

b ext = 3 f(RH) [(NH4)2SO4] + 3 f(RH) [NH4NO3] + 4[OC] + 1[Soil] + 0.6[Coarse Mass] + 10[EC] + b Ray

The concentrations, in square brackets, are in ug/m 3 and b ext is in units of Mm-1. The Rayleigh scattering term (b Ray ) has a default value of 10 Mm-1, as recommended in EPA guidance for tracking reasonable progress (EPA, 2003a). However, as recommended in the VISTA S protocol (Section 6.2.4), for refined 4-km grid ( or smaller) CALPUFF runs, the Rayleigh scattering term will be modified for the specific elevation of the Class I area receptors. The Rayleigh term for estimating n atural background will also, be adjusted to be cons istent with this approach.

The assessment of visibility impacts at the Class I areas will use CALPOST Method 6 (VISTAS common protocol Section 4.3.2). Each hour’s source-caused extinction is calculated by first using the hygros copic components of the source-caused concentrations, due to ammonium sulfate and nitrate, and monthly Class I area-specific f(RH) values. The contribution to th e total source-caused extinction from ammonium sulf ate and nitrate is then added to the other, non-hygroscopic components of the particulate concentration (from coarse and fine soil, secondary organic aerosols, and from elemental carbon) to yield the total hourly source -caused

extinction.

The BART rule significance threshold for the contri bution to visibility impairment is 0.5 deciviews. The VISTAS protocol (Section 4.3.2) indicates that with the us e of the 4-km sub-regional CALMET database, a sourc e does not cause or contribute to visibility impairment if the 98th percentile (or 8th highest) day’s change in extinction

from natural conditions does not exceed 0.5 decivie ws for any of the modeled years (an added check is: the 22nd highest prediction over the three years modele d should also not exceed 0.5 deciviews for a source to be exempted from a BART determination). Both the 98th percentile (or 8th highest) day's change in extinc tion from natural conditions for any modeled year and th e 22nd highest prediction over the three years mode led will be evaluated. The maximum impact from each me thod must should not exceed 0.5 deciviews for the source to be exempted from a BART determination.

Figure 4-1 of the VISTAS common BART modeling proto col presents a flow chart showing the components of that modeling protocol for the analysis to determin e whether a source is subject to BART. Again, it s hould be noted that the modeling for Plant Scherer will focu s on Subregional Fine-Scale modeling as depicted in the lower half of the figure.

If the exemption modeling demonstrates that Plant S cherer does not cause or contribute to visibility impairment, then the source will not be subject to BART requirements, and no further analysis is neede d. Otherwise, the source will proceed to perform BART determination modeling for the baseline and each co ntrol option in a similar manner as has been described in this document. This protocol will be supplemente d with a

revised Table 2-1 if the source is determined to be subject-to-BART.May 2006 5-1 050106 Scherer BART Modeling Protocol.doc 

# 5.0 Presentation of modeling results

The BART exemption and, if necessary, the BART dete rmination modeling results for Plant Scherer will b e provided to the state agency in a manner as describ ed in the VISTAS protocol (Section 4.5). A report will be produced that includes the following elements (as s uggested in the VISTAS protocol):

1. A map of the source location and Class I areas w ithin 300 km of the source.

2. For the CALPUFF modeling domain, a table listing all Class I areas in the VISTAS domain and those in neighboring states and impacts from the BART 4-k m grid exemption modeling at those Class I areas within 300 km of the source, as illustrated i n Table 4-3 of the VISTAS protocol.

3. A discussion of the number of Class I areas with visibility impairment due to source emissions for the 98th percentile days in each year (and the 98th per centile over all three years modeled) greater than

0.5 dv.

4. For the Class I area with the maximum impact, a discussion of the number of days beyond those excluded (e.g., the 98th percentile for refined ana lyses) that the impact of the source exceeds 0.5 dv, the number of receptors in the Class I area whe re the impact exceeds 0.5 dv, and the maximum impact.

5. For any finer grid CALPUFF exemption modeling, r esults for those Class I areas for which impacts of

the source exceeded 0.5 dv in the 4-km initial mode ling. We would report the same type of results as provided for 4-km exemption modeling.

