bart sip development: example from colorado rocky mountain national park wrap iwg meeting, denver,...
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BART SIP Development: BART SIP Development: Example from Colorado Example from Colorado
Rocky Mountain National Park
WRAP IWG Meeting, Denver, CO
August 29, 2007
Presented by: Ray Mohr and Curt Taipale
Presentation Topics
Background
Colorado’s state-only BART Rule development
BART determinations (process and status)
BART SIP Chapter and other materials in submittal
BART Rulemaking
Stakeholder Process
Most BART Sources Involved
Rule Passed March 2006
Modeled After EPA Rule
BART Rule
Contribute 0.5 Deciview
Cause 1.0 Deciview
Pollutants – NOx, SO2, PM
VOC not included
BART Rule
Post Combustion Controls NOT to be considered for NOX
Presumptive limits applicable to Coal Power Plants as guideline
Only 1 plant over 750 MW
BART Rule
Consideration of Impact on Coal Mines in Colorado
Due to concern over classification of sub-bituminous coal
Presumptive Limits based on Powder River coal
BART Rule
Some Colorado Sub-bituminous has higher Nitrogen and lower volatility
Presumptive levels can’t be met
BART Alternatives allowed
SIP must be approved by Legislature
Colorado BART
We hoped to simplify the BART process by using information gained from Craig and Hayden RAVI Settlements.
Previous RAVI BART Actions
Certification of Visibility Impairment in Mt. Zirkel Wilderness by NFS in 1993
Craig and Hayden Power Plants were Implicated
Settlements agreed to in 1996 and 2001
Colorado Regional Haze BART
Because all but one of our BART sources are power plants except for one Portland Cement Plane and one industrial boiler facility, Air Division provided Guidance to simplify the BART analyses.
Look at Lime Spray dryers only
Look at Current Lo-NOx burners and overfire air
Colorado Bart
All Plants have baghouses
Sources can look at other controls if they want.
BART SOURCES
Built between 1962 & 1977
Before PSD rules applied
One of 26 listed source categories
PTE > 250 TPY
Emit SO2, NOx, PM10
COLORADO SOURCES
Originally 16 Facilities
Final List 9 facilities
13 Coal Electric Units1 Portland cement plant2 Coal Fired Industrial Boilers at one facility
EXEMPT SOURCES
Reconstruction
Deminimis Impact Modeled
Less than 0.5 deciview
Exempt Sources
Gas Fired Boilers < 250 MMBtu/hr each
Reconstructed - Portland cement plant and Steel Mill Arc Furnace
Pharmaceutical Production – VOC only
Refinery and Power Plant – Modeled below 0.5 dV
One plant shutdown
BART Alternative
Must Be Better than BART
July 2005 EPA BART Rule Provides for Two pronged test to evaluate
Emissions reduction or Modeling
Colorado used Emission Test, Similar to CAIR example
Existing Agreements
XCEL Voluntary Emission Reduction Agreement – 1998
SO2 Emission Cap in Metro Denver Area – 10,500 TPY
Three Plants – 7 units involved
Previous SO2 = 25,000TPY
XCEL Alternative
Settles contested issue involving Pawnee plant and its BART applicability
In existence date is contested
Alternative includes BART Presumptive level Controls on Pawnee with stricter annual limit
Comanche Plant
Units 1 & 2 – 350 MW each are BART sources.
Agreement reached in order to Build Unit 3 (750 MW)
New LSD, LO-NOx Burners and OFA
Limits less than BART Presumptive
Emission Reduction Estimate
SO2 - 34,000 Tons per Year
Includes 12,000 from Comanche
NOx - 7,000 - 10,000 TPY
BART in the Colorado SIP
Regional Haze Rule and BART Rule provide basis of BART Chapter BART Chapter identifies required BART provisions in PlanBART Appendix A expands on discussion and application of Rule requirementsBART Technical Support Document (web site) includes all BART determination pertinent details (modeling, factor analysis, permit limits)
Chapter 1 OverviewChapter 2 Plan Development and ConsultationChapter 3 Monitoring StrategyChapter 4 Baseline and Natural Conditions and Uniform Progress for each Class I AreaChapter 5 Sources of Impairment in ColoradoChapter 6 Best Available Retrofit TechnologyChapter 7 Visibility Modeling and ApportionmentChapter 8 Reasonable Progress GoalsChapter 9 Long Term StrategyChapter 10 Commitment to Consultation, Progress Reports, Evaluations of Plan Adequacy and Future SIP RevisionsChapter 11 Guidance, Resources and References:
Regional Haze SIP - Chapter Overview
Regional Haze Web Site Technical Documentation
Air Division’s web site http://www.cdphe.state.co.us/ap/regionalhaze.html
Link to other web sites
Air Division’s BART web pagehttp://www.cdphe.state.co.us/ap/RegionalHazeBART.html
WRAP’s Technical Support System web sitehttp://vista.cira.colostate.edu/tss/
Some Observations and Lessons
State Rule provides necessary framework
State Guidance very important in establishing “subject to” parameters and evaluating source operator determinations
Practical considerations, if effective, should be utilized
Process worked “reasonably” well