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Colorado BART

APCD

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Class 1 Areas

National Parks and Wilderness Areas

12 in Colorado

4 National Parks

8 Wilderness Areas

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BART Rulemaking

Stakeholder Process

Most BART Sources Involved

Rule Passed March 2006

Modeled After EPA Rule

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BART Rule

Contribute 0.5 Deciview

Cause 1.0 Deciview

Pollutants – NOx, SO2, PM

VOC not included

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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

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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

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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

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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

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Craig plant

Units 1 & 2

Had Wet Limestone Scrubbers and ESP

Upgrade of Scrubbers – eliminate by-pass, improve spray modules with trays

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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

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Hayden Plant

Units 1 and 2

Originally only ESPs

New Controls Lime Spray Dryer Baghouse Lo-NOx Burners w/OFA

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Hayden Plant

SO2 - 0.16 Ib/MmBTU 30 day

0.13 lb/MMBtu 90 day average

Hayden and Craig actions included in Visibility SIP

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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

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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.

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Colorado BART

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

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BART SOURCES

Built between 1962 & 1977

Before PSD rules applied

One of 26 listed source categories

PTE > 250 TPY

Emit SO2, NOx, PM10

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COLORADO SOURCES

Originally 16 Facilities

Final List 9 facilities

13 Coal Electric Units 1 Portland cement plant 2 Coal Fired Industrial Boilers

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EXEMPT SOURCES

Reconstruction

Deminimis Impact Modeled

Less than 0.5 deciview

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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

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COLORADO EMISSIONS

From Stationary Sources 2003

SO2 – 83,640 Tons per Year

NOx – 123,273 TPY

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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

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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

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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

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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

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Emission Reduction Estimate SO2 - 34,000 Tons per Year

Includes 12,000 from Comanche

NOx - 7,000 - 10,000 TPY

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ISSUES

Post Combustion Controls

Annual Limit in XCEL Agreement

Are the Alternatives Appropriate?

Little Guidance in New EPA Alternative Rule

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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

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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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