EPA issues final regional haze rule for Arkansas

U.S. Environmental Protection Agency Administrator Gina McCarthy on Aug. 31 signed a final regional haze finding for the state of Arkansas, which affects several coal-fired generation units, with EPA now submitting this plan for publication in the Federal Register.

The agency has released a pre-publication version of the final rule.

The EPA is promulgating a final Federal Implementation Plan (FIP) addressing the requirements of the Regional Haze Rule and interstate visibility transport for the portions of Arkansas’ Regional Haze State Implementation Plan (SIP) that EPA disapproved in a final rule published in the Federal Register in March 2012. In that action, it partially approved and partially disapproved the state’s plan to implement the regional haze program for the first planning period. This Aug. 31 final rule addresses requirements for Best Available Retrofit Technology (BART).

The FIP includes sulfur dioxide (SO2), nitrogen oxide (NOX), and particulate matter (PM) emission limits for nine units located at six facilities to address BART requirements (these limits also satisfy reasonable progress requirements for these sources); and SO2 and NOX emission limits for two units located at one power plant to address the reasonable progress requirements.

This final rule is effective 30 days after it is published in the Federal Register.

The BART sources are: Arkansas Electric Cooperative‘s Carl E. Bailey Generating Station (AECC Bailey) Unit 1; Arkansas Electric Cooperative Corp.‘s John L. McClellan Generating Station (AECC McClellan) Unit 1; American Electric Power‘s Flint Creek Power Plant Unit 1; Entergy‘s White Bluff Plant Units 1, 2, and Auxiliary Boiler; Entergy’s Lake Catherine Plant Unit 4; and Domtar Ashdown Mill’s Power Boilers Nos. 1 and 2. In addition, EPA is establishing SO2 and NOX emission limits for Entergy’s Independence Plant Units 1 and 2 pursuant to the reasonable progress and long-term strategy provisions of the haze rule.

EPA noted that it eceived several comments, from Entergy and the Sierra Club, after the close of the comment period, which included new information on an alternative approach for White Bluff. But it will not address these late comments in this rulemaking and they are not a basis for its decision in this action. “We do note that the new information regarding an alternative approach may have promise with respect to addressing the BART requirements for White Bluff, and we encourage the State to consider it as it develops a SIP revision to replace our FIP,” the federal agency added.

The evaluated plants are:

