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WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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Page 1: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP States BART Status

Lee Gribovicz

Implementation Workgroup Meeting

Denver, Colorado

August 28-29, 2007

Page 2: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

What is BART?

Page 3: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007
Page 4: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

B est A vailable R etrofit T echnology

Page 5: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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”

Page 6: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 7: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 8: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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”

Page 9: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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 Sources in 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)

Page 10: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 11: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 12: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes,

potential)

AK Agrium U.S. Inc. (a.k.a. Unocal Urea Plant) 50 Units Y

AK Alyeska Pipeline Service Company Valdez Marine Terminal 16 Units Y

AK Anchorage MLP Sullivan Power Plant Units 5 and 7 Y

AK Chugach Beluga Power Plant Units 6 and 7 N

AK Conoco-Phillips Kenai LNG Plant 5 Units Y

AK GVEA Healy Coal Fired Power Plant Units 1 and 3 Y

AK Tesoro Refinery 11 Units Y

Page 13: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 14: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

Subject to BART? (yes/no)

AZ Abitibi Consolodated Sales Corp - Snowflake Pulp Mill Power Boiler 2 Y

AZ Apache Nitrogen Products Nitric Acid Plant AOPs 3-4 N

AZ Arizona Electric Power Coop - Apache Power Plant Units 1-3 Y

AZ Arizona Portland Cement Company Kiln 4 Y

AZ Arizona Public Service - Cholla Power Plant Units 1-4 Y

AZ Arizona Public Service - West Phoenix Power Plant CC 1-3 Y

AZ Chemical Lime Company - Douglas Lime Plant Kilns 4-5 N

AZ Chemical Lime Company - Nelson Lime Plant Kilns 1-2 Y

AZ Kennecott (ASARCO) - Hayden Coper Smelter Converters 1-5, Anode Furnaces 1-3 Y

AZ Phelps Dodge Corporation - Morenci Plant Gas Turbine 1-2, Gas Boiler 1-2, Boiler 4 N

AZ Phelps Dodge Miami Copper SmelterHoboken Converters 1-5, Remelt Furnace, Shaft

Furnace Y

AZ Salt River Project - Coronado Power Plant Units 1-2 Y

AZ Salt River Project - Santan Power Plant Units 1-4 N

AZ Tucson Electric Power - Irvington Power Plant Steam Unit 4 N

Page 15: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 16: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

BART Eligible?

(yes, potential)

CA ACE Cogeneration Company (Mojave Desert - Trona) N

CA CABRILLO POWER I LLC ENCINA PO (San Diego) Y (see note)

CA CONOCO-PHILLIPS Santa Maria Refinery (formerly TOSCO - San Luis Obispo) Y

CA CONOCO-PHILLIPS Rodeo Plant (formerly TOSCO; formerly Phillips 66; formerly Unocal) Y

CA CALIFORNIA PORTLAND CEMENT CO. (eastern Kern) N

CA CEMEX - River Plant (Mojave Desert - Victorville) N

CA CEMEX - (Mojave Desert - Black Mountain Quarry Plant - AppleValley) Y

CA CHEVRON USA Inc -(Bay Area - Richmond - Contra Costa)) Y

CA DUKE ENERGY MORRO BAY (SLO) Y (see note)

CA DUKE ENERGY MOSS LANDING, LLC (Monterey) Y (see note)

CA DUKE ENERGY-SOUTH BAY POWER PL (San Diego) Y (see note)

CAEVERGREEN PULP, INC. (formerly Samoa Pacific Cellulose, LLC; formerly LP Samoa) (North Coast - Humboldt) Y

CA JOHNS-MANVILLE (Glenn) N

CA LEHIGH SOUTHWEST CEMENT CO. (Eastern Kern) N

CA LEHIGH SOUTHWEST (formerly Calaveras Cement Company - Shasta) N

CA MARTINEZ REFINING COMPANY (Shell - Martinez - Bay Area - Contra Costa)) Y

Page 17: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes, potential)

CA MIRANT DELTA (formerly Southern Energy California Co.; formerly PG&E Antioch - Contra Costa) Y (see note)

CA MIRANT DELTA, LLC (Pittsburg - Bay Area - Contra Costa) Y (see note)

CA MIRANT POTRERO LLC (San Francisco - Potrero) Y (see note)

CA Mitsubishi Cement 2000 (Mojave Desert - Lucerne) N

CA NATIONAL CEMENT CO (eastern Kern) N

CA PACIFIC GAS & ELECTRIC CO - HUMBOLDT BAY (Eureka) N

CA Pacific Lumber Company Max-Am Corporation (Scotia) N

CA Reliant Energy Coolwater, LLC ALTA (Mojave Desert - Daggett) Y

CA Reliant Energy Ormond Beach Generating Facility LLC (Ventura) Y (see note)

CA RHODIA INC (Bay Area - Martinez - Contra Costa) Y

CA Searles Valley Mineral Utilities aka IMC Chemicals Inc. (Mojave Desert: Trona/Argus/Westend) Y

