The BART Process
by
Kathy Kaufman
and
Joe Kordzi
September 1, 2005
EPA Region 6
Applicability
 The CAA requires use of the BART
Guidelines for powerplants 750 MW or
greater.
 States are encouraged to use the BART
Guidelines for all source categories.
Part 1 - Identify the BART-eligible Sources
START
Is the source BART Eligible?
Part 1 - Identify the BART-eligible Sources
Does the PLANT
contain emissions units
in one or more of the 26
source categories?
No
Source is not
BART-eligible
Yes
Next Slide
The 26 BART Categories
1) Fossil-fuel fired steam electric plants > 250 million BTU/hr heat input
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 capable of charging > 250 tons of refuse per day
10) Hydrofluoric, sulfuric, and nitric acid plants
11) Petroleum refineries
12) Lime plants
13) Phosphate rock processing plants
The 26 BART Categories
14. Coke oven batteries
15. Sulfur recovery plants
16. Carbon black plants (furnace process)
17. Primary lead smelters
18. Fuel conversion plants
19. Sintering plants
20. Secondary metal production facilities
21. Chemical process plants
22. Fossil-fuel boilers of more than 250 million BTUs per hour heat input
23. Petroleum storage/ transfer facilities exceeding 300,000 barrels
24. Taconite ore processing facilities
25. Glass fiber processing plants
26. Charcoal production facilities
Part 1 - Identify the BART-eligible Sources
Sources in operation before
1962 but reconstructed
during 1962 to 1977 are
treated as new sources as of
the time of reconstruction.
“In operation” is defined as
engaged in activity related
to the primary design
function of the source.
For each UNIT
Yes
“in existence” means the owner/
operator obtained all necessary
approvals/permits and either has (1)
begun, or caused to begin on-site
construction of the facility, or (2)
executed binding agreements/contracts
for construction.
In existence on
August 7, 1977?
and
Began operation after
August 7, 1962?
Yes
A modification does
not change a unit's
construction date for
the purpose of
BART eligibility.
No
Source is not
BART-eligible
Next Slide
Part 1 - Identify the BART-eligible Sources
Visibility-impairing
pollutants include SO2,
NOx, PM, and optionally
VOCs and NH3.
"All units" are those
within the “contiguous or
adjacent” boundary, and
under common control.
Yes
Are the total
potential emissions of any
visibility impairing pollutant,
summed across all units,
> = 250 tpy?
“Potential to emit” is
the maximum capacity
of a stationary source
to emit a pollutant
under its physical and
operational design.
Yes
The collection of
emissions units is a
BART-eligible source.
The source is subject to a
BART review for SO2,
NOX, and PM.
Not pollutant specific at
this point.
No
Next Slide
Source is not
BART-eligible
Part 1 - Identify the BART-eligible Sources
Example: A stationary source has two emissions units, with the
following potential emissions:
Emissions unit A
Emissions unit B
200 tpy SO2
100 tpy SO2
150 tpy NOX
75 tpy NOX
25 tpy PM
10 tpy PM
Potential emissions of SO2 are 300 tpy, which exceeds the 250
tpy threshold. Therefore, the entire source is BART-eligible, even
though the potential emissions of PM and NOX at each
emissions unit are less than 250 tpy each.
Part 2 - Identify Sources Subject to BART
May be done pollutant by
pollutant, or for all visibilityimpairing pollutants to
determine if emissions from
these sources contribute to
visibility impairment.
No
Next Slide
Demonstrate
emissions from all
BART-eligible sources are not
reasonably anticipated to cause
or contribute to any visibility
impairment in a
Class I area?
No
More sources?
Yes
Yes
Check next source
No Sources are
subject to BART
STOP
Part 2 - Identify Sources Subject to BART
Consider SO2, NOx, PM
(and optionally, VOC and
NH3) emissions in
determining whether sources
cause or contribute to
visibility impairment.
No
Next Slide
Determine if one or more
BART-eligible sources can
be excluded from causing/
contributing to visibility
impairment in nearby
Class I areas.
Set a threshold for
contribution of a
change of 0.5 dv
A larger number of sources
causing impacts visibility in
a Class I area may warrant a
lower contribution threshold
than 0.5 deciviews.
No
Part 2 - Identify Sources Subject to BART
Using a contribution threshold of
0.5 dv, can exempt (1) a source of
< 500 tpy NOx/SO2, if > 50 km
from a Class I area, and (2) a
source of < 1000 tpy NOx/SO2 , if
> 100 km from a Class I area.
Use the Model Plants
approach
Next Slide
Run CALPUFF for
each source
Calculate daily visibility values
for each receptor as the change
in dv compared against natural
visibility conditions. Use EPA’s
‘‘Guidance for Estimating
Natural Visibility Conditions
Under the Regional Haze Rule,’’
You should develop a modeling
protocol, consulting with EPA and your
RPO. Consult EPA’s Interagency
Workgroup on Air Quality Modeling
(IWAQM) Phase 2 Summary Report
and Recommendations for Modeling
Long Range Transport Impacts.
