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