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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

24) ll-B-9 

Docket Number: 

A-90-37 

Printed 11/4/2008 10:22:19 AM Sheet 24 of 147 
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*V>:o IT*,. 

iJSK ® ' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

r ^ v»a-.a a i_w w t i-i i i—i uniiiwiainuiiin L n\uitL i luiinvatlNV , r 3 O 

* REGION IV f t """ / " 

345 COURTLAND STREET 

ATLANTA, GEORGIA 30365 

MEMORANDUM 

DATE: Ma«», 3D, 1387 

SUBJECT: Huntsville Incinerator - Determining BACT Under PSD 

. ch^f L-J- K7 7 i7l777' : 

i * 

* r, V' r. vi 

FRCM: Bruce P. Miller, Chief 

Air Programs Branch ||r' " _ 

Air, Pesticides, and Toxics Management Division \\7 'jftW *-0 

TO: Gary McCutchen, Chief 

New Source Review Section 

Office of Air Quality Planning Standards 

SUMMARY: 

The purpose of this memorandum is to provide you with background information 

concerning the circumstances surrounding the proposed BACT for the Huntsville 

incinerator and solicit Headquarters' guidance and interpretation of the 

December 1978 "Guidelines for Determining Best Available Control Technology 

(BACT)" as it relates to the Huntsville Incinerator facility. 

On December 31, 1986, the Alabama Department of Environmental Management 

(ADEM) submitted a draft PSD preliminary determination (Attachment I) for 

the Huntsville Municipal Incinerator. The proposed project will process 

690 tons/day of municipal solid waste (MSW). The MSW, along with dried 

sewage sludge will be processed in two (2) 345 tons/day units which will 

generate steam to heat the Redstone Arsenal. The draft preliminary determination set forth BACT emission limits for the regulated pollutants subject 

to review. In particular, the emission limits set were 0.02 gr/dscf corrected to 12% 062 for particulate matter and 0.28 Ib/mmBtu for sulfur dioxide 

(SO2). No emission limits were required for the nonregulated pollutants. 

Acid gas controls were not required to be installed. 

The reasons given by the ADEM for not requiring acid gas controls for SO2 

and H2SO4 emissions at the Huntsville plant were as follows: 

0 First, the Huntsville plant would produce steam while most of the otherplants produce electricity, which must be purchased by the appropriate 

. utility at the avoided cost to the utility. Second, the tipping fees 

currently charged elsewhere are generally several times the rate charged in 

Huntsville. The tipping fee generally reflects the availability of land 

for siting a landfill. A low tipping fee reflects the availability of low 

cost land, while a high fee reflects the opposite. 

0 Secondly, EPA proposed sulfur dioxide (40 CFR 60, Subpart Db, June 19, 

1986) mission standards for industrial-commercial-institutional steam 

generating units under NSPS. An emission limit was not proposed for 

sulfur dioxide or the other gases in question from this type of unit, 

MSW-fired boilers, which indicates that no control equipment was considered appropriate. Sulfur dioxide emissions would be low due to the • 

inherent lew sulfur content of MSW. 
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° Thirdly, ADEM's BACT determination included plans by Redstone Arsenal 

to build a coal-fired boiler(s) if steam cannot be purchased from the 

Huntsville incinerator. Installation of a coal-fired boiler(s) with 

equivalent steam production by Redstone Arsenal would result in sulfur 

dioxide emissions 1.5 to 3.0 times higher than emissions from the proposed 

MSW-fired and package boilers. Because of these factors and the inherent 

low sulfur content of the MSW fuel, an 0.28 Ib/mmBtu SO2 emission limit was 

determined to be BACT for the MSW boilers with no acid gas control. 

On February 10, 1987, EPA met with representatives from die ADEM, the City 

of Huntsville, and consultants to the City to discuss any comments that EPA 

had on the draft preliminary determination. (Attachment II is a list of the 

conments EPA presented to ADEM and the other parties). The discussions primarily focused on whether the installation of acid gas controls were warranted and should be required. 

ADEM and City officials presented the agrument that the installation of 

acid gas controls in addition to particulate emission controls would cause 

the tipping fee to go from $4/ton to $21/ton of garbage disposed. For the 

installation of only particulate emission controls, the tipping fee would 

rise to $9/ton of garbage disposed. The ADEM stated that the imposition of 

the installation of acid gas controls would kill the project and require 

the City to revert back to the landfill for disposing of its refuse. Furthermore, ADEM argued that if the incinerator was not built and the steam was 

not able to be generated, the Redstone Arsenal would have to rebuild the 

existing coal-fired boiler or replace it as it is presently in violation of 

the existing SIP. Operation of the existing coal-fired boiler would cause 

more pollutants to be emitted to the atmosphere than fran the incinerator 

project. 

EPA informed ADEM and the City of Huntsville at the meeting that the PSD 

regulations do not address the issue of whether a project goes forth or not 

but only that the BACT is employed while taking into account energy, environmental, and economic impacts and other costs. We do not feel that PSD regulations allow the flexibility to consider alternative build scenarios in 

determining BACT. In addition, EPA argued that if you consider the impact 

frcm the North County Remand on this project regarding the consideration of 

hazardous yet unregulated pollutants like dioxins, furans, heavy metals, and 

acid gases, the installation of acid gas control is warranted. Based upon 

the incremental cost differential tor the installation of the acid gas controls and the amount of pollutants removed, the cost per ton of pollutants 

appears reasonable. For an incremental cost of $2.4M (annualized costs), 

1589* tons of pollutants (SO2, HC1, H2SO4, and dioxins) would be removed. 

This equates to an incremental cost of $1510/ton of additional pollutants 

removed. 

* 70% of 321.1 TPY of S02 

90% of 1502.3 TPY of HC1 

90% of 13.1 TPY of H2S04 

90% of 6.4 x 10-4 T P Y of dioxin 

-1589 TPY 
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Subsequent to this meeting, Mr. Richard Grusnick, ADEM, wrote EPA on 

February 23, 1987, outlining the major area of disagreement between our 

agencies as it relates to the factors allowed to be considered in making a 

BACT determination (Attachment Ill-Feb. letter). In his letter, Mr. Grusnick 

submitted a copy of EPA's December 1978 policy entitled "Guidelines for 

Determining Best Available Control Technology (BACT)." Mr. Grusnick's 

opinion is that this policy supports the factors considered in his draft 

preliminary determination which he feels provides a large degree of latitude 

to States in evaluating these factors; specifically: 

1. Indirect energy impacts, such as the fact that the solid waste will substitute for fossil fuels otherwise burned, may be considered. 

2. Assessing the significance of additional controls based primarily on 

air quality impact is allowed under the policy. 

3. The environmental consequences of the fact that solid waste must be 

buried if the incinerator is not permitted is a relevant solid waste 

disposal impact. 

4.; The localized economic impacts are relevant, such as the low tipping 

fee presently charged by Huntsville when compared to other parts of the 

country. 

5. The guidance contains implications that BACT which would preclude the 

operation of a unit would not be expected. 

Finally, Mr. Grusnick argues that the,1978 guidelines clearly envisionsdifferent levels of control at identical units located in different places 

based on different circumstances and, in fact, different weighing of relevant 

factors and identical circumstances. It is his opinion from reading the 

guidelines that "State judgement and the federal emission standards are the 

foundations for the BACT determination". 

The issues raised in Mr. Grusnick's February 23 letter are fundamental issues 

with respect to EPA's role to oversee the State responsibility of implementing 

the PSD rules properly. Although we do not entirely agree with Mr.: Grusnick's 

arguments, we feel it is important to raise these issues with your office and 

get Headquarters' interpretation on these issues and whether the 1978 guide-, 

lines are being interpreted correctly by the ADEM. 

Specifically, we would like your office to respond to.the following-questions: 

1. The guidance for determining RACT under PSD dated December 1978, is-this 

current Agency guidance or has this been superseded? 
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2. Concerning Mr. Grusnick's point that the State's judgment and the federal 

emission standards are the foundation for the BACT determination, EPA 

agrees that State judgment is a factor in determining BACT. However, 

it has been Region TV's opinion that where a State's judgment concerning 

BACT emission limits is inconsistent with the BACT analysis considering 

energy, environmental, and economic impacts and other costs that it was 

our duty to renegotiate changes in the State permit or overturn that permit. Even if the State followed the correct procedures for determining 

a BACT emission limitation but came to a different conclusion than we 

would have (i.e., the State BACT emission limitations were less stringent 

than what EPA would have proposed), Region IV believes it can overturn 

that permit. Do you agree with Region IV's position? What is your 

position on Mr. Grusnick's contention? Finally, on what, if any, basis 

do you believe EPA should overturn a State PSD permit (i.e., not a delegation of the Federal PSD program) pursuant to BACT, and what do you consider to be our burden of proof? 

3. How would you interpret the guidance which contains implications that 

BACT decisions should not force new projects to the brink of cancellation? 

It is Region TV's opinion that if an appropriate level of controls 

represent BACT, we would not require additional air pollution controls 

'just for the sake of control if it wasn't reasonable (i.e., profitability 

of the project is independent of the BACT analysis). We do not believe 

that we should allow lesser than appropriate level of control to be 

installed even if the profitability of the project would be such that 

the project is cancelled. Do you agree with Region TV's opinion? 

4. Concerning Mr. Grusnick's items 1, 2, and 3, do you agree with his agruments that alternative build scenarios should be considered in determining BACT as it relates to energy, environmental, and economic impacts 

and then cost considerations? It has been our position that alternative 

build scenarios do not enter into the BACT analysis. Do you agree with 

Region IV's position? 

ACTICN: 

Please review the attached information and provide responses to the issues 

raised in this memorandum. We would appreciate a response by April 15, 1987, 

if at all possible. 

BACKGROUND: 

See attached information. 

Attachments 
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ATTACHMENT I 

Leigh Peguei. Director 

1751 Federal Drive 

Montgomery. AL 

36130 

205/271-7700 

Field Offices: 

Unit 806. Building 8 

225 Ox moor Circle 

Birmingham, AL 

35209 

205/942-6168 

P.O. Box 953 

Decatur. AL 

35602 

205/343-1713 

E9VI •$.&& & 

ALABAMA \0'z> 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT "':*£&f& 

.£•'•" 

December 31, 1986 

George C. Wallace 

Governor 

Mr. Bruce P. Miller, Chief 

Air Programs Branch 

Air, Pesticides and Toxics 

Management Division 

US Environmental Protection Agency 

Region IV 

345 Courtland Street 

Atlanta, GA 30365 

Dear Mr. Q/jki-S'^ 

AIR PROGRAMS BRANCH 

J

 JAN 2 1987 

EPA-REGION IV 

ATLANTA, GA. 

Enclosed is a draft of ADEM's preliminary determination on 

the Huntsville Refuse Fired Steam Project. As previously mentioned, 

we will be discussing this project in the near future. 

2204 Perimeter Road 

Mobile. AL 

36616 

205/479-233 6 fffc 

Richard E. Grusnick, Chief 

Air Division 

> Sd^ 

REG/SRR:dm 

Enclosure 
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SOLID WASTE DISPOSAL AUTHORITY 

OF THE CITY OF HUNTSVILLE 

Facility No. 709-1104 

INTRODUCTION 

The Solid Waste Disposal Authority of the City of Huntsville has submitted 

an application for Air Permits to construct a facilit y designed to. produce steam 

by combusting municipal solid waste, dried sewage sludge, shredded tires , 

methane-rich landfil l gas, natural gas, and fuel oil . The steam would be sold 

to a nearby customer. ADEM-A1r Division has reviewed this application and has 

made a preliminary determination that ADEM-Air Divison's Rules and Regulations 

would be satisfied by the proposed project. The purpose of this analysis is to 

identify the basis for this preliminary determination. Also attached are the 

proposed conditions which would be made a part of the A1r Permits to ensure that 

the project would be constructed and operated in compliance with ADEM-A1r 

Division's Rules and Regulations. 

This analysis deals only with those issues related to compliance with 

ADEM-Air Division's Regulations. 

I. Location of Project 

The proposed Huntsville Refuse Fired Steam Project will be located in 

Madison County on Triana Boulevard immediately adjacent to the Redstone Arsenal. 

The Redstone military facility will border the site on the north, west and south 

with the Triana Boulevard providing access/egress to the facility on the east. 

The facility is approximately 4.0 miles due east of the Redstone Air field and 

approximately 2 miles southwest of the former-Huntsvilie-Madison County Air 

Port. 

II. Scope of Project 

Two mass burn, waterwall furnace/stoker boilers and four fossil fuel-fired 

boilers, rated at 86.0Q0 and 100,000 pounds of steam per hour, respectively, 

would be installed. As stated 1n the "Introduction" section, municipal solid 

waste (MSW), dried sewage sludge, shredded tires, methane-rich landfill gas, 

natural gas and fuel oil would be used as fuels. Dravo Energy Resources, Inc. 

would operate the plant for the Huntsville Solid Waste Disposal Authority 

(HSWDA). 

Wastes would be delivered to the plant by HSWDA. Waste means normal 

municipal solid waste. Unacceptable waste and hazardous waste, such as drummed 

liquids, would not be accepted. There would be no outside storage of wastes. 

The wastes, boilers, and associated equipment would be contained in an enclosed 

structure which would be maintained under a negative pressure to prevent odors 

from escaping when at least one refuse fired boiler is operating. Alternate 

waste disposal plans have been formulated in case the refuse fired boilers are 

not operating or the wastes' volume is greater than the plant can process. 

