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WRAP States BART Status Lee Gribovicz

WRAP States BART Status Lee Gribovicz. Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007. What is BART?. B est A vailable R etrofit T echnology. BART is Applied To:.

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WRAP States BART Status Lee Gribovicz

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  1. WRAP States BART StatusLee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

  2. What is BART?

  3. BestAvailableRetrofitTechnology

  4. BART is Applied To: • stationary sources of air pollution constructed in a 15 year window between August 7, 1962 and August 7, 1977 …….….. • having the potential to emit more than 250 TPY of any air pollutant …….….. • and belonging to one of 26 categories of industrial operations (ie/ fossil fuel power plants, petroleum refineries, large industrial boilers, cement plants, sulfur recovery plants & etc.) • Meeting these three criteria makes a source “BART-Eligible”

  5. BART Definition • BART is a permit emission limitation not control technology itself, but the resulting emission rate (ie/ lb/MM Btu, pph, etc) • §308 (e)(1)(ii)(A) requires that this limitation incorporate:the best system of continuous emission control technology available ……considering

  6. 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

  7. BART Factors §308 (e)(1)(ii)(B) also requires BART to consider …… VISIBILITY Impact • 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 Modeling is required to determine the visibility impact – • Defined Threshold: Source is “Contributing” to Visibility Impairment at a level of 0.5 dV impact (could be less if state elects to consider a cumulative analysis) • If a source is contributing to Visibility Impairment, then it is: “Subject to BART”

  8. Given the definitions and factors states must: 1 Assure that they have the Authority (BART rule) to regulate BART sources for visibility (appx: 6 months, more?) 2 Identify a list of BART-Eligible Sourcesin their state (using the definitions of age, emissions, source category) (appx: 6 months, could overlap w/ BART Rule) 3 Determine if they are “Subject to BART” using Visibility Modeling of individual source impact on one or more Class I areas (appx: 6 months) 4 Require sources to conduct an engineering analysis of emission control options to propose a BART control scenario using the six BART factors (appx: 6 months) 5 Review the BART application (similar to an NSR BACT permit review) and make a proposed determination on BART controls (appx: 3 months) 6 Go through Public Notice and Review to formally set BART Emission Limits (appx: 3 months)

  9. Thus the BART Determination Process could stretch out over TWO YEARS (or more) Don’t think all the states fully appreciated the timeframe for completing this analysis

  10. BART Status: Alaska • RMC completed “Subject to BART” modeling for 7 AK sources April 6, 2007 (Chugach Beluga Plant subsequently NOT BART-Eligible) • all sources showed impacts above the 0.5 dV threshold, but some of the companies are remodeling with revised meteorological data to see whether they can convince Alaska that they are not “Subject” to the BART requirements • Alaska still must adopt a “BART Rule” into regulation before they can officially determine that any source is “Subject to BART” • the BART rule has been adopted by DEC, but must be reviewed and accepted by the Alaska Department of Law – expected early Fall ‘08 • formal determination on “Subject to BART” sources will then be made • BART control applications will be submitted after engineering analyses are completed (+/- six months) • therefore BART determinations will not be made until sometime in the middle of 2008

  11. BART Status: Arizona • RMC completed “Subject to BART” modeling for 14 AZ sources May 25, 2007 • (4) Apache Nitrogen, Chemical Lime Douglas, Phelps Dodge Morenci & Salt River Project San Tan plants exempt • (9) Abitibi Pulp Mill, Arizona Portland Cement Plant, Chemical Lime Nelson, ASARCO Hayden & Phelps Dodge Miami Copper smelters are the non-EGU’s “Subject to BART”. Coal fired power plants at AEP Apache, APS Cholla, West Phoenix & SRP Coronado are also Subject • Arizona notified the 9 “Subject to BART” sources of their inclusion in the BART program on July 13th • BART control applications are to be submitted no later than December 14th • review time and public notice will push the formal BART determination schedule into mid-2008 • regarding the Tucson Electric Irvington Plant, Arizona DEQ is in negotiations with the company as to whether the facility is BART-Eligible

  12. BART Status: California • has determined that a number of originally determined BART-eligible sources were mis-characterized in the clearinghouse in that they did not meet one or more of the BART factors (age, emissions or source category) (“N” for eligibility – green) • has determined that a number of BART-eligible sources won’t require further control because of strict existing/planned emission limitations (blue) • will conduct “Subject to BART” modeling for a limited number of sources (complete list yet to be defined – 11 possible) • has a number of special BART implementation questions due to the fact that CARB doesn’t regulate stationary point sources at the state level (local Air Pollution Control Districts have that function) • BART emission limitations will likely be coordinated through the Districts in their Title V renewal process • no established date for BART determinations at this point

