BEST AVAILABLE RETROFIT TECHNOLOGY ANALYSIS

TVA PARADISE FOSSIL PLANT

July 16, 2007
CONTENTS

Section Page

I. Introduction.......................................................................................1

II. BART Engineering Analysis..................................................................3

III. BART Modeling Analysis.....................................................................7

IV. Conclusions....................................................................................16

Appendix--Cost of Compliance Details
1

I. Introduction

Guidelines for Best Available Retrofit Technology (BART) evaluations have been issued 

by the U. S. Environmental Protection Agency (EPA) in the Federal Register (70 FR 

39104-39172). A BART determination is required for any eligible source that “emits any 

air pollutant which may reasonably be anticipated to cause or contribute to any 

impairment of visibility” within any of the 156 mandatory Class I federal areas. A source 

is considered to cause visibility impairment if it is responsible for a 1.0 deciview (dv) 

change in visibility; it is considered to contribute to visibility impairment if it is 

responsible for a 0.5 dv change in visibility. 

Major stationary sources are BART-eligible if they meet three criteria:

(1) Potential to emit at least 250 tons per year of a visibility-impairing pollutant.

(2) “Commenced construction” as of August 7, 1977, but not in operation more 

than 15 years (August 7, 1962).

(3) Belong to one of the 26 listed source categories in the guidance. 

If an eligible source is concluded to be subject to BART, determination of the appropriate 

control alternative must consider the following statutory factors:

(1) existing control equipment

(2) cost of compliance

(3) energy and non-air environmental impacts

(4) remaining useful life of the source

(5) degree of visibility improvement expected from the application of controls

The TVA Paradise Fossil Plant (PAF), located in Muhlenberg County, KY, has three 

pulverized-coal, cyclone steam generators that are considered BART eligible. Units 1 and 

2 are nominally rated at about 704 MW each, and Unit 3 is nominally rated at about 1150 

MW. All three units are equipped with flue gas desulfurization (FGD) systems for sulfur 

dioxide (SO2) control and selective catalytic reduction systems for controlling nitrogen 

oxides (NOx). Units 1 and 2 use wet venturi scrubbers to control particulate matter (PM) 

emissions, and Unit 3 uses an electrostatic precipitator (ESP).

All three units at PAF are subject to the EPA Clean Air Interstate Rule (CAIR). Based on 

guidance from EPA and the Kentucky Division for Air Quality (KDAQ), compliance 

with CAIR satisfies BART requirements for SO2 and NOx emissions at electric 

generating units. As a result, this BART analysis only considers PM10 emissions.

Two Class I areas are located within 300 km of PAF: Mammoth Cave National Park 

(MACA) and Mingo Wilderness Area (MING). The locations of the PAF stacks, the two 

class I areas that are within 300 km, and the VISTAS 12-km and 4-km grid for domain 3 

are shown in Figure 1.
2

Figure 1. Location of PAF and Class I Areas within 300 km (Mammoth Cave 

National Park (MACA) and Mingo Wilderness Area (MING)). The red box shows 

the VISTAS 12-km domain, and the green box shows the VISTAS domain #3, the 

4-km subdomain that will be used in BART modeling for PAF.

As discussed in Section III, exemption modeling showed that all three units at PAF are 

subject to BART requirements for PM10. Therefore, an engineering analysis was required 

to determine whether there is a technically and economically feasible control scenario 

that represents BART. The modeling analysis also demonstrated that approximately 90 

percent of the visibility impacts at the affected Class I areas can be attributed to 

condensable PM10 emissions (i.e., SO3). So the engineering evaluation for PAF focuses 

on control of SO3/H2SO4 emissions.
3

II. BART Engineering Analysis

Based on emissions testing at PAF, Units 1 and 2 emit approximately 17.7 ppmdv SO3, 

and Unit 3 emits approximately 17.6 ppmdv SO3 (both corrected to 3%02). These values 

were used as the baselines for the engineering analysis. 

