EPA extends comment period on controversial Wyoming haze plan

The U.S. Environmental Protection Agency said in a notice to be published in the July 8 Federal Register that it has scheduled additional public hearings for its proposed action on Wyoming’s State Implementation Plan (SIP) addressing regional haze.

“We are making this change in response to letters submitted by the Governor of Wyoming on June 13, 2013, the Wyoming Congressional Delegation on June 14, 2013, and the Wyoming Department of Environmental Quality on June 14, 2013,” the notice explained. “The comment period for this action was scheduled to close on August 9, 2013. EPA is extending the comment period to August 26, 2013 to allow for a full 30 days for the submission of additional comments following the public hearings.”

Public hearings are scheduled to be held on July 17 in Cheyenne, Wyo., and on July 26 in Casper, Wyo.

In the June 10 notice, EPA proposed to partially approve and partially disapprove a SIP submitted by Wyoming in January 2011. EPA is also proposing a Federal Implementation Plan (FIP) to address the deficiencies identified in the proposed partial disapproval of Wyoming’s SIP related to coal-fired power plants.

“In lieu of our proposed FIP, or a portion thereof, we will propose approval of a SIP revision as expeditiously as practicable if the State submits such a revision and the revision matches the terms of our proposed FIP,” EPA said in the June 10 notice. “We will also review and take action on any regional haze SIP submitted by the state to determine whether such SIP is approvable, regardless of whether or not its terms match those of the FIP.”

EPA is proposing to disapprove various things, including:

  • The state’s NOx best available retrofit technology (BART) determinations for PacifiCorp‘s Dave Johnston Unit 3, PacifiCorp/Idaho Power‘s Jim Bridger Units 1 and 2, PacifiCorp’s Wyodak Unit 1, and Basin Electric Power Cooperative’s Laramie River Station Units 1, 2, and 3.
  • The state’s NOx reasonable progress determination for PacifiCorp’s Dave Johnston Units 1 and 2.
  • The state’s Reasonable Progress Goals (RPGs).

EPA proposed to approve the remaining aspects of the state’s January 2011 SIP submittal. It also previously sought comment on two alternative proposals related to the state’s NOx BART determination for PacifiCorp Jim Bridger Units 1 and 2. It proposed the promulgation of a FIP to address the deficiencies in the Wyoming regional haze SIP that it identified in the proposal. 

In lieu of the proposed FIP, or a portion thereof, EPA previously stated that it would propose approval of a SIP revision if the state submits such a revision and the revision matches the terms of the proposed FIP. EPA said it encouraged the state to submit a SIP revision to replace the FIP, either before or after its final action.

EPA plan relies heavily on costly SCR for NOx control

The NOx compliance findings by EPA for each power plant are:

  • Laramie River – Basin Electric’s Laramie River Station has three 550-MW dry-bottom, wall-fired boilers (Units 1, 2, and 3), burning subbituminous coal for a total net generating capacity of 1,650 MW. All three units are subject-to-BART. EPA proposes to find that at an emission limit of 0.07 lb/MMBtu (30-day rolling average), which can be achieved by the installation of new Low NOx Burners (LNBs) with Overfire Air (OFA) plus SCR. It is proposing that the FIP NOx BART limit for Laramie River Units 1-3 is 0.07 lb/MMBtu (30-day rolling average), with five years from when the FIP is final for compliance.
  • Dave Johnston – PacifiCorp’s Dave Johnston plant is comprised of four units burning pulverized sub-bituminous Powder River Basin coal. Units 3 and 4 are the only units subject-to-BART. Dave Johnston Unit 3 is a nominal 230 MW pulverized coal-fired boiler that commenced service in 1964. It was equipped with burners in a cell configuration until 2010, but was then converted to a dry bottom wall-fired boiler. Dave Johnston Unit 4 is a nominal 330 MW pulverized coal-fired boiler that commenced service in 1972. It is a tangential-fired boiler. EPA proposes to find that LNBs with OFA plus SCR at an emission limit of 0.07 lb/MMBtu (30-day rolling average) is reasonable for NOx BART for Dave Johnston Unit 3. EPA proposes that new LNBs with OFA plus SNCR at an emission limit of 0.12 lb/MMBtu (30-day rolling average) is reasonable for Dave Johnston Unit 4. Both units would have five years to comply.
  • Jim Bridger – PacifiCorp/Idaho Power’s Jim Bridger plant has four nominal 530-MW tangentially-fired boilers burning pulverized coal for a total net generating capacity of 2,120 MW. EPA is seeking comment on a first proposal to approve the regional haze plan submitted by the state for Jim Bridger Unit 1 and Unit 2. EPA also is seeking comment on another alternative approach that would determine that BART for Units 1 and 2 at Jim Bridger is SCR, and would establish corresponding NOx emission limits for these units that would have to be achieved within five years of final action on the FIP. This would have the effect of accelerating the installation of the SCR controls at these units that the state and PacifiCorp had proposed to install in the 2021-2022 time-period. The state determined that BART for these units is LNB plus OFA, and selected the 2021-2022 time-period for SCR-based emission limits as a reasonable progress measure. The timeframe was based on the large number of actions PacifiCorp is undertaking (or helping to finance) at a large number of power units in Wyoming, Utah, Colorado, and Arizona. Under the second proposed approach, EPA would propose that it does not agree with the state’s conclusion that a limit of 0.26 lb/MMBtu is reasonable for BART for Jim Bridger Units 1 and 2, which can be achieved with the installation and operation on LNBs with OFA. Under the second approach, EPA would find that LNBs with SOFA plus SCR at an emission limit of 0.07 lb/MMBtu (30-day rolling average) is reasonable for Jim Bridger Units 1 and 2, with compliance mandated within five years of the final FIP being put in place, advancing the SCR installation schedule under the existing plan.
  • Naughton – PacifiCorp’s Naughton plant has three pulverized coal-fired units with a total net capacity of 700 MW. Naughton Unit 1 generates a nominal 160 MW, Naughton Unit 2 generates a nominal 210 MW and Naughton Unit 3 generates a nominal 330 MW. All three boilers are tangentially fired boilers. EPA proposes to find that new LNBs with OFA plus SCR at an emission limit of 0.07 lb/MMBtu (30-day rolling average) is reasonable for Naughton Units 1 and 2, with five years given to comply. The state determined that NOx BART for Naughton Unit 3 was existing LNBs plus OFA with SCR with an emission limit of 0.07 lb/MMBtu (30-day rolling average). EPA found this determination to be reasonable. It is also asking if interested parties have additional information regarding the possible conversion of Naughton Unit 3 from a coal-fired unit to a natural gas-fired unit as part of a better-than-BART demonstration.
  • Wyodak – PacifiCorp’s Wyodak plant has one coal-fired boiler, Unit 1, burning pulverized sub-bituminous Powder River Basin coal for a total net generating capacity of a nominal 335 MW. Wyodak’s boiler commenced service in 1978. EPA proposes to find that new LNBs with OFA plus SNCR at an emission limit of 0.17 lb/MMBtu (30-day rolling average) is reasonable for NOx BART for Wyodak Unit 1, with five years from the final FIP given for compliance.
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.