These plans 'nvolve using the existing landfill. 

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Operation of the refuse fired boilers would be continuous, except for 

planned maintenance periods and equipment breakdown. Steam produced by these 

boilers would normally be sufficient to meet the customer's demand. However, if 

one or both of the units were not operating and/or the customer demand were 

higher, one or more of the fuel oil or natural gas-fired package boilers would 

be used. The fuels for the refuse fired boilers would be MSW, dried sewage 

sludge, shredded tires, natural gas, diesel oil, and landfill gas. Fuels for ' 

the package boilers would be natural gas and diesel oil. Two of the package 

boilers would also have the capability of burning landfill gas, which is 

essentially equivalent to natural gas. 

An electrostatic precipitator (ESP) would be used to control emissions from 

each refuse-fired boiler. The ESPs would be in operation whenever the boilers 

are operating, including startup and shutdown. No air pollution control 

equipment would be necessary for the package boilers due to the use of fuels 

with a low potential for emissions. 

Combustion air for the refuse-fired boilers would be drawn from the enclosed 

tipping hall and refuse pit as well as from the boiler house. This would result 

in a negative draft in these areas, and odor causing compounds would be drawn 

into the furnaces and incinerated. Operation of one boiler would be sufficient 

to maintain the negative pressure. 

III. NSPS 

Both the refuse fired boilers and the package boilers will be subject to New 

Source Performance Standards (NSPS). Additionally the incinerators will be 

subject to National Emission Standards for Hazardous A1r Pollutants (NESHAPS). 

NSPS are emission standards, notification and testing procedures, and 

monitoring requirements established by the Environmental Protection Agency (EPA) 

for a number of individual industrial or source categories such as Portland 

cement plants, steam generators and sulfuric acid plants. Standards of 

performance are not intended to achieve any specific air quality level. 

Instead, they are designed to reflect best demonstrated technology (taking into 

account costs) for the source in question. 

NSPS applytonly to stationary sources that are constructed, modified or 

reconstructed after a relevant standard has been proposed. 

NESHAPS are emission standards, monitoring and testing requirements and 

reporting tasks which have been established by EPA for sources of pollutants 

to which no ambient standard is applicable and which in

 :the judgement of the EPA 

Administrator causes, or contributes to, air pollution which may reasonably be 

anticipated to result in an increase in mortality or an increase in serious 

irreversible, or incapacitating reversible, illness. Standards have been 

established for eight (8) pollutants. These are beryllium, mercury, vinyl 

chloride, benzene, asbestos, Radon-222, arsenic, and radionuclide emissions. 

NESHAPS applies to both existing and new sources. 

The NSPS for incinerators (40 CFR 60, Subpart E) applies to all units that 

commence construction or modification after August 17, 1971.. The only specific 

emission standard promulgated under this subpart is 0.08 gr/dscf corrected to 

12% C02 . 
P.9 —\ 

EPA is required to review promulgated NSPS e^ery four years to determine if 

changes are necessary. The last review of Subpart E occurred in 1979. No 

changes were proposed at that time. The review of Subpart E which was scheduled 

for 1983 was incorporated into the process of developing standards for boilers 

with a rated heat input between 100 and 250 million Btu per hour. 

The standards for boilers in this range were proposed on June 19, 1984, in 

the Federal Register as Subpart Db of 40 CFR 60. Particulate and nitrogen oxide 

emission standards were proposed with the statement that standards for sulfur 

dioxide would be proposed in the near future. The sulfur dioxide standards were 

proposed on June 19, 1986. 

ADEM's determination is that only the particulate standards of Subpart Db 

would apply to the MSW-fired boilers and that all three standards would apply to 

the package boilers. The particulate standards are 0.1 lb/MM Btu of heat input 

and 20% opacity. The sulfur dioxide and nitrogen oxides emission standards are 

0.2 lb/MM Btu and 0.1 lb/MM Btu, respectively. 

The allowable particulate emission limit for the MSW-fired boilers would be 

set at 0.02 gr/dscf corrected to 12% CO2 and 0.041 lb/MM Btu, which would be 

twenty-five percent (25%) and forty percent (40%) of the applicable Subpart E 

and Subpart Db regulations, respectively. 

The allowable particulate, sulfur dioxide, and nitrogen oxides emission 

limits for the package boilers would be set at 0.05 lb/MM Btu, 0.2 lb/MM Btu, 

and 0.1 lb/MM Btu, respectively, which is 50% of the particulate standard and 

equal to the sulfur dioxide and nitrogen oxides standards under Subpart Db. 

IV. Prevention of Significant Deterioration 

The proposed construction is also subject to the regulations for Prevention 

of Significant Deterioration (PSD). PSD is a program implemented by EPA in 1974 

and subsequently modified by Congress in 1977 which prevents relatively clean 

air areas from deteriorating beyond certain specified Increments due to 

industrial growth. (A summary of the PSD program is attached in Appendix A.) 

PSD also identifies certain requirements that sources must satisfy in order to 

obtain permission to construct in attainment areas (clean areas). A source that 

is subject to PSD, must satisfy the following requirements before being allowed 

to start construction: 

(1) Apply best available control technology (BACT), which is defined in 

terms of control technology or an emission limitation based on the 

maximum degree of reduction determined achievable for each significant 

pollutant for a particular source. Factors considered in a BACT 

determination include technical feasibility, performance levels, 

committed resources, energy requirements, economics and environmental 

impacts. Where applicable, BACT will equal or exceed New Source 

Performance Standards (NSPS). 

(2) Analyze the impairment to visibility, soils, and vegetation that might 

occur as a result of the operation of the source. 

(3) Demonstrate that the emissions from the source will not cause or 

contribute to a.violation of the PSD increment or the National Ambient 

Air Quality Standards (NAAQS). „ _ .,,-«,->.--J 
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(4) Analyze the air quality impacts projected due to the growth associated 

with the facility. 

(5) Conduct any air quality monitoring necessary to determine the effect 

of the emissions on air quality. 

(6) Provide an opportunity for public participation in the permitting 

process relative to the air quality impact the source will have if 1t 

is built. 

(7) Obtain a permit to construct which sets forth required control or 

emission limitations, fuel and/or operating restrictions designed to 

ensure PSD increments and the NAAQS are not violated. 

The expected emissions of nine pollutants are greater than the de minimus 

(significant) levels specified under PSD and will be subject to the requirements 

of PSD. These pollutants (see Table I) are: 

(1) total suspended particulate (TSP) 

(2) sulfur dioxides (SOg) 

(3) nitrogen oxides (N0X) 

(4) carbon monoxide (CO) 

(5) lead (Pb) 

(6) beryllium (BE) 

(7) mercury (Hg) 

(8) fluorides (F) 

(9) sulfuric acid mist (H2SO4) 

V. Best Available Control Technology (BACT) 

A BACT determination for any pollutant 1s a case-by-case (plant specific) 

determination of best available control technology when energy, economic and 

social effects in the proposed area of the plant are considered. This means 

that BACT for two identical plants located in different, parts of the country 

could be different. 

The emission levels which represent BACT for each pollutant are summarized 

in Table II. 

Following is a summary of the BACT determinations: 

A. MSW Fired Boilers 

(1) Particulate Emissions 

The applicant originally proposed an ESP with an emission limit of 

0.04 gr/dscf corrected to 12% C02 (0.083 lb:/MM Btu and 10.7 lb/hr) as^ 

BACT for particulate emissions from the MSW fired boilers instead of the 

emission limit (0.08 gr/dscf) required by the New Source Performance 

Standards (NSPS) for incinerators. EPA proposed particulate emission 

limits for industrial-commercial-institutional steam generating units 

under NSPS on June 19, 1984. These units Would be subject to a 

particulate standard of 0.1 lb/MM Btu. 

IT J 
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TABLE I 

Expected Emissions Summary 

Pollutant 

Particulates 

Sulfur Dioxide 

Nitrogen Oxides 

Carbon Monoxide 

Volatile Organics 

Lead 

Beryllium 

Mercury 

Fluorides 

Sulfuric Acid 

Mist 

Hydrogen Chloride 

Di oxi ns 

2-129.4 MM Btu/hr 

Boilers 

lb/hr tpy 

MO.7 46.9 

s

73.3 321.1 

'81.9 358.9 

-29.6 129.7 

6.0 26.4 

0.5 2.2 

9.1E-05 4.0E-04 

0.24 1.0 

2.3 10.1 

3.0 13.1 

343.0 1502.3 

1.38E-04 6.4E-04 

4-116.3 

Boil 

lb/hr 

6.7 

93.0 

46.5 

16.8 

2.6 

MM Btu/hr 

ers 

tpy 

29.4 

407.5 

203.8 

73.8 

11.4 

Total Emi 

lb/hr 

17.4 

166.3 

128.4 

46.4 

8.6 

0.5 

9.1E-05 

0.24 

2.3 

3.0 

343.0 

1.38E-04 

ssions 

tpy 

76.3 

728.6 

562.7 

203.5 

37.9* 

2.2 

4.0E-04 

1.0 

10.1 

13.1 

1502.3 

6.4E-04 

De Minimus 

Emissions 

tpy 

> 

> 

> 

> 

< 

> 

a 

> 

> 

> 

25. 

40. 

40. 

100. 

40. 

0.6 

4.0E-C 

0.1 

3.0 

7.0 

N/A 

N/A 

•Includes 0.09 TPY from diesel storage tank. 

EC7j_ 
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Unit 

TABLE I I 

Best Available Control Technology Summary 

Pollutant & BACT Emission Limits 1 

(1) 129.4 MM Btu/hr Boiler Particulate 

709-I104-X001, & 

709-1104-X002 

Lead 

Beryllium 

0.02 gr/dscf 

corrected to 12% COg 

0.25 lb/hr 

4.5 x IO"5 lb/hr 

Control Methods 

ESP 

Sulfur Dioxide - 0.28 lb/MM Btu 

Sulfuric Acid - 1.5 lb/hr 

Mist 

low sulfur 

content of MSW 

Nitrogen Oxides- 0.32 lb/MM Btu 

Carbon Monoxide- 0.11 lb/MM Btu 

grate and combustion air 

feed designs 

Fluorides 

Mercury 

1.15 lb/hr 

0.24 lb/hr 

(total for 2 units) 

no control 

(2) 116.3 MM Btu/hr Boiler 

709-1104-X003, 

709-1104-X004, 

709-1104-X005, 

709-1104-X006 

Particulate - 0.05 gr/dscf 

5.82 lb/hr 

Sulfur Dioxide - 0.2 lb/MM Btu 

23.26 lb/hr 

Sulfuric Acid - 0.91 lb/hr 

Mist 

low ash content 

of fuels 

low sulfur 

content of fuels 

Nitrogen Oxides- 0.1 lb/MM Btu 

. Carbon Monoxide- 4.21 lb/hr 

^•Emission limits are per boiler 

6 

boiler design & 

combustion 

controls 

Ff> 
P.13 

After a thorough review of the technical and economic aspects of 

the project and discussions with the Air Division, the applicant 

proposed a revised BACT of 0.02 gr/dscf (0.041 lb/MM Btu and 5.36 lb/hr) 

for particulate. This proposed emission rate would be 25% of the NSPS 

emission standard for incinerators and approximately 40% of the proposed 

NSPS emission standard under Subpart Db. In many cases BACT has proven 

to be the equivalent of the applicable NSPS when the NSPS had been 

recently reviewed or promulgated. 

Further reduction of the particulate emissions to 0.015 gr/dscf 

would likely require installation of a bagfilter. A 25% reduction from 

0.02 gr/dscf to 0.015 gr/dscf would result in a 2.7 lb/hr decrease of 

particulate emissions from 10.7 lb/hr to 8.0 lb/hr for both MSW boilers. 

A 25% reduction in the particulate limit would result in only a 

0.03 ug/nr reduction in the ambient impact of the MSW boilers, as 

indicated by Table III . Standard ambient monitoring methods for 

particulates would not detect any difference between the 0.02 and 0.015 

gr/dscf emission limit . 

TABLE II I 

Emission rate versus ambient impact of the MSW boilers. 

Emisssion Rate (gr/dscf) Ambient Impact (ug/nv*) 

Annual 24-Hour 

0.04 0.26 2.8 

0.02 0.13 1.4 

0.015 0.10 1.1 

ADEM concurs that 0.02 gr/dscf corrected to 12% CO2 is BACT for particulate 

emissions from the MSW boilers. 

(2) Sulfur Dioxide, Fluoride, Hydrogen Chloride, Sulfuric Acid Mist and 

Dioxins Emissions 

The applicant has proposed the low sulfur content of municipal 

fuels as BACT for sulfur dioxide and sulfuric acid mist. The applicant 

has also proposed no controls as BACT for fluorides. 

A scrubber using a caustic scrubbing medium to remove sulfur 

dioxide, acid gases and dioxin was also evaluated by the applicant and 

ADEM. Although hydrogen chloride and dioxin emissions are not subject 

to PSD, since PSD applies only to pollutants regulated under the Clean 

Air Act or pollutants emitted in amounts greater than de minimus, it is 

appropriate to consider the impact of any control device on their 

emissions. 
P.14 

i 

a. Dioxins 

One of the products of combustion from the incineration of 

municipal waste is dioxins. Dioxin is a generic name for al l (total) 

polychlorinated dibenzo-dioxins (PCDD). One of it s isomers is 2,3,7,8 

tetrachloro-dibenzo-p-dioxin, which is considered one of the most toxic 

compounds known. 