Two options were identified as technically feasible for controlling SO3 emissions at PAF: 

wet ESPs and hydrated lime injection. An ESP controls PM by imparting a negative 

charge to fly ash particles entering the device and collecting them on positively charged 

plates. In a wet ESP, the fly ash is removed by flushing the collection plates with water. 

Wet ESPs are very expensive, requiring large capital investments. They also require 

large volumes of water for cleaning the plates. This technology is capable of about 90% 

SO3 removal, so it was evaluated at an emission level of 1.8 ppmdv. It should be noted, 

however, that the vendor guarantee accompanying the capital cost quote that TVA 

received for this equipment equated to about 3 ppmdv SO3 (3%O2). 

Lime injection involves injecting hydrated lime in the convective pass or ductwork of the 

boiler. The lime reacts with SO3 to form calcium sulfate, which is removed downstream 

by the PM control device. TVA plans to install lime injection systems on all three units 

at PAF to mitigate opacity. These systems will be installed well before the regulatory

deadline for implementing BART. However, because they are not currently installed and 

operating, lime injection is included as a control option in the BART analysis. 

Lime injection testing on Unit 2 demonstrated an achievable SO3 emission level of 

approximately 7 ppmdv (3%O2). Because Unit 1 is similar to Unit 2, the same emission 

level would apply. Testing on Unit 3 has not been completed, so an achievable emission 

level has not been established. For the purposes of this analysis, an SO3 emission level of 

7 ppmdv was assumed. The analysis for Unit 3 may have to be revised after testing is 

completed if that emission rate cannot be achieved without negative impacts to existing 

particulate control equipment.
4

The top-down matrix of BART options is presented in Table 1.

Table 1. BART Hierarchy of Options

Control Option Achievable Emission Rate

(ppmdv SO3 @ 3%O2)

Comments

Wet ESP 1.8  High capital cost

 Large volumes of 

water required

 Vendor guarantee of 

only 3 ppm@3%O2

 Controls all PM10

components

Lime Injection 7.0  Lower capital cost

 High operating costs 

for reagent

 Achievable emission 

level not verified by 

testing for Unit 3

Cost of Compliance

Costs were estimated for both control options. Capital equipment costs for the wet ESP 

were obtained from a vendor quote (“Budgetary Proposal, Paradise Units 1 & 2, Babcock 

& Wilcox Company, July 3, 2007”). This quote applies to Units 1 and 2, but it was 

scaled using engineering assumptions for use with Unit 3. Capital costs for lime injection 

systems and annual reagent costs were based on TVA experience with similar equipment 

at other TVA locations. Other capital and annual costs were based on information in the 

EPA Air Pollution Control Cost Manual, Sixth Edition.

A summary of results from the cost analysis are presented in Table 2. Details can be 

found in the Appendix to this report. The total capital investment for a wet ESP ranges 

from about $100 million for Unit 1 or 2 to almost $156 million for Unit 3. Total annual 

costs range from about $29 million to $44 million per year. The corresponding total cost 

effectiveness ranges from $27,594 to $39, 263 per ton of SO3/H2SO4. Incremental cost 

effectiveness compared to lime injection ranges from $77, 821 to $82,940 per ton. Based 

on these results, a wet ESP is clearly economically infeasible for PAF and should, 

therefore, be eliminated from consideration as a basis for BART.

