Approval and Promulgation of Implementation Plans; State of Washington; Regional Haze State Implementation Plan; Federal Implementation Plan for Best Available Retrofit Technology for Alcoa Intalco Operations and Tesoro Refining and Marketing

Federal RegisterDec 26, 2012

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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 52

[EPA-R10-OAR-2010-1071, FRL-9760-6]

Approval and Promulgation of Implementation Plans; State of Washington; Regional Haze State Implementation Plan; Federal Implementation Plan for Best Available Retrofit Technology for Alcoa Intalco Operations and Tesoro Refining and Marketing

AGENCY:

Environmental Protection Agency (EPA)

ACTION:

Proposed rule.

SUMMARY:

EPA is proposing to partially approve and partially disapprove a Washington Regional Haze Implementation Plan (SIP) submitted by the State of Washington on December 22, 2010, that addresses regional haze for the first implementation period. This plan was submitted to meet the requirements of Clean Air Act (CAA) sections 169A and 169B that require states to prevent any future and remedy any existing man-made impairment of visibility in mandatory Class I areas. EPA is proposing to: (1) Approve portions of this SIP submittal as meeting most of the requirements of the regional haze program, (2) propose a limited approval and limited disapproval of the SO

Best Available Retrofit Technology (BART) determination for Intalco Aluminum Corp. (Intalco) potline operation and propose a federal “Better than BART” alternative, and (3) propose to disapprove the NOx BART determination for five BART emission units at the Tesoro Refining and Marketing refinery (Tesoro) and propose a federal Better than BART alternative. This combined rule package of proposed SIP approved elements and proposed federal elements will meet the requirements of CAA sections 169A and 169B. On August 20, 2012, EPA approved those provisions of the Washington SIP addressing the BART determination for TransAlta Centralia Generation L.L.C. coal fired power plant (TransAlta).

DATES:

Comments:

Written comments must be received at the address below on or before February 15, 2013.

Public Hearing:

A public hearing is offered to provide interested parties the opportunity to present information and opinions to EPA concerning our proposal. Interested parties may also submit written comments, as discussed below. If you wish to request a hearing and present testimony, you should notify Mr. Steve Body on or before January 10, 2013 and indicate the nature of the issues you wish to provide oral testimony during the hearing. Mr. Body's contact information is found in

FOR FURTHER INFORMATION CONTACT

below. At the hearing, the hearing officer may limit oral testimony to 5 minutes per person. The hearing will be limited to the subject matter of this proposal, the scope of which is discussed below. EPA will not respond to comments during the public hearing. When we publish our final action we will provide a written response to all written or oral comments received on the proposal. EPA will not be providing equipment for commenters to show overhead slides or make computerized slide presentations. A transcript of the hearing and written statements will be made available for copying during normal working hours at the address listed for inspection of documents, and also included in the Docket. Any member of the public may provide written or oral comments and data pertaining to our proposal at the hearing. Note that any written comments and supporting information submitted during the comment period will be considered with the same weight as any oral comments presented at the public hearing. If no requests for a public hearing are received by close of business on January 10, 2013, a hearing will

not

be held; please contact Mr. Body at (206) 553-0782 to find out if the hearing will actually be held or if it will be cancelled for lack of any request to speak.

ADDRESSES:

Public Hearing:

A public hearing, if requested, will be held January 16, 2013, beginning at 6:00 p.m. at the Washington Department of Ecology Offices, Room #ROA-32, 300 Desmond Drive, Lacey, WA 98503.

Comments:

Submit your comments, identified by Docket ID No. EPA-R10-OAR-2010-1071 by one of the following methods:

•

www.regulations.gov.

Follow the on-line instructions for submitting comments.

• Email:

R10-Public_Comments@epa.gov

• Mail: Steve Body, EPA Region 10, Suite 900, Office of Air, Waste and Toxics, 1200 Sixth Avenue, Seattle, WA 98101.

• Hand Delivery: EPA Region 10, 1200 Sixth Avenue, Suite 900, Seattle, WA 98101. Attention: Steve Body, Office of Air, Waste and Toxics, AWT-107. Such deliveries are only accepted during normal hours of operation, and special arrangements should be made for deliveries of boxed information.

Instructions:

Direct your comments to Docket ID No. EPA-R10-OAR-2010-1071. EPA's policy is that all comments received will be included in the public docket without change and may be made available online at

www.regulations.gov,

including any personal information provided, unless the comment includes information claimed to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute. Do not submit information that you consider to be CBI or otherwise protected through

www.regulations.gov

or email. The

www.regulations.gov

Web site is an “anonymous access” system, which means EPA will not know your identity or contact information unless you provide it in the body of your comment. If you send an email comment directly to EPA, without going through

www.regulations.gov,

your email address will be automatically captured and included as part of the comment that is placed in the public docket and made available on the Internet. If you submit an electronic comment, EPA recommends that you include your name and other contact information in the body of your comment and with any disk or CD-ROM you submit. If EPA cannot read your comment due to technical difficulties and cannot contact you for clarification, EPA may not be able to consider your comment. Electronic files should avoid the use of special characters, any form of encryption, and be free of any defects or viruses.

Docket:

All documents in the docket are listed in the

www.regulations.gov

index. Although listed in the index, some information is not publicly available (e.g., CBI or other information whose disclosure is restricted by statute). Certain other material, such as copyrighted material, will be publicly available only in hard copy form. Publicly available docket materials are available either electronically at www.regulations.gov or in hard copy at the Office of Air, Waste and Toxics, EPA Region 10, 1200 Sixth Avenue, Seattle, WA 98101. EPA requests that if at all possible, you contact the individual listed below to view a hard copy of the docket.

FOR FURTHER INFORMATION CONTACT:

Steve Body at telephone number (206) 553-0782,

body.steve@epa.gov,

or the above EPA, Region 10 address.

SUPPLEMENTARY INFORMATION:

Throughout this document whenever “we,” “us,” or “our” is used, we mean the EPA. Information is organized as follows:

Table of Contents

I. Overview and Summary of EPA's Proposed Action

II. Background for EPA's Proposed Action

A. Definition of Regional Haze

B. Regional Haze Rules and Regulations

C. Roles of Agencies in Addressing Regional Haze

III. Requirements for the Regional Haze SIP

A. The CAA and the Regional Haze Rule

B. Determination of Baseline, Natural, and Current Visibility Conditions

C. Consultation With States and Federal Land Managers

D. Best Available Retrofit Technology

E. Determination of Reasonable Progress Goals (RPGs)

F. Long Term Strategy (LTS)

G. Coordinating Regional Haze and Reasonably Attributable Visibility Impairment (RAVI)

H. Monitoring Strategy and Other Implementation Requirements

IV. EPA's Analysis of the Washington Regional Haze SIP

A. Affected Class I Areas

B. Baseline and Natural Conditions and Uniform Rate of Progress

C. Washington Emissions Inventories

D. Sources of Visibility Impairment in Washington Class I Areas

E. Best Available Retrofit Technology

1. BART-Eligible Sources in Washington

2. Sources Subject to BART

3. Washington Source Specific BART Analysis

a. British Petroleum, Cherry Point Refinery

b. Intalco Aluminum Corp.