  13. BART Status: Colorado • DONE !! • Colorado Regional Haze SIP available at: http://www.cdphe.state.co.us/ap/regionalhaze.html • Coal Fired Utility Rates (except CENC [Coors Brewery]): • SO2 between 0.10 & 0.13 lb/MM Btu • NOx between 0.15 & 0.39 lb/MM Btu • PM at 0.03 lb/MM Btu • One Cement Kiln • Kiln: 20% reduction NOx, Process Control SO2, 0.3 lb/Ton feed PM [Clinker Cooler same except 0.1 PM] • Established a 10,500 ton bubble for SO2 at Xcel Energy’s Metro Denver Plants: Cherokee 1-4, Valmont 5 ..&.. Arapahoe 3-4 [non-BART] Units (Arapahoe 1&2 retired)

  14. BART Status: Hawaii • Hawaii has 8 sources listed as BART-Eligible • They haven’t completed a “Subject to BART” modeling protocol as yet, therefore no further analysis of BART has occurred • The modeling protocol is “imminent”, but the “Subject to BART” modeling, the BART control engineering analysis, the review and notice will likely push BART determinations into late 2008

  15. BART Status: Idaho • Idaho completed “Subject to BART” modeling internally, with the issuance of July ’07 reports • all modeled sources exempt except for a coal fired industrial boiler at Amalgamated Sugar (TASCO) Nampa plant • TASCO control analysis due in September – BART control determination expected November • P4 Production’s Soda Springs Plant has also been determined to be Subject to BART, but they will meet BART level control through retrofits installed under a permit revision (to address NAAQS violations)

  16. BART Status: Montana • RMC completed “Subject to BART” modeling for 9 MT sources May 30, 2007 • (3) Cenex, Exxon, Montana Sulfur & Smurfit Stone exempt • (5) Columbia Falls Aluminum, Ash Grove & Holcim Cement, PP&L Corette & Colstrip Plants are “Subject to BART” • Montana DEQ bowed out of RH in June 2006, therefore EPA is now responsible for the Montana Regional Haze FIP • BART control applications are submitted for the Ash Grove & Holcim Cement, and the PP&L Corette & Colstrip Plants – Columbia Falls Aluminum has a 90 day extension to submit their application • EPA has contracted with EC/R to complete the BART evaluations -- but there is no schedule for completing the review • EPA expects to make BART determinations in late Fall ’07 • The ASARCO Helena lead smelter has been decommissioned and has been notified that it will require a NSR BACT permit to resume operations

  17. BART Status: Nevada • RMC completed “Subject to BART” modeling for 5 NV sources May 14, 2007 • (2) Chemical Lime & Nevada Power Sunrise exempt • (3) Nevada Power Reid Gardner & Sierra Power Ft. Churchill & Tracy are “Subject to BART” • So. Cal Edison Mojave is also “Subject”, but the plant is not currently operating: NV is waiting on a pending sale decision before taking action • Nevada Cement is re-doing their “Subject to BART Modeling to see whether they can convince Nevada that they are not “Subject” to the BART requirements • BART control evaluations are under way, but there is no deadline for completion • BART determinations not expected until mid-2008

  18. BART Status: New Mexico • RMC completed “Subject to BART” modeling for 10 NM sources April 21, 2007 • (9) Amoco Abo, SWPS Cunningham & Maddox, Duke Artesia & Linam Ranch, Dynegy Saunders, Giant San Juan & Ciniza, and Marathon Indian Basin plants are exempt • (1) PNM Reeves Station was subsequently found to have begun operation prior to the August 1962 BART timeframe • Public Service of New Mexico San Juan coal fired power plant is “Subject to BART”, but is also under a Consent Decree mandating improved controls • PNM submitted a BART control application June 6th, with evaluation currently under way to determine whether the Consent Decree controls also meet BART • a determination on whether any additional BART control is required, is expected in September

  19. BART Status: North Dakota • ND completed “Subject to BART” modeling their 7 sources in the Spring of 2006 • (3) American Sugar, MDU Heskett & Tesoro Refining exempt • (4) Basin Leland Olds, Great River Coal Creek & Stanton, and Minnkota Milton Young Coal Plants are “Subject to BART” • BART control applications submitted in July ‘06 • ND has essentially completed their determinations for SO2 & PM, but NOx control still has the decisions deadlocked over whether SCR can be used effectively with ND lignite coal • BART determinations are still targeted for Fall ’07, but the NOx issue may push that back