The estimated emissions of PCDD and 2,3,7,8 TCDD from the proposed 

Huntsville MSW (municipal solid waste) fired boilers is 0.000138 pounds 

per hour, and 0.000001 pounds per hour, respectively (see Appendix E). 

EPA published an article entitled "Interim Evaluation of Health 

Risks Associated with Emissions of TetrachloMnated Dioxins From 

Municipal Waste Resource Recovery Facilities" 1n November 1981. EPA 

reviewed studies conducted outside of the U.S. and conducted tests on 

five incinerators in this country. The range of stack concentrations of 

TCDD (tetrachlorinated dibenzo-dioxins), one of which is 2,3,7,8 TCDD, 

was from not detectable to 8.5 nanograms per standard cubic meter. The 

concentration of 2,3,7,8 TCDD was from not detectable to 3.5 nanograms 

per cubic meter. EPA's review of the foreign data did not suggest the 

existence of any problem that called for action due to the emission of 

TCDDs associated with the combustion of municipal wastes. An excerpt 

from this report: 

"An evaluation of the public health considerations related to TCDDs 

emissions has been made by applying the various mathematical models to 

the data from the five U.S. sites under the many combinations of 

assumptions that must be made in analyzing the data. These estimates 

suggest that the present emissions levels of TCDDs from the five 

municipal waste combustors described in this report do not present a 

public health hazard for residents living in the immediate vicinity . In 

addition, the health risk estimates presented in the assessment indicate 

that as long as emission levels of TCDDs do not greatly exceed the 

emissions measured at the five U.S. sites evaluated in this interim 

assessment, there should be no reason for concern. This conclusion is 

valid for al l toxicological effects (including reproductive and cancer) 

for which the available animal and human data have been analyzed." 

The estimated dioxin emissions and resulting ground-level 

concentrations from the proposed Huntsville MSW boilers are within the 

range of emissions in the above-mentioned EPA study. 

Since the above referenced report was issued in 1981, EPA has 

formulated three incinerator design and operating guidelines for 

minimizing dioxin emissions. The firs t guideline relates the rate of 

heat generation of the waste fuel and the theoretical portion of the 

combustion chamber which is-hotter than specified minimum temperatures, 

with a specified minimum oxygen concentration in the exhaust gases. 

This guideline is termed the Qualifying Maximum Volumetric Heat Release 

Rate (QMVHRR), and the recommended QMVHRRs are 15,000 Btu/hr/ft 3 for the 

zone hotter than 1500°F and 25,000 Btu/hr/ft 3 for the zone hotter than 

£ 
P.15 

1800°F. The recommended minimum oxygen concentration is 3% for the 

gases leaving the combustion zone. 

The second guideline is that air distribution be full y controllable 

at each location where pressurized air is introduced and that the air 

flow be measured and monitored continuously. This includes provisions 

to add over-fire air. 

The last guideline, for carbon monoxide emissions, is 100 ppmv 

rolling average during a four (4) day averaging period and a 400 ppmv 

rolling average for an 8 hour averaging period. The average 

concentrations must be corrected to 7% oxygen on a dry basis. 

The proposed Huntsville MSW fired boilers wil l meet the above 

design and operating guidelines. 

Recent stack tests on mass burn boilers/incinerators at Tulsa, 

Oklahoma and similiar incinerators support the conclusion that good 

combustion techniques minimize the formation of dioxin. The Tulsa 

boilers are controlled by ESP$ and emits PCDD's at a rate of 18.9 ng/nm3* 

Test results from similiar boilers/incinerators with dry scrubbers/bag 

filter s al l exceed this number with the exception of a recently built unit 

in Marion County Oregon which emits PCDD's at a rate of 1.13 ng/m3. 

b. Hydrogen Chloride 

A caustic scrubber would remove up to 90 + % of the hydrogen 

chloride emissions from the MSW boilers. 

Since there is no ambient standard for HC1, ADEM compared its 

estimated ambient impact against 1/420 of the TLV. The TLV is established 

by the American Conference of Governmental Industrial Hygienists (ACGIH) 

and is designed to protect workers in the workplace. ADEM used 1/420 of 

the TLV (annual averaging period) as a safety factor to account for more 

than an 8 hour exposure and other segments of the population such as very 

young or elderly people. 

The TLV for HC1 is 7,000 ug/m3. Dividing 7,000 by 420 would result 

in an ADEM guideline of 16.7 ug/m3. Dispersion modeling indicates that 

the ground level concentration of HC1 emissions from the MSW boilers 

would be 6.13 ug/m3 or 36.7% of the guideline. 

c. Fluorides 

A scrubber followed by a bagfilter would also remove greater than 90% 

of any fluoride emissions present. Since a NAAQS has not been established 

for fluorides, ADEM again compared the ambient impact of the incinerator 

against 1/420 of the TLV for fluorides. 

Dispersion modeling indicates that the ground level concentration of 

fluoride emissions from the MSW boiler controled by an ESP would be 0.029-

ug/m3 compared to the guideline of 6.0 ug/m3 or 1.5% of the ADEM 

guideline. 
P.16 

d. Sulfur Dioxide and Sulfuric Acid Mist 

A dry scrubber followed by a bagfilter would remove 70 - 90% of the 

SO2 and H2SO4 emissions. 

The ambient impact of sulfur dioxide from the MSW boilers is 0.04 

ug/m3 on a 24-hour basis. This is 0.01% of the 24-hour NAAQS of 365 

ug/m3. Assuming an 80% reduction for the dry scrubber/bagfilter, the 

ambient impact would be reduced to 0.008 ug/m3. 

The SO2 monitoring equipment would not distinguish between 0.04 and 

0.008 ug/m3. 

Site specific economic data submitted by the applicant showed that the 

cost to remove the acid gases and dioxins would be approximately $1,300 per 

ton of pollutants. In order to recoup the capital and operating costs of ar 

acid gas scrubber, the tipping fee, a fee charged to anyone bringing waste 

for disposal, would have to be raised from the projected level, $8.85 per 

ton of waste, to approximately $21.00 per ton. This would be necessary 

because the steam cost to the customer is fixed at this point in time. The 

high tipping fee could make the project infeasible and landfilUng of the 

municipal waste would be continued, according to the applicant. Landflllinc 

would engender other environmental risks, Including a greater risk of 

groundwater contamination. 

Scrubbers have been required on other plants in 

are two major differences between the proposed plant 

First, the Huntsville plant would produce steam whil 

plants produce electricity , which must be purchased 

utilit y at the avoided cost to the utility . Second, 

currently charged elsewhere are generally several t i 

Huntsville. The tipping fee generally reflects the 

siting a landfill . A low tipping fee reflects the a 

land, while a high fee reflects the opposite. 

the U.S. However, there 

and plants elsewhere. 

e most of the other 

by the appropriate 

the tipping fees 

mes the rate charged in 

availabilit y of land for 

vailabilit y of low cost 

EPA proposed sulfur dioxide (40 CFR 60, Subpart Db, June 19, 1986) 

emission standards for industrial-commercial-institutional steam generating 

units under NSPS. An emission limit was not proposed for sulfur dioxide or 

the other gases in question from this type of unit, MSW-f1red boilers, whictindicates that no control equipment was considered appropriate. Sulfur 

dioxide emissions would be low due; to the inherent low sulfur content of 

MSW. 

Another factor in ADEM's BACT determination were the plans by Retlstone 

Arsenal to build a coal fired boiler(s) i f steam can not be purchased from 

the HSWDA. Installation of a coal, fired boiler(s) with equivalent steam 

production by Redstone Arsenal would result in sulfur dioxide emissions 1.5 

to 3.0 times higher than emissions from the proposed MSW-fired and package 

boilers. 

ADEM has determined that the inherent low sulfur content of the fuel, 

and the following emission limits are BACT for the SO2 and H2SO4 emissions 

from the MWS boilers. ADEM has also determined that no controls and the 

following emission limit is BACT for fluorides. 

10 
P.17 

S02 

H2S04 

Fl 

0.28 lb/MM 

1.5 lb/hr 

1.15 lb/hr 

Btu 

Additional specifics supporting the conclusion that BACT should not 

include scrubbing can be found in the application. 

3. Carbon Monoxide Emissions 

The applicant proposes to minimize emissions of carbon monoxide through 

the proper design of the combustion grate and of the combustion air control 

system. 

EPA stated in the background information for the proposed Subpart Db 

regulations (June 19, 1984) that "carbon monoxide and hydrocarbons were not 

selected for regulation due to their relatively low emission rates and the 

lack of any control technology for these pollutants which is reasonable in 

cost." 

ADEM has determined that the use of the boiler design and operating 

techniques proposed by the applicant and compliance with a CO emission limit 

of 0.11 lb/MM Btu represents BACT for the control of CO emissions from the 

MSW boilers. 

4. Nitrogen Oxides Emissions 

The applicant proposes to minimize emissions of N0X through the use of 

proper design of the combustor and of the combustion control system. 

EPA proposed nitrogen oxide (40 CFR 60, Subpart Db, June 19, 1984) 

emission standards for industrial-commercial-institutional steam generating 

units under NSPS. An exclusion was provided for this type of unit, 

MSW-fired boilers, indicating that no control equipment is necessary. 

ADEM has determined that the use of the boiler design and operating 

techniques proposed by the applicant and compliance with a NOx emission 

limit of 0.32 lb/MM Btu represents BACT for the control of N0X emissions 

from the MSW boilers. 

5. Lead, Beryllium, and Mercury Emissions 

The applicant has proposed to control lead and beryllium emissions 

through the use of the ESP. I t is expected that lead and beryllium 

emissions wil l be reduced by 95% with the ESP. 

Mercury is typically emitted from a municipal incinerator in the vapor 

phase. Control of mercury would require temperature reductions to the 140 

-200°C range. This type of reduction could be achieved with a dry 

scrubber/bagfilter. However, recent stack test data indicate that mercury 

emissions reductions from dry scrubbers vary from poor to excellent and more 

research is needed in this area. 

EPA also stated in the background information for Subpart Db of 40 CFR 

Part 60 (June 1984) that "trace metals have not been selected for regulation 

under the proposed standards because of the lack of inj^matior± on the 

11 
P.18 

performance of alternative control technologies to reduce these emissions. 

It is anticipated that the proposed particulate matter standard" (0.1 lb/MM 

Btu for this unit)" would result in significant reductions in trace metal 

emissions." The proposed allowable BACT particulate emission limit is 0.041 

lb/MM Btu. 

ADEM has determined that the use of an ESP to control lead and beryllium 

and no controls for mercury as proposed by the applicant, and compliance 

with the following emission limits represents BACT for these pollutants. 

Lead - 0.25 lb/hr 

Beryllium - 4.5 x IO"5 lb/hr 

Mercury - 0.24 Ibs/hr (total for 2 units) 

B. Package Boilers 

(1) Particulate, Sulfur Dioxide and Sulfuric Acid Mist Emissions 

The applicant has proposed to use fuel with low ash and sulfur content 

to minimize TSP and SO2 emissions from the package boilers. 

The proposed uncontrolled emissions of these pollutants would be less 

than or equal to the NSPS standards (40 CFR Part 60, Subpart Db) proposed on 

June 19, 1984 and June 19, 1986. 

ADEM has determined that use of low ash and low sulfur fuel proposed by 

the applicant and compliance with the following emission limits represents 

BACT for the package boilers. 

Particulate 0.05 gr/dscf 

Sulfur dioxide 0.2 lb/MM Btu 

Sulfuric Acid Mist 0.91 lb/hr 

(2) Nitrogen Oxides arid Carbon Monoxide Emissions 

The applicant has proposed use of boiler design and combustion controls 

to minimize nitrogen oxides and carbon monoxide emissions. The applicant's 

proposal will meet the proposed nitrogen oxides emission limit under for NSPS 

(40 CFR Part 60, Subpart Db). EPA did not propose to regulate carbon 

monoxide emissions "due to their relatively low emission rates and the lack 

of any control technology for these pollutants which is reasonable in cost." 

ADEM has determined that boiler design and combustion controls and 

compliance with the following emission limits represents BACT for the control 

of carbon monoxide and nitrogen oxides emissions from the package boilers. 

N0X - 0.1 lb/MM Btu 

CO - 4.21 lb/hr 

VI. Air Quality Impact 

PSD requires that an air quality analysis be performed to determine the 

impact on any applicable increments and on the NAAQS. 

' 12 ur?a 
P.19 

The proposed project will be located in a Class II designated area. The 

nearest Class I designated area (the Sipsey Wilderness Area) is located 

approximately 50 miles (82 km) away from the proposed project site. This area 

was examined for potential visibility impact caused by emissions from the 

proposed project. (See Section VII, Additional Impact Analysis). 

A. Existing Air Quality 

In order to evaluate whether the emissions from the proposed Huntsville 

plant will cause violations of the NAAQS, it is necessary to have available 

measurements of existing ambient air quality levels in the vicinity of the 

site. The levels are needed for each criteria pollutant that will be 

emitted above the significant emission level (i.e., SO2, TSP, NO?, CO and 

Pb). 

The Huntsville Air Pollution Program operates four (4) TSP sampling 

sites within 4 miles of the site. This data is considered representative of 

the site for particulates. 

The Huntsville Air Pollution Program operates a nitrogen oxide and a 

lead monitor approximately 2 miles from the proposed site. This data is 

considered representative for the proposed site for nitrogen oxides and 

lead. 

