MEMO

TO:	James Brooks, Bureau Director, Bureau of Air Quality

FROM:	Marc Cone, Air Licensing Section; Tom Downs, Meteorology Section;
Jeff Crawford, Air Planning Section

DATE:	June 12, 2009

SUBJ:	BART Summary

************************************************************************

BART SUMMARY

BACKGROUND

The federal requirements that states must meet to achieve national
visibility goals are contained in the “Regional Haze Rule”.  These
regulations were adopted on July 1, 1999, and went into effect on August
30, 1999.  On June 15, 2005, EPA finalized the rule addressing a Court
remand.

The principle goal is: “Congress hereby declares as a national goal
the prevention of any future, and the remedying of any existing,
impairment of visibility in mandatory Class I Federal areas which
impairment results from man-made air pollution.”

Maine has three Class I areas: 1) Acadia National Park; 2) Moosehorn
National Wildlife Refuge Wilderness Area; and 3) Roosevelt Campobello
International Park

In consultation with the states and tribes, EPA designated five Regional
Planning Organizations (RPO) to assist with the coordination and
cooperation needed to address the haze issue.  The Mid-Atlantic /
Northeast states, including the District of Columbia, formed the
Mid-Atlantic / Northeast Visibility Union (MANE-VU)

Among the required elements of the SIPs, states must include
determinations of Best Available Retrofit Technology (BART) and long
term strategies to ensure that reasonable progress is being made to meet
the national goal by 2064.

The regional haze SIPs were due to EPA by December 17, 2007.

BEST AVAILABLE RETROFIT TECHNOLOGY (BART)

The Best Available Retrofit Technology (BART) requirement of Section
169A of the Clean Air Act (42 U.S.C.§7491(b)(2)(A)) and implementing
rules (40 C.F.R. Part 51, Appendix Y) are intended to reduce visibility
impairing pollutants emitted from existing stationary sources which were
grandfathered from the New Source Review (NSR). 

The visibility impairing pollutants are defined by the EPA as sulfur
dioxide (SO2), oxides of nitrogen (NOx) and particles with an
aerodynamic diameter less than or equal to 10 and 2.5 μm (i.e., PM10
and PM2.5, respectively). 

The BART requirements apply to existing facilities having any of 26
types of stationary sources which began operation between August 7, 1962
and August 7, 1977, with a cumulative potential to emit 250 tons per
year or more of any single visibility impairing pollutant and may
reasonably be anticipated to cause or contribute to any visibility
impairment in a Class I area.

Once the SIP is approved by the EPA, the BART facility has up to five
years to install the appropriate controls and comply with the
established emission standards.  Maine is requiring sources subject to
BART to install, operate and maintain BART rather than implement an
emissions trading program or other alternative measure.

In June 2005, EPA adopted the final BART rule.  The BART rule requires
states/tribes to develop an inventory of sources within each state or
tribal jurisdiction that would be eligible for controls. 

The federal BART rule requires that, for each BART-eligible source
within the state, any BART determination must be based on an analysis of
the best system of continuous emission control technology available and
the associated emission reductions achievable.  In addition to
considering available technologies, this analysis must evaluate five
specific factors for each source (better known as the Five-Factor
Analysis):

The costs of compliance,

The energy and non-air quality environmental impacts of compliance,

Any existing pollution control technology in use at the source,

The remaining useful life of the source, and

The degree of visibility improvement which may reasonably be anticipated
from the use of BART.

BART STATUS

In an effort to establish a consistent BART determination for all
BART-eligible Maine sources and remove any existing statutory
limitations in regulating sulfur dioxide as part of a BART
determination, in 2007 the Maine Legislature enacted enabling
legislation establishing deadlines and control requirements for BART
eligible units in Maine.  38 MRSA §603-A, sub-§8 states:

“8.  Best available retrofit technology or BART requirements.  For
those BART eligible units determined by the department to need
additional sulfur air pollution controls to improve visibility, the
controls must: 

A.  Be installed and operational no later than January 1, 2013; and

B.  Either: 

(1) Require the use of sulfur oil having 1% or less of sulfur by weight;
or

(2) Be equivalent to a 50% reduction in sulfur emissions from a BART
eligible unit based on a BART eligible unit source emission baseline
determined by the department under 40 Code of Federal Regulations,
Section 51.308 (d)(3)(iii)(2006) and 40 Code of Federal Regulations,
Section 51 Appendix Y (2006).”