c. Tesoro Refining and Marketing

d. Port Townsend Paper Company

e. Lafarge North America

f. TransAlta Centralia Generation, LLC

g. Weyerhaeuser Company-Longview

F. Determination of Reasonable Progress Goals

G. Long Term Strategy

H. Monitoring Strategy and Other Implementation Requirements

I. Consultation With States and Federal Land Managers

J. Periodic SIP Revisions and 5-Year Progress Reports

V. What action is EPA proposing?

VI. Washington Notice

VII. Scope of Action

VIII. Statutory and Executive Order Reviews

I. Overview and Summary of EPA's Proposed Action

In this action, EPA proposes to approve the following provisions of Washington's Regional Haze SIP submittal: Washington's identification of Class I areas and determination of baseline conditions, natural conditions and uniform rate of progress (URP) for each of these Class I areas. We also propose to approve Washington's emission inventories, sources of visibility impairment in Washington Class I areas, monitoring strategy, consultation with other states and Federal Land Managers (FLMs), reasonable progress goals (RPGs), and long term strategy (LTS).

EPA previously approved Washington's BART determination for the TransAlta power plant in Centralia, Washington. In today's action we are proposing to approve BART determinations for all other sources subject to BART with the exception of certain BART emission units at two sources subject to BART. Specifically EPA is proposing to approve the BART determinations for the British Petroleum (BP) Cherry Point Refinery, Port Townsend Paper Company, LaFarge North America, and Weyerhaeuser Longview and portions of the BART determinations for Intalco and Tesoro. EPA is proposing a limited approval and limited disapproval of Washington's SO

BART determination for the potlines at Intalco in Ferndale, Washington. EPA proposes an alternative `Better than BART” Federal Implementation Plan (FIP) for SO

BART for the potlines with an annual limit on SO

emissions of 80% of baseyear emissions. EPA is proposing to disapprove Washington's NO

BART determination for 5 BART units at the Tesoro refinery in Anacortes, Washington. EPA proposes a Better than BART alternative FIP for these 5 BART units.

II. Background for EPA's Proposed Action

In the CAA Amendments of 1977, Congress established a program to protect and improve visibility in national parks and wilderness areas. See CAA section 169A. Congress amended the visibility provisions in the CAA in 1990 to focus attention on the problem of regional haze. See CAA section 169B. EPA promulgated regulations in 1999 to implement sections 169A and 169B of the Act. These regulations require states to develop and implement plans to ensure reasonable progress toward improving visibility in mandatory Class I Federal areas

(Class I areas). 64 FR 35714 (July 1, 1999); see also 70 FR 39104 (July 6, 2005) and 71 FR 60612 (October 13, 2006).

Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6000 acres, wilderness areas and national memorial parks exceeding 5000 acres, and all international parks that were in existence on August 7, 1977. 42 U.S.C. 7472(a). In accordance with section 169A of the CAA, EPA, in consultation with the Department of Interior, promulgated a list of 156 areas where visibility is identified as an important value. 44 FR 69122 (November 30, 1979). The extent of a mandatory Class I area includes subsequent changes in boundaries, such as park expansions. 42 U.S.C. 7472(a). Although states and tribes may designate as Class I additional areas which they consider to have visibility as an important value, the requirements of the visibility program set forth in section 169A of the CAA apply only to “mandatory Class I Federal areas.” Each mandatory Class I Federal area is the responsibility of a “Federal Land Manager.” 42 U.S.C. 7602(i). When we use the term “Class I area” in this action, we mean a “mandatory Class I Federal area.”

A. Definition of Regional Haze

Regional haze is impairment of visual range or colorization caused by emission of air pollution produced by numerous sources and activities, located across a broad regional area. The sources include but are not limited to, major and minor stationary sources, mobile sources, and area sources including non-anthropogenic sources. Visibility impairment is primarily caused by fine particulate matter, particles with an aerodynamic diameter of less than 2.5 micrometers, (PM

2.5

) or secondary aerosol formed in the atmosphere from precursor gasses (e.g., sulfur dioxide, nitrogen oxides, and in some cases, ammonia and volatile organic compounds). Atmospheric fine particulate reduces clarity, color, and visual range of visual scenes. Visibility reducing fine particulate is primarily composed of sulfate, nitrate, organic carbon compounds, elemental carbon, and soil dust, and impairs visibility by scattering and absorbing light. Fine particulate can also cause serious health effects and mortality in humans, and contributes to environmental effects such as acid deposition and eutrophication.

See 64 FR at 35715.

Data from the existing visibility monitoring network, the “Interagency Monitoring of Protected Visual Environments” (IMPROVE) monitoring network, show that visibility impairment caused by air pollution occurs virtually all the time at most national parks and wilderness areas. Average visual range in many Class I areas in the Western United States is 100-150 kilometers, or about one-half to two-thirds the visual range that would exist without anmade air pollution.

Visibility impairment also varies day-to-day and by season depending on variation in meteorology and emission rates.

Id.

B. Regional Haze Rules and Regulations

In section 169A of the 1977 CAA Amendments, Congress created a program for protecting visibility in the nation's national parks and wilderness areas. This section of the CAA establishes as a national goal the “prevention of any future, and the remedying of any existing, impairment of visibility in Class I areas which impairment results from manmade air

pollution.” CAA section 169A(a)(1). On December 2, 1980, EPA promulgated regulations to address visibility impairment in Class I areas that is “reasonably attributable” to a single source or small group of sources, i.e., “reasonably attributable visibility impairment”. 45 FR 80084. These regulations represented the first phase in addressing visibility impairment. EPA deferred action on regional haze that emanates from a variety of sources until monitoring, modeling, and scientific knowledge about the relationships between pollutants and visibility impairment were improved.

Congress added section 169B to the CAA in 1990 to address regional haze issues. EPA promulgated a rule to address regional haze on July 1, 1999 (64 FR 35713) (the Regional Haze Rule or RHR). The RHR revised the existing visibility regulations to integrate into the regulation, provisions addressing regional haze impairment and established a comprehensive visibility protection program for Class I areas. The requirements for regional haze, found at 40 CFR 51.308 and 51.309, are included in EPA's visibility protection regulations at 40 CFR 51.300-309. Some of the main elements of the regional haze requirements are summarized in section III of this notice. The requirement to submit a regional haze SIP applies to all 50 states, the District of Columbia and the Virgin Islands.

40 CFR 51.308(b) requires states to submit the first implementation plan addressing regional haze visibility impairment no later than December 17, 2007.

Albuquerque/Bernalillo County in New Mexico must also submit a regional haze SIP to completely satisfy the requirements of section 110(a)(2)(D) of the CAA for the entire State of New Mexico under the New Mexico Air Quality Control Act (section 74-2-4).

C. Roles of Agencies in Addressing Regional Haze

Successful implementation of the regional haze program will require long-term regional coordination among states, tribal governments and various federal agencies. As noted above, pollution affecting the air quality in Class I areas can be transported over long distances, even hundreds of kilometers. Therefore, to effectively address the problem of visibility impairment in Class I areas, states need to develop strategies in coordination with one another, taking into account the effect of emissions from one jurisdiction on the air quality in another.