An exemption from the monitoring requirement is provided by the PSD 

regulations if the net emissions increase of the pollutant would not cause, 

. in any area, air quality impacts greater than certain threshold 

concentrations prescribed by the PSD regulations. Huntsville has 

demonstrated that the ambient impact of CO emissions from the proposed 

source (146 ug/m3 - 8-hour average) is less than the PSD Threshold value of 

575 ug/m3, 8-hour average, and preconstruction monitoring 1s not appropriate. 

The SO2 inventory of the area and the subsequent ambient monitoring 

indicates that the area is generally free from the impact of other 

SO2 sources. ADEM, therefore, agreed that monitored data from a "regional 

site" could be used as representative data. It was decided that SO2 data 

from a monitor in Decatur, Alabama would be representative since it was in 

the same general area. Since the Decatur monitor is impacted by more 

industrial sources of SOg, the use of this data will be conservative. 

B. Air Quality Analysis 

The ambient impact of the proposed facilit y was evaluated using 

dispersion models. (ADEM review of the applicant's submittal is includedjn 

Appendix C.) 

As incicated in Table IV, the major ambient impact for particulates and 

sulfur dioxide emissions was caused by the package boilers. These 

concentrations occurred because of downwash (refer to Appendix C) from the 

relatively short (less than GEP) package boiler stacks and impacts the area 

immediately adjacent to the plant. 

The submittal by the applicant and ADEM's review indicate that the 

proposed project would violate no applicable NAAQS or PSD increment. 

13 
P.20 

rTm,**T^''yrT'TT" 

TABLE IV 

Maximum Ambient Impact of Particulate and Sulfur Dioxide Emissions from Proposed 

Huntsville Facility^) 

Pollutant and 

Averaging Period 

S02 

TSP 

Annual 

24-Hour 

3-Hour 

Annual 

24-Hour 

MSW Boilers 

ug/m3 

0.91 % 

0.04(2) 

25.7 

0.13 

1.4 

Package 

Boilers 

ug/m3 

18.5 , % 

78.55(2) 

460.8 

4.6 

34.6 

(l)Except where noted, values reflect worst case downwash. Numbers are not 

necessarily additive since highest values may occur at different locations. 

(2)val ues from refined downwash modeling (see Appendix C) . 

VII. Additional Impact Analysis 

In addition to assessing the ambient air quality Impact expected from a 

proposed new source or modification, the PSD regulations require that certain 

other impacts be considered. These additional impacts are those on visibility, 

soils, and vegetation. 

A. Visibility 

The PSD regulations require that an analysis of the potential 

impairment to visibility in Class I areas be completed, for this analysis, 

procedures outlined in the EPA "Workbook for Estimating Visibility" were 

applied to the Sipsey Class I area (approximately 82 km from the proposed 

facility). In this analysis the applicant used emission rates of NO2, SOg. 

and TSP 1n a "Level 1" analysis. The Level 1 screening procedures are based 

on the finding that perceptible visibility impacts are likely to occur only 

if the absolute value of one or more of the screening parameters C\, C2, and 

C3 exceeds 0.1. 

The maximum value of any of the parameters calculated for the 

Huntsville incinerator was 0.0005. Since the contrast parameters were 

significantly less than 0.1, it is unlikely that the proposed project would 

adversely affect visibility in the Sispey Wilderness Area. 

14 
P.21 

B. Soil and Vegetation . 

The PSD regulations require an analysis of the impact of the emissions 

from a major source on soils and vegetation having a significant commercial 

or recreational value. Since the predicated ambient impacts: of the source 

are projected to be in the immediate area of the source and are relatively 

minor, no discernible impact on soils or vegetation is expected. 

VII Conclusions 

Based on the information supplied by the applicant, The Solid Waste Disposal 

Authority for the City of Huntsville, and the analysis performed by ADEM, it is 

the preliminary determination of ADEM is that the proposed project will employ 

Best Available Control Technology, will not cause or contribute to a violation of 

any PSD increment or NAAQS in the area of the proposed facility, and will comply 

with all applicable ADEM, Air Division Rules and Regulations. Therefore, ADEM 

proposes to issue Air Permits subject to the conditions 1n Appendix B. 

Richard E. Grusnick 

Date 

15 
P.22 

APPENDIX B 

PROPOSED PERMIT PROVISOS 

32 ifTa 
P.23 

SOLID WASTE DISPOSAL AUTHORITY 

OF THE CITY OF HUNTSVILLE 

129.4 MM Btu/Hr Refuse Fired Boiler 

709-1104-X001, X002 

1. This permit is issued on the basis of Rules and Regulations existing on the 

date of issuance. In the event additional Rules and Regulations are 

adopted, it shall be the permit holder's responsibility to comply with such 

rules. 

2. This permit is not transferable. Upon sale or legal transfer, the new owner 

or operator must apply for a permit within 30 days. 

3. A new permit application must be made for new sources, replacements, 

alterations or design changes which may result in the issuance of, or an 

increase in the issuance of, air contaminants, or the use of which may 

eliminate or reduce or control the issuance of air contaminants. 

4. Each point of emission will be provided with sampling ports, ladders, 

platforms, and other safety equipment to facilitate testing performed in 

accordance with procedures established by Part 60 of Title 40 of the Code of 

Federal Regulations, as the same may be amended or revised. 

5.

 :In the event there is a breakdown of equipment 1n such a manner as to cause 

increased emission of air contaminants for a period greater than 1 hour, the 

person responsible for such equipment shall notify the Department within an 

additional 24 hours and provide a statement giving all pertinent facts, 

including the duration of the breakdown. The Department shall be notified 

when the breakdown has been corrected. 

6. All air pollution control devices and capture systems for which this permit 

is issued shall be maintained and operated at all times in a manner so as to 

minimize the emissions of air contaminants. Procedures for ensuring that 

the above equipment is properly operated and maintained so as to minimize 

the emission of air contaminants shall be established. 

7. This permit expires and the application is cancelled if construction has not 

begun within 24 months of the date of issuance of the permit. 

8. On completion of construction of the device for which this permit is issued, 

notification of the fact is to be given to the Chief of the Air Division at 

least 10 days 1n advance of planned operation of the unit. Authorization to 

operate the unit must be received from the Chief of the Air Division. 

Failure to notify the Chief of the Air Division of completion of 

construction and/or operation without authorization could result in 

revocation of this permit. 
P.24 

9. Prior to a date to be specified by the Chief of the Air Division in the 

authorization to operate, emission tests are to be conducted by persons 

familiar with and using the EPA Sampling Train and Test Procedure as 

described in the Code of Federal Regulations, Title 40, Parts 60 and 61 or 

as approved by the Chief of the Air Division, for the following pollutants. 

Written tests results are to be reported to the Department within 15 working 

days of completion of testing. 

Particulates (X) Carbon Monoxide (X) Total Chlorides (X) 

Sulfur Dioxide ( ) Nitrogen Oxides ( ) 

Hydrocarbons (X) Mercury (X) 

10. Emission tests are to be conducted for the following pollutants at intervals 

not to exceed one year following the date of initial compliance testing. 

All test reports must be submitted to the Department within 15 days of 

completion of testing. 

Particulates (X) Carbon Monoxide ( ) 

Sulfur Dioxide ( ) Nitrogen Oxides ( ) 

Hydrocarbons (X) Total Chlorides (X) 

11. Submission of other reports regarding monitoring records, fuel analyses, 

operating rates, and equipment malfunctions may be required as authorized in 

the Department's air pollution control rules and regulations. 

12. Additions and revisions to the conditions of this Permit will be made, 1f 

necessary, to ensure that the Department's air pollution control rules and 

; regulations are not violated. 

13. Nothing in this permit or conditions thereto shall negate any authority 

granted to the Department pursuant to the Alabama Environmental Management 

Act or regulations issued thereunder. 

14. This permit is issued with the provision that the operation of this facility 

by the owner or operator will not result in emissions of obnoxious odors. 

15. The Department must be notified in writing at least 10 working days in 

advance of all emission tests to be conducted and submitted as proof of 

compliance with the Department's air pollution control rules and 

regulations. 

To avoid problems concerning testing methods and procedures, the following 

shall be included with the notification letter: 

(1) The date the test crew is expected to arrive, the date and time 

anticipated of the start of the first run, how many and which 

sources are to be tested, and the names of the persons and/or 

testing company that will conduct the tests. 

(2) A complete description of each sampling train to be used, 

including type of media used in determining gas stream components, 

type of probe lining, type of filter media, and probe cleaning 

method and solvent to be used (if test procedure requires probe 

cleaning). 
P.25 

(3) A description of the process(es) to be tested, including the feed 

rate, any operating parameter used to control or influence the 

operations, and the rated capacity. 

(4) A sketch or sketches showing sampling point locations and their 

relative positions to the nearest upstream and downstream gas flow 

disturbances. 

A pretest meeting may be held at the request of the source owner or the 

Department. The necessity for such a meeting and the required attendees 

will be determined on a case-by-case basis. 

All test reports must be submitted to the Department within 15 days of the 

actual completion of the test, unless an extension of time is specifically 

approved by the Department. 

16. This source is subject to the New Source Performance Standards for 

incinerators as defined in 40 CFR Part 60, Subpart E. 

17. This source will be subject to the particulate emission limit under New 

Source Performance Standards for industrial - commercial - institutional 

steam generating units as defined in 40 CFR Part 60, Subpart Db when 

promulgated. 

18. The annual capacity factor for natural gas and fuel oil as defined in 40 CFR 

Subpart Db proposed June 19, 1984, shall not exceed 5%. 

19; This source is subject to the National Emission Standards for Hazardous Air 

Pollutants for mercury as defined in 40 CFR Part 61, Supart E. 

20. Only non-hazardous solid wastes, tires, and wastewater treatment sludge 

shall be accepted at the site without prior approval of the ADEM Director. 

Only representatives approved by the Solid Waste Disposal Authority 

(Authority) shall deliver wastes to the plant. The Authority shall be 

responsible for ensuring that hazardous wastes are not received at the plant 

site. 

21. No liquid wastes shall be charged to the incinerator or accepted on plant 

property prior to written approval by the ADEM Director. 

22. No wastes shall be stored outside of the building. 

23. Continuous carbon monoxide and combustion chamber temperature monitors with 

recorders shall be installed, calibrated, maintained, and operated. The 

monitor locations and types shall be approved by ADEM prior to installation. 

24. During startup, fossil fuels shall be used to preheat the combustion chamber 

to at least 1560°F prior to feeding any solid wastes. 

25. During shutdown, fossil fuels shall be used to maintain the combustion 

chamber temperature at 1560°F or greater until all wastes in the combustion 

chamber have been removed. 

26. The combustion chamber temperature shall be maintained at 1560°F or greater 

except as allowed during startup and shutdown. 
P.26 

27. The following allowable emission limits shall apply: 

(1) Particulate 

(2) Sulfur Dioxide 

(3) Nitrogen Oxides 

(4) Carbon Monoxide 

(5) Lead 

(6) Beryllium 

(7) Mercury 

(8) Fluorides 

(9) Sulfuric Acid Mist 

0.02 gr/dscf corrected to 12% CO2 

0.28 lb/MM Btu 

0.32 lb/MM Btu 

0.11 lb/MM Btu 

0.25 lb/hr 

4.5 x 10-5 lb / n r 

2,612.7 grams/day (0.24 lb/hr) 

(total for 2 MSW-f1red boilers) 

1.15 lb/hr 

1.5 lb/hr 

28. An opacity monitor which meets the specifications as defined in 40 CFR Part 

60, Appendix B shall be installed, calibrated, maintained, and operated on 

the ESP exhaust stack. 
P.27 

£iL£f.I f.i£IIi£ l 

SOLID WASTE DISPOSAL AUTHORITY 

OF THE CITY OF HUNTSVILLE 

116.3 MM Btu/Hr Package Boiler 

709-1104-X003-6 

1. This permit is issued on the basis of Rules and Regulations existing on the 

date of issuance. In the event additional Rules and Regulations are 

adopted, it shall be the permit holder's responsibility to comply with such 

rules. 

2. This permit is not transferable. Upon sale or legal transfer, the new owner 

or operator must apply for a permit within 30 days. 

3. A new permit application must be made for new sources, replacements, 

alterations or design changes which may result in the issuance of, or an 

increase in the issuance of, air contaminants, or the use of which may 

eliminate or reduce or control the issuance of air contaminants. 

4. Each point of emission will be provided with sampling ports, ladders, 

platforms, and other safety equipment to facilitate testing performed in 

accordance with procedures established by Part 60 of Title 40 of the Code of 

Federal Regulations, as the same may be amended or revised. 

5. In the event there is a breakdown of equipment In such a manner as to cause 

increased emission of air contaminants for a period greater than 1 hour, the 

person responsible for such equipment shall notify the Department within an 

additional 24 hours and provide a statement giving all pertinent facts, 

including the duration of the breakdown. The Department shall be notified 

when the breakdown has been corrected. 

6. This permit expires and the application is cancelled if construction has not 

begun within 24 months of the date of issuance of the permit. 

7. On completion of construction of the device for which this permit is issued, 

notification of the fact is to be given to the Chief of the A1r Division at 

least 10 days in advance of planned operation of the unit. Authorization to 

operate the unit must be received from the Chief of the Air Division. 

Failure to notify the Chief of the Air Division of completion of 

construction and/or operation without authorization could result in 

revocation of this permit. 

8. Prior to a date to be specified by the Chief of the Air Division in the 

authorization to operate, emission tests are to be conducted by persons 

familiar with and using the EPA Sampling Train and Test Procedure as 

described in the Code of Federal Regulations, Title 40, Part 60, for the 

following pollutants. Written tests results are to be reported to the 

Department within 15 working days of completion of testing. 