  • Georgia Pacific-Crossett Mill 6A and 9A Power Boilers: In the FIP proposal, EPA proposed to find that the Georgia Pacific-Crossett Mill 6A Boiler is a BART-eligible source, but not subject to BART. It also proposed to find that the 9A Boiler, which the state had previously determined was BART-eligible, is not subject to BART.
  • AECC Bailey Unit 1: EPA proposed that BART for SO2 and PM is the use of fuels with 0.5% or lower sulfur content by weight. It also proposed to require that, after the effective date of the final rule, the facility shall not purchase fuel that does not meet the sulfur content requirement, but to allow the facility five years to burn its existing supply of No. 6 fuel oil, in accordance with any operating restrictions enforced by the state. It proposed to require the facility to comply with the requirement to use fuels with 0.5% or lower sulfur content by weight no later than five years from the effective date of the final rule. Itproposed that BART for NOX is the existing emission limit in the permit of 887 lb/hr, which would not necessitate the installation of additional controls. It proposed to require the source to comply with this emission limit for BART purposes as of the effective date of the final rule.
  • AECC McClellan Unit 1: EPA proposed that BART for SO2 and PM is the use of fuels with 0.5% or lower sulfur content by weight. It also proposed to require that, after the effective date of the final rule, the facility shall not purchase fuel that does not meet the sulfur content requirement, but to allow the facility five years to burn its existing supply of No. 6 fuel oil, in accordance with any operating restrictions enforced by ADEQ. It proposed to require the source to comply with the requirement to use fuels with 0.5% or lower sulfur content by weight no later than five years from the effective date of the final rule. It proposed that BART for NOX are the existing emission limits in the permit of 869.1 lb/hr for natural gas firing and 705.8 lb/hr for fuel oil firing, which would not necessitate the installation of additional controls. It proposed to require the source to comply with these emission limits for BART purposes as of the effective date of the final rule.
  • AEP Flint Creek Unit 1: EPA proposed that BART for SO2 is an emission limit of 0.06 lb/MMBtu on a 30 boiler-operating-day rolling average, which is consistent with the installation and operation of a type of dry flue gas desulfurization (FGD) system called Novel Integrated Desulfurization (NID) technology. It stated that the full compliance time of five years allowed under the CAA and Regional Haze Rule is appropriate for a new scrubber retrofit, and proposed to require the source to comply with this emission limit no later than five years from the effective date of the final rule. It proposed that BART for NOX is an emission limit of 0.23 lb/MMBtu on a 30 boiler-operating-day rolling average, which is consistent with the installation and operation of new low NOX burners (LNB) with overfire air (OFA). It proposed to require the source to comply with this emission limit no later than three years from the effective date of the final rule.
  • Entergy White Bluff Units 1 and 2: EPA proposed that BART for SO2 for Units 1 and 2 is an emission limit of 0.06 lb/MMBtu on a 30 boiler-operating-day rolling average, consistent with the installation and operation of dry FGD or another control technology that achieves that level of control. It proposed to require the source to comply with this emission limit no later than five years from the effective date of the final rule. It proposed that BART for NOX for Units 1 and 2 is an emission limit of 0.15 lb/MMBtu on a 30 boiler-operating-day rolling average, consistent with the installation and operation of LNB with separated overfire air (SOFA). It proposed to require the source to comply with this emission limit no later than three years from the effective date of the final rule.
  • Entergy White Bluff Auxiliary Boiler: EPA proposed that the existing emission limit in the permit of 105.2 lb/hr is BART for SO2, the existing emission limit of 32.2 lb/hr is BART for NOX, and the existing emission limit of 4.5 lb/hr is BART for PM for the Auxiliary Boiler. These emission limits would not necessitate the installation of additional controls. It proposed to require the source to comply with these emission limits for BART purposes as of the effective date of the final rule.
  • Entergy Lake Catherine Unit 4: EPA proposed that BART for NOX for the natural gasfiring scenario is an emission limit of 0.22 lb/MMBtu on a 30 boiler-operating-day rolling average, consistent with the installation and operation of burners out of service (BOOS). The agency proposed to require the source to comply with this emission limit no later than three years from the effective date of the final rule. It invited public comment specifically on whether this proposed NOX emission limit is appropriate or whether an emission limit based on more stringent NOX controls would be appropriate. It did not propose BART determinations for the fuel oil-firing scenario for Lake Catherine Unit 4 in light of the source’s commitment to submit to Arkansas a five-factor BART analysis for the fuel oil-firing scenario, to then be submitted to EPA as a SIP revision for approval, before any fuel oil combustion takes place at Unit 4. EPA proposed that fuel oil-firing is not allowed to take place at Lake Catherine Unit 4 until BART determinations are promulgated for SO2, NOX, and PM for the fuel oil-firing scenario through its approval of a SIP revision and/or promulgation of a FIP.
  • Domtar Ashdown Mill Power Boiler No. 1: EPA proposed that BART for SO2 is an emission limit of 21.0 lb/hr on a 30 boiler-operating-day averaging basis, where boiler-operating-day is defined as a 24-hour period between midnight and the following midnight during which any fuel is fed into and/or combusted at any time in the Power Boiler. This emission limit is consistent with the Power Boiler’s baseline emissions and would not necessitate additional controls. EPA proposed to require the source to comply with this emission limit as of the effective date of the final rule. It proposed to require the source to use a site-specific curve equation, provided to it by the facility, to calculate the SO2 emissions from Power Boiler No. 1 when combusting bark for purposes of demonstrating compliance with the BART requirement, and to confirm the curve equation using stack testing no later than one year from the effective date of the final rule. EPA also proposed that to calculate the SO2 emissions from fuel oil combustion for purposes of demonstrating compliance with the BART requirement, the facility must assume that the SO2 inlet is equal to the SO2 being emitted at the stack. EPA invited public comment on whether this method of demonstrating compliance with the proposed SO2 BART emission limit for Power Boiler No. 1 is appropriate. It proposed that BART for NOX is an emission limit of 207.4 lb/hr on a 30 boiler-operating-day rolling average, where boiler-operating-day is defined as a 24-hour period between midnight and the following midnight during which any fuel is fed into and/or combusted at any time in the Power Boiler. This emission limit is consistent with the Power Boiler’s baseline emissions and would not necessitate additional controls. It proposed to require the source to comply with this emission limit as of the effective date of the final rule. To demonstrate compliance with this NOX BART emission limit, it proposed to require the source to conduct annual stack testing. It invited public comment on the appropriateness of this method for demonstrating compliance with the proposed NOX BART emission limit for Power Boiler No. 1.
  • Domtar Ashdown Mill Power Boiler No. 2: EPA proposed that BART for SO2 is an emission limit of 0.11 lb/MMBtu on a 30 boiler-operating-day rolling average, which it estimated is representative of operating the existing venturi scrubbers at 90% control efficiency and can be achieved through the installation of scrubber pump upgrades and use of additional scrubbing reagent. EPA indicated that boiler-operating-day is defined as a 24-hour period between midnight and the following midnight during which any fuel is fed into and/or combusted at any time in the Power Boiler. EPA invited public comment specifically on the appropriateness of the agency’s proposed SO2 emission limit. It proposed to require compliance with this BART emission limit no later than three years from the effective date of the final action, but invited public comment on the appropriateness of a compliance date anywhere from 1–5 years. It also proposed to require the source to demonstrate compliance with this emission limit using the existing continuous emissions monitoring system (CEMS). EPA proposed that BART for NOX is an emission limit of 345 lb/hr on a 30 boiler-operating-day rolling averaging basis, consistent with the installation and operation of LNB. It indicated that boiler-operating-day is defined as a 24-hour period between midnight and the following midnight during which any fuel is fed into and/or combusted at any time in the Power Boiler. It proposed to require compliance with this emission limit no later than three years from the effective date of the final rule, and invited public comment on the appropriateness of this compliance date. It also proposed to require the source to demonstrate compliance with this emission limit using the existing CEMS. Power Boiler No. 2 is subject to the Boiler Maximum Achievable Control Technology (MACT) standards for PM required under CAA section 112. EPA proposed to find that the current Boiler MACT PM standard satisfies the PM BART requirement for Power Boiler No. 2. It also proposed that the same method for demonstrating compliance with the Boiler MACT PM standard is to be used for demonstrating compliance with the PM BART emission limit. EPA proposed to require the source to comply with this emission limit for BART purposes as of the effective date of the final rule.

