The U.S. Environmental Protection Agency said in a July 2 Federal Register notice that it is finalizing a limited approval of revisions to the state of Ohio’s regional haze State Implementation Plan (SIP) related to coal-fired industrial boilers of P.H. Glatfelter (NYSE: GLT) at Chillicothe, Ohio.
The state had submitted the revision in March 2011, addressing regional haze for the first implementation period that ends 2018. EPA’s approval of the revision becomes effective Aug. 1.
EPA proposed a limited approval of Ohio’s submittal on Jan. 25 and that proposal provided a lengthy delineation of the requirements that Ohio intended to meet and that EPA proposed to approve, including requirements for mandating best available retrofit technology (BART), consultation with other states in establishing goals representing reasonable further progress in mitigating anthropogenic visibility impairment, and adoption of limitations as necessary to implement a long term strategy (LTS) for reducing visibility impairment.
Of particular interest were EPA’s proposed findings regarding BART. Using modeling performed by the Lake Michigan Air Directors Consortium (LADCO), Ohio identified one nonelectric generating unit (non-EGU) source, the P.H. Glatfelter facility in Ross County, as having sufficient visibility impact to warrant being subject to a requirement representing BART.
Ohio determined that BART was the use of flue gas desulfurization (FGD) on the two BART-subject boilers. P.H. Glatfelter then requested limits that would allow an alternative strategy. In response to P.H. Glatfelter’s request, Ohio adopted SO2 limits governing the combined emissions from P.H. Glatfelter’s boilers #7 and #8, with limits requiring FGD more stringent than BART on individual boilers. In the notice of proposed rulemaking, EPA proposed to approve Ohio’s alternative-to-BART limits for SO2, and continued operation of particulate matter (PM) and NOX controls for P.H. Glatfelter.
During the public comment period on the Jan. 25 proposed approval, EPA received comments from the U.S. Forest Service (FS), the U.S. National Park Service (NPS), the Ohio Utility Group, and Earthjustice (on behalf of organizations representing the National Parks Conservation Association, Natural Resources Defense Council and the Sierra Club).
Among the comments were FS and NPS recommending additional review of the BART determination for P.H. Glatfelter. The commenters asserted that the alternative BART determination for P.H. Glatfelter, boilers #7 and #8, may not result in equivalent reduction in SO2 emissions compared to application of BART. NPS commented that the SO2 emission limit of 24,930 pounds per day (4,550 tons per year), represents only a 77% reduction from 2002 emission rates.
NPS agreed with Ohio’s determination that P.H. Glatfelter’s alternative BART approach to include a process capable of 90% SO2 removal was appropriate. However, NPS believes that because P.H. Glatfelter could also choose to operate its boilers at reduced capacity or shut down one boiler, and still meet the emission limit with no additional control of SO2, this does not meet the intent of the BART regulation.
In response, EPA said it believes that Ohio has used an adequate representation of emissions for the baseline period. EPA believes further that Ohio’s alternative BART limit for SO2 is slightly more stringent than what BART would achieve.
Headquartered in York, Pa., Glatfelter is a global manufacturer of specialty paper and engineered products. The company said in a March 9 Form 10-K filing: “Currently, we anticipate that we could incur material capital and operating costs to comply with several air quality regulations including the U.S. EPA Best Available Retrofit Technology rule (BART; otherwise known as the Regional Haze Rule) and the Boiler Maximum Achievable Control Technology rule (Boiler MACT). For example, on March 21, 2011, the U. S. Environmental Protection Agency issued new rules which could require process modifications and/or installation of air pollution controls on power boilers at two of our U.S.- based facilities. We are currently reviewing these rules, and challenges to them filed by others in the court system, to understand the effect they may have on our operations if we are required to comply with the rules in their current form. We are also evaluating options that may be available to us, such as reducing or curtailing boiler usage or modifying the types of boilers operated or fuel consumed. The cost of compliance is likely to be significant. Our initial estimates to implement viable options could result in additional capital spending in excess of $30 million, however, the amount ultimately incurred may be less depending on the outcome of challenges to current rules or on our successful implementation of appropriate available options. In addition, the timing of any additional capital spending is uncertain.”
NPS noted in its Feb. 22 comments to EPA that both Glatfelter units are pulverized coal facilities, with boiler 7 having a capacity of 422 mmBtu/hr and boiler 8 with 505 mmBtu/hr. The Ohio BART proposal was semi-dry FGD with 90% SO2 removal. The BART alternative is an unspecified control technology or permanent shutdown of both boilers.