COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

PPL Generation LLC

Montour

18 McMichael Road

Washingtonville, PA 17884

TV Operating Permit #: 47-00001

To: Muhammad Q. Zaman Joyce Epps

Environmental Program Manager Bureau Director

Air Quality Program Bureau of Air Quality Control

Northcentral Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

Chief, Division of Permits

Bureau of Air Quality Control

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, Montour

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:

Montour Generating Station is a 762 Megawatt coal fired power plant. The facility has identified 

two BART affected boilers, Units 1 and 2. Unit 1 is rated at 6,772 MMBtu/hr heat input and 

Unit 2 is rated at 6, 954 MMBtu/hr heat input. Both units are equiped with ESPs and SCR. The 

ESPs were replaced in 2000 and 2001 during the installation of the SCRs. Both units are 

expected to have FGD by 2008.

3. BART Analysis

The facility provided cost analysis data for a pulse jet fabric filter replacement for the existing 

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 

estimated useful life for this cost analysis was 20 years. This cost analysis indicates that it would 

cost $123,000/ton of additional filterable PM10 removed as compared to the existing ESPs for 

one unit. Additional fan power would be required to overcome the pressure drop. The 

annualized cost per unit is $43,352,070, $86,704,140 for both units.

The facility’s CALPUFF modeling results based on maximum hourly throughput and the 

removal of additional filterable PM10 indicate a 0.011 delta deciview impact improvement for 

the maximum 98th percentile deciview impact for the Brigantine WA and a 0.007 delta deciview 

impact improvement for the maximum 98th percentile deciview impact for the Shenandoah NP. 

At an annualized cost of $86,704,140 and a delta deciview of 0.011 the total cost calculates to 

$7,882,194,545/delta dv at the Brigantine Wilderness Area. 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 limit of 0.1 lbs/MMBtu.

A three to five percent reduction from ESP enhancement for Units 1 and 2 at the existing 98th

percentile deciview impact of 0.022 deciview at Brigantine would yield a 0.00066 to 0.0011 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 $113,636,364 to 

$363,636,364/delta dv.

 

4. Permit Conditions

TV Permit # 47-00001 requires the control equipment that achieves the actual emission rates 

used in this analysis. Therefore, present permit conditions including the present permit limit of 

0.1 lbs/MMBtu along with the implementation of EGU CAIR requirements meet the BART 

requirements for this facility.
BART Application Review – PPL Generation LLC, Montour

Page 3 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 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.

The facility provided cost analysis data for a pulse jet fabric filter in addition the existing ESPs. 

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 

lesser or equivalent percent reductions but at costs that do not justify the associated possible 

reductions. The Department concurs with the facilities selection of a fabric filter in addition to 

the existing controls as being the most viable option. 

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

The facility assumed an additional 50% reduction of the remaining filterable particulate matter 

after existing controls.

Step 4 – Evaluate Impacts and Document the Results.

The estimated useful life for this cost analysis was 20 years. This cost analysis indicates that it 

would cost $123,000/ton of additional filterable PM10 removed as compared to the existing 

ESPs for one unit. Additional fan power would be required to overcome the pressure drop. The 

annualized cost per unit is $43,352,070 per unit, $86,704,140 for both units.

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 0.011 delta deciview impact improvement for 

the maximum 98th percentile deciview impact for the Brigantine WA and a 0.007 delta deciview 

impact improvement for the maximum 98th percentile deciview impact for the Shenandoah NP. 

At an annualized cost of $86,704,140 and a delta deciview of 0.011 the total cost calculates to 

$7,882,194,545/delta dv at the Brigantine Wilderness Area. This analysis indicates that it would 

not be cost effective to require this control option to achieve the modeled delta deciview impact. 
BART Application Review – PPL Generation LLC, Montour

Page 4 of 4

January 17, 2008
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

Subject: Review Memo for BART Application May 4, 2009

Reliant Energy Company

Orion Power - Cheswick Plant

121 Champion Way

Canonsburg, PA 15317

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

States and local agencies 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. 
BART Review Memo– Reliant Energy Corp., Orion Power Cheswick Plant

Page 2 of 5

May 4, 2009

The Allegheny County Health Department (ACHD) requested that Allegheny County facilities 

subject to BART conduct the BART analysis required by the Regional Haze rule and submit a 

BART proposal. The PA DEP and ACHD have determined 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 Allegheny County EGUs the only 

pollutant requiring an engineering analysis is filterable PM10. 

2. Process Description:

Orion Power Cheswick is a fossil fuel fired steam electric generating plant of more than 250 

million BTU’s per hour heat input. The plant is composed of one main boiler (Boiler #1) 

exhausting to one stack, which fires coal or synfuel as an alternate fuel. Natural gas is combusted 

as an auxiliary fuel for startup, shutdown, and at the operator’s description. Pollution control 

equipment for the main boiler includes low NOx burners, electrostatic precipitation with flue gas 

conditioning, and selective catalytic reduction. 

Boiler #1 was originally constructed between 1962 and 1977, and the total emissions of three of 

the eligible pollutants (SO2, NOx and PM10) are over 250 tons, making it subject to the Best 

Available Retrofit Technology (BART) requirements that are a part of the Regional Haze rules 

specified in 40 CFR Part 51, Subpart P Protection of Visibility. 

The following information relates to Boiler #1, the lone BART affected unit:

Point Emission 

Source

Install 

Date

SO2

Potential

To Emit

(TPY)

SO2

Actual

(TPY) 

1999

NOx

Potential

To Emit

(TPY)

NOx

Actual

(TPY) 

1999

PM10

Potential

To Emit

(TPY)

PM10

Actual

(TPY) 

1999

VOC

Potential

To Emit

(TPY)

VOC

Actual

(TPY) 

1999

S-001 Coal/ Gas 

Boiler 1

1970 67452.0 41602.0 10840.0 5029.0 361.0 228.0 15.8 13.7

Reliant Energy (Tax I.D. 52-2201498) Orion Power Midwest, L.P.- Cheswick Power Station (Facility I.D. 00157)

BART Category 1 - Fossil Fuel Fired Steam Electric Plant

Emissions data taken from Form K of October 2000 Operation Permit Application

The facility reported the 2002 Boiler #1 emissions (tpy) as follows:

SO2 NOx PM10 VOC

42,017.9 5,761.2 205.7 10.7
BART Review Memo– Reliant Energy Corp., Orion Power Cheswick Plant

Page 3 of 5

May 4, 2009

3. NESCAUM CALPUFF Modeling:

Based upon the NESCAUM modeling (results shown in table below) the maximum impact of this 

source on a Class 1 area due to PM10 was 0.0336 deciviews (dv). This impact is on the Otter Creek 

Wilderness Area. The impacts from SO2 and NOx are not considered in this memo, since the 

source will be participating in CAIR.

Change in visibility (delta-deciview)

Nat_bgr Maxclsi Total SO4 NO3 PM10

Best otcr 3.4898 3.1606 0.8134 0.0336

Average otcr 2.5034 2.2569 0.5611 0.0229

Worst otcr 1.7710 1.5910 0.3856 0.0156

4. BART Analysis

Orion Power Cheswick did not submit a BART engineering analysis. Instead the company 

performed their own BART modeling in January 2007, and provided the ACHD with a report 

containing their results, which will not be discussed in this memo.

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. 

 

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 the 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 this 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 unit at this facility that had the greatest impact. 
BART Review Memo– Reliant Energy Corp., Orion Power Cheswick Plant

Page 4 of 5

May 4, 2009

BART Five-Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Boiler #1

Existing 

controls:

Low NOx burners, electrostatic precipitator (ESP) with flue gas 

conditioning, selective catalytic reduction (SCR)

Retrofit 

controls:

Baghouse

A baghouse is the available retrofit control option with the practical potential for application to 

Boiler #1 for the control of PM10. 

