Agenda Item J Proposed adoption of the Oregon Regional Haze Plan and New Controls for PGE Boardman Power Plant
June 19, 2009
What we will be covering
• Our recommendation on this rulemaking • Rulemaking background – how we got here • Review of Public Comment Process
Our evaluation of over 1200 comments Rationale for our recommendation _____________________________________
DEQ staff present: - Brian Finneran, DEQ Regional Haze Coordinator - Mark Fisher, DEQ Senior Permit Writer
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Why this rulemaking is important
Mt. Hood
Three Sisters
Eagle Cap
Mt. Jefferson
Mt. Washington
Strawberry Mtn.
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Mountain Lakes Crater Lake Diamond Peak
Why this rulemaking is important
Results from DEQ’s 3-year effort to develop a comprehensive regional haze plan to enhance Oregon’s national park and wilderness areas. Involves the following rulemaking:
1. 2008 Oregon Regional Haze Plan 2. Regional Haze Rules for PGE Boardman
and other BART sources. 3. Related items: Revised Oregon Smoke Management Plan Proposed changes to Mercury Rules
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The Problem
Haze Pollution in Grand Canyon National Park
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The Problem
Haze Pollution in Yosemite National Park
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The Problem
Haze Pollution in Crater Lake National Park
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Many Sources of Haze
Wildfire
Slash Burning
Motor Vehicles
Road Dust
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Field Burning
Marine Shipping
Components of Haze
- Sulfur Dioxide (SO2) - Nitrogen Oxides (NOx) - Organic Carbon - Elemental Carbon - Fine Soil - Coarse
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Air Pollution and Haze
Small amounts of air pollution can have significant effect on visibility Visual range in Oregon Cascades: 25-200 miles
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Visibility measured in Deciview: 1 Dv = perceptible change to most people. 0.5 Dv = the “limit of perceptible change”
EPA’s Regional Haze Rule
• Adopted in 1999 to address 156 Class I areas. • 2064: improve the Worst (20% haziest) days,
and protect the Best (20% clearest) days. For worst days, reach “natural conditions” For best days, “no degradation of visibility”.
• Must adopt a state regional haze plan and
update it every 5 years.
• First plan due Dec. 2007
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156 Class I Areas in U.S.
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Oregon’s 12 Class I Areas
Mt. Hood Mt. Jefferson Mt. Washington Three Sisters Diamond Peak Crater Lake National Park Kalmiopsis
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Eagle Cap
Hells Canyon
Strawberry Mountain
Gearhart Mtn Mountain Lakes
EPA’s Regional Haze Rule
• 156 Class I areas • 2064: improve the Worst (20% haziest) days,
and protect the Best (20% clearest) days. For worst days, reach “natural conditions” For best days, “no degradation of visibility”.
• Must adopt a state regional haze plan and
update it every 5 years.
• First plan due Dec. 2007
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First Regional Haze Plan
• “Reasonable Progress” by 2018 Milestone • BART (Best Available Retrofit Technology). • Long-Term Strategy
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First Regional Haze Plan
Haziest Show reasonable progress by 2018 benchmark 20% WORST DAYS
Clearest
20% BEST DAYS 2008
Natural conditions protect
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2018 Milestone
2064
Crater Lake National Park
20% Best Day
2 dV = 200 miles
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Crater Lake National Park
20% Worst Day
14 dV = 50 miles
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The Columbia Gorge NSA
• Established under the Gorge Scenic Area Act in
1986. Not a Class I area.
• Will see significant visibility benefits due proximity
to nearby Class I areas, such as Mt. Hood.
Mt. Hood Class I Area
Columbia River Gorge NSA
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What’s in Oregon’s Regional Haze Plan?
1. Comprehensive analysis of haze in Oregon’s 12
Class I areas.
2. Projects emissions and visibility in 2018 3. Reasonable Progress Demonstration for each Class
I area.
4. Long-Term Strategy for making visibility
improvements over next 10 years.
5. BART review for PGE Boardman Power Plant and
other BART-eligible facilities.
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Demonstration of Reasonable Progress
• • • •
20% Best Days show reasonable progress. 20% Worst Days fall short of 2018 Milestone. Requires additional emission reductions. PGE Boardman is the single largest industrial source of haze in Oregon. additional visibility improvements.