Particulates (X) Carbon Monoxide ( ) 

Sulfur Dioxide ( ) Nitrogen Oxides (X) 

Hydiocarbons ( ) 
P.28 

9. Submission of other reports regarding monitoring records, fuel analyses, 

operating rates, and equipment malfunctions may be required as authorized in 

the Department's air pollution control rules and regulations. 

10. Additions and revisions to the conditions of this Permit wil l be made, i f 

necessary, to ensure that the Department's air pollution control rules and 

regulations are not violated. 

11. Nothing in this permit or conditions thereto shall negate any authority 

granted to the Department pursuant to the Alabama Environmental Management 

Act or regulations issued thereunder. 

12. This permit is issued with the provision that the operation of this facilit y 

by the owner or operator wil l not result in emissions of obnoxious odors. 

13. The Department must be notified in writing at least 10 working days in 

advance of all emission tests to be conducted and submitted as proof of 

compliance with the Department's air pollution control rules and 

regulations. 

To avoid problems concerning testing methods and procedures, the following 

shall be included with the notification letter: 

(1) The date the test crew 1s expected to arrive, the date and time 

anticipated of the start of the firs t run, how many and which 

sources are to be tested, and the names of the persons and/or 

testing company that wil l conduct the tests. 

(2) A complete description of each sampling train to be used, 

including type of media used in determining gas stream components, 

type of probe lining , type of filte r media, and probe cleaning 

method and solvent to be used (i f test procedure requires probe 

cleaning). 

(3) A description of the process(es) to be tested, including the feed 

rate, any operating parameter used to control or influence the 

operations, and the rated capacity. 

(4) A.sketch or sketches showing sampling point locations and their 

relative positions to the nearest upstream and downstream gas flow 

disturbances. 

A pretest meeting may be held at the request of the source owner or the 

Department. The necessity for such a meeting and the required attendees 

wil l be determined on a case-by-case basis. 

All test reports must be submitted to the Department within 15 days of the 

actual completion of the test, unless an extension of time is specifically 

approved by the Department. 

14. This source wil l be subject to the New Source Performance Standards for 

industrial - commercial - institutional steam generating units as defined in 

40 CFR Part 60, Subpart Db when promulgated. 

15. Only diesel oil , natural gas, and landfil l gas may be fired in this boiler. 
P.29 

16. The following allowable emission limits shall apply: 

(1) Particulate - 0.05 lb/MM Btu not to exceed 5.82 lb/hr 

(2) Sulfur Dioxide - 0.1 lb/MM Btu not to exceed 23.26 lb/hr 

(3) Nitrogen Oxides - 0.1 lb/MM Btu 

(4) Carbon Monoxide - 4.21 lb/hr frf*-^ 

(5) Sulfuric Acid Mist - 0.91 lb/hr CrdT^ ' 

*&m 
P.30 

• 1JLLL1' £I£I1I£I 

SOLID WASTE DISPOSAL AUTHORITY 

OF THE CITY OF HUNTSVILLE 

200,000 Gallon Diesel Storage Tank 

709-I104-X007 

1. This permit is issued on the basis of Rules and Regulations existing on the 

date of issuance. In the event additional Rules and Regulations are 

adopted, it shall be the permit holder's responsibility to comply with such 

rules. 

2. This permit is not transferable. Upon sale or legal transfer, the new owner 

or operator must apply for a permit within 30 days. 

3. A new permit application must be made for new sources, replacements, 

alterations or design changes which may result 1n the issuance of, or an 

increase in the issuance of, air contaminants, or the use of which may 

eliminate or reduce or control the issuance of air contaminants. 

4. This permit expires and the application is cancelled 1f construction has not 

begun within 24 months of the date of issuance of the permit. 

5. On completion of construction of the device for which this permit 1s Issued, 

, notification of the fact is to be given to the Chief of the A1r Division at 

least 10 days in advance of planned operation of the unit. Authorization to 

operate the unit must be received from the Chief of the A1r Division. 

Failure to notify the Chief of the Air Division of completion of. 

construction and/or operation without authorization could result 1n 

revocation of this permit. 

6. Submission of other reports regarding monitoring records, fuel analyses, 

operating rates, and equipment malfunctions may be required as authorized in 

the Department's air pollution control rules and regulations. 

7. Additions and revisions to the conditions of this Permit will be made, if 

necessary, to ensure that the Department's air pollution control rules and 

regulations, are not violated. 

8. Nothing in this permit or conditions thereto shall negate any authority 

granted to the Department pursuant to the Alabama Environmental Management 

Act or regulations issued thereunder. 

9. This tank will be subject to the proposed New Source Performance Standards 

for VOL storage vessels as defined in 40 CFR Part 60, Subpart Kb when 

promulgated. 
P.31 

APPENDIX C 

DISPERSION MODELING ANALYSIS 
P.32 

Review and Analysis of Air Quality Modeling 

for the 

Huntsville Refuse Fired Steam Plant 

Introduction 

The purpose of this review and analysis is to provide an assessment of the 

air quality modeling study conducted by Courtney Consultants, Inc. (CCI) for the 

proposed Huntsville Refuse Fired Steam (HRFS) Project and to provide a summary 

of the Alabama Department of Environmental Management's (ADEM) modeling efforts. 

ADEM has reviewed the CCI air quality modeling study and the proposed facility's 

air emissions to determine its compliance with applicable PSD requirements and 

the National Ambient Air Quality Standards (NAAQS). 

Modeling Methodology 

Particular models which addressed the ambient impact of sulfur dioxide and 

particulate matter were the PTPLU Model, VALLEY Model, and the ISCST Model. The 

PTPLU Model was the first-level screening technique to provide conservative 

estimates of the air quality impact. Subsequent receptor sites were chosen in 

sufficient detail to allow determination of the highest concentrations. 

The VALLEY Model was used by CCI and ADEM as a second-level screening technique 

to determine concentrations at complex terrain points found in the vicinit y of 

the proposed facility . For distances less than 2.5 km, the ISCST Model was used 

by CCI and ADEM, since for modeling purposes tbe terrain within that radial 

distance may be considered essentially flat . The ISCST Model may be considered a 

third-level, final analytical technique for determining SO2 and TSP concentration 

levels where the terrain height is less than stack height. For pollutants other 

than SO2 and TSP (N0X, CO, HC1, etc.), ambient impact was determined by 

emission ratios (e.g., allowable CO emission rate per package boiler 0.530 

gs"V2.931 gs_*. allowable SO2 emission rate per package boiler) which were 

multiplied by the highest five-year SO2 increment-consumption value. 

Modeling was also performed to determine impacts upon the Sipsey 

Wilderness Area, a Federal Class I wilderness area. The nearest boundary 

point (UTM coopd+nafes 465.0, 3795.625 km) of this wilderness area 1s located 

approximatel/JJl^km WSW of the HRFS facility . 

Review of the Air Quality Impact Analysis 

Table 2.2-1 (page 9) of CCI's analysis is a detailed listin g of worst-case 

emission rates. Revisions to the SO2 AND TSP emission rates were subsequently 

made by HRFS. The revised rates are given below in Table 1. 
P.33 

Table 1. Emission rates of the proposed Huntsville facility . 

Expected Allowable 

Source Pollutant Emission Rate Emission Rate 

1-MSW Boiler S02 4.618 g/sec 4.618 g/sec 

TSP 0.675 g/sec 0.675 g/sec 

1-Package Boiler S02 2.931 g/sec 2.931*g/sec 

TSP 0.215 g/sec 0.733 g/sec 

•Emission rate modeled was 2.94 "g/sec, based upon ADEM calculation of 09SEP86, 

instead of updated (02DEC86) calculation of 2.931 g/sec based upon 0.2 lb/10°" BTU. 

Another revision to the modeling was increasing the height of the proposed 

stacks for the package boilers by 10 m, from 16.77 to 26.77 m. Since these unit s 

have potentially the largest air quality impact for the Huntsville facility , 

the additional height lessens the effects caused by downwash, which, as 

addressed in this report, refers to plume dispersion caused by aerodynamic 

effects of buildings. Emission parameters are included 1n Table 2. 

:

 It is the opinion of ADEM that CCI correctly performed the PTPLU and VALLEY 

modeling requirements. The revision to the emission rates and stack height, 

however, required additional modeling . The revised modeling was performed by 

ADEM. ADEM's modeling summaries are given 1n the following section of this 

report, "Air Quality Modeling Results." 

The next section of the analysis of CCI which required review was "GEP -

Downwash Discussion" (pp. 21+). To determine building dimensions, ADEM followed 

the building downwash screening procedure as outlined by EPA (Addendum to the 

Regional Workshop," December 13, 1983, Appendix C). The building downwash 

screening procedure was required, since the good engineering practice (GEP) 

analysis indicated that the proposed stack heights were less than the GEP height. 

After cavity effects were determined not to impact ambient air, wake effects 

were analyzed for both the refuse building and the ash-dump building. CCI's 

worst-case minimum projected widths were 42.55 m and 21.95 m for the refuse and 

ash-dump buildings, respectively. 

ADEM recalculated these building dimensions (w » 1), based upon the 

"effective diameter" or projected width, and found them to be 59.24 m and 28.63 m 

for the refuse and ash-dump buildings, respectively. Since the report of CCI 

did not include the actual length and width dimensions of the ash-dump building, scale conversions of these dimensions were made by ADEM from the drawings 

provided by CCI. It is noted that concentration values obtained from subsequent 

modeling showed wery littl e difference resulting from the projected widths 

calculated by ADEM and CCI. I t is important to note, however, that the ISCST 

downwash algorithm was involved in this phase of modeling, since the proposed 

stacks of the MSW and package boiler sources are shorter than the GEP stack 

height. 
P.34 

Table 2. Emission parameters for the proposed Huntsville facility . 

1-MSW Boiler 1-Package Boiler* 

UTM Coordinates (km) 535.654,3836.451 

535.654,3836.452 

535.664, 3836.415 

535.670, 3836.415 

535.676, 3836.415 

535.682, 3836.415 

Base Elevation (f t above m.s.l.) 

Allowable Emission Rate (g/s) 

S 02 

TSP 

N0X 

CO 

Lead 

Beryllium 

Mercury 

Fluorides 

:• Sulfuric Acid Mist 

Expected Emission Rate (g/s) 

HC1 

Total Dioxins 

Actual Stack Height (meters) 

GEP Stack Height (meters) 

Stack Diameter (meters) 

Stack Gas Temperature (Kelvin) 

Stack Gas Velocity (m/s) 

585 

^•4.618 36.6/^/^ 

s. 0.675 5-.JS-/*./-* 

H\ 4.89153»'^**^* 

\.1.8655''»'.r!/<** 

N0.0315* ur/ *

, A * . r , \.5.7xl0"6

 </.s-i«i* W*< 

\ o!oi 51 «//*«*»/•* 

^ 0.145 /./a-A./** 

^•0.1885 /V9/**/"*-

585 

*^ 2.931 ,1M1'*«/"* 

"^0.733 s.9t '*»/*"• 

.3 1.465 //.*W,»/*A 

N 0.530 V-A/**>"*• 

N/A 

N/A 

N/A 

N/A 

N/A 

/Tl 30.8825 **/«•"»/** N/A 

r

 1.512x10-5 /.a***"/*'**• N/A 

60.97 26.77 

85.18 85.18 

1.98 0.91 

477 450 

10.4 25.34 

•Subsequent plant-design revision (November, 1986) calls fHFTrttt+iijiq two 

stacks, instead of four. Although the facilit y was modeled for four stack; 

impact would not be expected to exceed those concentrations summarized in this 

report, since the same design conditions wil l be served as with smaller .sized, 

\ individual stacks. 

\ 
P.35 

""1 

ADEM examined the various downwash regions affected by the proposed structures. After careful analysis, i t was decided that the CCI report does not 

completely address all downwash regions to the maximum extent possible. The 

sectors and affected downwash regions determined by ADEM were based upon a 

single grid system, using the MSW stacks as the central point of reference. The 

analysis of CCI describes sectors and corresponding degrees in terms of grid 

systems using both the MSW and package boiler stack-sources as points of 

reference. This dual-grid system is not satisfactorily explained, especially in 

terms of sectors 028-092 degrees and 208-272 degrees for the package boilers/ 

refuse-building receptor system (CCI Analysis, August 1986, p. 24). The 

detailed downwash regions as prepared by ADEM give a more definitive approach 

to the effects of downwash in the ISC modeling. 

ADEM redefined the receptor network to include the area east of McDonald 

Creek to the plant boundary, as well as the area north of the plant boundary 

(3836.527 UTM, North) to the Une at 3836.645 UTM, North, and extending to 

McDonald Creek. These areas were not addressed in the CCI analysis. 

Finally, a review of the CCI analysis 1n Sections 5 and 6 was made. The 

report states that "the results of the modeling are compared [to Class I area 

significant thresholds] and found to be well below the significant impact 

criteria." Significant impact criteria or thresholds do not exist for Class I 

areas. 

Air Quality Modeling Results 

CCI and ADEM performed the firs t level screening by using the PTPLU model as 

a prerequisite for the VALLEY Model. The methodology for this modeling 

described by CCI is both correct and acceptable to ADEM. CCI cited VALLEY Model 

results for worst-case 24-hour averaging times for SO2 and TSP concentrations of 

54 ug/m3 and 21.2 ug/m3, respectively. As indicated in the Air Quality Impact 

Analysis (August 1986), CCI noted that it s values were presented in May 1986 to 

ADEM, who "concurred that these concentrations were sufficiently low such that 

terrain effects had been sufficiently treated." Subsequent VALLEY modeling by 

ADEM supports this conclusion, since similar values to those of CCI were 

obtained. 