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.

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

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

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. Based on the installation of a new baghouse for 

Boiler #1, sized for similar operating parameters listed in the operating permit and the operating 

permit application, and not correcting for inflation, the annualized cost is $7,351,900. The 

modeled emissions for Boiler #1 were 228.9 tons per year, resulting in a cost of $32,118 per ton 

PM10 removed, and a cost of $218,806,000 per deciview change

STEP – 5: Evaluate Visibility Impacts

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

to PM10 on the Otter Creek Wilderness Area was found to be 0.0336 dv. 

The costs of possible new controls in terms of dollars per deciview for this facility were 

calculated to be at least $218,806,000 /dv for the baghouse for Boiler #1. This analysis indicates 

that it would not be cost effective to require this control option to achieve this modeled delta 

deciview impact

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 Orion Power Cheswick 
BART Review Memo– Reliant Energy Corp., Orion Power Cheswick Plant

Page 5 of 5

May 4, 2009

facility: The control equipment described in this analysis is required by Operating Permit 

1065009-003-00100 and Installation Permits IP93-I-0009-C, IP0054-I002, and IP0054-I004. The 

conditions of these permits along with the implementation of EGU CAIR requirements satisfy 

BART requirements for this facility.

cc: Nancy Herb, PA DEP, Harrisburg

Jane Mahinske, PA DEP, Harrisburg

OPERATING PERMITS FOR BART ELIGIBLE SOURCES - - Orion Power Cheswick Plant

ID Emission Source Permit #

S-001 Main Boiler 

Number 1

1065009-003-00100

IP93-I-0009-C (Low NOx 

Burners)

IP-0054-I-002 (SCR)

RACT Plan 217, 

3-8-1996

IP #0054-I004 (FGD)

Table V-A-1
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

Reliant Energy, Conemaugh

1442 Power Plant Road

New Florence, PA 15944-9154

TV Operating Permit #: 32-00059

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 – Reliant Energy, Conemaugh

Page 2 of 4

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:

Reliant Energy, Conemaugh is an 1711 MW power plant with two BART affected coal fired 

boilers, Units 1and 2. Both units have ESPs and FGD. The facility used source specific 

emission factors from the 2005 AIMS submittal and the maximum daily heat input recorded 

during a five-year period from October 30, 2001 and October 30, 2006. The recalculated facilty 

wide filterable PM10 emissions for purposes of this determination are as summarized below:

Unit 1 86.2 lbs/hr

Unit 2 145 lbs/hr

231.2 lbs/hr = 1012.7 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 0.06 0.02 0.05 0.02 0.03 0.02

Otter Creek Wilderness Area dv 0.10 0.01 0.05 0.01 0.04 0.01

Shenandoah National Park dv 0.08 0.05 0.06 0.03 0.07 0.03

 

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 evaluated by the Department provide lesser percent 

reductions at costs that do not justify the associated possible reductions. The Department 

assummed that COHPAC is technically feasible and performed a basic cost analysis for this 

option as being the most viable. COHPAC installations would require the use of booster fans 

which will consume energy. The estimated useful life for this cost analysis was 20 years. The 
BART Application Review – Reliant Energy, Conemaugh

Page 3 of 4

January 17, 2008

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 annual 

filterable PM10 emission rate of 231.2 lbs/hr after existing ESP control and assumming 8760 

hrs/yr of operation, a COHPAC estimated efficiency of 80% and an annualized COHPAC cost of 

$14,271,144 for the two boiler total AIMS listed scfm of 3,567,786, the cost of additional 

filterable PM10 removed calculates to approximately $14,093 per ton. 

($4/scfm x 3567786 scfm) / (0.80 x (231.2 lbs/hr x 8760 hrs/yr x 1 ton/2000lbs)) = $14,093/ton 

annualized

This analysis shows that this additional cost is not cost effective where the maximum theoretical 

visibilty reduction would be approximately 0.10 deciview for the maximum 24 hr impact at the 

Otter Creek Wilderness area due to PM10 filterable emissions. The annual cost of $14,271,144 

translates to a minimal cost of $142,271,144/delta dv at the Otter Creek Wilderness Area for the 

one day maximum effect. This option would also not be cost effective at the existing permit 

limit of 0.1 lbs/MMBtu for filterable PM emissions.

A three to five percent reduction from ESP enhancement would yield a 0.003 to 0.005 delta dv 

improvement respectively. Using a two unit 3 to 5 percent annualized cost range of $150,000 to 

$800,000 per year yields a dollar per deciview improvement cost range of $50,000,000 to 

$160,000,000/delta dv.

4. Permit Conditions

Title V Permit # 32-00059 that requires the ESPs that achieved the actual emission rates used in 

this analysis which were achieved at the existing permit limit of 0.1 lbs/MMBtu along with the 

implementation of EGU CAIR requirements satisfy the BART requirements for this facility.
BART Application Review – Reliant Energy, Conemaugh

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.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

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 evaluated by 

the Department provide lesser percent reductions at costs that do not justify the associated 

possible reductions. The Department assummed that COHPAC is technically feasible and 

performed a basic cost analysis for this option as being the most viable. A COHPAC efficiency 

of 80% removal of filterable particulate was assummed in this analysis.

Step 4 – Evaluate Impacts and Document the Results.

COHPAC installations would 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 annual filterable PM10 emission rate of 231.2 lbs/hr after 

existing ESP control and assumming 8760 hrs/yr of operation, a COHPAC estimated efficiency 

of 80% and an annualized COHPAC cost of $14,271,144 for the two boiler total AIMS listed 

scfm of 3,567,786, the cost of additional filterable PM10 removed calculates to approximately 

$14,093 per ton. 

($4/scfm x 3567786 scfm) / (0.80 x (231.2 lbs/hr x 8760 hrs/yr x 1 ton/2000lbs)) = $14,093/ton 

annualized

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 0.10 deciview for the maximum 24 hr impact at the 

Otter Creek Wilderness area due to PM10 filterable emissions. The annual cost of $14,271,144 

translates to $142,271,144/delta dv at the Otter Creek Wilderness Area.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

Reliant Energy, Keystone

313 Keystone Lane

Shelocta, PA 15744-2305

TV Operating Permit #: 03-00027

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 – Reliant Energy, Keystone

Page 2 of 4

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:

Reliant Energy, Keystone is an 1711 MW power plant with two BART affected coal fired 

boilers, Units 1and 2. Both units have ESPs. The facility used source specific emission factors 

developed as part of a compliance air emissions test program conducted from September 26 

through October 4, 2006 and the maximum daily heat input recorded during a five-year period 

from May 1, 2002 through October 30, 2006 for Unit 1 and from October 30, 2001 through 

October 30, 2006 for Unit 2. The maximum daily heat input data was derived from the continuos 

emission monitoring (CEM) data. The recalculated facilty wide filterable PM10 emissions for 

purposes of this determination are as summarized below:

Unit 1 67.7 lbs/hr

Unit 2 123 lbs/hr

190.7 lbs/hr = 835.3 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 0.06 0.02 0.04 0.02 0.04 0.02

Otter Creek Wilderness Area dv 0.05 0.02 0.07 0.02 0.03 0.02

Shenandoah National Park dv 0.08 0.05 0.07 0.05 0.05 0.03

 

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 an lesser or equivalent percent reductions but at 

costs that do not justify the associated possible reductions. Since this facility did not do a 
BART Application Review – Reliant Energy, Keystone

Page 3 of 4

January 17, 2008

technical feasibility study the Department assummed that COHPAC is technically feasible and 

performed a basic cost analysis for this option. COHPAC installations would 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 annual 

filterable PM10 emission rate of 190.7 lbs/hr after existing control and assumming 8760 hrs/yr 

of operation, a COHPAC estimated efficiency of 80% and an annualized COHPAC cost of 

$17,119,976 for the two boiler total AIMS listed scfm of 4,279,994 the cost of additional 

filterable PM10 removed calculates to approximately $25,621 per ton. 