The total capital investment for hydrated lime injection ranges from $4.2 million for Unit 

1 or 2 to $8.4 million for Unit 3. Total annual costs range from about $2.3 million to 

$4.4 million per year. The corresponding cost effectiveness ranges from $3,265 to 

$6,776 per ton of SO3/H2SO4. Although considerably less expensive than a wet ESP, the 

cost effectiveness values for lime injection are still too high to be considered as an 

acceptable cost of compliance for BART.
5

Non-air Environmental Impacts

As stated previously, a wet ESP is a water intensive system. According to the EPA Air 

Pollution Control Cost Manual, a wet ESP uses at least 5 gal/min of water per 1,000 cfm 

of flue gas. Based on this ratio, operating wet ESPs on all three units at PAF would 

consume about 16 billion gallons per year of additional water and require treatment of an 

equivalent volume of wastewater.
6

Table 2. BART Cost of Compliance Summary

Unit 1 Unit 2 Unit 3

Lime Injection Wet ESP Lime Injection Wet ESP Lime Injection Wet ESP

Emission Reduction 

from Baseline 

(tons/yr) 697 1,035 705 1,047 644 1,123

Incremental 

Emission Reduction 

(tons/yr) -- 338 -- 342 -- 479

Total Capital 

Investment ($) 4,200,000 100,216,875 4,200,000 100,216,875 8,400,000 155,948,800

Total Annualized 

Cost ($/yr) 2,301,659 28,877,504 2,301,659 28,877,504 4,363,849 44,092,044

Total Cost 

Effectiveness ($/ton) 3,305 27,914 3,265 27,594 6,776 39,263

Incremental Cost 

Effectiveness ($/ton) -- 78,627 -- 77,821 -- 82,940
7

III. BART Modeling Analysis

TVA conducted BART modeling for PAF following both the general VISTAS protocol 

and the revised TVA BART protocol submitted to the Kentucky Division for Air 

Quality on July 17, 2006. Modeling was conducted on the VISTAS 4-km domain for the 

state of KY (dom 3). Two Class I areas are located within 300 km of PAF: Mammoth 

Cave (MACA) at 63.3 km and Mingo (MING) at 283 km. Stack parameters are 

presented in Table 3.

Table 3. Stack Parameters for PAF

Stack Parameter Unit 1 Unit 2 Unit 3

Stack Height (m) 182.9 182.9 182.9

Base Elevation (m) 129 129 129

Stack Diameter (m) 7.92 7.92 11.3

Gas Exit Velocity (m/s) 22.7 22.7 15.4

Stack Gas Exit 

Temperature (oK) 333 333 329

Exemption Modeling

CALPUFF modeling was conducted following the example files that were made 

available by Earth Tech, Inc. Following the example files, PM emissions were set to 1 

g/s for all size categories. The emission rate for SO3 was entered as H2SO4 in g/s as 

indicated on the “BART” worksheet of the emissions spreadsheet 

“PAF_CY06_BART.xls,” which was submitted with the revised modeling protocol 

document. All emissions for the modeling analysis were calculated assuming operation at 

maximum heat input to conservatively represent maximum 24-hour actual emissions. 

Emissions of HNO3 and PM-NO3 were set to zero, because no credible emissions factors 

were available for these species for EGUs. Support for setting HNO3 and PM-NO3 to 

zero was found in some SMOKE emissions factors provided by VISTAS. In the 

SMOKE emissions table provided by VISTAS, the factor provided for PM-NO3 was 

zero, as shown in Table 4. The SMOKE emissions factors were not used except as 

justification for setting emissions of HNO3 and NO3 to zero. 

Table 4. Emissions profiles from SMOKE for EGUs (provided by VISTAS).

profile Pllt species split divisor mass_frac

22001 PM2_5 PEC 0.0183 1 0.0183

22001 PM2_5 PMFINE 0.852 1 0.852

22001 PM2_5 PNO3 0 1 0

22001 PM2_5 POA 0.0107 1 0.0107

22001 PM2_5 PSO4 0.119 1 0.119
8

CALPUFF exemption modeling on the 4-km domain was conducted as follows:

1. A CALPUFF simulation was conducted using the VISTAS-approved version of 

CALPUFF (version 5.754) for each unit of PAF for each of the three years, 2001, 

2002 and 2003. 

2. Emission factors entered in the POSTUTIL control file are shown in Table 5. 

These factors were calculated in the spreadsheet “pm_distribution_PAF.xls” from 

the emissions values in the electronic workbook PAF_CY06_BART.xls following 

the example spreadsheet pm-distribution-sample-source, which was provided by 

Earth Tech. 