Analytical modeling with ISCST was conducted by using worst-case building 

downwash from the refuse building with al l facilit y sources. ADEM narrowed the 

receptor range for TSP to 500 m, with ring distances every 100 m along al l 36 

radials. The highest second-high predicted 24-hour total value increment, for 

increment consumption including nine additional sources, was slightl y more than 

35 ug/m3 for both CCI and ADEM. 

Since the increment resulting from modeling by ADEM represented the worstcase concentration from refuse-building downwash and.was no higher than that 

reported by CCI, no additional modeling was required for determining TSP 

concentrations. Results of ADEM's TSP modeling with the five-year data set 

(1970-1974) for the 24-hour period are provided in Table 3. Figure 1 shows an 

analysis of the projected 24-hour concentrations for 1972. Concentration 

values lessen with increasing distance from the plant. 
P.36 

Table 3. 24-hour TSP increment consumption from all sources (highest 

second-high, worst-case values from ISCST modeling by ADEM). 

Year 

1970 

1971 

1972 

1973 

1974 

Concentration^ 

(ug/m3) 

34.2 

33.8 

35.1 

33.6 

31.3 

Receptor Location 

(meters, degrees) 

100, 280° 

100, 300° 

200, 130° 

100, 290° 

100, 290° 

% Class II 

Increment (37 ug/m3) 

92.4 

91.4 

94.9 

90.8 

84.6 

*Values also representative of proposed facilit y alone. 

SO2 screening modeling with ISCST was also conducted using worst-case 

building downwash from the refuse building with all proposed stacks. 

Again, the receptor range was every 100 m, extending to 500 m with ring 

distances along al l 36 radials. Initially , 1974 data were analyzed, since the 

CCI analysis showed this to be the year of maximum concentration (71.95 

ug/m3 from all sources, including six additional sources). From the 1974 ISCST 

worst-case modeling run conducted by ADEM, many SO2 concentration values 

exceeded the maximum value reported by CCI. ADEM therefore refined the modeling 

methodology to account for appropriate source-building-receptor downwash 

regions. All SO2 concentration values greater than the CCI value of 71.95 

ug/m3 were analyzed. Values greater than the CCI maximum were suspect, since 

the model generated its results based upon worst-case downwash. Therefore, any 

higher concentration value was scrutinized for the appropriate downwash 

region(s) in the wake(s) of the appropriate building(s). Subsequent refined 

modeling^by ADEM resulted in a maximum second highest 24-hour concentration 

value of 71.8 ug/m3 for 1974. The receptor for this value was noted in the 

downwash sector (300 m, 210°) of the refuse building against the package boiler 

stacks, with no downwash effects against the MSW stacks. 

Because this value was so close to the maximum value (71.95 ug/m3) reported 

by CCI, ADEM continued the ISCST modeling for the remainder of the five-year 

data set. The methodology was the same for each year: worst-case runs were 

firs t completed for refuse-building downwash against al l proposed facilit y 

stacks. Results were analyzed for values exceeding those of 1974. Next, 

refined modeling was completed to account for appropriate downwash regions. 

Results of ADEM's SO2 modeling with the five-year data set (1970-1974) for the 

24-hour period are provided in Table 4. 
P.37 

Fig. 1. Isopleths showing areas of projected maximum TSP concentrations (ug/m ) for'1972. 
P.38 

Table 4. 24-hour SO? increment consumption (highest second-high values from 

ISCST modeling by ADEM). 

Facility Other Sources Total Receptor % Class I I 

Year Concentration Concentration Increment Location Increment 

(ug/m3) (ug/m3) (ug/m3) (meters,degrees) (91 ug/m3) 

1970 

1971 

1972 

1973 

1974 

18.70 

17.61 

22.12 

78.95 

71.84 

0.01 

0.02 

0.46 

0.06 

0.004 

18.71 

17.63 

22.58 

79.01 

71.841 

100, 310° 

300, 300° 

300, 130° 

200, 250° 

300, 210° 

20.6 

19.4 

24.8 

86.8 

78.9 

The highest second-high SOo concentration value reported by ADEM is 

therefore approximately 7 ug/m3 higher than that of CCI. The location of the 

receptor for this predicted SO2 concentration value is 200 meters and 250° from 

north, as measured from the central point of reference (MSW stacks), 1n the 

downwash sector of the refuse building's influence of all facilit y stacks. 

Modeling results show impact of outside (non-plant) sources to be minimal. 

Figure 2 shows an analysis of the projected 24-hour concentrations for 1973. 

Table 5 is a summary of the total air quality assessment, including 

background air quality, completed by ADEM. 

Table 5. Total air quality assessment by ADEM. 

Facility Background Total NAAQS 

Pollutant Period Model Concentration Concentration Concentration (ug/m3) 

(ug/m3) (ug/m3) (ug/m3) 

TSP 

TSP 

TSP 

S02 

24-hour 

24-hour 

Annual 

3-hour 

24-hour 

24-hour 

Annual 

VALLEY 

ISCST 

ISCST 

ISCST 

VALLEY 

ISCST 

ISCST 

10.3** 

35.1* 

4.6* 

460.8* 

47.5** 

78,95 

18.5* 

100 

100 

40 

125 

47 

47 

10 

116.3 

135.1 

44.6 

585.8 

94.5 

125.95 

28.5 

260/150 

260/150 

75/60 

1300 

365 

365 

80 

*Values for worst-case downwash, using refuse building for all receptors. 

••Values corrected for emissions and stack height changes since original CCI results. 

» _& T 

~E~ 
P.39 

• 1 "•• -" • 

• . 1 

1

 ! / 

* «• ^ / 

« 

' '• ' 

Fig. 2. Isopleths showing areas of projected maximum SO2 concentrations (ug/m3) for 1973.. 
P.40 

Table 6 is a summary of emission ratios and projected ambient impact of all 

other pollutants, based upon the results of modeling for SO2 and TSP. Concentrations for these pollutants were determined by ratioing the respective emission 

rates with the maximum SO2 or TSP impact for each source, resulting in a 

conservative estimate of the maximum combined impact for the other pollutants. 

Finally, impact upon the Sipsey Wilderness Area was addressed. Table 7 is 

a summary of the allowable Class I PSD increments and concentrations determined 

from ADEM's modeling. Model predictions are well below Class I limits. 

Table 7. Federal Class I Sipsey Wilderness Area impact. 

Pollutant Period Class I Limits 

(ug/m3) 

1970-74 Maximum 

Concentration 

(ug/m3 )* 

S02 

TSP 

Annual 

24-hour 

3-hour 

Annual 

24-hour 

2 

5 

25 

5 

10 

0.08 

2.03 

8.17 

0.02 

0.45 

•Concentration values represent highest second-high ISCST 

model predictions for the 24-hour and 3-hour concentrations. 

Summary and Conclusions 

The Alabama Department of Environmental Management has reviewed the air 

quality impact report for the proposed Huntsville Refuse Fired Steam (HRFS) 

Project prepared by Courtney Consultants, Inc. In addition, ADEM performed its 

own extensive analysis of this proposed project. Both screening techniques and 

refined modeling methodology were employed to assure that the proposed air 

pollution sources will not violate national ambient air quality standards 

(NAAQS) or prevention of significant deterioration (PSD) increments. The 

Department has reviewed the procedure of CCI to determine visibility impact upon 

the Federal Class I Sipsey Wilderness Area and agrees with the results that trie 

HRFS facility will not cause an adverse visibility impact. ADEM therefore 

concurs with the conclusion presented by CCI that "the modeling results show 

that compliance for the pollutants considered is achievable with the current 

plant design and contemplated operation of the HRFS." 

J 
TABLE 6. Projected Concentrations (ug/m3) for Other Pollutants 

Pollutant 

N0X 

coM) 

Lead 

Beryllium 

Mercury 

Fluorides 

Sulfuric 

A d d Mist 

Averaging 

Period 

Annual 

8-Hour 

1-Hour 

Quarterly 

Annual 

Annual 

Annual 

Annual 

MSW 

Emission Rat 

(g/sec) 

9.784 . 

3.732 

3.732 

.064 

11.4 x 10-

.030 

.29 

.377 

Boil 

.e 

•6 

ers Package 

Maximum Impact Emission Rate 

(ug/m3) (g/sec) 

.969( 2) 

21.8 

21.8 

.0650) 

11.3 x 10-7(2) 

.003(2) 

.029(2) 

.037(2) 

5.86 

2.12 

2.12 

N/A 

N/A 

N/A 

N/A 

N/A 

Boilers 

Maximum Impact 

(ug/m3 

9.219( 3) 

146.2 

146.2 

N/A 

N/A 

N/A 

N/A 

N/A 

Total 

Combi ned 

Impact 

(ug/m3) 

10.188 

146.2 

146.2 

.065 

11.3 x 10~7 

.003 

.029 

.037 

NAAqs 

(ug/m3) 

100 

10.000 

40,000 

1.5 

TLV/420 

4.8 x IO" 3 

.024 

6.0 

2.4 

HC1 Annual 61.765 6.123(2) N/A N/A 6.123 16.7 

(^Taken from the highest second-high 24-hour SO2 Impact due to the MSW boilers. This results 1n a conservative 

estimate for quarterly lead concentrations. 

(2|Taken from maximum annual SO2 impact due to MSW boilers. 

(

3)Taken from maximum annual SO? impact due to package boilers, ,. , J ... . 

(4)l-Hour and 8-Hour CO concentrations are taken from 1-hour ISCST results for CO. The maximum combined impact is 

primarily due to the package boilers. 
P.42 

APPENDIX D 

EXAMPLE EMISSION CALCULATIONS 

SUMMARY OF EMISSIONS 

SUMMARY OF APPLICABLE REGULATIONS 
P.43 

Emissions Calculations 

(1) 2-129.4 MM Btu/hr Boilers 

: Example Calculations: 

(E.F.) x Waste Feed = Uncontrolled Emissions (lb/hr) 

Uncontrolled Emissions x (1-Removal Efficiency) = Expected Emissions 

Expected Emissions x 4.38 = Expected Emissions (tpy) 

For Particulate: 

(690 tpd)/(24 hr/d) = 28.75 tph = Waste Feed 

46.5 lb/t x 28.75 tph » 1,336.88 lb/hr 

(1,336.88 lb/hr) x (1-0.992) » 10.7 lb/hr 

(10.7 lb/hr) x (4.38 t-hr/lb-y) * 46.9 tpy 

(2) 116.3 MM Btu/hr Boiler 

Example Calculations: 

(a) firin g natural gas 

(116.3 MM Btu/hr)/(l,030 Btu/cf) » 1.13 x 105 c f/hr 

1.13 x IO5 cf/hr x E.F. lb/MM cf » lb/hr 

( lb/hr) x (4.38 t-hr/lb-yr) tpy 

(b) firin g diesel 

(116.3 MM Btu/hr)/(19,460 Btu/lb) = 5,976.3 lb/hr 

(5,976.3 lb/hr)/(7.1 lb/gal) = 841.73 gal/hr 

(841.73 gal/hr) x (E.F. lb/103 gal) » lb/hr 

( lb/hr) x (4.38 t-hr/lb-yr) = tpy 
P.44 

Expected Emissions 

200,000 Gallon Diesel Tank 

Breathing losses from a fixed roof tank can be estimated from: 

LB = 2.26 x 10-2 [M] x (P/(14.7-P))-68 D1-

73

 H-51 dT-50 Fp Kc 

where L„ = breathing loss (lb/yr) 

M = molecular weight of vapor = 130 lb/lb mole 

P = vapor pressure

 s 0.0074 psia @ 60°F 

D

 3 tank diameter = 34 f t 

H = average vapor space height = 16.1 f t 

dT = average ambient diurnal temperature change

 a 30°F 

Fp = paint factor = 1.0 (dimensionless) 

C = adjustment factor • 1.0 (dimensionless) 

Kc = product factor = 1.0 (dimensionless) 

:LB = 169.4 lb/yr » 0.085 tpy 

Working losses are estimated as: 

LW = 2.4 x IO"5 Mv P V N Kn KG 

where Ly = working loss (lb/yr) 

Mv = molecular weight of vapor » 130 lb/lb mole 

P = vapor pressure 0.0074 psia @ 60°F 

Kn = turnover factor » 1.0 (dimensionless) 

V » tank capacity = 200,000 gal 

Kc » product factor * 1.0 (dimensionless) 

N = number of turnovers per year = (581,600/200,000) 

(dimensionless) 

Lw = 13.4 lb/yr = 0.007 tpy 

2.908 

. . TOTAL LOSSES = 182.8 lb/yr = 0.09 tpy 
APPENDIX D 

P.45 

TABLE I 

Expected Emissions 

2-129.4 MM Btu/hr Boilers 

\ 

Pollutant 

Particulates 

Sulfur Dioxide 

Nitrogen Oxides 

Carbon Monoxide 

Volatile Organics 

Lead 

Beryllium 

Mercury 

Fluorides 

Sulfuric Acid 

Mist 

Hydrogen 

Chloride 

Dioxins 

The emissions 

E.F. 