Because the pollutants that lead to regional haze impairment can originate from across state lines, even across international boundaries, EPA has encouraged the states and Tribes to address visibility impairment from a regional perspective.

Five regional planning organizations

(RPOs) were created nationally to address regional haze and related issues. One of the main objectives of the RPOs is to develop and analyze data and conduct pollutant transport modeling to assist the States or Tribes in developing their regional haze plans.

The Western Regional Air Partnership (WRAP), one of the five RPOs nationally, is a voluntary partnership of state, Tribal, federal, and local air agencies dealing with air quality in the West. WRAP member states include: Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. WRAP Tribal members include Campo Band of Kumeyaay Indians, Confederated Salish and Kootenai Tribes, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Native Village of Shungnak, Nez Perce Tribe, Northern Cheyenne Tribe, Pueblo of Acoma, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall.

II. Requirements for the Regional Haze SIPs

A. The CAA and the Regional Haze Rule

Regional haze SIPs must assure reasonable progress towards the national goal of achieving natural visibility conditions in Class I areas. Section 169A of the CAA and EPA's implementing regulations require states to establish long-term strategies for making reasonable progress toward meeting this goal. Implementation plans must also give specific attention to certain stationary sources that were in existence on August 7, 1977, but were not in operation before August 7, 1962, and require these sources, where appropriate, to install BART controls for the purpose of eliminating or reducing visibility impairment. The specific regional haze SIP requirements are discussed in further detail below.

B. Determination of Baseline, Natural, and Current Visibility Conditions

The RHR establishes the deciview (dv) as the principal metric for measuring visibility. This visibility metric expresses uniform changes in haziness in terms of common increments across the entire range of visibility conditions, from pristine to extremely hazy conditions. Visibility is determined by measuring the visual range (or deciview), which is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky. The deciview is a useful measure for tracking progress in improving visibility, because each deciview change is an equal incremental change in visibility perceived by the human eye. Most people can detect a change in visibility at one deciview.

The preamble to the RHR provides additional details about the deciview. 64 FR 35714, 35725 (July 1, 1999).

The deciview is used in expressing reasonable progress goals (which are interim visibility goals towards meeting the national visibility goal), defining baseline, current, and natural conditions, and tracking changes in visibility. The regional haze SIPs must contain measures that ensure “reasonable progress” toward the national goal of preventing and remedying visibility impairment in Class I areas caused by manmade air pollution by reducing anthropogenic emissions that cause regional haze. The national goal is a return to natural conditions, i.e., manmade sources of air pollution would no longer impair visibility in Class I areas.

To track changes in visibility over time at each of the 156 Class I areas covered by the visibility program (40 CFR 81.401-437), and as part of the process for determining reasonable progress, states must calculate the degree of existing visibility impairment at each Class I area at the time of each regional haze SIP submittal and periodically review progress every five years midway through each 10-year implementation period. To do this, the RHR requires states to determine the degree of impairment (in deciviews) for the average of the 20% least impaired (“best”) and 20% most impaired (“worst”) visibility days over a specified time period at each of their Class I areas. In addition, states must also develop an estimate of natural visibility conditions for the purpose of comparing progress toward the national goal. Natural visibility is determined by estimating the natural concentrations of pollutants that cause visibility impairment and then calculating total light extinction based on those estimates. EPA has provided guidance to states regarding how to calculate baseline, natural and current visibility conditions in documents titled, EPA's

Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule,

September 2003, (EPA-454/B-03-005 located at

http://www.epa.gov/ttncaaa1/t1/memoranda/rh_envcurhr_gd.pdf

), (hereinafter referred to as “EPA's 2003 Natural Visibility Guidance”), and

Guidance for Tracking Progress Under the Regional Haze Rule

(EPA-454/B-03-004 September 2003 located at

http://www.epa.gov/ttncaaa1/t1/memoranda/rh_tpurhr_gd.pdf

)), (hereinafter referred to as “EPA's 2003 Tracking Progress Guidance”).

For the first regional haze SIPs that were due by December 17, 2007, “baseline visibility conditions” were the starting points for assessing “current” visibility impairment. Baseline visibility conditions represent the degree of visibility impairment for the 20% least impaired days and 20% most impaired days for each calendar year from 2000 to 2004. Using monitoring data for 2000 through 2004, states are required to calculate the average degree of visibility impairment for each Class I area, based on the average of annual values over the five-year period. The comparison of initial baseline visibility conditions to natural visibility conditions indicates the amount of improvement necessary to attain natural visibility, while the future comparison of baseline conditions to the then current conditions will indicate the amount of progress made. In general, the 2000-2004 baseline time period is considered the time from which improvement in visibility is measured.

C. Consultation With States and Federal Land Managers

The RHR requires that states consult with Federal Land Managers (FLMs) before adopting and submitting their SIPs. 40 CFR 51.308(i). States must provide FLMs an opportunity for consultation, in person and at least 60 days prior to holding any public hearing on the SIP. This consultation must include the opportunity for the FLMs to discuss their assessment of visibility impairment in any Class I area and to offer recommendations on the development of the reasonable progress goals and on the development and implementation of strategies to address visibility impairment. Further, a state must include in its SIP a description of how it addressed any comments provided by the FLMs. Finally, a SIP must provide procedures for continuing consultation between the state and FLMs regarding the state's visibility protection program, including development and review of SIP revisions, five-year progress reports, and the implementation of other programs having the potential to contribute to impairment of visibility in Class I areas.

D. Best Available Retrofit Technology

Section 169A of the CAA directs states to evaluate the use of retrofit controls at certain larger, often uncontrolled, older stationary sources in order to address visibility impacts from these sources. Specifically, section 169A(b)(2)(A) of the CAA requires states to revise their SIPs to contain such measures as may be necessary to make reasonable progress towards the natural visibility goal, including a requirement that certain categories of existing major stationary sources

built between 1962 and 1977 procure, install, and operate the “Best Available Retrofit Technology” as determined by the state. States are directed to conduct BART determinations for such sources that may be anticipated to cause or contribute to any visibility impairment in a Class I area. Rather than requiring source-specific BART controls, states also have the flexibility to adopt an emissions trading program or other alternative program as long as the alternative provides greater reasonable progress towards improving visibility than BART.

The set of “major stationary sources” potentially subject to BART is listed in CAA section 169A(g)(7).

On July 6, 2005, EPA published the

Guidelines for BART Determinations Under the Regional Haze Rule

at appendix Y to 40 CFR part 51 (hereinafter referred to as the “BART Guidelines”) to assist states in determining which of their sources should be subject to the BART requirements and in determining appropriate emission limits for each applicable source. In making a BART applicability determination for a fossil fuel-fired electric generating plant with a total generating capacity in excess of 750 megawatts, a state must use the approach set forth in the BART Guidelines. A state is encouraged, but not required, to follow the BART Guidelines in making BART determinations for other types of sources.