3. POSTUTIL version 1.52, level 060412 was run on each output file from step 1. 

4. The outputs from POSTUTIL were summed across the three units.

5. CALPOST version 5.6393, level 060202 was run separately for each class I area 

on the output from step 4. Method 6 was used. The baseline was based on the 

annual average for each Class I area, taken from Appendix B of Guidance for 

Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA 

454/B-03-005, published in September, 2003. The f(RH) values were taken from 

Table A-3, Monthly Site-Specific f(RH) Values for Each Mandatory Federal 

Class I Area, Based on the Centroid of the Area (Supplemental Information), 

found in the same EPA document. 

6. The lists of delta dv in the CALPOST.LST files for each of the 3 years were used 

to get the 98th percentile for each individual year, the 8th highest value. The data 

from the 3 years were combined together and sorted by delta dv to find the 98th

percentile value (22nd highest value) for the three years combined.

Results from the 4-km simulations are presented in Tables 6 and 7. 
9

Table 5. Emission Rates for PAF Used in POSTUTIL for Exemption Modeling

Species Unit Emission Rate (g/s)

PM800 PM425 PM187 PM112 PM081 PM056 Total*

PM10 1 111.8

PMC 1 11.1531 18.5892 29.74

SOIL 1 12.5307 4.4751 14.0233 1.1922 32.22

EC 1 0.4814 0.1719 0.5388 0.0458 1.24

H2SO4 1 45.08

SOA 1 1.7539 1.7539 3.51

NO3/

HNO3

1 0

PM10 2 113.

PMC 2 11.5206 19.2013 30.72

SOIL 2 12.9432 4.6227 14.4854 1.2316 33.28

EC 2 0.4973 0.1776 0.5566 0.0473 1.28

H2SO4 2 45.01

SOA 2 1.7512 1.7512 3.50

NO3/

HNO3

2 0

PM10 3 116.8

PMC 3 6.5827 10.9705

SOIL 3 7.3955 2.6414 8.2766 0.7039 19.02

EC 3 0.2841 0.1015 0.3180 0.0270 0.73

H2SO4 3 73.70

SOA 3 2.8870 2.8870 5.77

NO3/

HNO3

3 0

Table 6. Summary of CALPUFF Results for PAF on 4-km Grid.

Class I Area Dist 

(km) 

from 

source 

to 

nearest 

receptor

# Days with 98th

Percent > 0.5 dv, 

98th percentile, 

in Class I Area 

(2001)

# Days with 98th

Percent > 0.5 dv, 

98th percentile, 

in Class I Area 

(2002)

# Days with 98th

Percent > 0.5 dv, 

98th percentile, 

in Class I Area 

(2003)

# Days with 98th

Percent > 0.5 dv, 

98th percentile 

in Class I Area 

for 3-Year 

Period (2001-

2003)

Delta dv Used 8th highest 8th highest 8th highest 22nd highest

Mammoth Cave 

National Park, 

KY

63.3 101 3.62 76 3.45 96 3.93 273 3.86

Mingo 

Wilderness 

Area, MO

283 9 0.595 22 0.865 8 0.527 39 0.723
10

Table 7. 98th Percentile Results for Paradise-Impacted Class I Areas. (DeltaDeciview Rankings #1-22 Shown for 2001-2003.)