  20. BART Status: Oregon • Oregon completed “Subject to BART” modeling in February 2007 • (3) Georgia Pacific in Toledo, and the Kingsford & Smurfit plants in Springfield are exempt • Oregon initially found that 6 plants were “Subject to BART”, but all of these six are in negotiation with Oregon DEQ to adopt federally enforceable emission limits which would reduce their Class I impact below the 0.5 dV impact threshold, and remove them from BART requirements • And Oregon is looking at defining a “Cumulative Impact” criteria for some Oregon BART-Eligible Sources • in addition, the PGE Boardman coal fired power plant has also been found to be “Subject” and will go through BART review • the deadline for Boardman to submit their control analysis is August 31st; review & BART determination date unknown • There is no deadline for the other 6 plants to complete their alternative plans and re-demonstration of visibility impact

  21. BART Status: South Dakota • RMC completed “Subject to BART” modeling for 2 SD sources August 15, 2007. Results indicate: • Pete Lien does not have a 0.5 dV impact on any Class I area • Otter Tail Power Big Stone Plant does have a 0.5 dV impact on several Class I areas in the region “Subject to BART” • SD is in negotiations with Otter Tail over these modeling results, and has not made a formal determination that the Big Stone Plant is “Subject to BART”. There is currently no deadline for completing this determination. • once a determination is made, engineering evaluation of potential BART control options, and review of the selected proposal will push BART determinations well into mid-2008

  22. BART Status: Utah • only two BART-Eligible Sources in Utah: Pacificorp Hunter & Huntington Plants • RMC completed “Subject to BART” modeling for 2 UT sources April 21, 2007, which indicated both Pacificorp plants do exceed the 0.5 dV Class I area impact threshold • Pacificorp made commitments to meet or exceed presumptive BART limits at these plants under their MidAmerican buyout agreement (installation of wet-lime FGD’s, baghouse’s and low-NOx combustion controls) • Utah issued permits for Huntington 2 in April ’05 and for Hunter 1-3 in April ’07 for legally enforceable limits • 0.12 lb/MM Btu SO2 // 0.26 lb/MM Btu NOx • the Huntington 1 permit application is expected in Dec ’07

  23. BART Status: Washington • Washington requested that each of the 14 BART-Eligible facilities in the state conduct “Subject to BART” modeling in early 2007 • Goldendale Aluminum, Phillips 66, Puget Sound Refining & Simpson Kraft were found to be exempt • Three plants (ALCOA, Ft. James & Longview Fibre) are re-modeling with revised ozone data to see if their initial modeled impact will be reduced below the 0.5 dV threshold, with determinations expected in early Fall ‘07 • Washington has found that 7 plants are “Subject to BART” • DEC will issue an order for these 7 plants (& the other 3, if found to be “Subject”) to prepare BART control applications, with submittal deadlines ranging from November ’07 through March ’08 • review time and public notice will push the formal BART determination schedule into mid-2008

  24. BART Status: Wyoming • Wyoming contracted out “Subject to BART” modeling for 14 facilities in early 2006 • Black Hills Neil Simpson I, Dyno Nobel, P4 Production Coking, Sinclair Oil Casper and Sinclair Refineries were exempt • OCI Trona was eventually determined to be not BART-Eligible • Wyoming determined that 8 Facilities were “Subject to BART” in June ’06 (General Chemical, FMC Granger & Green River industrial boilers, along with Basin Electric Laramie River & Pacificorp EGU’s at Dave Johnston, Jim Bridger, Naughton and Wyodak plants) • BART control applications were submitted in January & February ’07 for Pacificorp EGU’s, March & April ’07 for industrial boilers at the FMC and General Chemical Trona Plants. Wyoming has not yet received the application from the Basin Electric Laramie River EGU. • Review of the BART proposals is currently under way for the applications that have been received, with BART determinations expected sometime in the Fall ’07.

  25. BART Status: Tribal Sources • EPA is responsible for completing BART analyses for sources located on Tribal lands • the Region 9 EPA Office is responsible for: • APS Four Corners power plant (FCPP) located in northwest New Mexico & SRP Navajo Generating Station (NGS) located at Page in northern Arizona, both BART-Eligible sources situated on the Navajo Indian Reservation • Region 9 EPA made a direct determination that these two plants are “Subject to BART”, bypassing the modeling demonstration as their high emission totals and proximity to Class I areas gave strong indication that modeling would show over 0.5 dV impact • Region 9 EPA requested BART control plans from the plant operators and now expects to receive the NGS plan in September, with the FCPP plan due in November ’07 • review time and public notice will push the formal BART determination schedule into mid-2008

  26. BART Status: Tribal Sources • The Graymont Western Lime/Calcium Carbonate Plant is located on tribal land under the control of the Puyallup Indians near Tacoma, Washington • As a result of a provision of a federal law concerning a claims settlement for the tribe, the plant is not subject to EPA jurisdiction, but is subject to air pollution regulation by Washington local air pollution control district authorities and by state law • Washington DEC’s request for “Subject to BART” modeling included this plant, and their review of the results showed that Graymont Western is exempt from BART regulations

  27. Probable BART Completion Matrix

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