William R. Barnard MACTEC Engineering and Consulting, Inc. 404 SW 140 th Terrace

1. Best Available Retrofit Technology (BART) Engineering Analysis for Non-EGU Sources William R. Barnard MACTEC Engineering and Consulting, Inc. 404 SW 140th Terrace Newberry, FL 32669-3000 wrbarnard@mactec.com

2. Yosemite National Park Grand Canyon National Park

3. Background • Who’s Affected? • What’s the Timeline? • What’s Expected? • Is There an Alternative? • What Guidelines are Available? • How Do I Conduct a Case-by-Case BART? • Who Performs the Analysis? • What Are the Steps Involved in the Engineering Analysis? • What Happens Next? • What are the “gotchas” ? • Suggestions/Tips

4. Who’s Affected? • Only sources that are BART Eligible may be Subject to BART • BART Eligibility is determined by: • Began operation after 8/7/62 but before 8/7/77 • Source falls into one of 26 categories • (e.g., industrial/utility boilers > 250 MMBtu/hr, Kraft mill) • PTE > 250 tpy of any pollutant contributing to regional haze • If you are Eligible are you Subject? • ONLY if the BART-eligible source emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area. All such sources are subject to BART. • Exemption: BART eligible SO2 and NOx sources emitting less than 40 tpy or 15 tpy PM10

5. Fossil Fuel-fired Steam Electric Plants (250 MMBTU heat input per hour) Coal Cleaning Plants (thermal dryers) Kraft Pulp Mills Portland Cement Plants Primary Zinc Smelters Iron and Steel Mill Plants Primary Aluminum Ore Reduction Plants Primary Copper Smelters Municipal Incinerators (> 250 T refuse per day) Hydrofluoric, Sulfuric, and Nitric Acid Plants Petroleum Refineries Lime Plants Phosphate Rock Processing Plants 26 BART Categories • Coke Oven Batteries • Sulfur Recovery Plants • Carbon Black Plants (furnace process) • Primary Lead Smelters • Fuel Conversion Plants • Sintering Plants • Secondary Metal Production Facilities • Chemical Process Plants • Fossil Fuel-Fired Boilers C5 (250 MMBTU heat input per hour) • Petroleum Storage and Transfer Facilities (capacity > 300,000 barrels) • Taconite Ore Processing Plants • Glass Fiber Processing Plants • Charcoal Production Facilities

6. Class I Federal Areas

7. What Pollutants Must be Considered? • SO2 • NOx • Particulate Matter • DON’T USE TSP! Use PM10 or PM2.5 (or both) • NH3 and VOC do not necessarily have to be considered

8. What Techniques Can Be Used to Determine Sources Subject to BART? • Determine threshold for causing or contributing to visibility impairment • Causes: Single source is responsible for a 1 deciview change in visibility • Contributes: Single source not higher than 0.5 deciview • 3 options for determining whether or not source is subject to BART: • Individual Source Attribution Approach – dispersion modeling • CALPUFF • Use Of Model Plants • Can use modeling analysis of representative plants to reflect groupings of specific sources • Establish limits and distances from Class I areas that would allow opt out • Less than 500 tons of SO2 and NOx (or combined SO2 and NOx) if more than 50 Km from Class I area or less than 1000 tons if more than 100 Km from Class I can be automatically exempted based on EPA’s modeling • Cumulative modeling to Show that No Sources in a State are Subject to BART • Must submit to EPA a demonstration (modeling) that emissions from BART-eligible sources within State considered together do not cause or contribute to any visibility impairment in a Class I area • Done on pollutant-by-pollutant basis or lumping all pollutants together • Can use either CALPUFF or photochemical grid modeling

9. What’s the Timeline? • Each State must submit, for the entire State, an implementation plan (SIP) for regional haze no later than December 17, 2007. • Must include the elements of BART controls program including emission limits representing BART • States may establish design, equipment, work practice or other operational standards when limitations on measurement technologies make emission standards infeasible. • Compliance demonstration required no later than 5 years after approved SIP

10. What’s Expected? • Sources Subject to BART must have an analysis to determine: • the best system of continuous emission control technology available and associated emission reductions achievable for each BART-eligible source that is subject to BART within the State. • Analysis encompasses: • The technology available • The costs of compliance • The energy and nonair quality environmental impacts of compliance • Any pollution control equipment in use at the source • The remaining useful life of the source • The degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology • Steps 1-5 are the engineering analysis

11. Is There an Alternative? • Yes – Emissions Trading • Alternative to BART must: • Show that distribution of emissions are not substantially different than under BART; • The alternative measure results in greater emission reductions • If emissions distribution is significantly different then the State must conduct modeling to show visibility between BART and trading program for each impacted Class I area for worst and best 20% days. Greater reasonable progress (than BART) is demonstrated if both the following can be shown: • Visibility does not decline in any Class I area • There is an overall improvement in visibility, determined by comparing the average differences between BART and the alternative over all affected Class I areas.