States must address all visibility-impairing pollutants emitted by a source in the BART determination process. The most significant visibility-impairing pollutants are sulfur dioxide, nitrogen oxides, and fine particulate matter. EPA has indicated that states should use their best judgment in determining whether volatile organic compounds or ammonia compounds impair visibility in Class I areas.

Under the BART Guidelines, states may select an exemption threshold value to determine those BART eligible sources not subject to BART. A BART-eligible source with an impact below the threshold would not be expected to cause or contribute to visibility impairment in any Class I area. The state must document this exemption threshold value in the SIP and must state the basis for its selection of that value. Any source with emissions that model above the threshold value would be subject to a BART determination review. The BART Guidelines acknowledge varying circumstances affecting different Class I areas. States should consider the number of emission sources affecting the Class I areas at issue and the magnitude of the individual sources' impacts. Generally, an exemption threshold set by the state should not be higher than 0.5 deciview.

In their SIPs, states must identify BART sources, (BART-eligible sources), as well as those BART eligible sources that have a visibility impact in any Class I area above the “BART subject” exemption threshold established by the state and thus, subject to BART. States must document their BART control analysis and determination for all sources subject to BART.

The term “BART-eligible source” used in the BART Guidelines means the collection of individual emission units at a facility that together comprises the BART-eligible source. In making a BART determination, section 169A(g)(2) of the CAA requires that states consider the following factors: (1) The costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any existing pollution control technology in use at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology. States are free to determine the weight and significance to be assigned to each factor.

The regional haze SIP must include source-specific BART emission limits and compliance schedules for each source subject to BART. Once a state has made its BART determination, the BART controls must be installed and in operation as expeditiously as practicable, but no later than 5 years after the date EPA approves the regional haze SIP. CAA section 169A(g)(4)). 40 CFR 51.308(e)(1)(iv). In addition to what is required by the RHR, general SIP requirements mandate that the SIP must also include all regulatory requirements related to monitoring, recordkeeping, and reporting for the BART controls on the source. States have the flexibility to choose the type of control measures they will use to meet the requirements of BART.

E. Determination of Reasonable Progress Goals (RPGs)

The vehicle for ensuring continuing progress towards achieving the natural

visibility goal is the submission of a series of regional haze SIPs from the states that establish two RPGs (i.e., two distinct goals, one for the “best” and one for the “worst” days) for every Class I area for each (approximately) 10-year implementation period. The RHR does not mandate specific milestones or rates of progress, but instead calls for states to establish goals that provide for “reasonable progress” toward achieving natural (i.e., “background”) visibility conditions. In setting RPGs, states must provide for an improvement in visibility for the most impaired days over the (approximately) 10-year period of the SIP, and ensure no degradation in visibility for the least impaired days over the same period.

States have significant discretion in establishing RPGs, but are required to consider the following factors established in section 169A of the CAA and in EPA's RHR at 40 CFR 51.308(d)(1)(i)(A): (1) The costs of compliance; (2) the time necessary for compliance; (3) the energy and non-air quality environmental impacts of compliance; and (4) the remaining useful life of any potentially affected sources. States must demonstrate in their SIPs how these factors are considered when selecting the RPGs for the best and worst days for each applicable Class I area. States have considerable flexibility in how they take these factors into consideration, as noted in EPA's

Guidance for Setting Reasonable Progress Goals under the Regional Haze Program,

(“EPA's Reasonable Progress Guidance”), July 1, 2007, memorandum from William L. Wehrum, Acting Assistant Administrator for Air and Radiation, to EPA Regional Administrators, EPA Regions 1-10 (pp. 4-2, 5-1). In setting the RPGs, states must also consider the rate of progress needed to reach natural visibility conditions by 2064 (referred to as the “uniform rate of progress” or the “glidepath”) and the emission reduction measures needed to achieve that rate of progress over the 10-year period of the SIP. Uniform progress towards achievement of natural conditions by the year 2064 represents a rate of progress which states are to use for analytical comparison to the amount of progress they expect to achieve. In setting RPGs, each state with one or more Class I areas (“Class I state”) must also consult with potentially “contributing states,” i.e., other nearby states with emission sources that may be affecting visibility impairment at the Class I state's areas. 40 CFR 51.308(d)(1)(iv).

F. Long Term Strategy (LTS)

Consistent with the requirement in section 169A(b) of the CAA that states include in their regional haze SIP a 10 to 15 year strategy for making reasonable progress, section 51.308(d)(3) of the RHR requires that states include a LTS in their regional haze SIPs. The LTS is the compilation of all control measures a state will use during the implementation period of the specific SIP submittal to meet applicable RPGs. The LTS must include “enforceable emissions limitations, compliance schedules, and other measures as necessary to achieve the reasonable progress goals” for all Class I areas within, or affected by emissions from, the state. 40 CFR 51.308(d)(3).

When a state's emissions are reasonably anticipated to cause or contribute to visibility impairment in a Class I area located in another state, the RHR requires the impacted state to coordinate with the contributing states in order to develop coordinated emissions management strategies. 40 CFR 51.308(d)(3)(i). In such cases, the contributing state must demonstrate that it has included, in its SIP, all measures necessary to obtain its share of the emissions reductions needed to meet the RPGs for the Class I area. The RPOs have provided forums for significant interstate consultation, but additional consultations between states may be required to sufficiently address interstate visibility issues. This is especially true where two states belong to different RPOs.

States should consider all types of anthropogenic sources of visibility impairment in developing their LTS, including stationary, minor, mobile, and area sources. At a minimum, states must describe how each of the following seven factors listed below are taken into account in developing their LTS: (1) Emissions reductions due to ongoing air pollution control programs, including measures to address RAVI; (2) measures to mitigate the impacts of construction activities; (3) emissions limitations and schedules for compliance to achieve the RPG; (4) source retirement and replacement schedules; (5) smoke management techniques for agricultural and forestry management purposes including plans as currently exist within the state for these purposes; (6) enforceability of emissions limitations and control measures; and (7) the anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions over the period addressed by the LTS. See 40 CFR 51.308(d)(3)(v).

G. Coordinating Regional Haze and Reasonably Attributable Visibility Impairment (RAVI)

As part of the RHR, EPA revised 40 CFR 51.306(c) regarding the LTS for RAVI to require that the RAVI plan must provide for a periodic review and SIP revision not less frequently than every three years until the date of submission of the state's first plan addressing regional haze visibility impairment, which was due December 17, 2007, in accordance with 40 CFR 51.308(b) and (c). On or before this date, the state must revise its plan to provide for review and revision of a coordinated LTS for addressing RAVI and regional haze, and the state must submit the first such coordinated LTS with its first regional haze SIP. Future coordinated LTS's, and periodic progress reports evaluating progress towards RPGs, must be submitted consistent with the schedule for SIP submission and periodic progress reports set forth in 40 CFR 51.308(f) and 51.308(g), respectively. The periodic review of a state's LTS must report on both regional haze and RAVI impairment and must be submitted to EPA as a SIP revision.