lb/ t 

46.5 

46.6 

2.55 

2.29 

2.70 

2.85 

0.94 

1.03 

0.19 

0.21 

0.20 

0.35 

2.30E-05 

6.30E-05 

3.30E-03 

8.20E-03 

8.0E-02 

1.04E-01 

9.30E-02 

11.93 

represent 

Waste 

Feed 

tph 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

28.75 

the tota l 

Uncontrolled 

Emissions 

lb/hr 

1,336.88 

1,339.75 

73.31 

65.84 

77.63 

: 81.94 

27.03 

29.61 

5.46 

6.04 

5.75 

10.06 

6.61E-04 

1.81E-03 

9.49E-02 

0.24 

2.30 

2.99 

2.67 

342.99 

1.38E-04 

for two 129.4 

Removal 

Efficiency 

% 

99.2 

99.2 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

95.0 

95.0 

95.0 

95.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

MM Btu/hr boi l 

Expected 

Emissions 

lb/h r tpy 

10.7 

10.7 

73.31 

65.84 

77.63 

81.94 

27.03 

29.61 

5.46 

6.04 

0.29 

0.50 

3.31E-05 

9.06E-05 

9.49E-02 

0.24 

2.30 

2.99 

2.67 

342.99 

46.9 

46.9 

321.1: 

288.3} 

340. OC 

358.88 

118.37 

129.7C 

23.93 

26.44 

1.26 

2.20 

1.45E 

3.97E 

0.42 

1.03 

10.07 

13.10 

11.71 

1,502 

1.38E-04 6.04E 

ers . The firs t an 

second rows for each pollutant reflect emission rates at 100% MSW firing and -10:1 MS 

sewage sludge firing, respectively, both at 690 TPD charging rate. 
P.46 

APPENDIX D 

TABLE II 

Expected Emissions 

116.3 MM Btu/hr Boiler 

Pollutant 

Particulate 

Sulfur Dioxide 

Nitrogen Oxides 

Carbon Monoxide 

Volatile Organics 

Fuel 

Usage 

1.13 x IO5 cf/hr 

841.73 gal/hr 

1.13 x IO5 cf/hr 

116.3 MM Btu/hr 

116.3 MM Btu/hr 

1.13 x IO5 cf/hr 

841.73 gal/hr 

1.13 x IO5 cf/hr 

841.73 gal/hr 

Emission 

Factor 

5 lb/MM cf 

2 lb/103 gal 

0.6 lb/MM cf 

0.2 lb/MM Btu* 

0.1 lb/MM Btu* 

35 lb/MM cf 

5 lb/103 gal 

5.8 lb/MM cf 

0.252 lb/103 gal 

Expected 

Emissions 

lb/hr tpy 

0.56 

1.68 

0.07 

23.26 

11.63 

3.95 

4.21 

0.65 

0.21 

2.45 

7.37 

0.31 

101.88 

50.94 

17.30 

18.43 

2.85 

0.93 

NOTE: The firs t entry is for combustion emissions utilizin g only natural gas, 

The second entry is for combustion emissions utilizing only fuel oil . 

Emissions are per boiler. 

•Equal to emission limit proposed under 40 CFR 60, Subpart Db. 
APPENDIX D 

TABLE II I 

Applicable Emission Limiting Regulations 

Source Regulation Pollutant Emission Limit 

(1) 129.4 MM Btu/hr Boiler (2 each) 40 CFR Part 60, Subpart E Particulates 0.08 gr/dscf 

7-09-1104-X001, 2 corrected to 12% C02 

(2) 116.3 MM Btu/hr Boiler (4 each) 

7-09-I104-X003-6 

40 CFR Part 60, Subpart Db1 Particulat e 

Huntsville APC-Part 6.3 Particulates 

40 CFR Part 61 , Subpart E Mercury 

Huntsville APC-Part 7.1 Sulfur 

Dioxide 

Huntsville APC-Part 6.3 Particulates 

40 CFR Part 60, Subpart Db Particulates 

Sulfur 

Dioxide 

Nitrogen 

Oxides 

Sulfur 

Dioxide 

Huntsville APC-Part 7.1 

0.10 lb/MM Btu heat input 

and 20% opacity 

0.16 lb/MM Btu heat input 

3200 grams per day2 

1.2 lb/MM Btu heat input 

0.17 lb.MM Btu heat input 

0.10 lb/MM Btu heat input 3 

and 20 % opacity 

0.2 lb/MM Btu heat input 3 

0.10 lb/MM Btu heat input 1 

1.2 lb/MM Btu heat Input 

Proposed 6/19/84 

2Total allowed fo r two units . 

Proposed 6/19/86 
P.48 

APPENDIX E 

DIOXIN EMISSION CALCULATIONS 
P.49 

Dioxins Calculations 

(1) Based upon emission factors estimated by Arthur D. Litle , Inc. 1 

total PCDD = 4.8 x IO"6 lb/t of municipal refuse 

total TCDD = 3.5 x IO-7 lb/t of municipal refuse 

2,3,7,8 TCDD = 3.5 x IO8 lb/t of municipal refuse 

Estimated Emissions: 

(1) total PCDD 

(4.8 x IO-6 lb/t) x (28.75 t/hr) = 1.38 x IO"4 lb/hr 

(2) total TCDD 

(3.5 x IO"7 lb/t) x (28.75 t/hr) = 1.0 x IO"5 lb/hr 

(3) 2,3,7,8 TCDD 

(3.5 x IO"8 lb/t) x (28.75 t/hr) * 1.0 x IO"6 lb/hr 

(2) Based upon stack test results of a similar plant in Germany (340,000 tpy of 

waste) the total dioxin and 2,3,7,8 TCDD emissions were 31 nanograms per 

normal cubic meter and less than 0.1 nanograms per normal cubic meter 

(1/310 PCDD), respectively. This facility has a scrubber and ESP to 

control emissions. 

Recent stack tests results on different types of dry scrubbers lead to 

inclusive results on the percent of dioxin that is removed by a scrubber. 

Based on discussions with EPA, a scrubber can remove 50 to 95% of the 

dioxins. 

Therefore, to estimate the worst case uncontrolled dioxin emissions for the 

Huntsville units (252,000 tpy of waste), it will be assumed that a scrubber 

could remove 95% of the dioxins because it gives the most conservative estimate 

total PCDD:; 

(31 ng/m3) x (1/(1-0.95)) x (1 g/109 ng) = 6.20 x IO"7 g/m3 

The maximum design flow is 94,725 cfm at 482°F. 

(94,725 cfm x ((460 + 70)°R/(460 + 482)°R) = 53,295 scfm 

(6.20 x IO"7 g/m3) x 53,295 cfm) x (1 m3/35.32 cfm) x (1 lb/453.6g) x 

(60 min/hr) = 1.2 x IO' 4 lb/hr 

total TCDD - Data not available from test report. 
P.50 

2,3,7,8 TCDD: 

(6.2 x 10"7g PCDD/m3) x (lg TCDD/310g PCDD) = 2.0 x 10-9 g/m 3 

(1.2 x IO"4 lb/hr) x (lg TCDD/310g PCDD) = 4.0 x 10"7 lb/hr 

Proceedings of the ASME/EPA Hazardous Waste Incineration Conference, 

Williamsburg, VA, May 27-29, 1981, p. 90. 

Total PCDD 

Total TCDD 

2,3,7,8 TCDD 

Range of Dioxin Emissions from MSW Boiler 

1.2 x IO*4 lb/hr 1.38 x IO"4 lb/hr 

1.0 x 10-5 lb/h r 

0.4 x IO"6 lb/hr 1.0 x IO"6 lb/hr 
P.51 

APPENDIX F 

SUMMARY OF ABBREVIATIONS 

USED IN REPORT 

r 
P.52 

ABBREVIATIONS 

cf - cubic feet r 

ft - feet 

MM - million 

m - meter 

Btu - British Thermal Unit 

ng - nanogram 

lb - pounds 

g - grams 

hr - hour 

sec - second 

t - ton 

d' - day 

E.F. - emission factor 

tpd - tons per day 

tph -

 ; tons per hour 

tpy - tons per year 

ESP - electrostatic precipitator 

MSW - municipal solid waste 

HSWDA - Huntsville Solid Waste Disposal Authority 

PSD - Prevention of Significant 

BACT - best available control technology 

QMVHRR - Qualifying Maximum Volumetric Heat Release Rate 

ppmv - parts per million on a volume basis 

NAAQS - National Ambient Air Quality Standard 

CO2 - carbon dioxide 
P.53 

gr - grains 

dscf - dry standard cubic feet 

scfm - standard cubic feet per minute 

Nm3 - normal (standard) cubi c meter 

CAA - Clean Ai r Act 

ACGIH - American Conference of Governmental Industrial Hygienists 

PCDD - polychlorinated dibenzo-dioxins 

TCDD - tetrachloro-dibenzo-p-dioxin 

°K - degrees Kelvin 

°F - degrees Fahrenheit 

1.0E-XX - 1.0 x 10"xx 
P.54 

ATTACHMENT II 

HUNTSVILLE INCINERATOR COMMENTS 

1. The proximate analysis for landfill gas has not been provided. A significant sulfur content in this gas is expected and may influence SO2 

emission rates for all boilers. 

2. Sulfur content of sewage sludge has been stated by applicant as zero. 

AP-42 shews a 1 lb./ton emission factor (dried sludge), and an incinerator project in California states a 1.2% wt sulfur content; this would 

be 24 lbs./ton (assumes 100% conversion and no retention). 

3. No comment has been made as to the projected throughput of automobile 

tires and the characteristic emissions expected fran this fuel. 

4. The emission factor for sulfur dioxide emissions frcm MSW with a sulfur 

content of 0.19% S by wt assumes a retention in the ash of approximately 75%. Although it has been reported that retention of SO2 in MSW 

ash may reach this level, we feel a more conservative estimate is 33%. 

This vould equate to a higher emission rate of SO2 (4 lbs./ton) and in 

conjunction with sewage sludge and landfill gas incineration may result 

in lower acid gas and SO2 "cost per ton" control values. 

5. Although an ESP has the comparable control of a baghouse, the baghouse 

has demonstrated a much better control efficiency for fine particulate 

matter. In considering the relatively high concentrations of furans 

;and dioxins on fine particulate matter, baghouse controls appear to be 

most appropriate. In addition to the dilution of flyash particulate 

emissions through dry scrubbing for reduction of acid gases, the use of 

dry scrubbing will also reduce flue gas temperatures and result in 

increased removal of mercury and other condensible organics. Ccmbined, 

the acid gas removal and baghouse controls provide a minimum emission rate 

for pollutants (dioxins) which have no minimum acceptable exposure limits. 

Therefore, due to the precedent established by the North County (CA) 

remand, it is our opinion that the projected cost of approximately 

$1500/ton of pollutants removed is a reasonable cost to incure for the 

operation of this facility. In regard to the increase in the cost of the 

tipping fee ($8.85 to $21.00 per ton), other facilities within Region IV 

will charge in excess of this amount to provide acid gas control, and 

the surrounding communities have indicated a willingness to pay the 

additional fees for protection of their health and wellbeing through 

petitions and letters supporting the installation of acid gas controls. 

6. Each of these boilers will be subject to NSPS subpart Db which was 

promulgated on November 25, 1986. 

7. Was UNIMAP 6 used by ADEM in modeling the impacts of the proposed 

facility? When was ADEM modeling analysis performed? 

8. Continuous emissions monitors should be provided for SO2, NO2, and CO to 

ensure continuous compliance with emissions limits. 

9. We feel that BACT for particulate emissions is 0.015 gr/dscf corrected to 

12% CO2 instead of 0.02 gr/dscf corrected to 12% CO2 as proposed in the 

draft preliminary determination. 
P.55 

ATTACHMENT III 

> ^ >M,»/> 

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ALABAMA 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT '^LS^ ' 

Leigh Pegues. Director 

1751 Federal Drive 

Montgomery. AL 

36130 

205/271-7700 

Field Officer 

Unit 806. Building 8 

225 Oxmoor Circie 

Birmingham. AL 

35209 

205/942-6168 

P.O. Box 953 

Decatur. AL 

35602 

206/353-1713 

2204 Perimeter Road 

Mobile. AL 

36615 

205/479-2336 

February 23, 1987 

A I S ??• 

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Guv Hum 

Governor 

'••S *?ANCH 

H FEB 24 1987 

ETSELTDTIJ 

EPA-REGION IV 

ATLANTA, GA. 

Mr. Bruce P. Miller, Chief 

Air Programs Branch 

Air, Pesticides, and Toxics 

Management Division 

U. S. Environmental Protection Agency 

Region IV 

345 Courtland Street 

Atlanta, GA 30365 

Dear Mr. Miller: 

This is a followup to our recent meeting regarding the Huntsville 

incinerator permit application pesently under consideration. One 

major area of disagreement during the meeting were the factors 

allowed to be considered in making a Best Available Control Technology 

(BACT) determination. I have enclosed a copy of the current EPA 

policy for performing BACT assessments. 

It is my opinion that the EPA policy supports the factors 

considered in our draft analysis and provides a large degree of 

latitude to states in evaluating these factors; specifically: 

1. Indirect energy impacts, such as the fact that the solid 

waste will substitute for fossil fuels otherwise burned, 

may be considered (see pages 7 and 9). 

2. Assessing the significance of additional controls based 

primarily on air quality impact is allowed under the 

policy (see page 11). 

3. The environmental consequences of the fact that solid 

waste must be buried if the incinerator is not permitted 

is a relevant solid waste disposal impact (see page 12). 

4. The localized economic impacts are relevant, such as 

the low tipping fee presently charged by Huntsville when 

compared to other parts of the country (see page 15). 