12. Alternative for EGUs • CAIR – If the State opts to participate in the CAIR cap-and-trade program, then BART-eligible EGUs do not have to install, operate and maintain BART controls. • CAIR is “good enough” for BART • ONLY APPLIES TO EGUs!!

13. What Guidelines Are Available? • Original Guidelines Proposed by EPA - 7/20/01 • Remanded by DC Circuit Court of Appeals - 5/24/02 • Latest Guidelines released on 6/24/05 • Guidelines are only guidelines for EGUs • Not required to use this process for Non-EGUs! “States must follow the guidelines in making BART determinations on a source-by-source basis for 750 megawatt (MW) power plants but are not required to use the process in the guidelines when making BART determinations for other types of sources.”

14. How Do I Conduct A Case-by-Case BART Analysis? • Step 1: Identify all available retrofit emission control techniques. • Step 2: Determine whether the options identified in Step 1 are technically feasible. • Step 3: Evaluate technically feasible alternatives. • Step 4: Calculate BART impacts – 2 parts • Part 1: Determine any existing controls at unit, estimate the costs of control, determine cost effectiveness, calculate average cost effectiveness, calculate baseline emissions, and calculate incremental cost effectiveness • Part 2: Determine energy impacts, non-air quality environmental impacts, and remaining useful life • Step 5: Determine visibility impacts

15. Who Performs the Analysis? • States may do it themselves or • States have the authority to require source owners to assume part of the analytical burden or • Data collection, analysis, and rule development may be performed by RPOs for adoption within each SIP/TIP or • Combination of all of the above

16. Step 1: Identify All Available Retrofit Emission Control Techniques • Sources of information • RACT/BACT/LAER Clearinghouse – EPA http://www.epa.gov/ttn/catc/rblc/htm/welcome.html • AirControlNet – EPA http://www.epa.gov/ttnecas1/AirControlNET.htm • Controls identified for BACT/LAER/NSPS/MACT control programs • Many VOC and PM sources are well controlled if they are subject to MACT – MACT is likely sufficient for these sources UNLESS newer controls have come on line since MACT requirements • Similarly for PSD/NSR determinations. However NSPS demonstrations from 70s and 80s not thought to be considered “best” • Internet – including non-U.S. techniques • Work by other RPOs/States • http://www.ladco.org/reports/rpo/MWRPOprojects/Strategies/Final%20Control%20Measures.pdf • http://bronze.nescaum.org/committees/haze/BART_Control_Assessment.pdf • Control Equipment vendors

17. Step 1: (cont’d) • Control alternatives can include not only existing controls but technologies applied to similar sources and gas streams • Pollution prevention alternatives • Improvements to existing controls • Controls considered should be applied to full scale operations • Where NSPS standard (current) exists that level of control should be considered as an option • BART is NOT considered a requirement for redesign • If existing controls in place represent the most stringent controls available, no further BART analysis required (as long as Fed enforceable) • Controls in place MUST have all possible improvements to ensure that they are the most stringent

18. Step 2: Determine Whether Step 1 Options Are Technically Feasible • Must apply the “availability” and “applicability” test • Technologies have been installed and operated successfully for type of source and • Technology could be applied to source being reviewed • A technology that is available and applicable is considered technically feasible

19. Step 2: Determine Whether Technically Feasible (cont’d) • Technology is available if it has reached the licensing and commercial demonstration stage • It is not considered available if it is in the concept, research and patenting, or bench, laboratory or pilot scale testing stages • It IS considered available if it is a new control that has reached the appropriate stage (e.g., commercial demonstration) before the public comment period has closed • Technology is applicable if it has been used on the same or similar source types • If no showing of similarity available, evaluate feasibility by examining physical/chemical characteristics of the stream and comparing to sources where technology has been applied • What type demonstration is required to show infeasibility? • Commercially unavailable • Characteristics of stream prohibit use • Unresolved technical issues (size/space constraints, reliability issues, adverse side effects, etc.) but NOT cost associated with these

20. Step 3: Evaluate Technically Feasible Alternatives • Two key issues • Express degree of control using metric that allows “apples to apples” comparison • Give appropriate treatment to control techniques that can be used over wide range of emission levels • Metrics: • Lbs of SO2 per MMBTu • Lbs of NOx per ton of product (e.g., cement)

21. Step 3: (cont’d) • Evaluation across wide range of emission levels • Don’t have to evaluate all levels of control possible from technology – only the most stringent • But you can evaluate other levels as long as most stringent is considered • Special circumstances can be considered but should be well documented • Consideration should always be given to improving performance of existing devices

22. Step 4: Impacts Analysis • 4 components: • Costs of compliance • Energy impacts • Non-air quality environmental impacts • Remaining useful life • Each evaluation should include supporting information • Should include both beneficial and adverse impacts • Focus should be on direct impacts

