There will be some coal backed out of the permitted fuel mix at one of the facilities in North Carolina covered by the “reasonable progress” provision of the U.S. Environmental Protection Agency’s regional haze rules.
EPA, in a Feb. 28 Federal Register notice, proposed a limited approval of a revision to the North Carolina state implementation plan (SIP) submitted by the North Carolina Department of Environment and Natural Resources, Division of Air Quality (NCDAQ). This revision addresses the requirements of the Clean Air Act (CAA) and EPA’s rules that require states to prevent any future and remedy any existing anthropogenic impairment of visibility in mandatory Class I areas (national parks and wilderness areas) caused by emissions of air pollutants from numerous sources. States are required to assure reasonable progress toward the national goal of achieving natural visibility conditions in Class I areas.
EPA is proposing a limited approval of this SIP revision on the basis that the revision, as a whole, strengthens the North Carolina SIP. In a separate action, EPA has proposed a limited disapproval of the North Carolina regional haze SIP because of deficiencies in the state’s regional haze SIP submittal arising from the remand by the U.S. Court of Appeals for the District of Columbia Circuit to EPA of the Clean Air Interstate Rule (CAIR). North Carolina had relied on CAIR for much of its regional haze compliance. Consequently, EPA is not proposing to take action in this rulemaking to address the state’s reliance on CAIR to meet certain regional haze requirements. Comments on this action are being taken until March 29.
One of the facilities impacted by the reasonable progress mandate is operated by Blue Ridge Paper Products and has four coal-fired boilers; G–66, G–24, G–25 and G–65. Boilers G–24, G–25, and G–65 burn a washed and blended coal from different portions of the coal seam at the Apollo mine to meet Blue Ridge Paper’s specifications for heat, ash and sulfur content. Coal from the Apollo mine has high heat content, low to moderate ash, and low to moderate sulfur (1.4 to 1.5 lbs SO2/MMBtu). The electrostatic precipitators (ESPs) on these boilers perform well on this moderate sulfur coal and test well below applicable particulate matter (PM) standards. They are not designed, however, to burn low sulfur coal. Ash from low sulfur coal has a higher resistivity than ash from the moderate sulfur coal that Blue Ridge Paper burns in these boilers. G-66 burns washed, low sulfur coal subject to new source performance standards (NSPS) with a limit of 1.2 lbs SO2/MMBtu.
Based on information from Blue Ridge Paper Products, this lower sulfur coal is $75–$90/ton SO2, and the other coal used at the facility is $65/ton SO2, EPA noted. The cost difference is $10–25/ton SO2. The company burned 277,214 tons of higher sulfur coal in 2005; switching to lower sulfur coal would cost about $2,772,140–$6,930,350 extra per year. If 1,400 tons of SO2 were reduced by switching from the current higher sulfur coal (one percent sulfur or approximately 1.6 lbs SO2/MMBtu) to lower sulfur coal (0.75 percent sulfur or approximately 1.2 lb SO2/MMBtu) at the 2005 rate of coal consumption, associated costs would range from $1,980–$4,950/ton SO2 with an average cost of $3,465/ton SO2.
NCDAQ determined that the cost for add-on control technology for these units ranges from $12,055 to $100,961/ton SO2. NCDAQ concluded that there are no cost-effective controls available for these units at this time within the cost threshold established for this reasonable progress assessment. Although NCDAQ has concluded that there are no cost-effective controls for this reasonable progress period, the state acknowledges that the emissions from Blue Ridge Paper Products impact North Carolina’s inland Class I areas.
NCDAQ notified the company that although additional controls are not required during this implementation period, the state may require the installation and operation of controls for future implementation periods. NCDAQ is committed to working with this company over the next review period and encouraging the company to modernize some of its processes with more efficient equipment with lower emissions.
Controls at Weyerhaeuser deemed too expensive
Weyerhaeuser, at its Plymouth facility, has three power boilers subject to analysis: Riley No. 1 Combination Boiler, No. 1 Hog Fuel Boiler, and No. 2 Hog Fuel Boiler. The Riley No. 1 Combination Boiler burns coal, No. 6 fuel oil, Low Volume High Concentration (LVHC) gases, and Stripper Off Gas (SOG) gases. The No. 1 Hog Fuel Boiler burns hog fuel (wood waste), No. 6 fuel oil, coal, used oil, sludge, and High Volume Low Concentration (HVLC) gases. The No. 2 Hog Fuel Boiler burns hog fuel, No. 6 fuel oil, coal, used oil, sludge, HVLC, LVHC, and SOG gases.
NCDAQ did not identify any available controls for the Hog Boiler 1 or 2. For the Riley Boiler, the only available control that NCDAQ identified is a flue gas desulfurization (FGD) scrubber at a cost of $20,460/ton SO2. Therefore, NCDAQ concluded that there are no cost-effective controls for these units at this time within the cost threshold established for this reasonable progress assessment.
Kenansville plant to excise coal from permit
The Cogentrix Kenansville plant has one affected emissions unit, which is Gen1, a 215 MMBtu/hr heat input mixed fuel-fired electric generating unit capable of burning coal, natural gas, No. 2 and No. 4 fuel oil, tire-derived fuel, pelletized paper fuel, flyash briquette and wood. Although the company retains coal as a permitted fuel on the permit, it is currently burning unadulterated wood (pure wood with up to 5% impurities), and its new business plan is to continue burning only wood as part of the ‘‘green power’’ movement in North Carolina.
The 2005 actual SO2 emissions for Gen1 were 23.25 tons, whereas the projected 2018 SO2 emissions were 1,833.8 tons based on using coal. In the final SIP submittal, the NCDAQ stated that it is sending the company a letter indicating that they are currently on the list of sources contributing greater than 1%to the total sulfate visibility impairment at the Swanquarter Wilderness Area based on the estimated emissions from burning coal. The SIP submittal indicated that the letter will suggest that the facility change its permit to remove coal as a possible fuel source for this unit.