BART EPAforVISTASPlanning 050304 by aR8wG9


									Reproposal of the Regional Haze
Rule and BART Guidelines
Regional Haze Timeline
   Regional Haze (RH) final rule: July 1999
   Regional Haze remand vacating BART provisions in
    section 308 of RH rule: May 2002
      Court objected to inclusion of individual sources
       based on collective assessment of visibility impacts
       from all sources
   Consent decree deadline for RH/BART reproposal:
    April 15, 2004; deadline for final action: April 15,
   Regional Haze state implementation plans (SIPs) due
    3 years after designation of PM2.5 attainment and
    nonattainment areas (January 2008)

1999 Regional Haze Rule –
General Requirements
   States must submit regional haze SIPs addressing
    emissions which “may reasonably be anticipated to
    cause or contribute to any impairment of visibility” in
    any Class I area
       States are required to establish reasonable progress goals and
        timetables; we established a rebuttable presumption that States
        should achieve natural conditions by 2064, with long-term
        strategies due every 10 years (first one in 2018).
       Regional planning encouraged
   Regional Haze program applies to all States, regardless
    of whether the State contains a Class I area
       Emissions from States without Class I areas reaches Class I areas
        in other States
       Clean Air Act (CAA) directs us to “prevent any future impairment”

    1999 Regional Haze Rule – Best
    Available Retrofit Technology
    (BART) Provisions
   Requires States to implement BART for all BART-
    eligible sources.
   Includes CAA mandate that BART determinations
    should be based on five factors:
      Cost of compliance

      Energy and nonair quality environmental impacts

      Existing pollution control technology at the source

      Remaining useful life of the source, and

      Degree of visibility improvement which may reasonably
       be anticipated from controls
   Includes option for States to implement “better
    than BART” trading program in lieu of individual
    source BART determinations.

         BART Guidelines
   BART guidelines provide States with:
       Approach for determining which BART-eligible sources should be
        subject to BART determinations, and
       Approach for making BART determinations.
   Which sources are BART-eligible?
       Major sources >250 tons built between 1962 and 1977
       Includes: electric generating units (EGUs), industrial boilers, other 26
        source categories
       But only if such sources are reasonably anticipated to contribute to
        regional haze in any Class I area
   BART guidelines proposed: July 2001; now must
    repropose in light of the Regional Haze Rule

    Major Points of the Remand
   The Court vacated our approach to deciding which
    sources are reasonably anticipated to contribute to
    regional haze in any Class I area
        Rejected our approach to assessing visibility impacts by evaluating
         the impacts cumulatively from all BART facilities.
             Approach did not look at individual source contributions to haze
             Approach lacked necessary process by which States can exempt
              individual sources

   The Court also vacated our approach to determining the
    degree of visibility improvement from use of such
        Rejected our approach to assessing visibility impacts by evaluating
         cumulatively the effect of reductions from all BART facilities.
             Approach did not account for impacts on haze of individual source

Response to the Remand
   Revise RH rule to allow States to
    exempt an individual source from BART
    based on its visibility impacts
   Revise BART Guidelines to provide
    methodology for individual source

Major Issues in Reproposal
   Creating a State exemption process using
    individual source air quality modeling
   Requiring individual source air quality
    modeling to evaluate visibility impacts when
    determining BART control requirements
   Establishing control levels for SO2 and NOx
    from EGUs

State exemption process
   State may choose to subject all BART-eligible
    sources to BART determinations, or
   State may choose to allow individual sources
    to show they should be exempt.
       Exemption process: each individual source models
        its emissions to show visibility impacts at nearest
        Class I area, using “CALPUFF” model
       State decides whether to exempt, focusing on
        whether the individual source’s emissions alone
        cause an amount of visibility impairment
        discernible to the naked eye.

Determining BART control
   If a source is not exempt, then it must model
    two scenarios: (1) current (baseline)
    emissions, and (2) future expected emissions
    with control technology in place, using
    “CALPUFF” model, to show expected visibility
    improvement at nearest Class I area.
   State considers modeled visibility impacts,
    along with cost and other factors, in
    determining BART control requirements.

Control Levels for SO2 and NOx
from EGUs
   CAA specifically requires EPA to establish
    guidelines for >750 MW power plants.
   We include presumptive control levels for
    units >250 MW at all power plants.
       SO2
           Propose choice of 95% control or 0.1 to .15 lbs/MMBtu.
               Facilities using Eastern coal can meet 95% control

               Facilities using Western coal can meet 0.1 to 0.15
       NOx
           All sources currently using selective catalytic reduction
            (SCR) for the ozone season (those subject to the NOx
            SIP call), keep and extend controls to year-round.
           All sources currently without SCR, propose control to 0.2
            lbs/MMBtu.                                              11
Control Levels for SO2 and NOx
from EGUs, con’t.
   States must require these control levels
    at >750 MW plants, unless analysis of
    other BART factors dictate otherwise.

   We presume that States should require
    these control levels at >250 MW units,
    unless analysis of other BART factors
    dictates otherwise.

       Issues also Important to Note

   Regional Haze rule allows trading as
    alternative to source-by-source BART.

   IAQR has potential to serve as trading


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