($4/scfm x 4279994 scfm) / (0.80 x (190.7 lbs/hr x 8760 hrs/yr x 1 ton/2000lbs)) = $25,621/ton 

annualized

This analysis shows that this additional cost is not cost effective where the maximum theoretical 

visibilty reduction would be approximately 0.064 deciview for the maximum 24 hr impact at the 

Shenandoah National Park. Using the annualized cost of $17,119,976 for both units the resulting 

cost calculates to a minimum $267,499,625/delta dv at Shenandoah National Park. This also 

indicates that this option is not cost effective at the existing permit level of 0.1 lbs/MMBtu.

A three to five percent reduction from ESP enhancement would yield a 0.0024 to 0.0040 delta dv 

improvement respectively. Using a two unit 3 to 5 percent annualized cost range of $150,000 to 

$400,000 per year yields a dollar per deciview improvement cost range of $62,500,000 to 

$100,000,000/delta dv.

4. Permit Conditions

TV Permit # 03-00027 requires the control equipment that achieves the actual emissions rates 

that were used in this analysis. Therefore, existing permit conditions including the 0.1 

lb/MMBtu emission rate along with the implementation of EGU CAIR requirements satisfy 

BART requirements for this facility. 
BART Application Review – Reliant Energy, Keystone

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 an 

lesser or equivalent percent reductions but at costs that do not justify the associated possible 

reductions.

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

The COHPAC efficiency assumed for this analysis was 80%.

Step 4 – Evaluate Impacts and Document the Results.

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 annual filterable PM10 emission rate of 

190.7 lbs/hr after existing control and assumming 8760 hrs/yr of operation, a COHPAC 

estimated efficiency of 80% and an annualized COHPAC cost of $17,119,976 for the two boiler 

total AIMS listed scfm of 4,279,994 the cost of additional filterable PM10 removed calculates to 

approximately $25,621 per ton.

Step 5 – Evaluate Visibility Impacts.

This analysis shows that this cost is not justified where the maximum theoretical visibilty 

reduction would be approximately 0.064 deciview for the maximum 24 hr impact at the 

Shenandoah National Park. Using the annualized cost of $17,119,976 for both units, the 

resulting cost calculates to a $267,499,625/delta dv at Shenandoah National Park.
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

January 17, 2008

Subject: Review Memo for BART Application

Reliant Energy

Portland Generating Station

P. O. Box 238, River Road

Portland, PA 18351

TV Operating Permit #: 48-00006

To: Mark Wejksner Joyce Epps

Environmental Program Manager Director, Bureau of Air Quality

Northeast Regional Office

From: Joseph R. White, Air Quality Engineer 

Through: Ramamurthy, Krishnan

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 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, Portland Generating Station

Page 2 of 5

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:

Reliant Energy, Portland Generating Station has one BART affected boiler, Unit 2. Unit 2 is 

rated at an input of 2,511.6 MMBtu/hr. The facility calculated a filterable emission rate of 29 

lbs/hr. This equates to an emission rate of 0.0115 lbs/MMBTu of filterable particulate using the 

rated input. The facility used the 2005 emission inventory and the maximum daily heat input 

recorded from the 5-year period from January 2000 through Decemver 2004 as extracted from 

the facilities certified continious emission monitoring (CEM) system. Unit 2 is equiped with an 

ESP which was installed in 1967 as recorded in PA AIMS database.

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 

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 

facilities modelling indicate that, for filterable particulate, the existing 24-hr maximum deciview 

impact is 0.01 at both the Brigantine and Lye Brook Wilderness areas. 

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 equivalent or 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 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 29 lbs/hr after existing ESP control and assumming 8760 

hrs/yr of operation, a COHPAC estimated efficiency of 80% and an annualized COHPAC cost of 

$1,929,000 for the Unit 2 AIMS listed scfm of 482251 the cost of additional filterable PM10 

removed calculates to approximately $18,986.00 per ton. 
BART Application Review – Reliant Energy, Portland Generating Station

Page 3 of 5

January 17, 2008

This cost is not justified where the maximum theoretical visibilty reduction would be 

approximately 0.005 deciview for the maximum 24 hr impact at the Lye Brooks and Brigantine 

Wilderness Areas. Using the annualized COHPAC cost of $1,929,000 this calculates to 

$385,800,000/delta dv at either wilderness area. The cost would also not be justified at a 

modeled permit emission limit of 0.1 lb/MMBto for filterablr PM emissions.

The existing dv impact from Unit 2 is 0.010 dv. A three to five percent reduction from ESP 

enhancement would yield a 0.0003 to 0.0005 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 $ 250,000,000 to $800,000,000/delta dv.

4. Permit Conditions

TV Permit # 48-00006 requires the control equipment that achieves the actual emission rate that 

was used in this analysis. Therefore, present permit conditions including the existing permit 

limit of 0.1 lbs/MMBtu along with the implementation of EGU CAIR requirements satisfy 

BART requirements at this facility. 
BART Application Review – Reliant Energy, Portland Generating Station

Page 4 of 5

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 

equivalent or lesser percent reductions at costs that do not justify the associated possible 

reductions. 

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

For purposes of this evaluation the COHPAC efficiency was assumed to be 80%.

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 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 29 lbs/hr after 

existing ESP control and assumming 8760 hrs/yr of operation, a COHPAC estimated efficiency 

of 80% and an annualized COHPAC cost of $1,929,000 for the Unit 2 AIMS listed scfm of 

482251 the cost of additional filterable PM10 removed calculates to approximately $18,986.00 

per ton. 

Step 5 – Evaluate Visibility Impacts.

This cost is not justified where the maximum theoretical visibilty reduction would be 

approximately 0.005 deciview for the maximum 24 hr impact at the Lye Brooks and Brigantine 
BART Application Review – Reliant Energy, Portland Generating Station

Page 5 of 5

January 17, 2008

Wilderness Areas. Using the annualized COHPAC cost of $1,929,000 this calculates to 

$385,800,000/delta dv at either wilderness area.
CITY OF PHILADELPHIA

Department of Public Health

Environmental Protection Division

Air Management Services

InterOffice Memo

To: File

From: Edward Wiener

Date: August 21, 2007

Subject: BART approval for Sunoco Chemicals, Frankford Plant

Company Description:

Sunoco Chemicals, Frankford Plant (Sunoco Chemicals) owns and operates a synthetic organic chemical 

manufacturing plant which produces phenol, acetone, and alpha methyl styrene through the oxidation of cumene. 

The chemical process equipment located at the facility includes oxidizers, process boilers, distillation columns, 

reaction vessels, storage tanks, pumps, valves, and flanges.

Applicability for BART:

Sunoco Chemicals is a chemical process plant, one of the BART-eligible source categories. The plant has units that 

were in existence before August 7, 1977 and commenced operation after August 7, 1962, and the units within the 

date range have the potential to emit 250 tons per year of at least one of the following visibility impairing pollutants:

sulfur dioxide (SO2), nitrogen oxides (NOx), and particulate matter less than 10 microns (PM10). As a result, units 

within the above date range at the facility are BART-eligible. Pennsylvania decided not to allow modeling 

exemptions for BART. Therefore, all BART-eligible sources are subject to BART.