H. Monitoring Strategy and Other Implementation Requirements

Section 51.308(d)(4) of the RHR includes the requirement for a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility impairment that is representative of all mandatory Class I Federal areas within the state. The strategy must be coordinated with the monitoring strategy required in section 51.305 for RAVI. Compliance with this requirement may be met through “participation” in the IMPROVE network, i.e., review and use of monitoring data from the network. The monitoring strategy is due with the first regional haze SIP, and it must be reviewed every five years. The monitoring strategy must also provide for additional monitoring sites if the IMPROVE network is not sufficient to determine whether RPGs will be met.

The SIP must also provide for the following:

• Procedures for using monitoring data and other information in a state with mandatory Class I areas to determine the contribution of emissions from within the state to regional haze visibility impairment at Class I areas both within and outside the state;

• Procedures for using monitoring data and other information in a state with no mandatory Class I areas to determine the contribution of emissions from within the state to regional haze

visibility impairment at Class I areas in other states;

• Reporting of all visibility monitoring data to the Administrator at least annually for each Class I area in the state, and where possible, in electronic format;

• Developing a statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any Class I area. The inventory must include emissions for a baseline year, emissions for the most recent year for which data are available, and estimates of future projected emissions. A state must also make a commitment to update the inventory periodically; and

• Other elements, including reporting, recordkeeping, and other measures necessary to assess and report on visibility.

The RHR requires control strategies to cover an initial implementation period extending to the year 2018, with a comprehensive reassessment and revision of those strategies, as appropriate, every 10 years thereafter. Periodic SIP revisions must meet the core requirements of section 51.308(d) with the exception of BART. The requirement to evaluate sources for BART applies only to the first regional haze SIP. Facilities subject to BART must continue to comply with the BART provisions of section 51.308(e), as noted above. Periodic SIP revisions will assure that the statutory requirement of reasonable progress will continue to be met.

III. EPA's Analysis of the Washington Regional Haze SIP

A. Affected Class I Areas

There are eight mandatory Class I areas within Washington: Olympic National Park, North Cascades National Park, Glacier Peak Wilderness Area, Alpine Lakes Wilderness Area, Mt. Rainier National Park, Goat Rocks Wilderness Area, Mt. Adams Wilderness Area, and Pasayten Wilderness Area. See 40 CFR 81.434. The Washington SIP submittal addresses all eight Class I areas.

B. Baseline and Natural Conditions and Uniform Rate of Progress

Washington, using data from the IMPROVE monitoring network, identified baseline and natural visibility conditions for all eight Class I areas in Washington. Baseline visibility was calculated from monitoring data collected by IMPROVE monitors for the 20% most-impaired (20% worst) days and the 20% least-impaired (20% best) days. Washington used the WRAP derived natural visibility conditions. In general, WRAP based their estimates on EPA guidance, “Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program” (EPA-45/B-03-0005 September 2003), (

http://www.epa.gov/ttn/caaa/t1/memoranda/rh_envcurhr_gd.pdf

), but incorporated refinements which EPA believes provides results more appropriate for western states than the general EPA default approach. See section 2.E of the WRAP Technical Support Document (WRAP TSD).

Olympic National Park:

An IMPROVE monitor is located northeast of the Park boundary at the extreme northeast corner of the Olympic Peninsula near Sequim, Washington. Based on baseline data from the years 2000 to 2004, the average 20% worst days visibility is 16.7 dv and the average 20% best days visibility is 6.0 dv. Natural visibility for the average 20% worst days is 8.4 dv.

North Cascades National Park and Glacier Peak Wilderness Areas:

The North Cascades National Park and Glacier Peak Wilderness Area are both represented by an IMPROVE monitor located near Ross Lake on the Skagit River just outside the eastern boundary of the northern section of North Cascades National Park. Based on baseline data from the years 2000 to 2004, the average 20% worst days visibility is 16.0 dv and the average 20% best days visibility is 3.37 dv. Natural visibility for the average 20% worst days is 8.39 dv.

Alpine Lakes Wilderness Area:

Alpine Lakes Wilderness Area visibility is represented by an IMPROVE monitor located southwest of the wilderness area at Snoqualmie Pass in the Cascade Mountains. Based on baseline data from the years 2000 to 2004, the average 20% worst days visibility is 17.8 dv and the average 20% best days visibility is 5.5 dv. Natural visibility for the Alpine Lakes Wilderness Area average 20% worst days is 8.4 dv.

Mt. Rainier National Park:

Mt. Rainier National Park visibility is represented by an IMPROVE monitor located at Park headquarters at Tahoma Woods. Based on baseline data from the years 2000 to 2004, the average 20% worst days visibility is 18.2 dv and the average 20% best days visibility is 5.5 dv. Natural visibility for the Mt. Rainier National Park average 20% worst days is 8.5 dv.

Goat Rocks and Mt. Adams Wilderness Areas:

The Goat Rocks and Mt. Adams Wilderness Area's visibility are both represented by an IMPROVE monitor located at White Pass in the Cascade Mountain Range. Based on baseline data from the years 2000 to 2004, the average 20% worst days visibility is 12.7 dv and the average 20% best days visibility is 1.7 dv for both areas. Natural visibility for the Goat Rocks and Mt. Adams Wilderness Areas average 20% worst days is 8.35 dv.

Pasayten Wilderness Area:

The Pasayten Wilderness Area visibility is represented by an IMPROVE monitor located 50 km south and east of the wilderness boundary. Based on baseline data from the years 2000 to 2004, the average 20% worst days visibility is 15.2 dv and the average 20% best days visibility is 2.7 dv. Natural visibility for the Pasayten Wilderness Area average 20% worst days is 8.3 dv.

Based on our evaluation of the Washington's baseline and natural conditions analysis, EPA is proposing to find that Washington has appropriately determined the baseline visibility for the average 20% worst and 20% best days, and natural conditions for the average 20% worst days in each Class I area in Washington.

C. Washington Emissions Inventories

There are three main categories of air pollution emission sources: Point sources, area sources, and mobile sources. Point sources are larger stationary sources. Area sources are large numbers of small sources that are widely distributed across an area, such as residential heating units, wildfire, re-entrained dust from unpaved roads, or windblown dust from agricultural fields. Mobile sources are sources such as motor vehicles, locomotives, and aircraft.

The RHR requires a statewide emission inventory of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I area. 40 CFR 51.308(d)(4)(v). The WRAP, with data supplied by Washington, compiled emission inventories for all major source categories in Washington for the 2002 baseline year and estimated emissions for 2018. Emission estimates for 2018 were generated from anticipated population growth, growth in industrial activity, and emission reductions from implementation of expected control measures, e.g., implementation of BART limitations and motor vehicle tailpipe emissions. Chapter 6 of the SIP submittal discusses how emission estimates were determined and contains the emission inventory. Detailed estimates of the emissions, used in the modeling conducted by the WRAP and Washington, can be found at the WRAP Web site:

http://vista.cira.colostate.edu/TSS/Results/Emissions.aspx

There are a number of emission inventory source categories identified in

the Washington SIP submittal. The source categories vary with type of pollutant but include: Point, area, on-road mobile, off-road mobile, anthropogenic fire (prescribed forest fire, agricultural field burning, and residential wood combustion), natural fire, biogenic, road dust, fugitive dust and windblown dust. The 2002 baseline and 2018 projected emissions, as well as the net changes of emissions between these two years, are presented in Tables 6-1 through 6-8 of the SIP submittal for sulfur dioxide (SO

), oxides of nitrogen (NO

), volatile organic carbon (VOC), organic carbon (OC), elemental carbon (EC), PM

2.5,

and ammonia. The methods that WRAP used to develop these emission inventories are described in more detail in the WRAP TSD. As explained in the WRAP TSD, emissions were calculated using best available data and approved EPA methods. See WRAP TSD section 12.