CLASS I 

AREA: Mammoth Cave

 Rank Year Day Delta dv

1 2001 32 6.95

2 2001 361 6.11

3 2003 123 5.89

4 2002 245 5.35

5 2002 59 5.34

6 2003 14 5.24

7 2002 237 4.89

8 2003 263 4.77

9 2001 241 4.60

10 2001 216 4.55

11 2001 312 4.39

12 2001 73 4.38

13 2002 291 4.35

14 2003 20 4.17

15 2003 161 4.07

16 2003 340 4.01

17 2002 316 3.98

18 2003 329 3.97

19 2002 362 3.95

20 2003 167 3.93

21 2003 169 3.88

22 2002 212 3.86

CLASS I 

AREA: Mingo

 Rank Year Day Delta dv

1 2001 177 1.44

2 2002 269 1.40

3 2002 39 1.28

4 2002 257 1.20

5 2003 254 1.18

6 2001 95 1.17

7 2001 79 1.16

8 2002 174 1.13

9 2002 222 1.10

10 2003 53 1.07

11 2001 247 1.04

12 2003 348 0.999

13 2002 345 0.995

14 2001 256 0.887

15 2003 173 0.884

16 2002 270 0.871

17 2002 253 0.865

18 2002 160 0.855

19 2002 243 0.835

20 2001 178 0.827

21 2002 216 0.824

22 2002 273 0.723

Because exemption modeling for PAF showed impacts greater than 0.5 dv at both MACA 

and MING, all three units at PAF are subject to BART requirements, and an engineering 

analysis and determination modeling were conducted.

Determination Modeling

The BART determination modeling for PAF was conducted for each unit. Because Units 

1 and 2 have similar design and operating parameters, determination modeling conducted 

for Unit 1 was considered applicable to both units. Determination modeling was 

conducted separately for Unit 3. The control options that were modeled are presented in 

Table 8. 
11

Table 8. Control Options for BART Determination Modeling

Unit 1 or 2 Unit 3

Control Option

SO3 Emissions 

(ppm H2SO4)

Filterable 

Particulate 

Emissions 

(lbs/MMBtu)

SO3 Emissions 

(ppm H2SO4)

Filterable 

Particulate 

Emissions 

(lbs/MMBtu)

Baseline level 17.7 0.110 17.6 0.038

Lime Injection 7.0 0.110 7.0 0.038

Wet ESP 1.8 0.015 1.8 0.015

CALPUFF determination modeling on the 4-km domain was conducted as follows:

1. A CALPUFF simulation was conducted using the VISTAS-approved version of 

CALPUFF (version 5.754) for each of the three years, 2001, 2002 and 2003. 

Separate simulations were conducted for each of the options in the modeling 

matrix. 

2. Emission factors entered in the POSTUTIL control file are shown in Table 9. 

These factors were calculated in the spreadsheet “pm_distribution_PAF.xls” from 

the emissions values in the electronic workbook “PAF_CY06_BART.xls”

following the example spreadsheet pm-distribution-sample-source, which was 

provided by Earth Tech. Factors were calculated separately for each option in the 

modeling matrix.

3. POSTUTIL version 1.52, level 060412 was run on each output file from step 1. 

4. CALPOST version 5.6393, level 060202 was run separately for each class I area 

on the output from step 3. Method 6 was used. The baseline was based on the 

annual average for each Class I area, taken from Appendix B of Guidance for 

Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA 

454/B-03-005, published in September, 2003. The f(RH) values were taken from 

Table A-3, Monthly Site-Specific f(RH) Values for Each Mandatory Federal 

Class I Area, Based on the Centroid of the Area (Supplemental Information), 

found in the same EPA document. 

5. The lists of delta dv in the CALPOST.LST files for each of the 3 years were used 

to get the 98th percentile for each individual year, the 8th highest value. The data 

from the 3 years were combined together and sorted by delta dv to find the 98th

percentile value (22nd highest value) for the three years combined.
12

Table 9. Emission Rates for PAF Used in POSTUTIL for Determination Modeling

Species Unit/Run Emission Rate (g/s)