BART Analysis: 

Boiler No. 3 (BL-703), a 381 MMBTU/hr boiler capable of burning No. 6 oil and natural gas, was installed in 1964 

and is a BART-eligible source. The following table includes an analysis of the technically feasible control options: 

Pollutant Control Control 

Efficiency

Impact Benefit

(delta dv)

Cost Effectiveness

($/ton removed)

Cost for 

Improvement

($/dv)

NOx FGR 40%

NOx ULNB 50%

NOx SNCR 72%

NOx SCR 85% 0.0760 40,495 67,480,093

NOx ULNB + FGR 70% 0.0625 25,453 37,139,097

SO2 Wet Scrubber 90% 0.0301 2,836 29,439,689

PM Baghouse 99.5% 0.0144 26,894 44,506,519

The facility’s BART proposal did not provide an analysis of FGR and ULNB individually because they are rarely 

applied separately. The proposal did not provide an analysis of SNCR because the normal temperature range of the 

boiler is well below the optimal temperature range so the NOx control efficiency is expected to be well below 

normal. 
The facility also has emergency generators, distillation columns, oxidation processes, reactors, bulk loading 

facilities, storage tanks, and cooling towers that were installed during the BART-eligibility period. These units are 

considered insignificant activities because they have minimal emissions with a negligible impact on visibility, and/or 

they emit only VOCs, which PA DEP and AMS do not have the capability to model for impact. The degree of 

visibility improvement that could be obtained by requiring additional controls on these sources is so small that no 

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

controls under BART.

Conclusions and Recommendations:

Based on the five factors required for consideration in the BART analysis, AMS recommends no additional controls 

to reduce emissions of SO2, NOx and PM from the Sunoco Chemicals/Frankford Plant for purposes of BART. 
- 1 -

 COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

Sunoco Inc. June 10, 2008

100 Green St

PO Box 426

Marcus Hook, PA 19061

Operating Permit #: 23-00001

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: 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 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 -

Sunoco Marcus Hook Refinery is an oil refinery located in Marcus Hook, PA. It has thirty-six 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) 

045 12-3 DESULF. HEATER 6.1 0.5 0.1

075 17-2A,H-01 HEATER 153.8 6.2 0.7

076 17-2A,H-02 HEATER

077 17-2A,H-03 HEATER

078 17-2A,H-04 HEATER 4.5 0.3

089 15-BH-7 BOILER 103.6 5.6 0.6

101 PLT. 10-4 FCC UNIT 1489.1 208.7 4373.9

104 12 PLANT FLARE 0.9 1.4 5.3

105 10 PLANT FLARE 0.6 1.0 4.7

110 PURGING, SAMPLING, ETC.

111 COOLING TOWERS 42.0

112 PROCESS DRAINS

114 FACILITY-WIDE FUGITIVES

121 TANK 139 INT FLOAT 6.5 MBBL

146 TANK 344 INT FLOAT 180.67 MBBL

147 TANK 351 INT FLOAT 180.67 MBBL

148 TANK 352 INT FLOAT 180.69 MBBL

149 TANK 353 INT FLOAT 197.95 MBBL

150 TANK 354 INT FLOAT 197.99 MBBL

151 TANK 355 INT FLOAT 198.95 MBBL

181 TANK 593 INT FLOAT 130.1 MBBL

203 TANK 12 FIXED ROOF 54 MBBL

204 TANK 253 INT FLOAT 90.2 MBBL

340 TANK 340 FIXED ROOF 198.8 MBBL

349 TANK F-23 INT FLOAT 1.2 MBBL

401 BENZENE BARGE LOADING

402 BLIND CHANGING

606 TANK 244 FIX ROOF 70 MBBL

608 MARINE VESSEL LOADING

609 TRUCK LOADING-TOLUENE/XYLENE

610 TRUCK LOADING-TOLUENE

612 TOLUENE-MARINE VESSEL

613 GASOLINE-MARINE VESSEL LOADING

614 NAPHTHA-MARINE VESSEL

615 TRUCK LOADING - CYCLOHEXANE
- 3 -

COB1 CO BOILER NO.1 

Total: 1758.6 265.7 4385.3

Source IDs 101 and COB1 will see significant reductions as a result of Consent Decree 05-CV-2866 with 

the USEPA. The consent decree mandated the installation of a wet scrubber and SCR on the FCCU/CO 

Boiler. This installation is required prior to 2013, but installation is expected sometime in 2009. Among 

the affected units, this unit contributed approximately 85% of the actual 2002 NOx emissions, 99% of the 

2002 actual SO2 emissions, and 79% of the 2002 actual PM emissions. As a result, NOx emissions from 

the FCCU unit will not exceed 20 ppmvd based on a 365-day rolling average or 40 ppmvd based on a 7-

day rolling average, each at 0% oxygen and 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 1 lb/1000 lb coke burn or lower. 

3. NESCAUM CALPUFF modeling:

The Sunoco Marcus Hook 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 2.197 deciviews (dv). This impact is on the Brigantine wilderness area. 

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

regional haze at this facility. These three units are Source ID numbers 075, 089, and 101. However, 

Source 089 was inactivated on 4/27/2005, so no further analysis was required for that 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

045 Brigantine 0.005 0.000 0.005 0.000

075 Brigantine 0.080 0.000 0.077 0.002

076 N/A N/A N/A N/A

077 N/A N/A N/A N/A

078 Brigantine 0.003 0.000 0.003 0.000

089 N/A N/A N/A N/A

101 Brigantine 1.230 0.465 0.789 0.077

104 Brigantine 0.002 0.001 0.001 0.001

105 Brigantine 0.002 0.001 0.001 0.001

110 N/A N/A N/A N/A

111 N/A N/A N/A N/A
- 4 -

112 N/A N/A N/A N/A

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

121 N/A N/A N/A N/A

146 N/A N/A N/A N/A

147 N/A N/A N/A N/A

148 N/A N/A N/A N/A

149 N/A N/A N/A N/A

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

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

181 N/A N/A N/A N/A

203 N/A N/A N/A N/A

204 N/A N/A N/A N/A

340 N/A N/A N/A N/A

349 N/A N/A N/A N/A

401 N/A N/A N/A N/A

402 Brigantine 0.000 0.000 0.000 0.000

606 N/A N/A N/A N/A

608 N/A N/A N/A N/A

609 N/A N/A N/A N/A

610 N/A N/A N/A N/A

612 N/A N/A N/A N/A

613 N/A N/A N/A N/A

614 N/A N/A N/A N/A

615 N/A N/A N/A N/A

COB1 N/A N/A N/A N/A

Total: 1.2918

*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

045 N/A N/A N/A N/A

075 Brigantine 0.085 0.000 0.082 0.003

076 N/A N/A N/A N/A

077 N/A N/A N/A N/A

078 N/A N/A N/A N/A

089 N/A N/A N/A N/A

101 Brigantine 2.114 1.436 0.803 0.100

104 N/A N/A N/A N/A

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

110 N/A N/A N/A N/A

111 Brigantine 0.019 0.000 0.000 0.019

112 N/A N/A N/A N/A
- 5 -

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

121 N/A N/A N/A N/A

146 N/A N/A N/A N/A

147 N/A N/A N/A N/A

148 N/A N/A N/A N/A

149 N/A N/A N/A N/A

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

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

181 N/A N/A N/A N/A

203 N/A N/A N/A N/A

204 N/A N/A N/A N/A

340 N/A N/A N/A N/A

349 N/A N/A N/A N/A

401 N/A N/A N/A N/A

402 Brigantine 0.000 0.000 0.000 0.000

606 N/A N/A N/A N/A

608 N/A N/A N/A N/A

609 N/A N/A N/A N/A

610 N/A N/A N/A N/A

612 N/A N/A N/A N/A

613 N/A N/A N/A N/A

614 N/A N/A N/A N/A

615 N/A N/A N/A N/A

COB1 N/A N/A N/A N/A

Generic Stack Brigantine 0.010 0.003 0.006 0.001

Total: 2.197

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 
- 6 -

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

17-2A,H-01 Heater (ID 075)

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 17-2A,H-01 Heater for NOx, SOx, and PM. 

FCCU Unit and CO Boiler (IDs 101 and COB1)

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 FCCU Unit and CO Boiler for NOx, SOx, and PM.