Sulfur dioxide emissions in Washington come mostly from one coal fired power plant, oil refineries, aluminum plants, pulp and paper mills, and a cement plant. SO

emission estimates for point sources come either from source test data (where available) or calculations based on the quantity and type of fuel burned. These industrial point sources contribute 64% of total statewide SO

emissions. The second largest source category contributing to SO

emissions in Washington is off-road mobile sources which contribute 17%. The remainder of SO

emissions is from a variety of area sources including anthropogenic and natural fire. See Table 6-1 of the SIP submittal.

Washington projects a 29% statewide reduction in point source S0

emissions by 2018 due to implementation of BART emission limitations and other Washington State and federal emission reduction actions. Washington projects total 2018 statewide SO

emissions to be reduced by 40% below 2002 levels as a result of BART and additional reductions from mobile sources.

emissions in Washington come mostly from mobile sources, both on-road and off-road, which contribute 76% of total statewide NO

emissions. The second largest source category of NO

emissions is point source emissions which accounts for 11% of statewide NO

emissions. Area source emissions account for less than 5% of statewide NO

emissions.

Washington projects that 2018 total statewide emissions of NO

will be 46% lower than 2002 levels. Washington also projects on-road and off-road mobile source emissions to be reduced by 72% and 45% respectively by 2018, due to new federal motor vehicle emission standards and fleet turnover. Washington projects area source NO

emissions to increase by 29% due to population growth. See Table 6-2 of the SIP submittal.

Volatile organic compounds in Washington come mostly from biogenic emissions from forests, agriculture, and urban vegetation. The second largest source category in VOC emissions is on-road and off-road mobile sources. Washington projects 2018 statewide VOC emissions to increase by only 1% over 2002 levels. This very minor change is due to anticipated increases in area and point source emissions that would offset anticipated decreases in mobile sources and anthropogenic fire. See Table 6-3 of the SIP submittal.

Organic carbon in Washington comes almost equally from wildfire at 35% and other area sources at 33%. Anthropogenic fire accounts for 20% of statewide organic carbon emissions. Washington projects 2018 statewide organic carbon emissions to decrease 4% from 2002. Large reductions in emissions from mobile sources and anthropogenic fire are expected to be offset by increases in emissions from point and area sources due to population growth. See Table 5-4 of the SIP submittal.

The largest source categories of elemental carbon are mobile sources, natural fire and area sources. Washington projects 2018 statewide elemental carbon emissions to decrease by 25% from 2002 emission levels. These projected reductions are the result of anticipated emission reductions in on-road mobile and off-road mobile emissions of 76% and 60% respectively. See Table 6-5 of the SIP submittal.

Fine particulate is emitted from a variety of area sources which account for 95% of statewide fine particulate. Fugitive dust, from agriculture, mining, construction and roads, is the largest source category contributing 31% of total fine particulate. Anthropogenic and natural fire only account for 12% of the statewide fine particulate emissions. Point sources account for only 5% of statewide fine particulate. Washington projects that 2018 fine particulate emissions will increase by 20% over 2002 emission levels due to population and industrial growth. Emissions increases are projected from point, area, and fugitive dust at 16%, 36%, and 34% respectively. See Table 6-6 of the SIP submittal.

Ammonia does not directly impair visibility but can be a precursor to the formation of particulate in the atmosphere through chemical reaction with SO

and NO

to form a “secondary aerosol” of ammonium sulfate and ammonium nitrate. Area sources are the primary source category contributing to ammonia emissions and account for 77% of total ammonia emissions. Washington projects ammonia emissions in 2018 to increase by 8% over 2002 emission levels with increasing emissions in all categories except for anthropogenic fire which Washington projects to decrease by 30%. See Table 6-8 of the SIP submittal.

EPA believes Washington's inventory of baseline emissions is accurate and comprehensive as Washington used the most current and appropriate methods at the time it was developed. We note that additional emission reductions may occur between the baseline year and 2018 that are not accounted for in the 2018 inventory. For example, no emission reductions from the new regulations relating to the International Maritime Organization Emission Control Area (ECA) on the west coast of the United States and Canada were taken into account in the 2018 emission estimates (ECA Amendments to MARPOL Annex VI). These emissions are outside the modeling domain but may impact the visibility in the Class I areas. Washington's projected 2018 emissions inventory also did not account for the now anticipated NO

emission reductions from the TransAlta NO

BART determination recently approved into the SIP.

The federal Better than BART determination proposed today for Tesoro identifies SO

emission reductions of 1068 t/y that were not included in the 2018 emission inventory. Also, the proposed federal Better than BART emission limits for Alcoa's Intalco operations, if finalized, are expected to reduce SO

emissions from the baseline year emission inventory by 1310 t/y. The sum total of the expected NO

reductions from the TransAlta BART determination and the proposed FIP actions for Tesoro and Intalco are: 3688 t/y NO

from TransAlta and 2378 t/y SO

Tesoro and Intalco.

D. Sources of Visibility Impairment in Washington Class I Areas

Each pollutant species has its own visibility impairing property; 1 μg/m

of sulfate, for example, is more effective in scattering light than 1 μg/m

of organic carbon and therefore impairs visibility more than organic carbon. Following the approach recommended by the WRAP and as explained more fully below, Washington used a two-step process to identify the contribution of each source or source category to existing visibility

impairment. First, ambient pollutant concentration by species (sulfate, nitrate, organic carbon, fine particulate, etc.) was determined from the IMPROVE sampler in each Class I area. These concentrations were then converted into light extinction values to distribute existing impairment among the measured pollutant species. This calculation used the “improved IMPROVE equation” (See section 2.C of the WRAP TSD) to calculate extinction from each pollutant specie concentration. Total extinction, in inverse megameters, was then converted to deciview using the equation defining deciview.

After considering the available models, the WRAP and western states selected two source apportionment analysis tools. The first source apportionment tool was the Comprehensive Air Quality Model with Extensions (CAM

) in conjunction with PM Source Apportionment Technology (PSAT). This model uses emission source characterization, meteorology and atmospheric chemistry for aerosol formation to predict pollutant concentrations in the Class I area. The predicted results are compared to measured concentrations to assess accuracy of model output. CAM

PSAT modeling was used to determine source contribution to ambient sulfate and nitrate concentrations. Thus, the WRAP used state-of-the-science source apportionment tools within a widely used photochemical model. EPA has reviewed the PSAT analysis and considers the modeling, methodology, and analysis acceptable. See section 6.A of the WRAP TSD.

