The U.S. Environmental Protection Agency, in a notice to be published in the July 30 Federal Register, offers the latest of a series of decisions on a regional haze plan for the state of Arizona.
EPA is approving Arizona’s determination that the coal-fired Cholla Unit 1 and the gas-fired Sundt Unit 3 are not best available retrofit technology (BART)-eligible.
EPA is disapproving Arizona’s determination that the coal- and gas-fired Sundt Unit 4 is not BART eligible. EPA is required to conduct BART analyses in an upcoming federal implementation (FIP) for Sundt Unit 4.
The July 30 final notice also covers various other things, including regional haze findings for the Chemical Lime Nelson Kilns 1 and 2, the Hayden Smelter (NOx and SO2), and the Miami Smelter (NOx and SO2). Other areas covered include Arizona’s Reasonable Progress Goals and Long-Term Strategy.
The July 30 notice, which is 127 pages long, also addressed the comments on various parties on EPA’s December 2012 proposed haze plan. For example: “Two commenters (Earthjustice, [National Park Service]) supported EPA’s proposal to disapprove the State’s determination that Sundt Unit 4 is not BART-eligible, arguing that Sundt Unit 4 is BART-eligible despite a 1987 coal-conversion reconstruction because it never underwent New Source Review/Prevention of Significant Deterioration (NSR/PSD) review as part of the reconstruction. Earthjustice and NPS further asserted that Sundt Unit 4 causes and contributes to visibility impairment and is therefore subject to BART. In contrast, [Tucson Electric Power] and [the Arizona Department of Environmental Quality] argued that Sundt Unit 4 is not BART-eligible because it was reconstructed in 1987 and the BART Guidelines specify that ‘any emissions unit for which a reconstruction ‘commenced’ after August 7, 1977, is not BART-eligible.’”
EPA responded: “We do not agree with ADEQ and TEP that we ignored the BART Guidelines in finding Sundt Unit 4 to be BART-eligible. On the contrary, we carefully considered the BART Guidelines’ statement that, ‘any emissions unit for which a reconstruction ‘commenced’ after August 7, 1977, is not BART-eligible.’”
Related to two coal units, EPA said: “TEP agreed with EPA’s conclusion that it is not reasonable to require additional SO2 controls on Springerville Units 1 and 2. Two commenters (Earthjustice and NPS) disagreed with EPA’s conclusion. TEP stated that Springerville Units 1 and 2 are equipped with dry FGD systems for SO2 control, which operate at greater than 90-percent control efficiency, and both systems were upgraded as recently as 2006 reducing the emission rate from these units to between 0.17 and 0.26 lb/MMBtu on an annual average basis.”
In its notice of Dec. 21, 2012, EPA proposed to approve Arizona’s determination that specific units at the following six sources are eligible for BART: ASARCO Hayden Smelter (Hayden Smelter); Freeport-McMoRan Inc. Miami Smelter (Miami Smelter); Chemical Lime Nelson Plant (Nelson Lime Plant) Kilns 1 and 2; Arizona Public Service West Phoenix Power Plant (West Phoenix Power Plant) Combined Cycle Units 1 through 3; CalPortland Rillito Cement Plant (Rillito Cement Plant) Kiln 4; and Catalyst Pulp Mill in Snowflake (Catalyst Paper) Power Boiler 2.
EPA at that time proposed to disapprove Arizona’s determination that Tucson Electric Power’s Sundt Unit 4 is not eligible for BART. Finally, it proposed to approve the state’s determination that no other units in the state are BART-eligible. In particular, it proposed to approve the state’s finding that Cholla Power Plant Unit 1 and Sundt Unit 3 are not BART-eligible. In a notice of May 20, 2013, EPA proposed to approve revisions to the sets of BART-eligible units at the Hayden and Miami smelters.
Tucson Electric’s website shows that Sundt Unit 4 can operate on either coal (110 MW of capacity when on this fuel) or gas (156 MW). The utility’s integrated resource plan issued in April 2012 said that the unit is planned to run on coal during the plan forecast period, but that this intention will be re-examined as time goes along.
EPA proposed to approve the state’s determination that no other units in the state are BART-eligible. In particular, EPA proposed to approve the state’s finding that the coal-fired Cholla Unit 1 and gas-fired Sundt Unit 1 are not BART eligible. Sundt 1-3 are fired primarily with natural gas.