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

17-2A,H-01 Heater (ID 075) Technically 

Feasible/Infeasible

NOx
- 7 -

Water/Steam Injection Infeasible

SNCR Feasible

SCR Feasible

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

Fuel Switching Feasible

SNCR, 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.

ULNB with SNCR is not feasible because it has not been installed and operated successfully for process 

heaters and is therefore considered technically infeasible. 

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

17-2A,H-01 Heater 

(ID 075)

Control Effectiveness

NOx Controls

SCR 80%

SNCR 19%

ULNB 73%

ULNB and SCR 94%

SO2 Controls
- 8 -

Fuel Specification Not considered further 

because NSPS standard 

already meets BACT.

A control efficiency of 73% for an Ultra Low NOx Burner is representative of the achievable level for 

that particular control device. A control efficiency of 94% for an Ultra Low NOx Burner and SCR is 

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

SNCR is an economically inferior option because it achieves very small NOx reductions with a higher 

cost than combustion controls. Therefore, it will be removed from consideration.

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

17-2A,H-01 Heater 

(ID 075)

Cost Effectiveness 

($/ton)

Cost of Visibility 

Improvement ($/dv)

NOx Controls

ULNB 4,791 9,159,501

ULNB and SCR 17,517 33,526,031

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 

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 17-2A,H-01 Heater (ID 

075) in the foreseeable future. 

STEP – 5: Evaluate Visibility Impacts

The Department examined the possibility of the installation of an ULNB on Process Heater 075. Even 

though it was calculated that cost of an ULNB would be approximately $4791/ton of NOx removed or 

$9,159,501/dv improvement, a complete heater rebuild would be required for the retrofit, which would 

make this option technically infeasible. This installation would cause an approximately 0.035 deciview 

visibility improvement. The basis of the visibility impact is the modeling conducted by Sunoco which was 

performed in accordance with NESCAUM’s procedures and utilized the maximum daily impact. This is a 

relatively high cost for minimal visibility improvement.
- 9 -

5. Conclusion:

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

BART for the Sunoco Marcus Hook Refinery: compliance with the terms of the EPA consent decree for 

the FCCU/CO Boiler (Source ID numbers 101 and COB1); and compliance with the existing operating 

permit for the 17-2A,H-01 Heater (Source ID number 075). The current NOx emission limitation for the 

heater is 0.25 lb/MMBtu (24 hour) when firing refinery gas. The current SO2 emissions limitation for 

the heater is 500 ppmvd.

cc: Southeast Regional Office

Central Office

 
CITY OF PHILADELPHIA

Department of Public Health

Environmental Protection Division

Air Management Services

InterOffice Memo

To: File

From: Edward Wiener

Date: August 22, 2007

Subject: BART approval for Sunoco, Inc. (R&M) 

Company Description:

Sunoco, Inc. (R&M) (Sunoco Refinery) owns and operates a petroleum refining facility in Philadelphia, Pennsylvania. The facility is 

comprised of three processing areas: Point Breeze, Girard Point, and Schuylkill River Tank Farm. Girard point processing area and

Schuylkill River Tank Farm were formerly owned by Chevron. Equipment used at the facility includes storage tanks, heaters, boilers, 

reactors, distillation columns, heat exchangers, cooling towers, pumps, valves and flanges. The refinery currently processes crude oil 

into various products such as blended residual oils, home heating oils, kerosene, jet fuels, asphalt, butanes, gasoline, propane, 

propylene, benzene, and cumene.

Applicability for BART:

Sunoco Refinery is a petroleum refinery, one of the BART-eligible source categories and has units that were in existence before 

August 7, 1977 and commenced operation after August 7, 1962. The units within the date range have the potential to emit 250 tons 

per year of at least one of the following visibility impairing pollutants: sulfur dioxide (SO2), nitrogen oxides (NOx), and particulate 

matter less than 10 microns (PM10). As a result, units within the above date range at the facility are BART-eligible. Pennsylvania 

decided not to allow modeling exemptions for BART. Therefore, all BART-eligible sources are subject to BART.

BART Analysis: 

Sunoco Refinery has numerous process heaters that are BART-eligible. The following table includes an analysis of the control 

options for NOx (some of the controls are not technically feasible for some of the heaters): 

Unit Rated 

Capacity

(MMBTU/hr)

Control Control 

Efficiency

Impact Benefit

(delta dv)

Cost Effectiveness

($/ton removed)

Cost for 

Improvement

($/dv)

2H-8 Heater 49.6 UNLB/SCR 85.0% 0.0020 34,481 93,278,165

ULNB 33.3% 0.0008 17,008 66,264,829

Unit 137 F-3 Heater 60.0 UNLB/SCR 97.5% 0.0228 12,571 24,662,223

ULNB To be 

installed 

(12/08)

Unit 433 Iso. H-1 

Heater

243.0 UNLB/SCR 92.9% 0.0024 32,049 150,638,298

ULNB Installed

H-101 Heater 49.5 UNLB/SCR 92.9% 0.0024 39,098 173,337,178

ULNB 68.5% 0.0019 6,207 27,285,518

H-201 Heater 242.0 UNLB/SCR 92.5% 0.0230 34,326 48,238,753

ULNB Installed

13H-1 Heater 235.4 UNLB/SCR 90.6% 0.0115 27,481 134,326,699
ULNB 58.3% 0.0074 4,924 25,730,886

2H-2 Heater 70.0 UNLB/SCR 94.7% 0.0083 10,429 38,780,522

ULNB 76.5% 0.0068 2,898 11,321,875

2H-3 Heater 174.7 UNLB/SCR 94.4% 0.0169 13,390 51,895,239

ULNB 75.2% 0.0135 1,775 7,021,833

2H-4 Heater 99.0 UNLB/SCR 94.7% 0.0111 11,355 42,113,981

ULNB 76.5% 0.0090 3,261 12,727,696

2H-5 Heater 155.0 UNLB/SCR 94.7% 0.0184 14,261 55,117,625

ULNB 76.5% 0.0149 2,148 8,502,180

2H-7 Heater 59.0 UNLB/SCR 93.8% 0.0063 11,398 41,624,288

ULNB 72.4% 0.0049 2,721 10,498,749

PH-1 Heater 80.0 UNLB/SCR 94.1% 0.0043 20,383 73,944,412

ULNB 73.7% 0.0034 7,737 30,191,668

PH-7 Heater 45.5 UNLB/SCR 94.9% 0.0039 16,381 57,726,642

ULNB 77.3% 0.0032 8,254 32,090,515

PH-11 Heater 74.0 UNLB/SCR 93.3% 0.0054 17,279 61,550,487

ULNB 70.3% 0.0040 6,455 25,322,044

PH-12 Heater 85.1 UNLB/SCR 92.2% 0.0033 33,747 114,926,362

ULNB 65.2% 0.0024 16,413 64,046,760

11H-1 Heater 72.2 UNLB/SCR 90.9% 0.0034 23,180 88,551,307

ULNB 59.6% 0.0024 10,073 43,424,611

11H-2 Heater 49.9 UNLB/SCR 90.4% 0.0037 21,862 69,455,190

ULNB 57.2% 0.0023 11,147 43,610,187

12H-1 Heater 43.0 UNLB/SCR 89.9% 0.0004 23,399 73,247,399

ULNB 55.3% 0.0014 12,033 46,954,526

A consent decree requires all process heaters at the facility to eliminate oil burning and to only burn refinery fuel gas with a hydrogen 

sulfide content of less than 0.1 gr/dscf by December 31, 2010, which will lower SO2 and PM10 emissions. Add-on SO2 and PM10 

controls are not used in practice for process heaters according to EPA’s RACT/BACT/LAER clearinghouse database, would be cost 

prohibitive, and would not result in a significant impact benefit. 