5. The guidance contains implications that BACT which.would 

preclude the operation of a unit would not be expected 

(see page 15). 

i / 
P.56 

Mr. Bruce P. Miller, Chief '- 2 - February 23, 1987 

Finally, the guidelines clearly envision different levels 

of control at identical units located in different places based 

on different circumstances and, in fact, different weighting of 

relevant factors and identical circumstances (see pages 1 and 4) . 

The high-lighted portion on page 4 also indicates that "state judgement 

and the federal emission standards are the foundations for the 

BACT determination". 

I appreciate your willingness to discuss this issue and would 

appreciate your thoughts on the contents of this letter and attachment. 

Sincerely, 

Lchard E. Grusnick, Chief 

Air Division 

REG:um 

Enclosure 
P.57 

s 

8.8 

CS5A" 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20460

 / 

JAN 4 1973 OPTICS or 

AIR ANO WASTE MANAGEMENT 

SUBJECT: Guidance for Determining BACT Under PSD 

FROM: David G. Hawkins, Assistant Administrator 

for Air, Noise, and Radiation 

TO: Regional Administrators, I-X 

yy 

The 1977 Clean Air Act amendments pertaining to the Prevention of 

Significant Deterioration (PSD) require that the determination of best 

available control technology (BACT) be performed on a case-by-case basis 

considering energy, environmental, and economic Impacts and other costs. 

The enclosed document provides guidance to assist you in determining 

BACT 1n the PSD review. This document has been circulated 1n draft 

form and reviewed by your staff. 

The purpose of the guideline 1s to provide the framework for a 

consistent approach In determining BACT. The guidance 1s rather general, 

focusing on the parameters which should be considered 1n the analysis 

supporting the proposed control system. Unfortunately, no specific 

criteria can be developed a priori, nor can quantitative factors relating 

f to the weighting and evaluation bf energy, environmental, and economic 

consideration be prescribed. However, consideration of the same set of 

parameters should contribute to more consistent decisions among the 

Regions. 

I recognize that the case-by-case BACT determination 1s a difficult 

task and one which may be resource Intensive. To minimize the resource 

requirements, the primary responslblity for defending the proposed control system must be placed on the source. The guidelines suggest a 

significant effort by the source to provide data and analysis to support 

a permit application. My office will continue to provide assistance for 

the engineering aspects of control technology selection through operation 

of the OAQPS new source review clearinghouse. 

Enclosure 

cc: Assistant Administrators and Office Directors 

Director, A1r and Hazardous Materials Division, Regions I - X 

Director, Facilities Technology Division, Region I I 

Director, Enforcement Division, Regions I-X 

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Office of Air Quality Planning and Standards 

U. S. Environmental Protection Agency 

8.8 

P.58 

GUIDELINES FOR DETERMINING 

BEST AVAILABLE CONTROL TECHNOLOGY (BACT) 

V**-r»:.?3 

. 

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OECEMBER 1978 

r 
8.8 

P.59 

I GUIDELINES FOR DETERMINING BEST AVAILABLE 

CONTROL TECHNOLOGY (BACT) 

Tec, 

f 

INTRODUCTION 

The 1977 Clean A1r Act Amendments establish more restrictive 

conditions for the approval of pre-construct1on permit applications under 

the Prevention of Significant Deterioration (PSD) program. One of the 

new requirements 1s for best available control technology (BACT) to be 

installed for all pollutants regulated under the Act. Under the revised 

Act, BACT 1s to be determined on a case-by-case basis rather than automatically applying an applicable Federal New Source Performance Standard 

(NSPS), as was the case under the previous regulation. Concem has been 

expressed that these determinations should be consistent from area to 

area.: In the context of case-by-case BACT, consistency does not necessarily mean that a new facility 1n one area will have an identical 

emission limit as the same type of facility 1n another area. Consistency means that a consistent approach 1s used In determining BACT and 

that the Impacts of alternative emission control systems are measured by 

the same set of parameters, although evaluation of specific parameters 

1s done on a case-by-case basis. 

PURPOSE 

This guideline 1s Intended for use by (1) EPA Regional Offices in 

determining BACT during the Interim period before the States adopt 

•Pollutants subject to National Ambient A1r Quality Standards, Standards 

of Performance for New Stationary Sources, National Emission Standards 

for Hazardous A1r Pollutants, and Emission Standards for Moving Sources. 

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8.8 

P.60 

V 

( 

are well established. In short, the BACT analysis should be held to a 

minimum with the depth of analysis being dependent on the difficulty of 

the decision. 

PHILOSOPHY OF BACT 

The primary purpose of BACT 1s to optimize consumption of PSD air 

quality increments thereby enlarging the potential for future economic 

growth without significantly degrading air quality. The Act places the 

responsibility of determining BACT with th* State once a PSD SIP revision 

1s approved. The BACT decision 1s to take Into account energy, environmental, and economic Impacts and other costs associated with application 

of alternative control systems. This case-by-case approach allows 

adoption of Improvements 1n emission control technology to become widespread 

more rapidly than would occur through the uniform Federal new source or 

hazardous emission standards. In setting the NSPS, for example, emission 

limits are selected which can reasonably be met by all new or modified 

sources 1n an Industrial category, even though some Individual sources 

are capable of lower emissions. Additionally, because of resource 

limitations 1n EPA, revision of new source standards must lag somewhat 

behind the evolution of new or improved technology. Accordingly, new or 

modified facilities in some source categories may be capable of achieving 

lower emission levels that NSPS without substantial economic impacts. 

The case-by-case BACT approach provides a mechanism for determining and 

applying the best technology in each Individual situation. Hence, NSPS 

and NESHAPS are Federal guidelines for BACT determinations and establish 

minimum acceptable control requirements for a BACT determination. 

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penalties associated with alternative control options as they apply 

to his processes. The permit application should contain the following 

elements relative to BACT: 

(1) Proposal of a control system representing BACT. BACT should 

address control of each emission point at a facility, Including fugitive process, fugitive dust, and stack emissions. Technology selection 

should consider application of flue gas treatment, fuel treatment, and 

processes or techniques which are Inherently low-polluting. In no 

circumstance should a system be proposed for any emission point unless 

1t is at least as stringent as the applicable SIP or Federal emission 

requirement (whichever 1s more stringent). In cases where technological or economic limitations on the application of measurement techniques 

would make the Imposition of an emission standard Infeasible, a design, 

operating, or equipment standard may be established. 

. (2) Presentation of alternative systems that could achieve a 

hiqher degree of emission control. For each pollutant, the BACT permit 

application should present control alternatives which have greater control 

capabilities than the system proposed as BACT and which have been used or 

proposed for the same or similar applications. In some cases, the BACT 

decision may require a trade-off of control among pollutants. That is, 

a technology may do slightly worse in controlling one pollutant, but do 

significantly better in controlling another air, water, or solid waste 

residual. Such alternatives should not be excluded from consideration, 

but 1n justifying BACT for a given pollutant only those alternatives 

which have greater control capabilities for that pollutant need be 

presented in the permit application. 

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P.62 

to be significant and well quantified. Indirect energy impacts include 

such_7mpacts as energy to produce raw materials for constructionjsfL 

control equipment, increased use of foreign oil, or increased oil use in 

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8.8 

I'.. 

specific energy, environmental, and economic impacts which may be addressed £"•... 

. - — . £v .^ 

in this impact analysjs and explains the data requirements for documenting [--".. 

. • i.. •, 

an^adverse impact. Each of the factors discussed below need not be t. •-

addressed in every permit application. Rather this guideline presents a | 

set of potential impacts any number of which may be addressed in a £ 

_-.-

permit application depending on the individual situation. For example, 

even though a control system may produce solid waste by-products, such 

impacts need not be presented in the PSD permit application unless the 

applicant wishes to use solid waste impact as an argument against selection £ 

of a particular control alternative as BACT. 

In general, the BACT analysis should focus on the direct (on-site) 

impacts of alternative control systems. Indirect energy or environmental 

impacts are not required but may be considered where such impacts are_found 

the utility grid. Indirect environmental impacts include such considerations as pollution at an off-site manufacturing facility which produces 

materials needed to construct or operate a proposed control system. 

Indirect impacts will generally not be considered, in the BACT review, \ 

s 

• 

since the complexity of consumption patterns in the economy makes those t 

impacts difficult to quantify. For example, since manufacturers purchase 

capital equipment and supplies from many suppliers, who in turn purchase 

goods from the other suppliers, accurate tracing of indirect impacts may not 

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8.8 

P.63 

in all cases, while, in other instances, factors which are not included 

here may be relevant to the BACT determination. The guideline does not 

address the evaluation of each factor nor the weighting of any factor 

relative to another. Such determinations should be made on a case-bycase basis by the permitting authority. For purposes of this discussion, 

terms such as "emission control system" or "BACT system" refer to design, 

equipment, or operating standards and non-polluting processes as well as 

flue gas control equipment. 

I. Energy Impact 

Energy impacts should address energy use associated with a control 

system and the direct effects of such energy use on the facility and the 

community. As noted earlier, indirect energy impacts (such as energy to 

produce raw materials for construction of control equipment) are not 

required but may be considered if the permitting authority determines, based 

on a showing by the applicant, that the impact is significant and_th_at 

the impact can be well quantified. Some specific considerations for J 

energy impacts are presented below. 

A. Energy Consumption 

The amount,- type (e.g., electric, coal, natural gas), and source 

of energy required by each alternative emission control system should 

be identified and compared to the quantities and types of energy required by the proposed BACT system. In analyzing for energy consumption, 

various alternatives can be compared in terms of a) energy consumption 

per unit of pollution removed (for example, Btu/ton hydrocarbon removed) 

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P.64 

11 

8.8 

II. Environmental Impact 

The net environmental impact associated with each alternative 

emission control system should be determined. Both beneficial impacts 

(e.g., reduced emissions attributed to a control system) and adverse 

impacts (e.g., exacerbation of another pollution problem through use of 

a control system) should be discussed and quantified. As pointed out 

above, indirect environmental impacts (such as pollution impacts at an 

off-site plant which manufacturers chemicals for use in pollution control 

equipment) normally need not be considered. The analysis should be 

presented in the form of the incremental impact of alternative control 

systems relative to the system proposed as BACT in the permit application. 

Some specific considerations are presented below; 

A. Air Pollution Impact 

The impact of air pollutants emitted from, a ga< 

fugitive emission source can be asse«»H term* nf 

ja< stream nr fl_ A 

either quanitv of j 

gmissions, modeled effects on air quality, or both. If aipplication of a 

control system directly removes or releases other air pollutants (or 

precursors to other air pollutants), then the pollutants affected and 

the impact of these emission changes should be identified. The analysis 

can consider any pollutant affecting local air quality including pollutants 

which are not currently regulated under the Act, but which may be of 

special concern locally. 

In the absence of a more systematic technique (e.g., market-type 

systems, etc.) for allocating PSD increments, BACT determinations are 

important for executing such allocations. PSD programs which depend on BACT 

determinations to implement the allocation of increments should project 

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13 

hazardous characteristics) which are significant with regard to potential 

surface water pollution or transport into and contamination of subsurface waters or aquifers should be considered. The relative effectiveness, hazard and opportunity for solid waste management options, 

such as sanitary landfill, incineration, and recycling, should be 

identified and discussed. 

D. Irreversible or Irretrievable Commitment of Resources 

The BACT decision may consider the extent to which the alternative 

emission control systems may involve a trade-off between short-term 

environmental gains at the expense of long-term environmental losses : 

and the extent to which the alternative systems may result 1n irreversible or Irretrievable commitment of resources (for example, use of 

scarce water resources). 

E. Other Environmental Impacts 

Incremental differences In noise levels, radiant heat, or dissipated static electrical energy should be considered where appropriate. 

III. Economic Impact 

This analysis should address the economic Impacts associated with 

the incremental costs of installing and operating alternative control 

systems above the economic impact associated with' the system proposed 

as BACT. The review should include a complete explanation of procedures for assessing economic impacts and any supporting data. As 

outlined below, economic considerations can address direct economic 

impacts on the firm and Impacts on local economic growth. 

A. Direct Economic Impacts on the Plant 

Direct economic impacts on the plant should be examined through :. 

evaluation of the following: 
a.8 

P.66 

* v 

t 

15 

2. Capital Availability 

Capital availability addresses the difficulty that some sources 

may face in financing alternative control systems. Proof of such 

claims should be fully documented. 

B. Local Economic Impacts 

Local economic impacts address the economic feasibility of alternat1ve jACT_requirements and the impact of the production decisions 

of the firm 1n response to alternative levels of control. For example, 

a BACT alternative may alter the economics of a project to the point 

where the decision would be made to cancel the construction or expan 

sion of a facility, to relocate a plant, to reduce the scale of opera- fe 

tion, or to change the production mix. The localeconomlc impacts of ^\ 

such^decisions should be assessed 1n terms of local employment effects / 

1ncTuid1ng_ number of jot?;, dollars paid in.salaries, and changes In / 

employee skiVI level_s_reguired. The guideline does not Imply that the 4 

BACT decision should force new projects to the brink of cancellation. \ 

The BACT decision must be based on sound judgment, balancing environment I 

benefits with energy, economic, and other Impacts. ^^ 

Local economic impacts also can address the effect of various BACT 

alternatives on air quality increment consumption and the subsequent 

impact on future growth potential 1n the surrounding area. The BACT 

decision should reflect policy decisions to conserve the available air 

quality increment for future growth. 

IV. Other Costs 

Other costs associated with alternative emission control systems 

may be considered where appropriate. 

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