EPA is finalizing the FIP with certain changes to the initial proposal in response to comments received during the public comment period. In particular, it is finalizing: a bifurcated NOX BART emission limit for White Bluff Units 1 and 2; an SO2 BART emission limit for the Domtar Ashdown Mill Power Boiler No. 1 in the form of lb/day based on a 30 boiler-operating-day average instead of lb/hr based on a 30 boiler-operating-day average; and an SO2 BART emission limit for the Domtar Ashdown Mill Power Boiler No. 2 in the form of lb/hr based on a 30 boiler-operating-day average instead of lb/MMBtu based on a 30 boiler-operating-day average.

In light of information received during the public comment period, it is also adjusting the compliance dates for some of the BART determinations. It is requiring AEP Flint Creek Unit 1 to comply with the SO2 BART emission limit within 18 months of the effective date of this final action, instead of the five-year compliance date it proposed.

EPA is requiring AEP Flint Creek Unit 1 and White Bluff Units 1 and 2 to comply with the NOX BART emission limit within 18 months of the effective date of this final action, instead of the three-year compliance date it proposed.

EPA is requiring the Domtar Ashdown Mill to comply with the SO2 and NOX BART emission limits for Power Boiler No. 1 and the PM BART emission limit for Power Boiler No. 2 within 30 days from the effective date of this final action instead of on the date of the final action. It is requiring the Domtar Ashdown Mill to comply with the SO2 and NOX BART emission limits for Power Boiler No. 2 within five years of the effective date of this final action, instead of the three-year compliance date it proposed.

EPA is making some adjustments to the requirements for demonstrating compliance, testing, reporting, and recordkeeping for SO2 and NOX BART for the Domtar Ashdown Mill Power Boiler No. 1 and for SO2, NOX, and PM BART for Power Boiler No. 2. It is also revising the definition of boiler-operating-day as it applies to Power Boilers No. 1 and 2 under this FIP.

EPA is finalizing SO2 and NOX controls under reasonable progress for Independence Units 1 and 2 (its proposed Option 1). In response to comments received during the public comment period, it is finalizing a bifurcated NOX emission limit for Independence Units 1 and 2 and requiring the source to comply with the NOX emission limit within 18 months of the effective date of this final action instead of the three-year compliance date it proposed.

Taking into consideration the BART factors, EPA is finalizing its determination that BART for SO2 for White Bluff Units 1 and 2 is an emission limit of 0.06 lb/MMBtu on a 30 boiler-operating-day rolling average, consistent with the installation and operation of dry FGD or another control technology that achieves that level of control. It is requiring the source to comply with this emission limit no later than five years from the effective date of the final rule.

Taking into consideration the BART factors, EPA is finalizing its determination that BART for SO2 at Flint Creek is an emission limit of 0.06 lb/MMBtu on a 30 boiler-operating-day rolling average, which is consistent with the installation and operation of NID technology, which is being installed at the plant.

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.