Pursuant to the above statute the Department issued air emission
licenses implementing the prescribed BART requirements.

The draft Regional Haze State Implementation Plan (SIP), including the
BART determinations, was submitted to EPA and federal land managers in
early 2009.

EPA and the Federal Land Managers provided the Department with comments
on the draft SIP; and both indicated the state’s legislation adopted
in 2007 and the BART license amendments did not fully meet the federal
BART rule requirements of the five factor analysis, and that the
proposed Maine regional haze SIP submittal did not address all of the
regional haze pollutants.

The Department is currently working with the BART-eligible sources, EPA,
and the federal land mangers to ensure completion of an approvable
Five-Factor Analysis.  

FIVE FACTOR BART ANALYSIS

The first step is identifying the BART eligible sources:

The Department has identified 25 units at 11 sources as being BART
eligible (Appendix A).

The next step is determining if any source has the option to accept
federally enforceable emission restriction limits in their air emission
license to stay below 250 tons per year of SOx, NOx, or PM and thus no
longer be a BART-eligible source. The Department expects two sources to
utilize this option.

Every source that does not accept a federally enforceable emission
limit must perform the first four steps (engineering analyses) of the
Five Factor Analysis.

The first part of the analysis is a technical feasibility analysis
considering existing controls and possible controls.  Guidance is found
in 40 CFR Part 51 Appendix Y, Section IV.  Generally, if possible
controls versus existing controls are minimally better at controlling
emissions and the impacts of the units are relatively small as
determined by the NESCAUM modeling (Appendix B) with the existing
controls, BART can be determined to be the existing controls and the
analysis would be complete.  Sources with less than 0.1 deciview impact
on Class 1 areas are presumed to have small impacts.  In general, if
there are emission reduction strategies for units that have minimal
existing controls then possible further emission reduction control
options are modeled to determine the most cost effective visibility
emission reduction strategy that will be determined to be BART.

Using the first four factors plus the NESCAUM modeling the Department
has preliminarily determined that 18 of the 25 BART-eligible units have
existing controls that should satisfy BART technology requirements. 
These units would not be subject to the fifth factor refined modeling
analysis.  

The remaining sources must complete the fifth factor of the Five Factor
Analysis as detailed in the following table:

Modeling Protocol Options

1 YEAR CALPUFF ANALYSIS OPTION	3 YEAR CALPUFF ANALYSIS OPTION

SUBMIT A CALPUFF/CALMET/CALPOST MODELING PROTOCOL FOR REVIEW with
detailed discussions of the following elements:

Model version

Model switches and procedures

CALPUFF and CALGRID modeling domains

Proposed receptors

Meteorological data inputs

Geophysical data inputs

Emission data inputs

CALMET METEOROLOGICAL DATA SET

Use 1 year of MM5 data, with mandatory observational data (Mass DEP has
2002 data currently processed in this manner) – EPA and FLMs have
indicated they will accept this option.	Use 3 years of MM5 data with
observational data - highly recommended by both USEPA and FLMs. 

PRE-CONTROL EMISSION INPUTS

Choose highest 24-hour emission rate during normal operating conditions
(i.e., excluding malfunctions, startups/shutdowns, etc.)

