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Colorado BART

Colorado BART. APCD. Class 1 Areas. National Parks and Wilderness Areas 12 in Colorado 4 National Parks 8 Wilderness Areas. BART Rulemaking. Stakeholder Process Most BART Sources Involved Rule Passed March 2006 Modeled After EPA Rule. BART Rule. Contribute 0.5 Deciview

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Colorado BART

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  1. Colorado BART APCD

  2. Class 1 Areas • National Parks and Wilderness Areas • 12 in Colorado • 4 National Parks • 8 Wilderness Areas

  3. BART Rulemaking • Stakeholder Process • Most BART Sources Involved • Rule Passed March 2006 • Modeled After EPA Rule

  4. BART Rule • Contribute 0.5 Deciview • Cause 1.0 Deciview • Pollutants – NOx, SO2, PM • VOC not included

  5. BART Rule • Post Combustion Controls NOT to be considered for NOx • Presumptive limits applicable to Coal Power Plants as guideline • 5 Factors also considered • Only 1 plant over 750 MW

  6. 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

  7. BART Rule • Some Colorado Sub-bituminous has higher Nitrogen and lower volatility • Presumptive levels can’t be met • Alternatives allowed • SIP must be approved by Legislature • Applications Received August 1, 2006

  8. Previous BART Actions • Certification of Visibility Impairment in Mt. Zirkel Wilderness by USFS in 1993 • Craig and Hayden Power Plants were Implicated • Settlements agreed to in 1996 and 2001

  9. Craig plant • Units 1 & 2 • Had Wet Limestone Scrubbers and ESP • Upgrade of Scrubbers – eliminate by-pass, improve spray modules with trays

  10. Craig plant • New Baghouses • New Lo –NOx burners with overfire air • SO2 - 0.16 lb/MMBtu 30 day average • 0.13 lb/MMBtu 90 Day • NOx – 0.30 lbs/MMBtu annual average

  11. Hayden Plant • Units 1 and 2 • Originally only ESPs • New Controls • Lime Spray Dryer • Baghouse • Lo-NOx Burners w/OFA

  12. Hayden Plant • SO2 - 0.16 Ib/MmBTU 30 day • 0.13 lb/MMBtu 90 day average • Hayden and Craig actions included in Visibility SIP

  13. Colorado BART • Because all but one of our BART sources are power plants, Guidance was issued to simplify the BART analyses. • Look at Lime Spray dryers only • Look at Current Lo-NOx burners and overfire air

  14. Colorado Bart • Consider ROFA if can’t reach presumptive levels (per EPA Appendix Y) • All Plants have baghouses • Sources can look at other controls if they want.

  15. Colorado BART • We hoped to simplify the BART process by using information gained from Craig and Hayden Settlements.

  16. BART SOURCES • Built between 1962 & 1977 • Before PSD rules applied • One of 26 listed source categories • PTE > 250 TPY • Emit SO2, NOx, PM10

  17. COLORADO SOURCES • Originally 16 Facilities • Final List 9 facilities • 13 Coal Electric Units • 1 Portland cement plant • 2 Coal Fired Industrial Boilers

  18. EXEMPT SOURCES • Reconstruction • Deminimis Impact Modeled • Less than 0.5 deciview

  19. 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

  20. COLORADO EMISSIONS • From Stationary Sources 2003 • SO2 – 83,640 Tons per Year • NOx – 123,273 TPY

  21. BART ALTERNATIVES • Must Be Better than BART • July 2005 BART Rule Provides for Two pronged test to evaluate • Emissions reduction or Modeling • Colorado will use Emission Test, Similar to CAIR example

  22. 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

  23. XCEL AGREEMENT • Settles contested issue involving Pawnee plant and its BART applicability • In existence date is contested • Alternative includes BART Presumptive level Controls on Pawnee

  24. 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

  25. Emission Reduction Estimate • SO2 - 34,000 Tons per Year • Includes 12,000 from Comanche • NOx - 7,000 - 10,000 TPY

  26. ISSUES • Post Combustion Controls • Annual Limit in XCEL Agreement • Are the Alternatives Appropriate? • Little Guidance in New EPA Alternative Rule

  27. ISSUES • How much Visibility Improvement is necessary for a source to achieve. • What $/Ton levels should be used to judge cost? • Should there be a $/deciview level set? • Averaging Times

  28. Future Action • Complete BART Determinations/Appeals and Conduct Public Comment in January 2007 • Receive EPA comments on Alternatives • Appeal of BART determinations • Rocky Mountain National Park Nitrogen deposition

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