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BART Status of Other States

Updates on eligibility status, modeling processes, and control analyses for BART-eligible sources in AK, NM, HI, ND, SD, OR, WA. Learn about challenges, reviews, and potential solutions.

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BART Status of Other States

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  1. BART Statusof Other States AK, Bernalillo County, HI ND, SD, OR, WA

  2. AK • Seven BART-eligible sources • About half emissions are from non-EGUs • Fuel conversion and chemical process plants • WRAP completed CalPuff modeling, but model performance under review

  3. Bernalillo County, NM • Two potentially-eligible sources • Gas-fired EGU boiler • Cement plant • Staffing issues have delayed resolution of eligibility status • Assistance to determine eligibility and perform modeling available from WRAP

  4. HI • Eight BART-eligible sources • 6 EGUs, a refinery, and an industrial boiler • State has initiated modeling process

  5. ND • Seven BART-eligible sources • 5 EGUs, a refinery furnace, and an ind. boiler • No major issues identifying eligible sources, although obtaining start-up dates for older units was a challenge • Contribution modeling • Completed about a year ago • Only major issue was whether to allow sources to conduct refined analyses (allowed) • One EGU did so and is not subject to BART

  6. ND • BART control analyses • Received analyses from all subject sources • All 5 BART factors are included • Review process similar to BACT • Major issues • Cost threshold -- Drawing some cues from EPA costs estimated in CAIR, BART, and Annex rules • Several companies rejected more efficient and cost-effective technologies because of small visibility improvements (< 0.1 dv) • Feasibility of SCR with lignite uncertain

  7. SD • One eligible EGU, and one potentially-eligible lime plant • EGU more than 300 km from nearest area • CalPuff will not be used

  8. OR • Eleven BART-elgible sources • 2 EGUs, pulp mills, boilers, and petro storage • No major issues identifying eligible sources • Contribution modeling still underway, but petro storage facility already found to be not subject • BART control analysis • Not yet discussed control limits or 5 factors, except for Boardman EGU, which started early • Examples from other states would be helpful

  9. WA • 15 eligible sources • 1 EGU, pulp mills, cement plants, refineries, lime plant, aluminum plant • Some difficulty determining construction dates, but ultimately each was verified • Contribution modeling • Common protocol with Region 10, OR, ID • Source have not yet completed modeling • Some are expected to revise potocol to address terrain issues

  10. WA • Some sources are small and may not be subject to BART • Another source may take an enforceable limit below 250 tpy • BART control analysis • Hoping for source submittals in Sept, which would include analysis of all 5 factors, but BART orders probably not issued before Dec. • Centrailia EGU probably met for SO2 and PM • Examples from other states would be helpful, including cost effectiveness for various sources

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