Coal-fired unit shutdowns covered by New York haze plan

The U.S. Environmental Protection Agency is proposing to only partially approve a revision to the State Implementation Plan (SIP) addressing regional haze submitted by the state of New York, including rejection of Best Available Retrofit Technology (BART) determinations for several power plants.

New York submitted the revised SIP to EPA in March 2010, and supplemented it in August 2010. New York’s revised SIP reduces regional haze during the first planning period from 2008 through 2018. EPA is proposing a Federal Implementation Plan (FIP) to address the deficiencies identified in the proposed partial disapproval of New York’s regional haze SIP. In lieu of this proposed FIP, or a portion of it, EPA is proposing approval of a SIP revision if the state submits such a revision in a timely way, and the revision matches the terms of the proposed FIP. EPA is also proposing approval of New York’s BART regulation.

Comments on the EPA actions are being taken until June 18, with a public hearing, if requested to be held on May 16 in New York City.

EPA proposes to disapprove the following BART determinations:

  • New York’s SO2 BART determinations and emissions limits for Units 1 and 2 of Dynegy’s Roseton plant.
  • New York’s SO2 BART determinations and emissions limits for Unit 4 of Dynegy’s Danskammer plant.
  • New York’s SO2, NOX and Particulate Matter (PM) emissions limits for Boiler 42 of Eastman Kodak’s Eastman Business Park.

Also, EPA proposes to disapprove the following facility BART determinations and emission limits because while New York has proposed permit modifications, New York has not issued final permit modifications or submitted them to EPA as a SIP revision. This includes New York’s SO2, NOX and PM BART determinations and emissions limits at the following facilities:

  • Bowline Point Generating Station [GenOn]
  • Danskammer [Dynegy]
  • Owens Corning Delmar Plant
  • Oswego Harbor Power [NRG Energy]
  • Syracuse Energy [GDF Suez]
  • Kodak Park Division

EPA proposes to disapprove the following facility BART determinations and emission limits because New York has not submitted final permit modifications to EPA as a SIP revision. EPA said it has reviewed the BART determinations for these facilities and New York has issued final permit modifications. EPA would propose to approve these final permit modifications, but New York has not submitted them to EPA as SIP revisions. Therefore EPA proposes to disapprove the following and proposes a FIP to address this deficiency. This covers New York’s SO2, NOX and PM BART determinations and emissions limits for the following facilities:

  • EF Barrett Power Station [National Grid]
  • Northport Power Station [National Grid]
  • 59th Street Station [Consolidated Edison]
  • Arthur Kill Generating Station [NRG]
  • Ravenswood Generating Station [TransCanada]
  • Ravenswood Steam Plant [Con Edison]
  • Roseton Generating Station [Dynegy]
  • Holcim (US) Inc.—Catskill Plant
  • Lafarge Building Materials
  • International Paper Ticonderoga Mill
  • Lehigh Northeast Cement
  • ALCOA Massena Operations (West Plant)
  • Samuel A Carlson Generating Station [Jamestown Board of Public Utilities]

EPA proposes to approve the remaining aspects of New York’s Regional Haze SIP revision, including New York’s determination under the reasonable progress requirements that all measures or their equivalents found to be reasonable by the state, and agreed to by the MANE-VU states, have been enacted and implemented. New York’s Long Term Strategy will be approvable only if New York submits all of the final permit modifications in a timely manner, and with the level of control in EPA’s proposed FIP. The MANE-VU “states” are Massachusetts, Rhode Island, Connecticut, New York, New Jersey, Pennsylvania, Maryland, the District of Columbia, the Penobscot Nation and the St. Regis Mohawk Tribe.

EPA proposes in the alternative to approve the following BART determinations and emissions limits should New York submit final permit modifications to EPA as SIP revisions, and the revisions match the terms of EPA’s proposed FIP:

  • Bowline Point Generating Station [GenOn]
  • Danskammer [Dynegy]
  • Owens Corning Delmar Plant
  • Oswego Harbor Power [NRG]
  • Syracuse Energy [GDF Suez]
  • Kodak Park Division
  • EF Barrett Power Station [National Grid]
  • Northport Power Station [National Grid]
  • 59th Street Station [Con Edison]
  • Arthur Kill Generating Station [NRG]
  • Ravenswood Generating Station [TransCanada]
  • Ravenswood Steam Plant [Con Edison]
  • Roseton Generating Station [Dynegy]
  • Holcim (US) Inc—Catskill Plant
  • Lafarge Building Materials
  • International Paper Ticonderoga Mill
  • Lehigh Northeast Cement
  • ALCOA Massena Operations (West Plant)
  • Samuel A Carlson [Jamestown Board of Public Utilities]

Syracuse Energy, Jamestown plan to retire coal capacity

EPA noted that the owners of BART eligible units at four of the nineteen facilities have decided to shut down those units rather than install BART to control emissions of NOX, SO2, and PM. The four facilities include Lafarge Building Materials, Syracuse Energy, Samuel A. Carlson and Holcim (US) – Catskill Plant. New York will be including the compliance shutdown dates in either final State Facility permits or final Title V permits and submitting them to EPA for approval as a SIP revision by mid-2012, after the opportunity for public comment.

