Gulf Power will make a final decision by Jan. 1, 2015, on a Best Available Retrofit Technology (BART) Implementation Plan which includes the installation of a scrubber, or a commitment to a unit specific retirement date, or a new permit limit sufficient to exempt out of BART.
Gulf Power, a unit of Southern Co. (NYSE: SO), said in a May 21 filing at the Florida Department of Environmental Protection that the Lansing Smith BART Implementation Plan includes a plan to complete a BART five-factor analysis for Smith Units 1 and 2 relative to visibility impairment at Saint Marks, the only Class 1 regional haze protection area within 300 kilometers of the plant.
The analysis will include cost, remaining useful life and visibility improvement factors focusing on maximum level control-technology for SO2, NOx and particulate matter (PM). Gulf Power will make a final decision by Jan. 1, 2015, on the plan. To implement this decision, Gulf Power is applying now for a Florida Air Construction Permit for Smith Units 1 and 2 to:
- Install and operate an SO2 flue gas desulfurization (FGD) scrubber system before Jan. 1, 2018, or within five years of the U.S. Environmental Protection Agency’s final approval of Florida’s final Regional Haze State Implementation Plan (SIP), whichever is later. This system will be designed to meet either 95% removal efficiency of SO2 from Smith Units 1 and 2 or an emission rate limit of 0.15 lb/mmbtu (presumptive BART) from Smith Units 1 and 2.
- Or the company would commit to retire Smith Unit 1 before Jan. 1, 2022, and Smith Unit 2 before Jan. 1, 2021, based upon a “remaining useful life” cost-effectiveness evaluation.
- Or it would agree to a permit limit for SO2 by October 2015 at a level sufficient to exempt out of BART.
Gulf Power will request that these conditions be included in a federally enforceable air permit and incorporated into the Lansing Smith Title V Permit as a specific operating condition.
Gulf previously submitted modeling to the DEP that demonstrated that PM emissions from Smith Units 1 and 2 do not contribute to visibility impairment in any Class I area and should therefore be exempt from BART for PM. The visibility assessment only evaluated impacts from PM because Smith is subject to EPA’s Clean Air Interstate Rule (CAIR) for SO2 and NOx, which EPA determined was “better-than-BART,” alleviating the need to include SO2 and NOx in BART exemption modeling for PM. The Florida DEP subsequently included that exemption in its SIP.
However, in 2008 CAIR was remanded by a federal court and, in July 2011, EPA issued CAIR’s successor, the Cross-State Air Pollution Rule (CSAPR). Currently CSAPR is stayed and CAIR remains in effect pending judicial review. This results in some uncertainty for regional haze purposes because while EPA has proposed that – like CAIR – CSAPR is better-than-BART, CSAPR applies differently in Florida. It only regulates ozone-season NOx and not annual NOx or SO2. As a result, if CSAPR is upheld as is, a BART analysis may be necessary for SO2 and PM emissions. In light of this uncertainty, Florida DEP requested a BART analysis for SO2, NOx and PM emissions for Lansing Smith Units 1 and 2.
Smith options part of broader clean-air planning
Gulf Power filed an air plan April 2 at the Florida Public Service Commission that outlined its options at four coal-fired plants, including Lansing Smith.
There are two coal-fired units at the Smith plant, with Unit 1 having a nameplate capacity of 149.6 MW and Unit 2 at 190.4 MW. Both have various NOx controls, including new selective non-catalytic reduction (SNCR) systems that became operational in the 2008-2009 period. Scrubber equipment for both units are in Gulf Power’s future plans, but that plan remains very flexible as new emissions rules are added and analyzed. A baghouse for Unit 2 is also in the utility’s very flexible future plans. Gulf Power said it hasn’t done a shutdown analysis for these coal units lately, but will do a new one when it gets closer to the time to make the scrubber/baghouse decisions.
An analysis run in 2011 shows it is better to keep Crist Unit 6 in operation, instead of retiring it in December 2014 and replacing it with new gas-fired combined cycle capacity, said Gulf Power. The April 2 plan noted that Crist is a four-unit (Units 4-7) coal-fired plant. Three other units have already been retired. Units 4 and 5 each have nameplate capacity of 93.75 MW, Unit 6 is at 370 MW and Unit 7 at 578 MW.
All four Crist units have low-NOx burners. Units 4-6 also have SNCR for NOx control. Unit 7 has selective catalytic reduction (SCR) for NOx. An SCR for Unit 6 is due to be operational this year. All four units are covered by an SO2 scrubber that became operational in December 2009, which gives the plant the option of burning higher sulfur coal.
Under the U.S. Environmental Protection Agency’s new Mercury and Air Toxics Standards (MATS), Gulf Power is looking at additional controls at Crist, including dry sorbent injection and/or a baghouse, changing the fuel sources for certain units, the addition of new generating resources, and/or transmission upgrades.
Gulf Power also owns 50% of each of the two coal-fired units at the Daniel plant, with the other 50% of each unit held by Mississippi Power, which is another subsidiary of Southern Co. Each of the units has a nameplate capacity of 548.25 MW.
Both Daniel units have low-NOx burners and a major need for new emissions controls to comply with various clean-air programs. SO2 scrubbers for both units are currently scheduled for completion in late 2015. SCRs for both units are planned to be operational in the 2017-2018 period. Analysis shows that these emissions projects are better than shutting the units and replacing them with gas-fired capacity, Gulf Power said.
The old, two-unit (49 MW nameplate for each unit) Scholz plant is nearing retirement, so Gulf Power said it won’t add any new controls there and will simply rely on emissions allowances for the time being.