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

Best Available Retrofit Technology Under the Regional Haze Rule

Illinois Environmental Protection Agency

December 6, 2010


Overview

Overview

  • Visibility Modeling of BART-eligible Sources

    • Modeling Methodology

    • Modeling Results

  • BART Controls in Illinois

    • EGUs

    • Non-EGUs


Visibility modeling

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

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

CALPUFF Modeling Domain


Meteorology and receptors

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

Class I Areas included in the BART modeling


Ladco modeling protocol

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

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 – EGU’s


Calpuff results non egu s

CALPUFF results – non EGU’s


Best available retrofit technology under the regional haze rule

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

Dominion’s Modeling Results


Iepa audit of dominion s modeling

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

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


Illinois approach to bart control requirements

Illinois Approach to BART Control Requirements


Illinois subject to bart sources

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 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

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

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 cps1

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

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 kincaid1

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

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 cwlp1

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 no x emissions from coal fired egus in illinois

Estimated NOx Emissions from Coal-fired EGUs in Illinois


Estimated so 2 emissions from coal fired egus in illinois

Estimated SO2 Emissions from Coal-fired EGUs in Illinois


Illinois analysis of subject to bart non egus

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 egus1

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

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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