Syracuse Energy has a plant located in Geddes that has a coal-fired boiler (Unit 1) with a heat input greater than 250 mmBtu/hr that is BART eligible. In a letter to New York dated September 2010, Syracuse Energy offered to shut the unit by Jan. 1, 2014. EPA is proposing to approve New York’s decision that Unit 1 will permanently shut down by Jan. 1, 2014, and is exempt from implementing any BART controls.

Samuel A. Carlson (SAC) is a municipal electric power generating plant owned and operated by the Jamestown Board of Public Utilities. The facility has three coal-fired boilers (Boilers #9, #10 and #12) with a combined output of 49 MW. New York has determined that Boiler 12 is BART eligible and Jamestown has decided to permanently shut down Boiler 12 by Jan. 1, 2014, in order to be exempt from the BART requirements for that unit. EPA is proposing to approve New York’s decision that Unit 12 will permanently shut down by Jan. 1, 2014 and is exempt from implementing any BART controls.

EPA rejects SO2 plan for Danskammer coal unit

Various emissions controls have been proposed by the state of New York for the various BART-eligible units. For example, Dynegy Northeast Generation has operated a 235-MW unit at the Danskammer plant in Orange County. Notable is that Dynegy companies that control this unit are in bankruptcy and giving up these assets. New York has determined that Boiler Unit 4 is BART eligible.

Boiler 4 is a tangentially coal-fired steam generating boiler and is capable of firing coal, No. 6 fuel oil and natural gas, with coal as the primary fuel. Boiler 4 has existing NOX emission controls of low excess air, combustion air manipulation, separated overfire air, burners out of service, and low NOX burners; PM emissions are controlled with an existing cold side electrostatic precipitator; and SO2 emissions are controlled through limitations on the sulfur content (0.7%) of the coal.

For control of SO2 emissions, New York is proposing that BART for Boiler 4 is the lowering of the current SO2 permit limit from 1.1 lbs/mmBtu to 0.50 lbs/mmBtu. According to Dynegy’s analysis, the flue gas desulfurization (FGD) and dry sorbent injection control options all have energy and adverse non-air quality environmental impacts, including solid waste disposal issues. Gas co-firing and coal switching were also looked at and rejected. EPA said it is disapproving the SO2 part of the Unit 4 BART determination by New York. “Our proposed disapproval is based in large part on Dynegy’s own BART analysis, showing that FGD controls and/or combusting natural gas are cost effective and would result in enough incremental visibility improvement at a single Class I area to justify the incremental cost of the control strategies.”

New York proposes that for the control of NOX emissions, BART for Boiler 4 is the lowering of the current NOX permit limit from 0.42 lbs/mmBTU to 0.12 lbs/mmBTU. This BART control option is based on optimizing the existing low NOX burners, co-firing with natural gas, installation of post combustion controls, use of alternative coals, or any combination thereof. For the control of PM emissions, Danskammer Unit 4 currently has a cold side electrostatic precipitator (ESP) that achieves an average 99.98% control efficiency, so the PM BART limit has been set based on that existing installation.

Another example is Eastman Kodak’s Eastman Business Park, which has mainly three coal-fired boilers – Boilers 41, 42 and 43 – which are BART eligible. The three units are cyclone type boilers that combust bituminous coal with a maximum sulfur content of 2.5%. The boilers are also capable of combusting Number 6 fuel oil with up to 1.5% sulfur content. All three units are equipped with ESP to control PM emissions and natural gas reburn to control emissions of NOX and SO2.

A draft Title V permit for the plant, issued for public comment by the state on April 4, said that: Boiler 41 is to permanently retire by Dec. 31, 2013; Boiler 42 is to either permanently retire or repower by the Boiler MACT compliance date but not later than Aug. 16, 2017; and there are no changes, including coal sulfur limit, for Boiler 43. EPA has told the state that the agency agrees with the draft permit’s BART requirements except that an emission limit for NOX is required for Boiler 42 should Kodak decide to repower this boiler with natural gas.

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.