The second tool was the Weighted Emissions Potential (WEP) model, used primarily as a screening tool to decide which geographic source regions have the potential to contribute to haze at specific Class I areas. WEP does not account for atmospheric chemistry (secondary aerosol formation) or removal processes, and thus is used for estimating inert particulate concentrations. The model uses back trajectory wind flow calculations and resident time of an air parcel over each area source to determine source area and source category and location for ambient organic carbon, elemental carbon, PM

2.5

, and coarse PM concentrations. These modeling tools were the state-of-the-science and EPA has determined that these tools were appropriately used by WRAP for regional haze planning. Description of these tools and our evaluation of them are described in more detail in section 6 of the WRAP TSD.

Chapter 8 of the Washington Regional Haze SIP submittal presents the light extinction for the base year at each Class I area by visibility impairing pollutant species for the average of the 20% worst days and the 20% best days. The most significant visibility impairing pollutant species identified for all Class I areas are: sulfate, nitrate, and organic carbon mass. For the Pasayten Wilderness area elemental carbon is also presented. See chapter 8 of the SIP submittal.

Tables 8-1 and 8-2 of the SIP submittal provides the percent contribution of “in state” sources to impairment in each Class I area on the 20% worst and best days for sulfate and nitrate for both 2002 and 2018. In the discussion below of each Class I area, the source category with the greatest impact will be identified.

Olympic National Park

Visibility at Olympic National Park is represented by the OLYM1 IMPROVE monitoring site. On the 20% most impaired days at Olympic National Park, sulfate accounts for 39%, nitrate accounts for 19%, and organic carbon accounts for 28% of impairment. On the 20% least impaired days, sulfate accounted for 36%, nitrate accounted for 17%, and organic carbon accounted 26% of impairment. See section 8.1 of the SIP submittal.

Sulfate on the 20% most impaired days at Olympic National Park: 37% is from outside the modeling domain, 21% originates from offshore Pacific offshore sources, and 21% from Canadian sources. Only 25% of the sulfate originates from sources in Washington. Washington point sources account for 15%, mobile sources 7%, and area sources 3% of sulfate impairment on the 20% most impaired days. Sulfate on the 20% least impaired days at Olympic National Park: 37% of the sulfate originates from outside the modeling domain, 34% from sources in Washington, 21% from sources in Canada, and 15% from Pacific offshore sources. Washington point sources account for 18% of the sulfate impairment on the 20% least impaired days.

Nitrate on the 20% most impaired days at Olympic National Park: 53% of the nitrate originates from sources in Washington, 21% originates in Canada, and 15% from the Pacific offshore. See Figure 8-5 of the SIP submittal. Of the sources in Washington, 40% is attributed to mobile sources, 9% to point sources, and 3% to area sources. Nitrate on the 20% least impaired days at Olympic National Park: 45% of the nitrate is from mobile sources, 8% from point sources, and 4% from area sources in Washington. See Table 8-2 of the SIP submittal.

Organic carbon is the second most significant pollutant impairing visibility in Olympic National Park. Most of the organic carbon originates in the Puget Sound area from area sources including aerosol formation from volatile organic compounds, natural and anthropogenic fire, and mobile sources. See section 8.1.3 of the SIP submittal.

North Cascades National Park and Glacier Peak Wilderness Area

These two Class I areas are represented by one IMPROVE monitor (NOCA1) located in the upper Skagit Valley. On the 20% most impaired days, sulfate accounts for 26%, nitrate accounts for 5%, and organic carbon accounts for 58% of impairment. On the 20% least impaired days, sulfate accounted for 45%, nitrate accounted for 14%, and organic carbon accounted to 21% of impairment. See section 8.2 of the SIP submittal.

Sulfate on the 20% most impaired: 32% of the sulfate originates from outside the modeling domain, 29% originates from sources in Washington, and 28% originates in Canada. See Figure 8-12 of the SIP submittal. Point sources in Washington contribute 20%, mobile sources contribute 5%, and area sources contribute 3% of the sulfate in these two areas. See Table 8-1 of the SIP submittal. Sulfate on the 20% least impaired days: 40% of the sulfate originates from outside the modeling domain, and 39% originates from sources in Washington. Of the sources in Washington, 23% comes from point sources, 10% from mobile sources, 5% from area sources (excluding fire), and 2% from fire. See Table 8-1 and Figure 8-15 of the SIP submittal.

Nitrate on the 20% most impaired days: 46% of the nitrate originates from sources in Washington, 27% from Canada, 16% from outside the modeling domain, and 7% from Pacific offshore sources. Of the sources in Washington, 34% is from mobile sources, 6% from point sources, 3% from fire, and 2% from area sources. See Table 8-2 and Figure 8-16 of the SIP submittal. Nitrate on the 20% least impaired days: 63% of the nitrate originates from sources in Washington, 13% from sources in Oregon and 10% originates from sources outside the modeling domain. Of the sources in Washington, 51% comes from mobile sources, 6% from point sources, 3% from area sources, and 2% from fire. See Table 8-2 and Figure 8-18 of the SIP submittal.

Organic carbon accounts for 56% of the impairment on the 20% most impaired days. Figure 8-21 shows that

most organic carbon originates in Washington with a smaller fraction originating in Canada. Most of the organic carbon originates in the Puget Sound area from area sources including aerosol formation from volatile organic compounds, natural and anthropogenic fire, and mobile sources.

Alpine Lakes Wilderness Area

Alpine Lakes Wilderness Area is represented by the SNPA1 IMPROVE monitoring site. On the 20% most impaired days, sulfate accounts for 34%, nitrate accounts for 23% and organic carbon accounts for 30% of impairment. On the 20% least impaired days, sulfate accounted for 40%, nitrate accounted for 18% and organic carbon accounted for 16% of impairment. See section 8.3 of the SIP submittal.

Sulfate on the 20% most impaired days: 38% of the sulfate originates from outside the modeling domain, 32% from sources in Washington, 17% from Canada, and 8% from Pacific offshore. Of the sources in Washington, 16% is from point sources, 10% from mobile sources, and 5% from area sources. See Table 8-1 and Figure 8-23 of the SIP submittal. Sulfate on the 20 least impaired days: 42% of the sulfate originates from sources in Washington, 38% from outside the modeling domain, and 8% from Pacific offshore. Of the sources in Washington, 26% is from point sources, 11% from mobile sources, and 5% from area sources. See Table 8-1 and Figure 8-25 of the SIP submittal.

Nitrate on the 20% most impaired days: 68% of the nitrate originates from sources in Washington, 9% from outside the modeling domain, and 5% from Canada. Of the sources in Washington, 56% is from mobile sources, 5% from point sources and 3% from area sources and 3% from fire. See Table 8-2 and Figure 8-27 of the SIP submittal. Nitrate on the 20% least impaired days: 65% of the nitrate originates from sources in Washington, 15% from sources in Oregon, 9% from outside the modeling domain, and 7% from offshore Pacific sources. Of the sources in Washington, 52% is from mobile sources, 7% from point sources, 3% from area sources, and 1% from fire. See Table 8-2 of the SIP submittal.