CA SIERRA PACIFIC INDUSTRIES - Standard (Tuolumne County) N

CA TXI Riverside Cement Company (Mojave Desert - Oro Grande) Y (see note)

CA TESORO Marketing and Refining (formerly ULTRAMAR) (Martinez - Contra Costa) Y

CA VALERO REFINING COMPANY - CALI (formerly Exxon-Mobil) Y

Page 18: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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)

Page 19: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitSubject to

BART? (yes/no)

CO CEMEX, INC. - LYONS CEMENT PLANT   Y

CO COLORADO REFINING CO TOTAL PETROLEUM   N

CO COLORADO SPRINGS UTILITIES - NIXON PLT Unit 1 N

CO COLORADO SPRINGS UTILITIES-DRAKE PLT Units 5-7 Y

CO CONOCO INC DENVER REFINERY   N

CO LAMAR UTILITIES BOARD Unit 6 N

CO PUBLIC SERVICE CO - VALMONT Unit 5 Y

CO PUBLIC SERVICE CO CHEROKEE PLT Unit 4 Y

CO PUBLIC SERVICE CO COMANCHE PLT Units 1-2 Y

CO PUBLIC SERVICE CO HAYDEN PLT Units 1-2 Y

CO PUBLIC SERVICE CO PAWNEE PLT Unit 1 Y

CO TRI STATE GENERATION CRAIG Units 1-2 Y

CO TRIGEN-NATIONS ENERGY CO - Trigen Colorado Units 4-5 Y

Page 20: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 21: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes, potential)

HI Hawaiian Commercial & Sugar Company   Y

HI HECO-Kahe Power Plant   Y

HI HECO-Waiau Power Plant   Y

HI HELCO-Kanoelehua Power Plant   Y

HI Hilo Coast Power Company   Y

HI KIUC-Port Allen Generating Station   Y

HI MECO-Kahului Power Plant   Y

HI Tesoro Refinery   Y

Page 22: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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)

Page 23: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes, potential)

Subject to BART? (yes/no)

ID JR Simplot Company Don Siding Complex   see column N N

ID Nu West Industries (Agrium)   see column N N

ID P4 Production LLC Soda Springs Plant (aka: Monsanto)   Y (see note)  

ID Potlatch Corp - Potlatch Idaho   see column N N

ID TASCO (Amalgamated Sugar), Nampa   see column N Y

ID TASCO (Amalgamated Sugar), Paul   see column N N

ID TASCO (Amalgamated Sugar), Twin Falls   see column N N

Page 24: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 25: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitSubject to

BART? (yes/no)

MT ASARCO (Helena Plant)   N

MT Ash Grove Cement (Clancy)   Y

MT CENEX-Laurel Refinery   N

MT COLUMBIA FALLS ALUMINUM   Y

MT EXXON CO USA - Billings Refinery   N

MT Holcim Cement (Three Forks)   Y

MT Montana Sulfur & Chemical (Billings)   N

MT PP&L MONTANA LLC - J E CORETTE SES Unit 2 Y

MT PPL, MONTANA COLSTRIP Plant Units 1-2 Y

MT Smurfit-Stone Container Corp - Missoula Mill   N

Page 26: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 27: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes, potential)

Subject to BART? (yes/no)

NV Chemical Lime Company (Apex) Kiln 3 see column N N

NV Nevada Cement Co. (Fernley) Kilns 1-2 Y  

NV NEVADA POWER CO - REID GARDNER Units 1-3 see column N Y

NV NEVADA POWER CO - SUNRISE Unit 1 see column N N

NV SIERRA PACIFIC POWER CO - FORT CHURCHILL Units 1-2 see column N Y

NV SIERRA PACIFIC POWER CO. - TRACY GENERATING STATION Units 1-3 see column N Y

NV SOUTHERN CALIFORNIA EDISON CO - MOHAVE Units 1-2 see column N Y

Page 28: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 29: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

Subject to BART? (yes/no)

ND Tesoro Marketing and Refining Co.   N

NM Amoco Empire Abo SRU Only N

NM SWPS Cunningham Station (Xcel Energy) One Unit N

NM Duke Energy Artesia Gas Plant SRU Only N

NM Duke Energy Linam Ranch Gas Plant SRU Only N

NM Dynegy Saunders SRU Only N

NM Giant Refining San Juan Refinery Unit #1 FCCP ESP stack N

NM Giant Refining, Ciniza Refinery 4 B&W CO boiler N

NM SWPS Maddox Station (Xcel Energy) One Unit N

NM Marathon Indian Basin Gas Plant SRU Only N

NM PNM, San Juan Units 1-4 Y

NM Reeves Station   N

NM Rio Grande Station One Unit N

NM Western Gas Resources San Juan River Gas Plant SRU Only N

Page 30: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 31: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitSubject to

BART? (yes/no)

