1. BART SIP Development: Example from Colorado Rocky Mountain National Park WRAP IWG Meeting, Denver, CO August 29, 2007 Presented by: Ray Mohr and Curt Taipale

2. Presentation Topics Background Colorado’s state-only BART Rule development BART determinations (process and status) BART SIP Chapter and other materials in submittal

3. BART Rulemaking Stakeholder Process Most BART Sources Involved Rule Passed March 2006 Modeled After EPA Rule

4. BART Rule Contribute 0.5 Deciview Cause 1.0 Deciview Pollutants – NOx, SO2, PM VOC not included

5. BART Rule Post Combustion Controls NOT to be considered for NOX Presumptive limits applicable to Coal Power Plants as guideline Only 1 plant over 750 MW

6. BART Rule Consideration of Impact on Coal Mines in Colorado Due to concern over classification of sub- bituminous coal Presumptive Limits based on Powder River coal

7. BART Rule Some Colorado Sub-bituminous has higher Nitrogen and lower volatility Presumptive levels can’t be met BART Alternatives allowed SIP must be approved by Legislature

8. Colorado BART We hoped to simplify the BART process by using information gained from Craig and Hayden RAVI Settlements.

9. Previous RAVI BART Actions Certification of Visibility Impairment in Mt. Zirkel Wilderness by NFS in 1993 Craig and Hayden Power Plants were Implicated Settlements agreed to in 1996 and 2001

10. Colorado Regional Haze BART Because all but one of our BART sources are power plants except for one Portland Cement Plane and one industrial boiler facility, Air Division provided Guidance to simplify the BART analyses. Look at Lime Spray dryers only Look at Current Lo-NOx burners and overfire air

11. Colorado Bart All Plants have baghouses Sources can look at other controls if they want.

12. BART SOURCES Built between 1962 & 1977 Before PSD rules applied One of 26 listed source categories PTE > 250 TPY Emit SO2, NOx, PM10

13. COLORADO SOURCES Originally 16 Facilities Final List 9 facilities 13 Coal Electric Units 1 Portland cement plant 2 Coal Fired Industrial Boilers at one facility

14. EXEMPT SOURCES Reconstruction Deminimis Impact Modeled Less than 0.5 deciview

15. Exempt Sources Gas Fired Boilers < 250 MMBtu/hr each Reconstructed - Portland cement plant and Steel Mill Arc Furnace Pharmaceutical Production – VOC only Refinery and Power Plant – Modeled below 0.5 dV One plant shutdown

16. BART Alternative Must Be Better than BART July 2005 EPA BART Rule Provides for Two pronged test to evaluate Emissions reduction or Modeling Colorado used Emission Test, Similar to CAIR example

17. Existing Agreements XCEL Voluntary Emission Reduction Agreement – 1998 SO2 Emission Cap in Metro Denver Area – 10,500 TPY Three Plants – 7 units involved Previous SO2 = 25,000TPY

18. XCEL Alternative Settles contested issue involving Pawnee plant and its BART applicability In existence date is contested Alternative includes BART Presumptive level Controls on Pawnee with stricter annual limit

19. Comanche Plant Units 1 & 2 – 350 MW each are BART sources. Agreement reached in order to Build Unit 3 (750 MW) New LSD, LO-NOx Burners and OFA Limits less than BART Presumptive

20. Emission Reduction Estimate SO2 - 34,000 Tons per Year Includes 12,000 from Comanche NOx - 7,000 - 10,000 TPY

21. BART in the Colorado SIP Regional Haze Rule and BART Rule provide basis of BART Chapter BART Chapter identifies required BART provisions in Plan BART Appendix A expands on discussion and application of Rule requirements BART Technical Support Document (web site) includes all BART determination pertinent details (modeling, factor analysis, permit limits)

22. Chapter 1 Overview Chapter 2 Plan Development and Consultation Chapter 3 Monitoring Strategy Chapter 4 Baseline and Natural Conditions and Uniform Progress for each Class I Area Chapter 5 Sources of Impairment in Colorado Chapter 6 Best Available Retrofit Technology Chapter 7 Visibility Modeling and Apportionment Chapter 8 Reasonable Progress Goals Chapter 9 Long Term Strategy Chapter 10 Commitment to Consultation, Progress Reports, Evaluations of Plan Adequacy and Future SIP Revisions Chapter 11 Guidance, Resources and References: Regional Haze SIP - Chapter Overview

23. Regional Haze Web Site Technical Documentation Air Division’s web site http://www.cdphe.state.co.us/ap/regionalhaze.html Link to other web sites Air Division’s BART web page http://www.cdphe.state.co.us/ap/RegionalHazeBART.html WRAP’s Technical Support System web site http://vista.cira.colostate.edu/tss/

24. Some Observations and Lessons State Rule provides necessary framework State Guidance very important in establishing “subject to” parameters and evaluating source operator determinations Practical considerations, if effective, should be utilized Process worked “reasonably” well