• Commitments in Long-Term Strategy for
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Long-Term Strategy
Primary focus next 5 years:
1. “Non-BART” Industrial sources. About 44%
of state industrial emissions. DEQ to undertake major evaluation of these sources
2. Forestry Prescribed Burning. Determine
contribution to haze and adopt additional smoke management controls if needed.
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DEQ’s BART Review
• Evaluated over 100 potential BART sources. • 10 sources were “BART-eligible.”
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Conducted visibility modeling to determine if causing “significant impact” of 0.5 deciview: “limit of a perceptible change” same level used for new industrial sources under PSD rules.
•
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5 of the 10 sources showed significant impact.
PGE Boardman Modeled Impacts
14 Class I Areas impacted
Highest impact Mt Hood 4.6 Dv
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The FEPL Option
Federally Enforceable Permit Limit (FEPL)
• Alternative to BART allowed under federal guidance. • Requires source to reduce emissions below 0.5 dv
visibility impact. Permanent change to permit.
• 4 BART-eligible sources chose FEPLs:
1) PGE Beaver gas-fired power plant 2) Georgia Pacific, Wauna Mill (pulp & paper plant) 3) International Paper (formally Weyerhaeuser Springfield) 4) Amalgamated Sugar, sugar beet plant
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Proposed Controls for PGE Boardman
Phase 1 Controls (BART)
• 2011 - NOx Combustion controls (low NOx burners with
modified over fire air). Cost $32.6 million. 46% emission reduction.
• 2014 - SO2 Scrubbers (semi-dry flue gas desulfurization).
Cost $247 million. 80% emission reduction. Phase 2 Controls (beyond BART)
• 2017 - Selective Catalytic Reduction (SCR) controls.
Additional NOx reduction. Cost $191 million. Increases NOx reduction from 46% to 84% = $471 million total cost
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= 21,000 tons/year emission reduction
Justification for Phase 2 SCR
1. Magnitude of PGE Boardman visibility impacts. 2. Needed for reasonable progress by 2018 Milestone. 3. SCR achieves 84% NOx reduction consistent with 80% from SO2 controls, at similar cost per ton. 4. Additional benefits to air quality, reducing acid deposition, Gorge visibility, protecting Native American rock art and other cultural resources.
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Emission Reductions from Proposed Controls
PGE Boardman Emissions & Percent Reduction
Tons/year (SO2 + NOx + PM)
25,000 20,000 15,000 10,000 5,000 0 Current
Phase 1 NOx + SO2 Controls 2011-2014
66% 81%
+ Phase 2 NOx SCR Controls 2017
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Visibility Improvements from Proposed Controls
PGE Boardman Reduction in Peak Impacts
Peak Impact Mt. Hood Wilderness Columbia Gorge NSA Mt. Ranier Nat’l Park WA Total Class I areas impacted over 0.5 dv Total Class I areas impacted over 1 dv
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Phase 1 + Phase 2 NOx, SO2 NOx (SCR) 2.5 dv 2.1 dv 0.9 dv 12 6 0.9 dv 0.8 dv 0.4 dv 4 0
4.6 dv 3.7 dv 2.0 dv 14 14
Proposed changes to Mercury Rule
• Two modifications that would allow DEQ to grant
extension to the 2012 compliance date for PGE Boardman. 1. Rules currently allow 1 year extension. Proposing a 2 year extension to align installation of Mercury controls with SO2 controls required in 2014. 2. Adds “fly ash contamination” as a reason for granting extension.
• Received some comments in opposition to #1 above.
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Proposed adoption of Oregon Smoke Management Plan
• OR Dept of Forestry adopted changes to the Oregon
Smoke Management Plan in 2007.
• Included new voluntary provisions to protect Class I
area visibility from prescribed burning smoke.
• Proposed Oregon Reg Haze Plan references these
provisions.
• Need to adopt OSMP into the State Implementation
Plan as part of this rulemaking.
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Rulemaking development and Public Comments
• Stakeholder Involvement
Large public workshop, outreach, DEQ Fiscal Advisory Committee.
• Public Comment Process
60-day comment period, 5 public hearings, 2-week extension of comment period
• Summary of Public Comments
111 persons attended hearings, 45 provided testimony, over 1200 comments received.
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Overview of Public Comments
Majority of comments on proposed controls for PGE Boardman, and PGE proposal to add future “decision points” closure options. Heard from all major stakeholder groups and large number of general public. • EPA, National Park Service, US Forest Service • PGE, industry, business and utility related groups • Environmental groups • Tribal Nations • General Public Attachment B is 40-page point-by-point DEQ response to comments.