ND AMERICAN CRYSTAL SUGAR - Drayton   N

ND BASIN ELECTRIC POWER COOP - LELAND OLDS Units 1-2 Y

ND GREAT RIVER ENERGY - COAL CREEK Units 1-2 Y

ND GREAT RIVER ENERGY - STANTON Unit 1 Y

ND MDU Resources Group Inc - R M Heskett Unit 2 N

ND MINNKOTA POWER COOP INC - MILTON R YOUNG Units 1-2 Y

ND Tesoro Marketing and Refining Co.   N

Page 32: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 33: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

Subject to BART? (yes/no)

OR Amalgamated Sugar Co LLC - Amalgamated Sugar Nyssa   Y

OR Boise Cascade (aka Boise Paper Solutions) St. Helens Pulp Mill   Y

OR Fort James Operating Company (Wauna Mill)   Y

OR Georgia-Pacific West, Inc. (Toledo)   N

OR Kingsford Manufacturing Charcoal Briquette Plant (Springfield)   N

OR Pope & Talbot, Inc. (Halsey Mill)   Y

OR Portland General Electric Company - Boardman   Y

OR Portland General Electric Company - Beaver Plant @ Clatskanie)   Y

OR Smurfit Newsprint Corporation (aka SP Newsprint - Springfield)   N

OR Weyerhaeuser - Springfield   Y

Page 34: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 35: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes, potential)

SD OTTER TAIL POWER CO - BIG STONE Unit 1 Y

SD PETE LIEN AND SONS, INC.   P

Page 36: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 37: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

Subject to BART? (yes/no)

UT PACIFICORP - Hunter Power Plant Units 1-2 Y

UT PACIFICORP - Huntington Power Plant Units 1-2 Y

Page 38: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 39: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name UnitBART Eligible? (yes, potential)

Subject to BART? (yes/no)

WA ALUMINUM CO OF AMERICA WENATCHEE WORKS 2 Units Y  

WA BP CHERRY POINT REFINERY 26 Units see column N Y

WA CENTRALIA (TransAlta Centrailia Generation, LLC) Units 1-2 see column N Y

WA FORT JAMES CAMAS LLC (now Georgia Pacific) 4 Units Y  

WA GOLDENDALE ALUMINUM 2 Units see column N N

WA INTALCO ALUMINUM CORP (FERNDALE) 19 Units see column N Y

WA Lafarge Corporation Cement Plant (Seattle) 2 Units see column N Y

WA Longview Fibre Co - Longview Fibre 6 Units Y  

WA PHILLIPS 66 COMPANY (Ferndale) 8 Units see column N N

WA Port Townsend Paper Co 4 Units see column N Y

WA Puget Sound Refining Company (aka: Shell) 9 Units see column N N

WA SIMPSON TACOMA KRAFT 3 Units see column N N

WA TESORO NORTHWEST COMPANY 12 Units see column N Y

WA Weyerhaeuser Co - Longview WA 3 Units see column N Y

Page 40: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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.

Page 41: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

Subject to BART? (yes/no)

WY BASIN ELECTRIC POWER COOP - LARAMIE RIVER Units 1-3 Y

WY BLACK HILLS POWER & LIGHT - NEIL SIMPSON 1 Unit 1 N

WY Dyno Nobel (formerly Coastal Chemical) 9 Units N

WY FMC CORP - GREEN RIVER SODA ASH PLANT 3 Units Y

WY FMC WYOMING CORP - GRANGER SODA ASH PLANT (Formerly Texasgulf) 2 Units Y

WY GENERAL CHEMICAL - GREEN RIVER SODA ASH PLANT 2 Units Y

WY P4 PRODUCTION - ROCK SPRINGS COKING PLANT 1 Unit N

WY PACIFICORP - DAVE JOHNSTON Units 3-4 Y

WY PACIFICORP - JIM BRIDGER Units 1-4 Y

WY PACIFICORP - NAUGHTON Units 1-3 Y

WY PACIFICORP - WYODAK Unit 1 (335MW) Y

WY SINCLAIR OIL CORP-SINCLAIR REFINERY 16 Units N

WY SINCLAIR REFINERY - CASPER 1 Unit N

Page 42: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 43: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

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

Page 44: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

WRAP BART Clearinghouse 8/31/2007

Sources that have been officially determined to be "Subject to BART"

Sources that have been formally exempted as not "Subject to BART"

State Plant Name Unit

Subject to BART? (yes/no)

Tribal (AZ) Salt River Project - Navajo Power Plant Units 1-3 Y

Tribal (NM) Arizona Public Service - Four Corners Power Plant Units 1-5 Y

Tribal (WA) Graymont Western Lime/Calcium Carbonate Plant (Tacoma) 1 Unit N

Page 45: WRAP States BART Status Lee Gribovicz Implementation Workgroup Meeting Denver, Colorado August 28-29, 2007

Probable BART Completion Matrix

State

BART Completion Date

Fall 2007 Mid 2008 Other

Alaska   X  

Arizona   X  

California     Later ?

Colorado     DONE

Hawaii     Later ?

Idaho X    

Montana X    

Nevada   X  

New Mexico X    

North Dakota X    

Oregon   X  

South Dakota   X  

Utah X    

Washington   X  

Wyoming X    

Tribal   X