Best available retrofit technology under the regional haze rule
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Best Available Retrofit Technology Under the Regional Haze Rule. Illinois Environmental Protection Agency December 6, 2010. Overview. Visibility Modeling of BART-eligible Sources Modeling Methodology Modeling Results BART Controls in Illinois EGUs Non-EGUs. Visibility Modeling.

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Best Available Retrofit Technology Under the Regional Haze Rule

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Best Available Retrofit Technology Under the Regional Haze Rule

Illinois Environmental Protection Agency

December 6, 2010


Overview

  • Visibility Modeling of BART-eligible Sources

    • Modeling Methodology

    • Modeling Results

  • BART Controls in Illinois

    • EGUs

    • Non-EGUs


Visibility Modeling

  • CALPUFF is the USEPA approved regulatory model for long range transport and visibility

  • It provides for chemical transformation of SO2 and NO2

  • It calculates light extinction coefficients, consistent with Federal guidance, to assess effects on visibility


Emissions Inventory

  • SO2, NOx, and primary PM are listed by USEPA as visibility impairing pollutants

  • IEPA developed a list of BART eligible sources from 26 applicable categories

  • Modeling parameters for each stack were developed from the IEPA emissions inventory system. Emissions used are based on maximum short-term allowables


CALPUFF Modeling Domain


Meteorology and Receptors

  • Meteorological files were developed by LADCO from national scale 36 km grid MM5 model. Three years of meteorological data (2002-04) are used in the modeling.

  • Multiple receptors are placed in each of 16 Class I areas that are likely to be impacted by Illinois sources.


Class I Areas included in the BART modeling


LADCO Modeling Protocol

  • Illinois followed the BART modeling protocol developed by LADCO and the MRPO states (dated March 21, 2006).

  • Protocol addresses selection of models, development of model inputs, and processing and interpretation of model outputs.

  • LADCO modeling protocol was approved by USEPA and FLMs.


BART Eligibility Based on Visibility Impacts

  • Based on USEPA’s BART guidance, a source considered to be causing or contributing to visibility impairment:“…if the 98th percentile daily change in visibility is greater than 0.5 deciviews (DV) as compared to natural conditions”.

  • In plain English, if 22 or more exceedances of the 0.5 DV threshold occur in three years at any Class I area, or if 8or more exceedances occur in any one year, the BART-eligible unit(s) at the source is(are) subject to BART controls


CALPUFF Results – EGU’s


CALPUFF results – non EGU’s


Modeling – Dominion Kincaid

Dominion Kincaid submitted modeling to support their proposed BART control strategy

Their modeling addressed the two closest Class I areas, Mingo NWR and Mammoth Cave NP


Dominion’s Modeling Results


IEPA Audit of Dominion’s Modeling

  • Used LADCO modeling protocol

  • Includes larger domain, more Class I areas

  • Compared the proposal to presumptive BART


Results showed that the proposal is comparable to “Presumptive BART”


Illinois Approach to BART Control Requirements


Illinois Subject-to-BART Sources

  • Eligible sources are subject-to-BART controls if shown to cause or contribute to visibility impairment

  • The only sources that were found to be subject-to- BART were coal fired power plants and two petroleum refineries

  • In most cases, measures that were previously agreed to were found to result in greater reductions than BART

  • In two cases, IEPA pursued agreements with subject-to-BART EGUs


Illinois Analysis of EGUs

  • Illinois EPA compared presumptive BART emission levels to existing emission reduction requirements and commitments for the subject-to-BART EGUs in Illinois.

  • In all cases, Illinois found emission reductions from existing commitments to be greater than presumptive BART.


Existing Requirements and Commitments

  • The Multi-Pollutant Standard (“MPS”) and Combined Pollutant Standard (“CPS”) in the Illinois Mercury Rule apply to Ameren, Dynegy, and Midwest Generation

  • A Memorandum of Understanding (“MOU”) between the IEPA and Dominion Energy Services applies to Kincaid Generating Station

  • A similar MOU between the IEPA and City, Water, Light and Power (CWLP)


MPS and CPS

  • The MPS and CPS affect the Coal-fired EGUs operated by Ameren, Dynegy, and Midwest Generation.

  • These three entities account for approximately 88% of Illinois’ coal-fired capacity.

  • Emission standards were negotiated on a case-by-case basis.


MPS and CPS

  • IEPA anticipates a reduction in SO2 emissions of approximately 214,600 tons per year by 2015.

  • IEPA anticipates a reduction in NOx emissions of approximately 90,000 tons per year by 2015.


MOU with Dominion Kincaid

  • Both units at the Kincaid facility are subject to BART controls.

  • Dominion conducted a site-specific BART analysis for the Kincaid plant, including a control technology review and CALPUFF modeling to assess the visibility impacts of several control alternatives.


MOU with Dominion Kincaid

  • Dominion agreed in the MOU to a very low NOx emission rate of 0.07 lbs/mmBTU by 2017.

  • Presumptive BART for NOx is 0.10.

  • The agreement requires an SO2 emission rate of 0.18 lbs/mmBTU by 2017.

  • Presumptive BART for SO2 is 0.15.

  • Modeling has shown that this alternate control plan will result in equivalent visibility improvement at a much lower cost.


MOU with CWLP

  • At the time of the MOU, CWLP was operating three BART eligible units: Dallman 31 and 32, and Lakeside 8.

  • The MOU includes an agreement to shut down Lakeside 8.

  • Presumptive BART for these units for NOx is the operation of SCR.

  • Presumptive BART for these units for SO2 is 95% control.


MOU with CWLP

  • CWLP agreed in the MOU to meet an annual NOx emission rate of 0.12 lbs/mmBTU by 2015, and an annual rate of 0.11 lbs/mmBTU by 2017

  • CWLP agreed in the MOU to meet an annual SO2 emission rate of 0.25 lbs/mmBTU by 2015, and an annual rate of 0.23 lbs/mmBTU by 2017.

  • The calculated presumptive BART for SO2 of 95% control is 0.30 lbs/mmBTU

  • Illinois EPA estimates these reductions to be 5,375 tons of NOx per year and 4,875 tons of SO2 per year in 2017.


Estimated NOx Emissions from Coal-fired EGUs in Illinois


Estimated SO2 Emissions from Coal-fired EGUs in Illinois


Illinois Analysis of Subject-to-BART Non-EGUs

  • Both non-EGU sources in Illinois that are subject to BART control are petroleum refineries.

  • The CITGO refinery in Lemont is subject to a Consent Decree finalized in 2004.

  • The ExxonMobil refinery in Joliet is subject to a Consent Decree finalized in 2005.


Illinois Analysis of Subject-to-BART Non-EGUs

  • Both refinery consent decrees result in large reductions of NOx, SO2, and PM emissions in Illinois.

  • Factors considered in control requirements for both consent decrees are very similar to those require for BART analyses.

  • Emission reductions from Consent Decree requirements are greater than applying BART control to subject-to-BART units at the refineries in both cases.

  • Emission reductions from the Consent Decrees will occur a few years earlier than if required by BART


Summary

  • Several sources in Illinois have been determined to be BART-eligible and are causing or contributing to visibility impairment in some federal Class I areas in the eastern US.

  • Illinois has promulgated or negotiated emissions control requirements for most subject-to-BART sources.

  • These requirements provide emissions reductions that are well beyond what would be anticipated from only applying BART controls on subject-to-BART units.

  • Illinois’ control requirements will provide greater visibility improvements than would occur from application of BART controls on subject-to-BART units.


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