The facility also has flares, cooling towers, miscellaneous process vents, storage tanks, wastewater processes, an alkylation unit, a 

cumene production unit, and a benzene production unit that were installed during the BART-eligibility period. These units are 

considered insignificant activities because they have minimal emissions with a negligible impact on visibility, and/or they emit only 

VOCs, which PA DEP and AMS do not have the capability to model for impact. The degree of visibility improvement that could be 

obtained by requiring additional controls on these sources is so small that no reasonable weighting of the five factors required by 

consideration in the BART analysis could justify additional controls under BART. 

Conclusions and Recommendations:

Based on the cost and potential visibility improvement from additional controls, AMS proposes to determine that compliance with the 

requirements of the federally enforceable consent decree should satisfy BART for the Sunoco Refinery. [Consent decree filed June 16, 

2005, in the United States District Court for the Eastern District of Pennsylvania between, on the one hand, the United States of 

America (on behalf of EPA), Plaintiff, and State of Pennsylvania, City of Philadelphia, State of Oklahoma, State of Ohio, 

Plaintiff/Intervenors and, on the other hand, Sunoco, Inc., Defendant.]
CITY OF PHILADELPHIA

Department of Public Health

Environmental Protection Division

Air Management Services

InterOffice Memo

To: File

From: Edward Wiener

Date: October 3, 2007

Subject: BART approval for Trigen - Edison Station

Company Description:

Trigen - Edison Station (Trigen – Edison) owns and operates a steam generating facility in Philadelphia, 

Pennsylvania. Equipment used at the facility includes boilers. 

Applicability for BART:

Trigen - Edison has fossil-fuel boilers greater than 250 MMBTU/hr heat input, one of the BART-eligible source 

categories. Trigen – Edision has units that were in existence before August 7, 1977 and commenced operation after 

August 7, 1962. The units within the date range have the potential to emit 250 tons per year of at least one of the 

following visibility impairing pollutants: sulfur dioxide (SO2), nitrogen oxides (NOx), and particulate matter less 

than 10 microns (PM10). As a result, units within the above date range at the facility are BART-eligible. 

Pennsylvania decided not to allow modeling exemptions for BART. Therefore, all BART-eligible sources are 

subject to BART.

Boiler No. 3 and Boiler No. 4 are the BART-eligible sources at the facility. Each is a 335 MMBTU/hr boiler that 

burns No. 6 oil as primary fuel and No. 2 oil as ignition fuel. Boiler No. 3 was installed in 1970 and Boiler No. 4 

was installed in 1969. In 2002, the boilers had the following actual emissions in tons per year:

NOx PM10 SO2

Boiler No. 3 42.7 1.38 50.7

Boiler No. 4 44.4 1.31 48.3

Based on NESCAUM CALPUFF modeling, the boilers had the following maximum impact values on a Class I area 

(Brigantine wilderness) in deciviews:

Total SO4 NO3 PM10

Boiler No. 3 0.0128 0.0065 0.0097 0.0011

Boiler No. 4 0.0131 0.0062 0.0101 0.0010

Total 0.0259 0.0128 0.0199 0.0021

BART Analysis: 

The following table includes an analysis of the technically feasible control options (Cost Effectiveness range 

includes totals for Boiler No. 3 and Boiler No. 4, Cost for Improvement lists the cost for the highest Impact Benefit 

only): 

Pollutant Control Control 

Efficiency

Impact Benefit

(delta dv)

Cost Effectiveness

($/ton removed)

Cost for 

Improvement

($/dv)
NOx LNB/ULNB 20% 0.0019-0.0020 5,936-6,620 23,230,500

NOx OFA 25% 0.0024-0.0025 3,844-4,018 15,044,400

NOx SNCR 35% 0.0034-0.0035 10,536-11,012 41,232,285

NOx FGR 40% 0.0039-0.0040 3,732-3,901 14,605,500

NOx SCR 90% 0.0087-0.0091 21,608-22,585 83,636,373

NOx LNB/ULNB 

and OFA

40% 0.0039-0.0040 5,371-5,614 21,081,000

NOx LNB/ULNB, 

OFA and SNCR

55% 0.0053-0.0056 10,610-11,091 40,783,035

NOx LNB/ULNB, 

OFA and FGR

55% 0.0053-0.0056 6,620-6,920 25,445,357

SO2 No. 2 Fuel Oil 57% 0.0035-0.0037 24,975 316,817,297

SO2 Low Sulfur 

Diesel Oil

89% 0.0055-0.0058 19,843 236,023,620

SO2 Ultra Low 

Sulfur Diesel 

Oil

>99% >0.0061-

0.0064

18,665 <221,985,000

The facility’s BART proposal did not provide an analysis of flue gas desulfurization or a wet scrubber because 

EPA’s RACT/BACT/LAER Clearinghouse database indicates that these controls are not used for oil-fired boilers in 

practice. The proposal did not include an impact benefit or cost of improvement analysis for any of the control 

options. The numbers in the table above were calculated based on the NESCAUM CALPUFF modeling impact 

values and the total annualized costs listed in the proposal. 

Conclusions and Recommendations:

The NESCAUM CALPUFF modeling analysis showed a baseline impact of 0.0128 delta dv for Boiler No. 3 and 

0.0131 delta dv for Boiler No. 4 without controls. Based on consideration of cost and potential visibility 

improvement from additional controls, AMS proposes no additional controls to reduce emissions of SO2, NOx and 

PM from the boilers subject to BART at the Trigen – Edison Station as justified for purposes of BART. 
CITY OF PHILADELPHIA

Department of Public Health

Environmental Protection Division

Air Management Services

InterOffice Memo

To: File

From: Edward Wiener

Date: October 3, 2007

Subject: BART approval for Trigen - Schuylkill Station

Company Description:

Trigen - Schuylkill Station (Trigen – Schuylkill) owns and operates a steam generating facility in Philadelphia, 

Pennsylvania. Equipment used at the facility includes boilers. 

Applicability for BART:

Trigen - Schuylkill has fossil-fuel boilers greater than 250 MMBTU/hr heat input, one of the BART-eligible source 

categories. Trigen - Schuylkill has a unit that was in existence before August 7, 1977 and commenced operation 

after August 7, 1962. The unit within the date range has the potential to emit 250 tons per year of at least one of the 

following visibility impairing pollutants: sulfur dioxide (SO2), nitrogen oxides (NOx), and particulate matter less 

than 10 microns (PM10). As a result, the unit within the above date range at the facility is a BART-eligible source. 

Pennsylvania decided not to allow modeling exemptions for BART. Therefore, all BART-eligible sources are 

subject to BART.

Boiler No. 26 is the BART-eligible source at the facility. It is a 761 MMBTU/hr boiler that burns No. 6 oil as 

primary fuel and No. 2 oil as ignition fuel. The boiler was installed in 1971. In 2002, the boiler had the following 

actual emissions in tons per year:

NOx PM10 SO2

Boiler No. 26 61.5 8.08 111.7

Based on NESCAUM CALPUFF modeling, the boilers had the following maximum impact values on a Class I area 

(Otter Creek) in deciviews:

Total SO4 NO3 PM10

Boiler No. 26 0.0210 0.0124 0.0077 0.0009

BART Analysis: 

The following table includes an analysis of the technically feasible control options: 

Pollutant Control Control 

Efficiency

Impact Benefit

(delta dv)

Cost Effectiveness

($/ton removed)

Cost for 

Improvement

($/dv)

NOx LNB/ULNB 20% 0.0015 3,640 70,360,667

NOx OFA 25% 0.0019 2,357 44,967,894

NOx SNCR 35% 0.0027 6,461 121,417,407

NOx FGR 40% 0.0031 2,289 42,810,645

NOx SCR 90% 0.0069 10,605 200,528,696
NOx LNB/ULNB 

and OFA

40% 0.0031 3,293 61,607,096

NOx LNB/ULNB, 

OFA and SNCR

55% 0.0042 6,507 123,525,714

NOx LNB/ULNB, 

OFA and FGR

55% 0.0042 4,060 77,070,238

SO2 No. 2 Fuel Oil 57% 0.0071 24,975 512,922,113

SO2 Low Sulfur 

Diesel Oil

89% 0.0110 19,843 386,624,909

SO2 Ultra Low 

Sulfur Diesel 

Oil

>99% >0.0123 18,665 <358,837,154

The facility’s BART proposal did not provide an analysis of flue gas desulfurization or a wet scrubber because 

EPA’s RACT/BACT/LAER Clearinghouse database indicates that these controls are not used for oil-fired boilers in 

practice. The proposal did not include an impact benefit or cost of improvement analysis for any of the control 

options. The numbers in the table above were calculated by AMS based on the NESCAUM CALPUFF modeling 

impact values and the total annualized costs listed in the proposal.

