WRAP Update Patrick Cummins WESTAR Meeting September 23, 2005.

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  • WRAP UpdatePatrick CumminsWESTAR MeetingSeptember 23, 2005

  • Where Weve Been Western states take leadership role on regional haze

    Grand Canyon CommissionWRAP formed as successor organization309 option included in final 1999 regsAnnex submitted Sept 30, 20005 309 SIPs submitted December 2003Completing state-of-the-art technical analysis

  • Laws, Regulations and LawsuitsJuly 1999: Regional Haze RuleJuly 2001: BART guidelines proposedMay 2002: Decision in Corn Growers vacates BARTJun 2003: Haze rule revised to incorporate AnnexJuly 2003: EPA revises mobile source section of 309Apr 2004: BART rule and guidelines reproposedFeb 2005: Decision in CEED vacates WRAP AnnexJuly 2005: BART rule finalizedAug 2005: BART alternatives & 309 reproposedSep 2005: CEED & others file suit on final BART ruleSep 2005: Comments on alternatives proposalNov 2005: Final Trading & 309 rule2000-2004: No revisions to the Clean Air Act2004-2005: EPA elects not to extend CAIR to the West2006 and beyond: More lawsuits and revisions

  • But What About Emissions?1998-2004 (11 Western states):35% reduction in SO2 from EGUs202,500 tons per year15% increase in heat inputHowd that happen?Centralia4 Corners and San JuanCraig, Hayden and Metro Denver PlantsNavajo

  • More on the way!SpringervilleCommancheSan JuanFour CornersMohavePacifiCorp PlantsHuntington 2Cholla 4Dave Johnston 3 & 4Upgrades at other plants (Jim Bridger WY)

    Addl. reduction: 135,000 tpy SO2

  • Whats LeftNot muchPawnee (CO)Colorado Springs (4 units)Boardman (OR)Total reduction = 30,000 tpy

  • Where does that leave us?309 Milestones

    2018 Milestone (5 states)=309,000Current emissions = 316,000 (incl. CEM adj.)After planned reductions = 235,000Need to add back some growth and new sources (25-35K?)Boardman only plant left in 309 states

    Annex milestones need to be reevaluated in order to show better than BART and resubmit 309 SIPs

  • Where does that leave us?Utilities-only look:9-state EGU target from Annex=271 K tpy SO2 (including new)300 K with WA & MT (a good better than BART number)

    Current 11-state emissions: 371 KAfter planned reductions: 235 KWith remaining sources: 205 KAdd growth and new sources

  • What about NOx?EGU emissions = about 15% of inventory

    NOx generally contributes < 10% of haze

    Some areas have larger NOx contributionsGreater contribution on clean days, but NOx will go down under any scenario

    NOx emissions are of concern for other reasons (ozone, acid deposition, etc.)

  • What about NOx?46 BART-eligible units >200 MW in 13 states that exceed presumptive limits

    Achieving presumptive limits at BART-eligible units = 30% reduction

    Plants > 750 MW = 16% reduction

    Presumptive limits on all units (including non-BART) = 40% reduction

  • Questions and IssuesRevisions to 309 SIPsHow to do better than BART demonstration3 options, all have problems309 states need to get together and determine next steps

    BART for 308 and NOx?Unlikely that SO2 program will be expandedTrading alternative may have value for NOx. Possible expansion to all non-CAIR states.Utility only program?

    Are there non-utility sources of concern (BART and non-BART)? How many, what kind, where?

  • In conclusion.Most of the progress through 2018 will be in the base case (incl., federal mobile source controls)

    Biggest effect will be from SO2 reductions that are already in the pipeHow do we package our success to meet the requirements (especially when BART remains a moving target)

    Work with EPA to address outstanding issues with alternative programs and 309.Reaffirm state leadership role, working with stakeholders, to establish solutions that work for the West

    NOx is a question that effects more sourcesPresumptive limits on 750 MW plants is the battleSeveral options exist. What do sources and states want?Can do some sensitivity runs


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