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RH Requirement for BART

RH Requirement for BART. §308 (e) contains BART requirements for regional haze visibility impairment….

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RH Requirement for BART

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  1. RH Requirement for BART • §308 (e) contains BART requirements for regional haze visibility impairment…. • The State must submit an implementation plan containing emission limitations representing BART and schedules for compliance with BART for each BART-eligible source that may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area

  2. BART Definition • BART is an emission limitation • §308 (e)(1)(ii)(A) requires that this limitation incorporate:the best system of continuous emission control technology available …… taking into consideration

  3. BART Factors • the control technology available • the costs of compliance • the energy & non-air quality environmental impacts • any pollution control equipment in use at the source • the remaining useful life of the source ….. AND

  4. BART Factors • Under §308 (e)(1)(ii)(B) also requires BART to consider …… • the degree of visibility improvement that would be achieved in each mandatory Class I Federal area as a result of the emission reductions achievable from all sources subject to BART located within the region that contribute to visibility impairment in the Class I area

  5. BART Factors • The “degree of visibility improvement” factor is addressed by July 6, 2006 EPA BART “Guidelines” • Sources “Subject to BART” are required to determine visibility improvement resulting from their proposed BART implementation plan, through visibility modeling

  6. “Subject to BART” • Late 2005,WY District Engineers identified BART Eligible Sources using the July 6th Guidelines (250 TPY, constructed in the ’63-’77 window & one of the 26 listed source categories) • WY conducted CALPUFF modeling to determine whether sources “contribute” 0.5 dV of visibility impairment to the nearest Class I area • 24 hr average actual emission rate/highest emitting day • Sources that “contribute” are “Subject to BART

  7. Wyoming Companies “Subject to BART” • Coal Power Plants • Pacificorp Dave Johnston Plant: U3(230) & U4(360MW) • Pacificorp Jim Bridger Plant: Units 1, 2, 3 & 4 (578 MW) • Pacificorp Naughton Plant: U1(110), U2(220) U3(360MW) • Pacificorp Wyodak Plant: one 360 MW unit • Basin Laramie River Plant: Units 1, 2 & 3 (570 MW) • Coal Fired Industrial Boilers • FMC GR Trona Plant: 2 @ 887MM; 1 @ 334MM Btu/Hr • FMC Granger Trona Plant: 2 @ 358 MM Btu/Hr • General Chemical GR Trona Plant: 534 & 880 MM Btu/Hr

  8. Wyoming BART Rule • Emission limits require the Administrator’s authority • To assure this authority is available WY EQC passed a “BART Rule” October 10, 2006 • Signed for Agency Adoption October 12th • Under SOS Review; Expected Final 12/26/06

  9. Wyoming BART Rule • Applicability • Definitions • BART Guidelines • Subject to BART Source Identification • BART Requirements (permit appl & review) • BART Alternatives (Trading) • Monitoring, Recordkeeping & Reporting Requirements

  10. BART Control Analyses • “Subject to BART” letters to the 8 Companies; June 14, 2005 • “Not Subject to BART” letters to the other 6 Companies that were BART Eligible, but did not “contribute” to visibility impairment • These 8 must now conduct BART control analyses using the five factors (technology available, costs, energy & non-air impacts, existing pollution control, and remaining useful life of the source • control plans to be completed by December 15, 2005 (appx) • AQ NSR Program will review control proposals for agreement and set emission limits for these sources (similar to BACT)

  11. Presumptive Levels • Provided Modeling Protocol for evaluating degree of visibility improvement from control of “Subject to BART” Sources on October 2, 2006 • Previously had advised that selecting Presumptive Limits for SO2 and NOx control eliminated the need for detailed analysis of the 5 BART Factors • Because of expressed EPA concern that there might be some economic benefit or peculiarity associated with specific site applications, WY is now advising that a “minimal” evaluation of all BART factors (1-technology, 2-costs, 3-energy/non-air env. impacts, 4-existing pollution control 5-remaining life) is required

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