Conclusions and Recommendations:

The NESCAUM CALPUFF modeling analysis showed a baseline impact of 0.0210 delta dv for Boiler No. 26 

without controls. Based on consideration of the cost and potential visibility improvement from additional control, 

AMS proposes no additional controls to reduce emissions of SO2, NOx and PM from the boiler subject to BART at 

the Trigen – Schuylkill Station as justified for purposes of BART. 
- 1 -

 COMMONWEALTH OF PENNSYLVANIA

 DEPARTMENT OF ENVIRONMENTAL RESOURCES

Subject: Review Memo for BART Application

United Refining Company/Warren Plant June 11, 2008

PO Box 780

Warren, PA 16365

Operating Permit #: 62-00017

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 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 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 -

United Refining Company/Warren Plant is an oil refinery located in Warren, PA. It has nine 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) 

034 BOILER NO.4 54.3 2.8 1.6

042 FCC HEATER (NEW UNIT) 15.2 1.1 0.5

049 EAST REFORMER HEATER 24.7 6.4 98.2

050 CRUDE HEATER - NORTH 103.9 48.6 748.2

051 PRETREATER HEATER 25.7 6.8 112.6

109 NSPS FUG EMISSIONS (VALVES/PUMPS/ETC)

110 WASTEWATER FUGITIVE EMISSIONS

206 FUEL STORAGE TANK #236

207 FUEL STORAGE TANK #337

Total: 223.8 65.7 961.1

3. NESCAUM CALPUFF modeling:

The United Refining Company/Warren Plant 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 0.094 deciviews (dv). This impact is on the Presidential Range Dry River. 

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

regional haze at this facility. These units are Source ID numbers 034 and 050.

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

034 Mingo Wilderness 0.002 0.000 0.001 0.000

042 Mingo Wilderness 0.000 0.000 0.000 0.000

049 Mingo Wilderness 0.006 0.006 0.001 0.000

050 Mingo Wilderness 0.047 0.044 0.003 0.001
- 3 -

051 Mingo Wilderness 0.007 0.007 0.001 0.000

109 N/A N/A N/A N/A

110 N/A N/A N/A N/A

206 N/A N/A N/A N/A

207 N/A N/A N/A N/A

Total: 0.059

*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

034 Shenandoah 0.006 0.000 0.006 0.000

042 N/A N/A N/A N/A

049 Presidential Range 0.010 0.008 0.002 0.000

050 Presidential Range 0.068 0.060 0.007 0.001

051 Presidential Range 0.011 0.009 0.002 0.000

109 N/A N/A N/A N/A

110 N/A N/A N/A N/A

206 N/A N/A N/A N/A

207 N/A N/A N/A N/A

Total: 0.094

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 
- 4 -

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

Boiler Number 4 (ID 034)

NOx SO2 PM

FGR None None

SNCR

SCR

ULNB

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

to Boiler Number 4 for NOx, SOx, and PM. 

Crude Heater North (ID 050)

NOx SO2 PM

ULNB Fuel Switching Fuel Switching

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

to the Crude Heater North for NOx, SOx, and PM. 

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

Boiler Number 4 Technically 

Feasible/Infeasible

NOx

FGR Feasible

SNCR Feasible

SCR Feasible

ULNB Infeasible

Crude Heater 

North

NOx

ULNB Feasible
- 5 -

SO2

Fuel Switching Feasible

PM

Fuel Switching Feasible

FGR, SNCR, and SCR are all considered technically feasible options for Boiler Number 4 because these 

control options have all been demonstrated as effective for boilers.

ULNB is not considered technically feasible for Boiler Number 4 because it would require a complete 

rebuild.

ULNB and fuel switching are considered technically feasible options for Crude Heater North because 

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

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

Boiler Number 4 Control 

Effectiveness

NOx

FGR 77%

SNCR 60%

SCR 75%

Crude Heater 

North

NOx

ULNB 75%

SO2

Fuel Switching 99%

SNCR is an economically inferior to FGR because it achieves smaller NOx reductions with a higher 

cost. Therefore, it will be removed from consideration.

SCR is economically inferior to FGR because it would require large amounts of ammonia and cause 

ammonia slip. Therefore, SCR will be removed from consideration.
- 6 -

FGR would achieve 77% control efficiency. This is representative of the achievable emission reduction 

level for FGR. 

A control efficiency of 75% for an Ultra Low NOx Burner on the Crude heater North is representative of 

the achievable level for that particular control device. A control efficiency of 99% for an fuel switching 

from residual oil to distillate oil on the Crude heater North is representative of the achievable level for 

that particular control option. 

STEP – 4: Evaluate Impacts and Document the Results

Boiler Number 4 Cost Effectiveness 

($/ton)

Cost of Visibility 

Improvement 

($/dv)

NOx

FGR 2,200 67,000,000

Crude Heater 

North

NOx

ULNB 3,266 50,000,000

SO2

Fuel Switching 4,441 55,000,000

The facility found no energy or non-air quality impacts associated with any of these control options. The 

remaining useful life of the sources were not calculated, so the Department has assumed that there are no 

plans to shutdown these sources in the foreseeable future.

STEP – 5: Evaluate Visibility Impacts

It would be possible to eliminate approximately 99% of the SO2 by using distillate oil instead of residual 

oil in the facility’s Crude Heater North. The cost of this change would be an estimated $4441/ton (on an 

actual basis) or $55 million/dv improvement for the Crude Heater North. This cost differs from an 

estimate provided in the April 16, 2007 MACTEC Report because MACTEC analyzed switching from 

low sulfur diesel fuel oil to ultra low sulfur diesel fuel oil. The Department looked at switching from 

residual oil to distillate oil. This change would eliminate 740 tons of SO2. 

The Department also examined installing an ultra low NOx burner at Crude Heater North, source number 

050. This technology would cost approximately $3266/ton of NOx removed (on an actual basis) or $50 

million/dv improvement, and it would improve visibility by 0.00525 deciviews. 

The Department also found that flue gas recirculation on Boiler Number 4 is a possibility. However, the 

cost would be $2200/ton of NOx (on an actual basis) or $67 million/dv improvement for a 0.0046 deciview 

visibility improvement. 
- 7 -

The cost effectiveness calculations 

5. Conclusion:

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

BART for the United Refining Company/Warren Plant: 

Compliance with the existing operating permit for Boiler Number 4 (Source number 034). The 

current NOx emissions limitation for the boiler is 0.173 lbs/MMBtu and 29.3 lbs/hr or 128.3 tpy 

based on a consecutive 12-month period. The current SO2 emission limitation for the boiler is 4 

lbs/MMBtu of heat input over any 1-hour period and 24.3 lbs/hr or 106.4 tpy based on a 

consecutive 12-month period.

Compliance with the existing operating permit for Crude Heater-North (Source number 050). 

