William R. Barnard

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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_at_mactec.com
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Background

• Whos Affected?
• Whats the Timeline?
• Whats 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

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Whos 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 gt 250 MMBtu/hr,
  Kraft mill)
• PTE gt 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

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26 BART Categories

1. Fossil Fuel-fired Steam Electric Plants (250
   MMBTU heat input per hour)
2. Coal Cleaning Plants (thermal dryers)
3. Kraft Pulp Mills
4. Portland Cement Plants
5. Primary Zinc Smelters
6. Iron and Steel Mill Plants
7. Primary Aluminum Ore Reduction Plants
8. Primary Copper Smelters
9. Municipal Incinerators (gt 250 T refuse per day)
10. Hydrofluoric, Sulfuric, and Nitric Acid Plants
11. Petroleum Refineries
12. Lime Plants
13. Phosphate Rock Processing Plants

1. Coke Oven Batteries
2. Sulfur Recovery Plants
3. Carbon Black Plants (furnace process)
4. Primary Lead Smelters
5. Fuel Conversion Plants
6. Sintering Plants
7. Secondary Metal Production Facilities
8. Chemical Process Plants
9. Fossil Fuel-Fired Boilers C5 (250 MMBTU heat
   input per hour)
10. Petroleum Storage and Transfer Facilities
    (capacity gt 300,000 barrels)
11. Taconite Ore Processing Plants
12. Glass Fiber Processing Plants
13. Charcoal Production Facilities

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Class I Federal Areas
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What Pollutants Must be Considered?

• SO2
• NOx
• Particulate Matter
• DONT USE TSP! Use PM10 or PM2.5 (or both)
• NH3 and VOC do not necessarily have to be
  considered

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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
  EPAs 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

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Whats 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

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Whats 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

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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.

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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!!

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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.

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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

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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

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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/Str
  ategies/Final20Control20Measures.pdf
• http//bronze.nescaum.org/committees/haze/BART_Con
  trol_Assessment.pdf
• Control Equipment vendors

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Step 1 (contd)

• 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

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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

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Step 2 Determine Whether Technically Feasible
(contd)

• 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

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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)

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Step 3 (contd)

• Evaluation across wide range of emission levels
• Dont 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

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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

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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

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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

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Cost Effectiveness Calculations

• Average
• Incremental

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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

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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
• Dont 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

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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

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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

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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 EPAs 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

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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

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What are the Gotchas?

• You Dont 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 dont!
• You Dont 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

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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 wont 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 havent 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