Choose highest 24-hour emission rate from 3 years of emissions data
using years representative of current existing controls

Examine emissions on a pollutant-by-pollutant basis for each BART
eligible unit (highest 24-hour emission rate could potentially be from
different days for different pollutants)



MODEL RUNS

For each BART-eligible unit, run CALPUFF at pre-control and all
post-control emission rates according to the accepted methodology in the
CALPUFF modeling protocol

Calculate, for each receptor, the change in deciview compared against
20% best visibility conditions (use new IMPROVE algorithm [CALPOST
Version 6.221 FLAG 2008 option (www.src.com)])	Calculate, for each
receptor, the change in deciview compared against natural visibility
conditions (use new IMPROVE algorithm [CALPOST Version 6.221 FLAG 2008
option (www.src.com)])

Use the highest daily predicted change-in-deciview for each
pre/post-control run	Use the 8th highest daily predicted
change-in-deciview in each year for each pre/post-control run

FINAL SUBMITTAL OF IMPACT ANALYSES

Submit the final modeling protocol and all model input, output and
diagnostic files 

Develop a chart (or charts) displaying the following for each of the
alternatives: 

1 - Expected emission rate (tons per year, pounds per hour)

2- Emissions performance level (e.g. percent pollutant removed,
emissions per unit product,

     lb/MMBtu, ppm)

3 - Expected emissions reductions (tons per year)

4 - Costs of compliance - total annualized costs ($), cost effectiveness
($/ton), and especially

      a cost-effectiveness measure ($/deciview)

5 - Modeled visibility impacts

6 - Compare results of potential BART controls



EPA FINDING OF FAILURE TO SUBMIT SIP

On January 9, 2009 EPA signed a Federal Register notice making a finding
of failure to submit all or a portion of their regional haze SIPs for 37
states, DC, and the Virgin Islands.  Maine is one of 34 states which
failed to submit SIPs that satisfy the basic program elements.

The FR notice initiates a 2-year deadline for EPA to issue a Federal
Implementation Plan (FIP); the 2-year period is referred to as the
“FIP clock”.  The FIP will provide the basic program requirements
for each state that has not completed an approved plan of their own by
January 15, 2011.  EPA must approve the State’s plan before the FIP
clock is turned off.  This notice does not initiate sanctions.

The Department expects to submit a complete regional haze plan well
before the FIP deadline.  Since EPA will need a number of months to
complete the review and approval of the regional haze plan, Maine will
need to submit the completed plan well in advance of the January 15,
2011 FIP deadline.  The Department is currently working with the Federal
Land Managers and EPA to address concerns with its preliminary draft
Regional Haze Plan, and expects to hold a public hearing and submit its
final Regional Haze Plan by January 31, 2010.  We believe that this
schedule will provide sufficient time for a complete review and approval
of the Maine SIP, including BART analyses.  Please submit your analyses
to the Department by September 15, 2009.

BART REFERENCES

“Five Factor Analysis of BART-Eligible Sources, Survey of Options for
Conducting BART Determinations”, June 1, 2007, NESCAUM

Informal guidance from EPA on Regional Haze Questions/Answers, August
25, 2006

“BART Resource Guide”, August 23, 2006, NESCAUM

“Assessment of Control Technology Options for BART-Eligible Sources,
Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and
Pulp Facilities”, March 2005, NESCAUM

MANE-VU Board decided in June 2004 that a BART determination would be
made for all sources, without exception.

“A Basis of Control for BART-Eligible Sources”, July 24, 2001,
NESCAUM



			Appendix A 

BART Eligible Sources

Wyman Station		Boiler #3 (expect full 5 factor analysis)

				Boiler #4 (expect full 5 factor analysis)

Domtar Industries		Power Boiler #9 

				Lime Kiln

			

Dragon Products		Kiln (expect full 5 factor analysis)

Red Shield Acquisition 	#4 Recovery Boiler

				Lime Kiln

Verso Paper Bucksport	Boiler #5 (expect 250 TPY restriction)

SAPPI Somerset		Lime Kiln

				Recovery Boiler

				Smelt Tanks #1 and #2

Verso Paper Jay		Power Boilers #1 and #2 (expect full 5 factor analysis)

				Waste Fuel Incinerator

				Recovery Boilers #1 and #2

				Smelt Tanks #1 and #2 

				Lime Kilns A and B

				Flash Dryer 

Katahdin Paper Millinocket	Power Boiler #4 (expect 250 TPY restriction)

