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Summary of June 15, 2005 Revisions to RH BART and BART Guidelines

Summary of June 15, 2005 Revisions to RH BART and BART Guidelines. Rulemaking Timeline. July 1999: Regional Haze Rule July 2001: BART guidelines proposed May 2002: Corn Growers vacates BART April 2004: BART amendment proposed / BART Guidelines reproposed

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Summary of June 15, 2005 Revisions to RH BART and BART Guidelines

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  1. Summary of June 15, 2005 Revisions to RH BART andBART Guidelines

  2. Rulemaking Timeline • July 1999: Regional Haze Rule • July 2001: BART guidelines proposed • May 2002: Corn Growers vacates BART • April 2004: BART amendment proposed / BART Guidelines reproposed • Feb 2005: CEED vacates WRAP Annex • Jun 2005: BART finalized • Sep 2005: CEED files suit • Nov 2005: Final Trading & Annex rule • Dec 2007: Regional haze SIPs due

  3. Key Features of June 15 Action • Provides states with more discretion • Provides guidance on how to determine if an eligible source is “reasonably anticipated to cause or contribute to haze” (subject to BART) • Provides guidance on how to determine what BART is at a particular source (how to apply the 5 statutory factors) • Establishes presumptive SO2 and NOx limits for EGUs > 200 MW at plants > 750 MW • CAIR is determined to be “better than BART” and thus can serve in lieu of BART for EGUs in CAIR states

  4. Changes in Eligibility • Fossil-fired EGUs and industrial boilers include boilers burning any amount of fossils fuel, not just 50% or more • VOC and NH3 are not required to be considered visibility impairing pollutants but may be considered as such by states on a case-by-case basis • Distinction not recommended between urban and rural VOCs

  5. Changes in Eligibility • Emission limits enforceable only under state law may be considered in determining PTE • De minimus emissions • No analysis required for • 40 tpy plant-wide PTE for SO2 and NOx • 15 tpy plant-wide PTE for PM10 • Streamlined analysis permitted for relatively small emissions (e.g., 40 – 250 tpy)

  6. Determine If Subject to BART • 3 Options: • Individual source assessment • Use CALPUFF or other appropriate models • Assume highest actual steady state emissions • Compare impacts against natural conditions • “Cause” = impact of 1.0 dv at 98th percentile • “Contribute” = impact of 0.5 dv at 98th percentile • Cumulative assessment of all eligible sources • Use results from “model plants” to exempt sources with common characteristics

  7. Determine BART • Five statutory factors • Costs of compliance • Energy and non-air environmental impacts • Existing controls at source • Remaining useful life of source • Degree of visibility improvement which may be reasonably anticipated from the technology • Broad discretion in weighing these factors • Guidance for determining visibility improvement similar to determining if subject to BART

  8. Guidelines for EGUs • CAA requires BART determinations to be made pursuant to EPA guidelines at plants > 750 MW • Mandatory/binding for these sources • Contain presumptive control limits • Presumptive control limits encouraged atEGUs >200 MW at plants <750 MW • Because of evidence that such controls are cost effective • Guidelines are guidance only for all other BART sources

  9. Presumptive Limits for EGUs>200 MW at Plants >750 MW • SO2 • Uncontrolled: 95% or 0.15 lbs/MMBtu • Controlled <50%: consider above and upgrades • Controlled >50%: consider upgrades • Plants <750 MW: consider same limits • NOx • Operate existing post-combustion controls year-round • For other units, apply combustion-based controls • For cyclone units, apply 0.10 lbs/MMBtu • Plants <750 MW: consider same limits

  10. Presumptive NOx emission limits

  11. 5 Steps In Determining BART • List all available control options for each pollutant • Eliminate technically infeasible options • Evaluate alternatives • Analyze impacts (5 statutory factors) • Select the best alternative Note: – repeat for each pollutant – guidance only for non-EGUs – States have discretion in how to do analysis

  12. Step 5:Selecting the Best Alternative • Develop a table or array of the options – include the emission rate, the control efficiency, and the five factors

  13. Step 5:Selecting the Best Alternative • Select the best emission reduction achievable considering all other factors • Consider mitigating factors or factors making the case stronger for best controls (i.e. visibility)

  14. CAIR “better than BART” Demonstration • BART Final Rule contains EPA’s determination that CAIR will result in greater progress than BART • Demonstration in CAIR final rule • Updated analysis in final BART rulemaking • CAIR + BART is better than BART by 2,911 ktons of SO2 and 738 ktons of NOx. • Average visibility improvement nationwide (on 20% worst days) is 0.5 dv for CAIR + BART vs. 0.2 dv for BART. On 20% best days, average visibility improvement nationwide is 0.1 dv in both cases.

  15. Some Questions EPA Has Received So Far • When are the SIPs due? • December 17, 2007 (3 years after PM2.5 designation) • Explain the de minimis levels (40 TPY for SO2 and NOx and 15 TPY for PM2.5) • Plant wide • Is BART pollutant specific? • Yes • Explain the threshold level of 0.5 dv • 0.5 or lower for the “subject to BART” step; no threshold for the visibility analysis for the control evaluation

  16. Some Questions EPA Has Received So Far • What about the model plant example in the rule – the 500 TPY/50 km exemption? • Illustrative only • Can a source take a permit limit to avoid a BART determination? • Yes

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