The U.S. Environmental Protection Agency is finalizing a full approval of the regional haze state implementation plan (SIP) from the Florida Department of Environmental Protection (FDEP), in March 2010, as amended in August 2010 and September 2012.
This final approval affects several oil- and coal-fired units in the state, EPA said in a notice to be published in the Aug. 29 Federal Register. Florida’s SIP submittal addresses regional haze for the first implementation period.
EPA is now finalizing full approval of all remaining portions of the Florida regional haze SIP as proposed in May 2012 and December 2012, including the remaining best available retrofit technology (BART) and reasonable progress determinations in Florida’s September 2012 amendment to the regional haze SIP submission not previously addressed in EPA’s November 2012 final action.
In October 2012 and on May 2, FDEP submitted supplemental information and documentation for coal units at Duke Energy’s (NYSE: DUK) Crystal River facility. Additionally, FDEP submitted a letter to EPA dated July 30 in which it committed to provide EPA with a regional haze SIP revision no later than March 19, 2015, the deadline for the state’s five-year regional haze periodic progress report, that will include a NOx BART emissions limit for the coal-fired Crystal River Unit 1 reflecting best operating practices for good combustion.
The BART determinations addressed by EPA’s November 2012 final action had included: Tampa Electric’s coal-fired Big Bend Units 1-3; City of Tallahassee-Purdom Generating Station (Unit 7); Florida Power & Light (FPL)-Port Everglades Power Plant (Units 3, 4); City of Gainesville-Deerhaven Generating Station (Unit 3); City of Tallahassee-Arvah B. Hopkins Generating Station (Unit 4); FPL-Riviera Power Plant (Unit 4); and Lakeland Electric-Charles Larsen Memorial Power Plant (Unit 4).
EPA addresses criticism of aspects of final haze plan
In the Aug. 29 notice, EPA responds to a series of comments on the Florida SIP.
For example, one commenter contended that FDEP improperly rejected wet flue gas desulfurization (FGD) as BART for the coal-fired Units 1 and 2 at Gulf Power’s Lansing Smith plant. The commenter states that it would be arbitrary and capricious for EPA to approve the BART determination because the analysis inflated the cost-effectiveness of wet FGD by using an emissions limit of 0.15 lb/MMBtu of SO2 rather than the removal efficiency potential of 95% identified by Gulf Power and by not evaluating the most stringent control efficiency associated with wet FGD (asserted to be 98% or greater). The commenter also states that wet FGD is cost-effective even using the “flawed” values provided in the SIP because Florida’s values are “still easily within the range which EPA has already determined to be cost-effective elsewhere” and because they are lower than cost-effectiveness values associated with BART controls adopted by FDEP at FPL’s Manatee power plant.
EPA, in response, noted that in evaluating the statutory BART factors for FGD, FDEP most heavily weighed the lack of visibility improvement associated with this control technology for Lansing Smith, not the cost of control. States have the flexibility to determine the weight and significance of each factor. As discussed in EPA’s December 2012, proposal, the model predicted limited visibility improvements considering both the absolute visibility benefits of FGD from the baseline as well as the incremental benefits from the use of FGD over dry sorbent injection (DSI). FDEP concluded that the predicted incremental improvements in visibility were not sufficient in light of the costs to warrant the selection of FGD as BART, regardless of whether FGD is cost-effective on a dollars per ton basis.
In response to criticism about Duke’s coal-fired Crystal Rivers Unit 1 and 2, EPA pointed out that the company has recently agreed to shut those units, making the criticism somewhat moot.
“On May 2, 2013, FDEP supplemented Florida’s regional haze SIP with an April 30, 2013, letter from Duke Energy (formerly known as Progress Energy) notifying FDEP of the Company’s binding decision to pursue Option 1 under the Crystal River BART construction permit and shut down Units 1 and 2 by December 31, 2020,” EPA wrote. “Pursuant to the construction permit, which was incorporated into Florida’s regional haze SIP, Duke Energy’s binding determination renders Option 2 and the corresponding permit provisions allowing for the implementation of Option 2 void. Today’s final action approving Florida’s regional haze SIP makes this shutdown requirement federally enforceable.”