The current NOx emissions limitation for the boiler is 0.226 lbs/MMBtu and 42.4 lbs/hr or 185.8 

tpy based on a consecutive 12-month period. The current SO2 emission limitation for the boiler 

is 4 lbs/MMBtu of heat input over any 1-hour period and 207.7 lbs/hr or 909.7 tpy based on a 

consecutive 12-month period.

cc: Northwest Regional Office

Central Office

 
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

Subject: Review Memo for BART Application May 5, 2009

United State Steel Corporation

Clairton Works

400 State Street

Clairton, PA 15025

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 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. 

The Allegheny County Health Department (ACHD), in a letter dated May 31, 2006, 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:

US Steel Clairton Works is a coke oven battery plant. It has eight units that meet the date criteria for 

BART.

The following are the Source ID numbers of the BART affected units at this facility.

US Steel Corporation (Tax I.D. 25-0996816)

Clairton Works (Facility I.D. 00032)

BART Category 14 - Coke Oven Batteries

Emissions data taken from Form K of March 2001 Operating Permit Application and April 2002 update, and from the ACHD 

Emission Inventory. 

Table I

Units Known to Have Been Installed Within 1962-77 Time Frame

Emission 

Unit

Units 

discharg 

ing to 

this 

stack

Emission 

Source 

Description

Install

Date

PM10

PTE 

(TPY)

PM10

Actual 

(TPY) 

2002

NOx PTE 

(TPY)

NOx

Actual

(TPY)

2002

SO2

PTE 

(TPY)

SO2

Actual 

(TPY)

2002

VOC

PTE

(TPY)

VOC 

Actual 

(TPY)

2002

N/A P019 Desulfurization 

Plant

1968 1.49 No data27.33 1.66 55.87 151.44 346.53 125.27

S032 B002 Boiler #2 - COG 1965 29.57 12.36 1285.00 263.03 1508.45 115.32 5.06 3.41

S032 B002 Boiler #2 - NG 1965 16.85 0.28 1285.00 26.82 1508.45 0.08 11.59 0.77

S036 B005 R1 Boiler - COG 1974 14.05 0.49 525.00 8.82 796.40 6.45 2.44 0.13

S036 B005 R1 Boiler - NG 1974 20.06 0.00 525.00 0.00 796.40 0.00 5.52 0.00

S036 B006 R2 Boiler - COG 1975 14.04 0.30 525.00 5.51 796.40 4.54 2.44 0.08

S036 B006 R2 Boiler - NG 1975 20.06 0.00 525.00 0.00 796.40 0.00 5.52 0.00

S038 B007 T1 Boiler - COG 1976 9.61 0.30 358.00 5.36 572.59 3.58 1.65 0.08

S038 B007 T1 Boiler - NG 1976 13.67 0.00 358.00 0.00 572.59 0.00 3.76 0.00

S039 B008 T2 Boiler - COG 1975 9.59 0.31 358.00 5.36 572.59 4.26 1.65 0.08

S039 B008 T2 Boiler - NG 1975 13.67 0.00 358.00 0.00 572.59 0.00 3.76 0.00

P020 Keystone Cooling 

Tower

1962-77 0.78 0.31 0.00 0.00 0.00 0.00 0.00 0.00

P041 Boom Conveyer 1962-77 6.23 0.16 0.00 0.00 0.00 0.00 0.00 0.00

TOTAL 169.67 14.35 6129.33 316.56 8548.73 285.67 389.92 129.82
3

3. NESCAUM CALPUFF modeling:

US Steel Corporation’s Clairton Works has emission units at its facility that were originally constructed 

between 1962 and 1977. The total potential emissions from the date-eligible units of three visibility 

impairing pollutants (SO2, NOx and VOC) 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, in this case the Otter Creek Wilderness Area, was 0.0897 deciviews (dv). 

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

displays the adjusted* NESCAUM modeling results. 

Table II

* Boiler #2 results are “adjusted” because an error in the emission rate was found in the NESCAUM 

modeling results for Boiler #2 after the modeling was completed. In order to make a proper analysis, 

modeling results were corrected by multiplying modeled results by the corrected emission rates, i.e., using 

ratios.

On an individual emission unit basis, the maximum impact of these units on a Class 1 area, again Otter 

Creek Wilderness Area, is from nitrates from Boiler #2. 

4. BART Analysis:

US Steel Corporation did not submit a BART engineering analysis. Rather, contrary to the requirements 

of the MANE-VU regional planning organization, the company submitted visibility impairment modeling, 

to exempt itself from the engineering analysis. The company submitted this modeling in a December 20, 

2006 letter to the ACHD. The results of the report are not discussed here.

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 ‘BART Determination’ 

process 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). The 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, the 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 

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 Otter Creek 0.0142 0.0140 0.0003 0.0001 Desulfurization_Plant

Best Otter Creek 0.0732* 0.0107* 0.0605* 0.0020* Boiler_#2

Best Otter Creek 0.0023 0.0006 0.0017 0.0000 R1_Boiler

Best Dolly Sods 0.0066 0.0013 0.0041 0.0012 Generic Stack
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, the 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 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

Desulfurization Plant Boiler #2 R1 Boiler

Existing controls Afterburner N/A N/A

Retrofit controls None Ultra Low NOx Burners Ultra Low NOx Burners

The facility’s Desulfurization Plant design incorporates redundant equipment to ensure its can continue 

to remove sulfur compounds from the coke oven gas in the event of component failures. No alternate 

control options to the Afterburner are identified in the RACT/BACT/LAER Clearinghouse.

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

to Boiler #2 and the R1 Boiler for the control of NOx. These boilers may use coke oven gas or natural 

gas.

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

No control options to the Afterburner are identified in the RACT/BACT/LAER Clearinghouse.

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

natural gas burners. These boilers may use coke oven gas or natural gas. 

STEP – 3: Evaluate Control Effectiveness of Remaining Control Technologies

Ultra Low NOx Burners provide a 65% improvement over the conventional natural gas burners. These 

boilers may use coke oven gas or natural gas.

STEP – 4: Evaluate Impacts and Document the Results

Cost Of Compliance: Ultra Low NOx Burner $12,800/ton.
5

The Annualized Cost for Boiler #2 is $2,406,400, and for the R1 Boiler it is $73,300. These calculations 

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

reductions for these controls were estimated to be 188 and 5.73 tons, respectively.

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 Otter Creek Class 1 area was found to be 0.0897 dv. 

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

(1) $39,775,000/dv for the ultra low NOx Burners for Boiler #2; and 

(2) $43,144,000/dv for the ultra low NOx Burners for the R1 Boiler.

The majority of the visibility impairing emissions was associated with the emissions from Boiler #2. 

The greatest visibility impact individually was 0.0605 dv attributed to the NOx emissions from Boiler 

#2. 

The other emission source, the Desulfurization Plant, has existing controls. Based on a review of current 

emissions reduction approaches in the RACT/BACT/LAER Clearinghouse (RBLC) there does not 

appear to be adequate alternatives available for the Desulfurization Plant, beyond the currently installed 

afterburner. Thus, no cost effectiveness calculations were performed for SOx from this unit. 

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 US Steel Clairton Works facility: 

Compliance with the existing operating permits for this facility. 

OPERATING PERMITS FOR BART ELIGIBLE SOURCES – U.S. Steel Clairton Works

ID Emission Source Permit #

S032 B002 Boiler No. 2 7035003-010-00800

S036-B005 & B006 Boiler Nos. R1 and R2 7035003-010-01300

S036- B007 & B008 Boiler Nos. T1 and T2 7035003-010-00600

P019 Desulfurization Plant 7035003-010-25600

P020 Keystone Cooling Tower No OP#

P041 Boom Conveyer No OP#
cc: Nancy Herb, PA DEP, Harrisburg

Jane Mahinske, PA DEP Harrisburg