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Regional Haze Rule SIP Template Stationary Sources

This template provides the requirements and recommendations for stationary sources in the Regional Haze Rule State Implementation Plans (SIPs), including milestones, trading programs, monitoring protocols, and geographic enhancements.

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Regional Haze Rule SIP Template Stationary Sources

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  1. Regional Haze Rule SIP TemplateStationary Sources Colleen Delaney, Utah DAQ

  2. Stationary Source Requirements • GCVTC stationary source recommendations • SO2 milestones that establish a regional emission cap • Backstop trading program if milestones are not met • Similar program should be evaluated for NOx and PM

  3. Stationary Source Requirements • EPA’s 1997 RH Rule • Incorporated GCVTC recommendations in section 309 • Required an Annex to GCVTC report by October 1, 2000 to provide more details of milestones and backstop trading program

  4. Stationary Source Requirements • Annex submitted on September 29, 2000 as required by §309(f) • EPA proposed approval of the Annex on May 6, 2002 • Final approval needed ASAP to establish requirements for SIPs

  5. Stationary Source Requirements • Regional milestones and details of the backstop trading program • How will this be addressed in the SIP? • Authorizing legislation [no model provided] • State rules that are substantially similar to the model rule [WRAP model rule] • SIP commitments that are substantially similar to model SIP text [WRAP SIP text]

  6. Stationary Source Requirements • Annual reporting of SO2 emissions for sources with emissions > 100 tons/yr • How will this be addressed in the SIP? • Modify existing state inventory rules (2003-2018 inventories) [no model rule provided] • Commit in SIP to work with other states and tribes to develop a regional inventory [WRAP model SIP text]

  7. Stationary Source Requirements • Track changes to inventory methodology (apples to apples comparison with milestones) • How will this be addressed in the SIP? • 1996 inventory methodology documented in TSD [WRAP TSD, supplemented by state] • Show any changes between 1996 and 1998 (non-utilities) and 1999 (utilities) [provided by state] • Commit to tracking changes in methodology in future inventory years [WRAP model SIP text]

  8. Stationary Source Requirements • SO2 allocations for sources within the state • How will this be addressed in the SIP • Allocation formula described in SIP [WRAP model SIP text] • Floor allocation established for existing sources and included as a SIP provision [provided by state using WRAP guidelines] Note: MTF is still discussing some of the details of the allocation process.

  9. Stationary Source Requirements • List of BART-Eligible Sources in the State • Not specifically required in 309, but would finalize information submitted with Annex • EPA’s BART guidance is not final • How will this be addressed in the SIP? • Table of BART-eligible sources in SIP text [provided by state] • Documentation for how the list was developed in TSD [provided by state]

  10. Stationary Source Requirements • Demonstrate that SO2 emissions decreased at least 13% between 1990 and 2000 • How will this be addressed in SIP • Include statement in SIP that SO2 emissions declined 25% between 1990 and 2000 [WRAP model SIP text] • Include WRAP 2000 inventory report in TSD [WRAP report]

  11. Stationary Source Requirements • Monitoring protocols • How will this be addressed in the SIP • Monitoring protocols included in state rule or SIP text [provided by WRAP]

  12. Stationary Source Requirements • Provisions to address NOx and PM • Report to assess potential NOx and PM control strategies and to evaluate need for trading program [provided by WRAP] • Commitment to revise SIP in 2008 to address BART for NOx and PM [WRAP model SIP text]

  13. Stationary Source Requirements • Emission and allowance tracking system, post-trigger • What is needed in SIP • TSD will include specifications for database to track emissions and allowances [provided by WRAP] • SIP will include commitment to develop system if the program is triggered [WRAP model SIP text]

  14. Geographic Enhancements

  15. Geographic Enhancements • What does the term “geographic enhancements” mean? • 1980’s requirement addresses impacts of a source on a specific Class I area (RAVI) • Regional haze rule added requirement to address impact of multiple sources on haze • Geographic enhancements addresses RAVI within the context of a regional trading program

  16. Geographic Enhancements • Annex outlined process for addressing geographic enhancements • Certification (screening process) • Attribution (guidelines to address principles and criteria, and to address difference between RH and RA impairment) • Remedy (several options included beyond traditional BART)

  17. Geographic Enhancements • What is needed in SIP? • MOA between States, Tribes, and FLMs outlining screening process for certification [draft developed by WRAP] • WESTAR Report addressing techniques for determining attribution could be included in TSD [provided by WRAP] • Remedy options outlined in SIP [WRAP model SIP text]

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