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Key Comments and Response
1. Stringency of emission limits. Many commenters agreed with proposed controls – but disagreed with the emission limits – should be set lower. DEQ response: The limits we identified do reflect lowest levels achievable in practice, in our judgment. Emission limits need to take into account normal fluctuations in emissions. Permit limits need to be set at a level that will ensure compliance. Actual emissions will be lower than permitted levels.
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Key Comments and Response
2. Stringency of SCR controls. Many comments for and against. Those in favor want them sooner (by 2014). Those against cited high cost, limited visibility benefit, and unfairly single out PGE. DEQ response: SCR controls are not typical for BART. SCR installation by 2014 is not reasonable. SCR essential for reasonable progress by 2018. SCR provides other environmental benefits. SCR is as cost-effective as the SO2 scrubbers.
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Key Comments and Response
3. Stringency of timing of proposed controls. Many comments in favor of installing controls as soon as possible – faster than DEQ proposed. DEQ response:
• Timetable we identified is realistic.
Phase 1 NOx combustion controls in 2011. SO2 scrubbers in 2014 is reasonable due to complex retrofit and competition with other BART sources, still sooner than required
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SCR controls need until 2017 due to significant boiler modifications.
Key Comments and Response
4. Fiscal impact. Many comments cited overall cost of proposed controls as too high and will result in large electricity rate increases. DEQ response:
• DEQ Fiscal Advisory Committee agreed with
the accuracy of DEQ’s fiscal analysis
• Proposed controls are expensive, but are cost
effective given overall environmental benefit.
• 3-4% rate increase estimated by 2018. Will be
phased in gradually with most increase at end.
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• Rate increases must be approved by PUC.
Key Comments and Response
5. PGE’s Decision Points proposal. Closure options for 2012 and 2015, to give PGE flexibility to plan ahead and make sound economic decisions once impact of carbon regulations are known. Plant would still install Phase 1 NOx controls in 2011 and Mercury controls by 2012. Carbon regulations are on the horizon Cost of regulations are unknown, but may force closure of the plant Avoids investing in expensive regional haze controls, if the plant is closed down due to carbon regulations
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Key Comments and Response
DEQ response:
• Understands PGE concerns • Carbon regulations are uncertain at this time • Proposal would allow continued operation without
SO2 controls through 2020 or SCR controls through 2029
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• Closure options may be reasonable based on: • Complete technology analysis • Adequate public process • DEQ recommends an alternative to PGE’s proposal
Key Comments and Response
DEQ’s alternative to PGE’s proposal: Amended RH Plan to include provisions to review and expedite PGE rule change request. Prefer PGE make request when more is known about the impact of carbon regulations. Provide a complete BART analysis Provide opportunity for Public to review DEQ’s analysis Allow sufficient time to process request. See Attachment A-6 for proposed language.
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Timeline for Boardman Controls
July 2011: Phase 1 NOx July 2014: SO2 controls July 2017: Phase 2 NOx (SCR controls)
Tons/year (SO2 + NOx + PM)
25,000 20,000 15,000 10,000 5,000
Timeline for submitting rule change request * 2011 2014
2009
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2017
* Request well in advance of control installation deadlines
In Summary
1. PGE Boardman – most single significant stationary source of haze pollution in OR. Multi-state impacts. Peak impact at 9x significance threshold. 2. DEQ conducted exhaustive 3-year study of appropriate controls for this facility. 3. DEQ carefully reviewed and considered all comments in developing our recommendation. Prepared a detailed summary and point-bypoint response to comments.
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In Summary
4. Concluded our original proposal provides best overall environmental benefit because: Meets federal requirements for BART Minimizes Boardman’s NOx and SO2 emissions to help make reasonable progress by 2018 Milestone. Helps improve visibility and better protect cultural resources in Columbia Gorge. 5. Provides PGE Boardman with alternative to address future carbon regulations.
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Recommended action
Recommend adoption of: 1. Regional Haze Rules (A-1) for PGE Boardman. 2. Oregon Smoke Management Plan (A-2) as revised by OR Dept. of Forestry in 2007. 3. 2008 Oregon Regional Haze Plan (A-3). 4. Proposed changes to Mercury Rules (A-4).
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End
MT WASHINGTON THREE-FINGERED JACK MT JEFFERSON MT HOOD
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