23. Estimating Control Costs • ID Emission Units and design parameters • Develop costs based on design parameters • Design parameters should be documented • Design parameter sources: • Vendors, NSPS BIDs, guideline documents, EPA cost manuals, trade publications, test data, internet. • Develop and document cost estimates • Capital and Annual costs • Preferred cost sources: • EPA OAQPS Control Cost Manual • Vendor bids/quotes • Cost analyses should take into account any site-specific design issues

24. Cost Effectiveness • Costs should show Cost Effectiveness • Effectiveness is measured in terms of tons of pollutant removed based on annualized control costs • 2 types of cost effectiveness evaluations recommended: • Average • Incremental

25. Cost Effectiveness Calculations • Average • Incremental

26. Incremental Cost – Least Cost Envelope • Incremental costs should focus on “dominant” options • Identify dominant options by graphing annual costs vs emission reductions and developing “least cost envelope” • The greater the number of controls the more weight should be given to incremental costs

27. Other Cost Considerations • Document any unusual circumstances that cause costs to exceed recent similar retrofits • e.g., large amounts of water for wet scrubbers in an arid region • Don’t focus on incomplete results or partial calculations • e.g., large capital costs alone would not preclude selection of a control measure if large emission reductions were also projected

28. Energy Impacts • Determine energy benefits and penalties • Should be quantified to the extent possible • Impacts can typically be factored into the cost analysis since most impacts can be quantified in terms of additional cost or income • Energy use in and of itself does not disqualify a technology • Should only consider DIRECT energy consumption not indirect impacts • e.g., energy used for raw materials used for construction of control equipment cannot be considered UNLESS it is unusual or signficant • Analysis CAN address the impact of locally scarce fuels • Can consider whether there is a relative difference between alternatives regarding use of local vs regional coal supplies • e.g., if two options have same basic control level but using a regional coal instead of a local coal would cause local unemployment

29. Non-Air Quality Environmental Impacts • Types to consider: • Solid/hazardous waste • Land use • Water supply and discharge • e.g., scrubber discharge or use of locally scarce resources such as water • Noise/heat/static electric discharge • Atmospheric deposition • If you select the most stringent control alternative you do not need to do analysis for entire list of technologies • Analysis only needed for controls with significant or unusual impacts or if they have the potential to eliminate a more stringent control • Start analysis with qualitative or semi-quantitative screening • Follow with quantification of mass and composition of any discharges to the extent possible

30. Remaining Useful Life • Typically treated in cost analysis • Short remaining useful life would affect the annualized costs of retrofits • Only affects BART process where remaining useful life is less than EPA’s Control Cost Manual time periods for amortization – use the shorter period when this applies • Remaining useful life is the difference between the time the controls will be put in place and the time of permanent shut down of facility • Shut down date must be Federally or State enforceable • Operational flexibility is allowed (operation beyond anticipated shut down date due to market conditions) BUT operator must still be consistent with requirement to install BART within 5 years • May require a reassessment of the level of controls required for BART • BART emission limitation may include the more stringent level of control as a contingency to the source operating more than 5 years after EPA approves SIP • Source would NOT be allowed to operate after the 5 year mark without controls

31. What Happens Next? • Assess visibility impacts of BART options • State or source? • CALPUFF is preferred model • Use results coupled with engineering analysis to select “best” control method • Start with assumption that most stringent alternative is selected • Consider other alternatives • Consider unusual circumstances • Make selection

32. What are the “Gotcha’s”? • You Don’t Have to Use These Guidelines for Non-EGUs – Or Do You? • No, But you better be able to document and justify your procedure if you don’t! • You Don’t Have to Consider NH3 or VOC – Or Do You? • Only if they are important in visibility degradation • could be important for some potential BART sources like chemical manufacturing and petroleum refineries • You may want to look at NH3 and VOC sources for opt out under either the Cumulative modeling or Model Plant scenarios • Cost assumptions and information on similar retrofits for Non-EGUs will be much more difficult to find than for EGUs • Vendors are your friends. They can help identify what technologies may not work at some Non-EGUs due to stream characteristics • Inventories will likely NOT tell you what the existing controls/emissions are • Work with LADCO showed that not one single BART source evaluated in preliminary engineering analysis listed any controls in the inventory, yet several of the units had controls especially for PM. Permit records will need to be reviewed • Emissions were substantially different/wrong in some cases

33. Suggestions • States/RPOs may want to make Non-EGU BART engineering analysis a partnership with facilities • States/RPOs develop preliminary BART engineering analysis • Have facilities evaluate whether there are any site specific issues that make preferred technology “infeasible” • Determine who will do the modeling of visibility impacts of proposed or optional technologies • Work with vendors early to determine what types of stream characteristics, scaling or other issues will likely affect use of certain technologies • Early work with LADCO has suggested that some proven technologies won’t scale – at least for now • These technologies may scale when the financial incentives are there to make them work for a number of sources • Start Early! • If you haven’t already start looking at potential technologies for controlling different types of sources, start now! • Piggyback on the work of other States/RPOs • MARAMA, LADCO and VISTAS have all taken preliminary steps in their identification of controls, costs and technologies