Part 2 - Identify Sources Subject to BART
Those BART-eligible
sources are subject
to BART
Next Slide
Yes
Do any single
sources contribute to
visibility impairment ?
No
No Sources are
subject to BART
STOP
Part 3 – Determine the BART Controls
For Each Emissions Unit
Establish BART for each
pollutant
Is the source
already controlled?
No
Yes
Next Slide
A control technique is considered
available, if it has reached the stage
of
licensing and commercial availability.
List all available control options
for that pollutant
Use information sources similar to
PSD, as listed in the Guidelines
(70 FR 39164)
Part 3 – Determine the BART Controls
Is the control
MACT?
Yes
Is the control
the latest, best?
No
Yes
The control can
be BART
Yes
Next Slide
Is the control
NSPS, BACT, or
LAER?
No
No
List all available control options
for that pollutant
Part 3 – Determine the BART Controls
Is the source
already controlled?
Yes
The control can
be BART
More pollutants?
No, all
pollutants
covered
Next Slide
List all available control options
for that pollutant
Part 3 – Determine the BART Controls
Document technical infeasibility by
explaining, based on physical, chemical,
or engineering principles, why technical
difficulties would preclude the successful
use of the control option on the
emissions unit under review.
Eliminate technically
infeasible options
Next Slide
Control technologies are technically
feasible if (1) they have been installed
and operated successfully for the type of
source under review under similar
conditions, or (2) the technology could be
applied to the source under review.
Part 3 – Determine the BART Controls
Use a common method of comparison, e.g.,
pounds of SO2 / million Btu heat input, or
pounds of NOx / ton of cement produced.
Evaluate technically
feasible alternatives
Next Slide
Take into account the most
stringent emission control
level that the technology is
capable of achieving.
Some latitude to consider special
circumstances pertinent to the
specific source under review,
Part 3 – Determine the BART Controls
Analyze impacts of the
BART determination.
Next Slide:
The Five Factors
Part 3 – Determine the BART Controls
(2) specify the control system design
parameters. See the Guidelines for potential
sources. The value selected for the design
parameter should ensure that the control
option will achieve the level of emission
control being evaluated.
(3) Develop and document estimates of
capital and annual costs and supply
documentation.
(4) Identify average and incremental cost
effectiveness (C/E) for each option. See
EPA's Cost Control Manual
(1) Clearly identify the emission units being
controlled - specify a well-defined area or
process segment within the plant. In some
cases, multiple emission units can be
controlled jointly.
Estimate the costs of
control
Part 3 – Determine the BART Controls
Determine whether the control technology
results in energy penalties or benefits and
quantify to the extent practicable.
Analyze and report
energy impacts
What is the energy consumption/tons
emissions removed? Are locally scarce
fuels involved? Are there economic impacts
of using different fuels?
Part 3 – Determine the BART Controls
Identify any significant or unusual
environmental impacts (e.g., haz waste
generation, waste water, land use, etc.)
Analyze non-air quality
environmental impacts
Identify, quantify, and assess the effects of
these non-air environmental impacts.
Part 3 – Determine the BART Controls
Consider the source’s
remaining useful life
Can be a part of the cost analysis if < the
control cost amortization period. If so, (1)
use the remaining useful life in the cost
calculations, and (2) use a permit
contingency for best control if source does
not shut down as planned.
Part 3 – Determine the BART Controls
Stastes have flexibility in setting absolute
thresholds, target levels of improvement, or
de minimis levels since the deciview
improvement must be weighed among the
five factors, and are free to determine the
weight and significance to be assigned to
each factor.
Determine visibility
Impacts in the BART
determination
De minimis values must not be higher than
the PSD applicability levels: 40 tons/yr for
SO2 and NOX and 15 tons/yr for PM10.
These de minimis levels may only be applied
on a plant-wide basis.
Next Slide
Part 3 – Determine the BART Controls
For Each Emissions Unit
Select a best
alternative
Establish BART for each
pollutant
Yes
More sources?
No, all sources covered
STOP
Presumptive controls for >200 MW EGUs
• SO2: 95% control or 0.15 lbs/MMBtu.
• NOx:
• In NOx SIP call area, extend use of controls to
year-round.
• Outside NOx SIP call area, current combustion
controls
• 0.2 – 0.45 lbs/MMBtu, depending on coal and boiler
type
Presumptive NOx emission limits
Dry-bottom wall-fired (75 units subject to presumptive limits)
Bituminous
0.39
Sub-bituminous
0.23
Lignite
0.29
Tangential-fired (110 units subject to presumptive limits)
Bituminous
0.28
Sub-bituminous
0.15
Lignite
0.17
Cell Burners (27 units subject to presumptive limits)
Bituminous
0.40
Sub-bituminous
0.45
Dry-turbo-fired (4 units subject to presumptive limits)
Bituminous
0.32
Sub-bituminous
0.23
Wet-bottom tangential-fired (3 units subject to presumptive limits)
Bituminous
0.62