PM800 PM425 PM187 PM112 PM081 PM056 Total*

PM10 1-base 111.8

PMC 1-base 11.1531 18.5892 29.74

SOIL 1-base 12.5307 4.4751 14.0233 1.1922 32.22

EC 1-base 0.4814 0.1719 0.5388 0.0458 1.24

H2SO4 1-base 45.08

SOA 1-base 1.7539 1.7539 3.51

NO3/

HNO3

1-base 0

PM10 1-lime 84.51

PMC 1-lime 11.1531 18.5892 29.74

SOIL 1-lime 12.5307 4.4751 14.0233 1.1922 32.22

EC 1-lime 0.4814 0.1719 0.5388 0.0458 1.24

H2SO4 1-lime 17.80

SOA 1-lime 1.7540 1.7540 3.51

NO3/

HNO3

1-lime 0

PM10 1-WESP 17.03

PMC 1-WESP 1.5781 2.6302

SOIL 1-WESP 1.7730 0.6337 1.9849 0.1685 4.56

EC 1-WESP 0.0681 0.0243 0.0763 0.0065 0.18

H2SO4 1-WESP 4.58

SOA 1-WESP 1.7538 1.7538 3.51

NO3/

HNO3

1-WESP 0

PM10 3-base 116.8

PMC 3-base 6.5827 10.9705

SOIL 3-base 7.3955 2.6414 8.2766 0.7039 19.02

EC 3-base 0.2841 0.1015 0.3180 0.0270 0.73

H2SO4 3-base 73.70

SOA 3-base 2.8870 2.8870 5.77

NO3/

HNO3

3-base 0

PM10 3-lime 72.39

PMC 3-lime 6.5827 10.9705

SOIL 3-lime 7.3955 2.6414 8.2766 0.7039 19.02

EC 3-lime 0.2841 0.1015 0.3180 0.0270 0.73

H2SO4 3-lime 29.31

SOA 3-lime 2.8871 2.8871 5.77

NO3/

HNO3

3-lime 0

PM10 3-WESP 28.04
13

Species Unit/Run Emission Rate (g/s)

PMC 3-WESP 2.5980 4.3311

SOIL 3-WESP 2.9189 1.0429 3.2675 0.2773 7.51

EC 3-WESP 0.1121 0.0401 0.1255 0.0107 0.29

H2SO4 3-WESP 7.54

SOA 3-WESP 2.8872 2.8872 5.77

NO3/

HNO3

3-WESP 0

Table 10. Summary of BART Determination Modeling Results for MACA

Delta dv 8th highest 8th highest 8th highest 22nd highest

Unit/Run 2001 2002 2003 2001-2003

1-base 1.203 1.192 1.285 1.264

1-lime 0.567 0.567 0.606 0.594

1-WESP 0.155 0.156 0.166 0.162

3-base 1.740 1.624 1.842 1.819

3-lime 0.790 0.726 0.836 0.824

3-WESP 0.248 0.224 0.264 0.255

Table 11. BART Determination Modeling Results for MACA (Delta dv)

