EPA issues federal air limits for a Danskammer coal unit, Roseton plant

The U.S. Environmental Protection Agency is taking final action on the Regional Haze State Implementation Plan (SIP) submitted by the state of New York, approving seventeen source-specific SIP revisions containing permits for Best Available Retrofit Technology (BART) and a section of the New York Environmental Conservation Law which regulates the sulfur content of fuel oil.

These revisions to the SIP were submitted by the state of New York in March 2010, and supplemented in August 2010, then on April 16 and July 2, EPA noted in an Aug. 28 Federal Register notice. Although New York addressed most of the issues identified in EPA’s proposal, EPA is promulgating a Federal Implementation Plan (FIP) to address two sources where EPA is disapproving New York’s BART determinations. This rule is effective on Sept. 27.

EPA is approving aspects of New York’s Regional Haze SIP revision, including:

  • The measures enacted by New York are shown to produce emission reductions sufficient to meet New York’s share of the reductions needed to meet reasonable progress goals at Class I areas affected by in-state emissions.
  • New York’s Long Term Strategy, since the state submitted final approvable permit modifications for all facilities on April 16, 2012 and July 2, 2012 (except for the Roseton and Danskammer power plants), in a timely manner with the level of control in EPA’s April 25 proposal.

EPA’s FIP contains BART determinations and emission limits for Roseton and Danskammer. Affected plants in the source-specific revisions include: Arthur Kill Generating Station [NRG Energy]; Bowline Generating Station [GenOn]; Con Edison 59th Street Station; EF Barrett Power Station [National Grid (NG)]; Northport Power Station [NG]; Oswego Harbor Power [NRG]; Ravenswood Generating Station [TransCanada]; Ravenswood Steam Plant [Con Edison]; Roseton—Dynegy (NOX and PM limits only); Samuel A Carlson Generating Station [Jamestown Board of Public Utilities]; and Syracuse Energy [GDF Suez].

EPA is disapproving New York’s SO2 BART determinations and emissions limits for Units 1 and 2 of Dynegy’s gas-fired Roseton plant. It is also disapproving New York’s SO2, NOX and particulate matter (PM) BART determinations and emissions limits for the coal-fired Unit 4 of Dynegy’s Danskammer plant.

For Danskammer Unit 4, the FIP limits are:

  • 0.12 lbs/MMBtu of NOx, to be met on a 24-hour average during the ozone season (May through September) and a 30-day rolling average the rest of the year, and a requirement that the owners/operators comply with this NOX BART limit by July 1, 2014.
  • The SO2 BART determination is 0.09 lb/MMBtu, to be met on a 24-hour average, and a requirement that the owners/operators comply with this SO2 BART limit by July 1, 2014.
  • The PM BART determination is 0.06 lb/MMBtu, to be met on a one-hour average, and a requirement that the owners/operators comply with this PM BART limit by July 1, 2014.

For Roseton, the SO2 BART determination and an emission limit for Unit 1 and Unit 2 is 0.55 lb/ MMBtu, to be met on a 24-hour average, and a requirement that the owners/operators comply with this SO2 BART limit by Jan. 1, 2014.

New York’s April 16 SIP revisions request that EPA include in New York’s Regional Haze SIP the New York State legislation regulating the sulfur content of fuel oil, Bill Number S1145C, which amends the New York Environmental Conservation Law to include a new section 19–0325, effective July 15, 2010. Major SO2 emission reductions are obtained as a result of the legislation being implemented. These reductions are occurring in 2012, well before a 2016 regional haze requirement. EPA proposed to determine that New York’s low sulfur fuel oil strategy in combination with other steps will provide the necessary in-state reductions for other Class I areas to meet their respective Reasonable Progress Goals.

EPA in the Aug. 28 notice also responded to several comments on its April 25 proposed rulemaking, including this response to an Earthjustice comment about Danskammer Unit 4: “EPA concludes that Earthjustice’s recommended BART technology, i.e., SCR, with an emission limit of 0.05 lb/MMBtu, would not be expected to provide any significant improvement in visibility at the seven Class I areas over Dynegy’s proposed BART implementation of a combination of specific possible controls with an emission limit of 0.12 lb/MMBtu. Therefore, EPA concludes that NOX BART for Danskammer Unit 4 is unchanged from our April 25, 2012 proposal, i.e., an emission limit of 0.12 lb/MMBtu by the optimization of existing Level II Low NOX Burners emission controls, co-firing with natural gas, installation of post-combustion controls, use of alternative coals, or any combination thereof.”

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.