The BART determination modeling will be performed f or those Class I areas shown in the exemption model ing to exceed 0.5 dv impact. The extent of the BART de termination modeling results will depend on the num ber of technically viable controls identified in the engin eering analysis phase of the BART assessment. The results presented will be a comparison of the 98 th percentile value for the baseline and each control strategy derived as is outlined above for the exemption modeling. T he same statistics as those mentioned above in Step s 3 and 4 would be provided, and a summary of the relat ive results among all emission scenarios run would be produced.

Additionally, the appropriate electronic files used to conduct the CALPUFF modeling will be submitted on CDROM or DVD media.May 2006 A-1 050106 Scherer BART Modeling Protocol.doc 

# Appendix A

Basis for Source-Specific Sulfuric Acid Emissions f or BART Baseline CaseMay 2006 A-2 050106 Scherer BART Modeling Protocol.doc 

### Appendix A

Basis for Source-Specific Sulfuric Acid Emissions f or BART Baseline Case

Sulfuric Acid (H2SO4) Emissions

During the combustion of sulfur-containing fuels, a percentage of the SO 2 formed is further oxidized to SO 3

. As the flue gas cools across the air heater, this S O 3 combines with flue gas moisture to form vapor-phas e and/or condensed sulfuric acid (H 2 SO 4 ). The baseline H 2 SO 4 emissions shown in Table 2-1 of this BART modeling protocol were calculated consistent with t he method used by Southern Company to derive these emissions for Toxics Release Inventory (TRI) purpos es. This method is documented in a report entitled Estimating Total Sulfuric Acid Emissions from Stati onary Power Plants: Revision 3 (2005) prepared by Keith Harrison and Dr. Larry Monroe (Southern Company Ser vices) and Edward Cichanowicz (Consultant). The approach described in this report assumes that H 2 SO 4 emissions released from the stack are proportional to
SO 2 emissions from combustion and are dependent on the fuel type and the removal of H 2 SO 4 by downstream equipment (i.e., ESP and air heater).

The calculations below show baseline sulfuric acid emissions that are expected. Since this facility d oes not contain post combustion emissions controls, the bas eline sulfuric acid emissions estimate only account s for

the manufacture of H 2 SO 4 through combustion and loss or removal within the system.

Sulfuric Acid Manufactured from Combustion (EMComb) : EMComb = K x F1 x E2 where,
EMComb = total sulfuric acid manufactured from comb ustion, lbs/yr K = Molecular weight and units conversion constant = 98.07 / 64.04 * 2000 = 3,063 (98.07 = Molecular weight of sulfuric acid; 64.04 = Molecular weight of SO2; Conversion from tons per year to pounds per year – multiply by 2000.) F1 = Fuel Impact Factor (from the emissions estimat ing report) E2 = Sulfur dioxide emissions, tons (from CEMS data ).

Sulfuric Acid Manufactured from Combustion is:
Scherer 1: EMComb = 3,063 x 0.008 x 8,779.8 lbs/hr / 2000 = 18 .8 lbs/hr
Scherer 2: EMComb = 3,063 x 0.008 x 8,716.3 lbs/hr / 2000 = 18 .7 lbs/hr
Scherer 3: EMComb = 3,063 x 0.008 x 8,773.2 lbs/hr / 2000 = 18 .2 lbs/hr
Scherer 4: EMComb = 3,063 x 0.008 x 8,662.5 lbs/hr / 2000 = 18 .6 lbs/hr

Sulfuric Acid Released from Combustion (ERComb) ERComb = EMComb x F2 (technology impact factors for air heater and ESP) ERComb = EMComb x (0.49) x (0.49)
Scherer 1: ERComb = 18.8 lbs/hr x (0.24) = 4.5 lbs/hr
Scherer 2: ERComb = 18.7 lbs/hr x (0.24) = 4.5 lbs/hr
Scherer 3: ERComb = 18.2 lbs/hr x (0.24) = 4.4 lbs/hr
Scherer 4: ERComb = 18.6 lbs/hr x (0.24) = 4.5 lbs/hrMay 2006 B-1 050106 Scherer BART Modeling Protocol.doc 

# Appendix B

Field Observational Information for Secondary Organ ic Aerosols (To Be Provide Later)