1-base 1-lime 1-WESP 3-base 3-lime 3-WESP

1 2.654 1.307 0.367 3.339 1.575 0.506

2 2.205 1.068 0.297 2.980 1.389 0.442

3 2.097 1.026 0.285 2.948 1.375 0.439

4 1.980 0.966 0.269 2.894 1.355 0.436

5 1.841 0.873 0.240 2.649 1.216 0.379

6 1.695 0.802 0.220 2.367 1.094 0.350

7 1.656 0.793 0.219 2.338 1.063 0.330

8 1.624 0.765 0.210 2.316 1.054 0.327

9 1.556 0.743 0.205 2.257 1.025 0.318

10 1.554 0.731 0.200 2.163 0.980 0.314

11 1.528 0.718 0.197 2.138 0.980 0.311

12 1.468 0.704 0.195 2.118 0.975 0.303

13 1.456 0.701 0.193 1.992 0.904 0.283

14 1.455 0.700 0.192 1.946 0.887 0.281

15 1.408 0.663 0.183 1.930 0.875 0.273

16 1.330 0.635 0.175 1.891 0.857 0.269

17 1.323 0.627 0.171 1.886 0.856 0.268

18 1.313 0.621 0.170 1.881 0.850 0.265

19 1.285 0.614 0.168 1.842 0.836 0.264

20 1.284 0.606 0.166 1.834 0.828 0.258

21 1.281 0.605 0.166 1.831 0.825 0.258

22 1.264 0.594 0.162 1.819 0.824 0.255
14

Table 12. Summary of BART Determination Modeling Results for MING

Delta dv 8th highest 8th highest 8th highest 22nd highest

Unit/Run 2001 2002 2003 2001-2003

1-base 0.167 0.251 0.149 0.209

1-lime 0.077 0.116 0.069 0.097

1-WESP 0.021 0.031 0.019 0.026

3-base 0.273 0.381 0.239 0.325

3-lime 0.118 0.166 0.104 0.141

3-WESP 0.036 0.051 0.032 0.043

Table 13. BART Determination Modeling Results for MING (Delta dv)

1-base 1-lime 1-WESP 3-base 3-lime 3-WESP

1 0.419 0.195 0.053 0.67 0.294 0.091

2 0.415 0.191 0.052 0.63 0.275 0.084

3 0.378 0.177 0.048 0.583 0.259 0.082

4 0.36 0.172 0.047 0.576 0.253 0.079

5 0.352 0.162 0.044 0.54 0.235 0.072

6 0.344 0.157 0.043 0.531 0.231 0.07

7 0.336 0.157 0.043 0.495 0.22 0.07

8 0.336 0.156 0.042 0.494 0.216 0.067

9 0.33 0.152 0.041 0.48 0.209 0.064

10 0.312 0.148 0.04 0.47 0.204 0.062

11 0.303 0.139 0.038 0.44 0.192 0.059

12 0.297 0.138 0.037 0.438 0.191 0.059

13 0.295 0.137 0.037 0.435 0.191 0.059

14 0.291 0.134 0.036 0.408 0.177 0.054

15 0.255 0.118 0.032 0.398 0.173 0.054

16 0.252 0.116 0.031 0.386 0.167 0.051

17 0.251 0.116 0.031 0.381 0.166 0.051

18 0.251 0.115 0.031 0.369 0.161 0.05

19 0.249 0.115 0.031 0.36 0.156 0.047

20 0.242 0.111 0.03 0.356 0.154 0.047

21 0.24 0.111 0.03 0.329 0.145 0.046

22 0.209 0.097 0.026 0.325 0.141 0.043

For Unit 1 or 2, lime injection is projected to reduce the visibility impact at MACA from 

1.285 dv to 0.606 dv (2003). A wet ESP is projected to further reduce the impact to 

0.166 dv. For Unit 3, lime injection is projected to reduce the visibility impact at MACA 

from 1.842 dv to 0.836 dv (2003). A wet ESP is projected to further reduce the impact to 

0.264 dv.
15

For Unit 1 or 2, lime injection is projected to reduce the visibility impact at MING from 

0.251 dv to 0.116 dv (2002). A wet ESP is projected to further reduce the impact to 

0.031 dv. For Unit 3, lime injection is projected to reduce the visibility impact at MING 

from 0.381 dv to 0.166 dv (2002). A wet ESP is projected to further reduce the impact to 

0.051 dv.
16

IV. Conclusions

Both control options reduce visibility impacts at MACA and MING. However, the 

excessive costs associated with wet ESPs, as well as the large volumes of water required, 

make that option infeasible as a basis for BART. Although lime injection is less 

expensive, the cost effectiveness results associated with that option are too high, making 

the technology unacceptable as a basis for BART. As a result, TVA proposes that no 

additional control be required under the BART regulations.

As stated previously, TVA plans to install lime injection on all three units at PAF to 

mitigate stack opacity. These controls will be in place well before BART controls are 

required. So visibility impacts at MACA and MING will continue to be reduced, 

regardless of any decision related to BART.
APPENDIX

COST OF COMPLIANCE DETAILS