Lincoln Paper and Tissue 	Recovery Boiler #2

Rumford Paper Company 	Power Boiler #5

APPENDIX B:  NESCAUM BART-ELIGIBLE SOURCE MODELING RESULTS

Facility Name	Stack Name	NWS CALPUFF	MM5 CALPUFF

 	 	Total	SO4	NO3	PM10	Total	SO4	NO3	PM10

 	 	24-hr dv impact	24-hr dv impact

Wyman Station	Boiler_4	0.1423	0.1276	0.0334	0.0010	0.4749	0.3846	0.1072
0.0005

Wyman Station	Boiler_3	0.2212	0.1715	0.0704	0.0004	0.3049	0.2545	0.0508
0.0014

Domtar Ind.	#9_Power_Boiler	1.3630	0.2828	0.7988	1.3134	1.6506	0.1815
0.7279	1.3717

Domtar Ind.	Lime_Kiln	0.5296	0.0559	0.4309	0.1207	0.4589	0.0427	0.3820
0.1048

Dragon Products	Kiln	2.0155	0.2434	1.7614	0.0604	1.8626	0.3208	1.7234
0.0413

Red Shield Acquisition, Old Town	#4_Recovery_Boiler	0.2425	0.0634	0.1633
0.0173	0.2631	0.0424	0.2070	0.0391

Red Shield Acquisition, Old Town	Lime_Kiln	0.0851	0.0171	0.0433	0.0278
0.1338	0.0138	0.0855	0.0463

Verso, Bucksport	Boiler_#5	0.0543	0.0260	0.0267	0.0021	0.1591	0.0817
0.0721	0.0098

SAPPI Somerset	Recovery_Boiler	0.2159	0.0151	0.1971	0.0087	0.4421	0.0179
0.4168	0.0158

SAPPI Somerset	Smelt_Tanks_#1_and_#2	0.0108	0.0034	0.0000	0.0095	0.0000
0.0000	0.0000	0.0000

SAPPI Somerset	Lime_Kiln	0.0380	0.0270	0.0105	0.0012	0.0651	0.0455
0.0187	0.0010

Verso, Jay	Power_Boiler_#1	0.6948	0.5720	0.1235	0.0094	1.7631	1.2176
0.5867	0.0290

Verso, Jay	Power_Boiler_#2	0.7223	0.5948	0.1287	0.0095	1.8289	1.2646
0.6105	0.0293

Verso, Jay	Waste_Fuel_Inc_	0.4256	0.0036	0.3651	0.0591	0.4956	0.0064
0.4544	0.0367

Verso, Jay	Recovery_Boiler_#1_and_#2	0.1101	0.0454	0.0598	0.0078	0.3856
0.0952	0.2723	0.0215

Verso, Jay	Smelt_Tank_#1	0.0139	0.0002	0.0000	0.0137	0.0122	0.0002
0.0000	0.0120

Verso, Jay	Smelt_Tank_#2	0.0129	0.0004	0.0000	0.0125	0.0135	0.0006
0.0000	0.0129

Verso, Jay	Lime_Kiln_A	0.0441	0.0001	0.0273	0.0167	0.0457	0.0004	0.0337
0.0123

Verso, Jay	Lime_Kiln_B	0.0296	0.0001	0.0197	0.0098	0.0293	0.0004	0.0228
0.0062

Verso, Jay	Flash_Dryer	0.0222	0.0044	0.0173	0.0005	0.0252	0.0097	0.0175
0.0003

Katahdin Paper Millinocket	PB_#4	0.8293	0.6630	0.1569	0.0210	0.4458
0.3832	0.1164	0.0216

Lincoln Paper and Tissue	Recovery_Boiler_#2	0.1151	0.0141	0.0806	0.0224
0.1200	0.0073	0.0882	0.0322

Lincoln Paper and Tissue	Boiler_#6	0.0182	0.0139	0.0047	0.0004	0.0119
0.0075	0.0051	0.0006

Rumford Paper	PB_#5	0.0369	0.0039	0.0327	0.0026	0.1025	0.0108	0.0897
0.0020







	> 0.1 dv TOTAL and a pollutant	> 0.1 dv TOTAL only



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