Organic carbon on the 20% most impaired days is dominated by area sources in Washington. See Figure 8.2.3 and Table 8-3 of the SIP submittal. Organic carbon on the 20% least impaired days is dominated by area sources in Washington. See Table 8-3 of the SIP submittal.

Mount Rainier National Park

In Mount Rainier National Park, as monitored at the MORA1 IMPROVE monitoring site, sulfate is the largest contributor to visibility impairment on the most impaired days, as well as on the least impaired days. On the 20% most impaired days, sulfate accounts for 46%, nitrate accounts for 10%, and organic carbon accounts for 29% of impairment. On the 20% least impaired days, sulfate accounted for 40%, nitrate accounted for 10%, and organic carbon accounted to 23% of impairment. See section 8.4 of the SIP submittal.

Sulfate on the 20% most impaired days: 42% originates from sources in Washington, 31% originates from outside the modeling domain, 12% from Canada, and 12% from Pacific offshore. See Figure 8-34 of the SIP submittal. Of the sources in Washington, 25% is from point sources, 11% from mobile sources, and 6% from area sources. See Table 8-1 of the SIP submittal. Sulfate on the 20% least impaired days: 36% of the sulfate originates from sources in Washington, 38% from outside the modeling domain, 16% from sources in Oregon, and 8% from Pacific offshore. Of the sources in Washington, 25% is from point sources, 7% from mobile sources, and 3% from area sources. See Table 8-1 and Figure 8-36 of the SIP submittal.

Nitrate on the 20% most impaired days: Washington sources account for 78% of nitrate impairment. Of the Washington sources, 62% is from mobile sources, 9% from point sources, 5% from area sources, and 1% from fire. Nitrate on the 20% least impaired days: Washington sources account for 42% and sources in Oregon accounts for 35% of nitrate impairment. Of the sources in Washington, 32% is from mobile sources, 7% from point sources, 2% from area sources, and 1% from fire.

On the 20% most impaired days, almost all the organic carbon originates from sources located in Washington. See Figure 8-43 of the SIP submittal. On the 20% least impaired days, almost all the organic carbon originates from sources in Washington with some contribution from sources in Oregon. See Figure 8-44 of the SIP submittal.

Goat Rocks and Mount Adams Wilderness Areas

Both wilderness areas are represented by one IMPROVE monitoring site WHPA1. On the 20% most impaired days at these areas, sulfate accounts for 37%, nitrate accounts for 13%, and organic carbon accounts for 36% of impairment. On the 20% least impaired days, sulfate accounts for 49%, nitrate accounts for 13%, and organic carbon accounts for 14% of impairment. See section 8.5 of the SIP submittal.

Sulfate on the 20% most impaired days: 39% originates from sources outside the modeling domain, 29% originates from sources in Washington, and 18% from Canada. See Figure 8-45 of the SIP submittal. Of the sources in Washington, 16% is from point sources, 8% from mobile sources, and 4% from area sources. See Table 8-1 of the SIP submittal. Sulfate on the 20 least impaired days: 44% of the sulfate originates from sources in Washington, 29% from outside the modeling domain, 16% from sources in Oregon, and 8% from Pacific offshore. Of the sources in Washington, 30% is from point sources, 9% from mobile and 4% from area sources.

Nitrate on the 20% most impaired days: 64% originates from sources in Washington and 13% from sources outside the modeling domain. Of the sources in Washington, 52% is from mobile sources, 6% from point sources, 4% from area sources, and 2% from fire. See Table 8-2 and Figure 8-49 of the SIP submittal. Nitrate on the 20% least impaired days: 49% originates from sources in Washington, and 29% from sources in Oregon. Of the sources in Washington, 38% is from mobile sources, 7% from point sources, 2% from area sources, and 1% from fire. See Table 8-2 and Figure 8-51 of the SIP submittal.

On the 20% most impaired days, organic carbon is the second largest contributor to impairment in the Goat Rocks and Mt. Adams Wilderness Areas. Most of the OMC originates in Washington, with Oregon sources contributing minor amounts. See Figure 8-54 of the SIP submittal. On the 20% least impaired days, organic carbon sources in Washington, and Oregon contribute almost equally. See Figure 8-55 of the SIP submittal.

Pasayten Wilderness Area

The Pasayten Wilderness Area is monitored by the PASA1 IMPROVE monitor. On the 20% most impaired days, 20% is due to sulfate, nitrate accounts for 8%, and organic carbon accounts for 56% of impairment. On the 20% least impaired days, sulfate accounts for 49%, nitrate accounts for 17%, and organic carbon accounts for 17% of impairment. See section 8.6 of the SIP submittal.

Sulfate on the 20% most impaired days: 50% originates from outside the modeling domain, 22% from Canada, and 18% from Washington. Of the Washington sources, 8% is from point sources, 4% is from mobile sources, 4%

from fire and 2% from area sources. See section 8.6 and Table 8-1 of the SIP submittal. Sulfate on the 20% least impaired days: 40% originates from outside the modeling domain, 36% from Washington sources, and 10% from Canadian sources. Of the sources in Washington, 21% is from point sources, 10% from mobile sources, and 5% from area sources.

Nitrate on the 20% most impaired days: 48% originates from sources in Washington, 17% from outside the modeling domain, and 13% from Canadian sources. Of the sources in Washington, mobile sources contribute 36%, natural fire and biogenic sources 8%, and 3% point sources. Nitrate on the 20% least impaired days: 62% originates from sources in Washington, 15% from Oregon, and 85 from outside the modeling domain. Of the sources in Washington, 49% is from mobile sources, 6% from point sources, and 4% from natural and biogenic sources.

On the 20% most and least impaired days, organic carbon is responsible for over half of the total impairment. Natural fire in Washington is responsible for almost all the organic carbon and a small portion due to Washington area sources. See Figure 8-65 of the SIP submittal.

EPA is proposing to find that Washington, using the WRAP analysis, appropriately identified the pollutant species and source categories contributing to impairment to the Class I areas in Washington. See WRAP TSD.

E. Best Available Retrofit Technology

1. BART-Eligible Sources in Washington

The first phase of a BART evaluation is to identify all the BART-eligible sources within the Washington's boundaries. Table 11-1 in the SIP submission presents the list of all BART-eligible sources located in Washington. These sources and their source categories are:

Source

Category

Graymont Western US INC (Tacoma)

Lime plants.

TransAlta Centralia Generation, LLC

Fossil fuel-fired steam electric plants with a heat input greater than 250 MMBtu per hour.

Longview Fibre Co—Longview

Kraft Pulp Mills.

Weyerhaeuser Co—Longview

Kraft Pulp Mills.

Fort James Camas LLC (now Georgia Pacific Corporation—Camas)

Kraft Pulp Mills.

Goldendale Aluminum

Primary Aluminum Ore Reduction Plants.

Port Townsend Paper Co

Kraft Pulp Mills.

Simpson Tacoma Kraft

Kraft Pulp Mills.

Lafarge North America (Seattle)

Portland Cement Plants.

Intalco (Ferndale)

Primary Aluminum Ore Reduction Plants.

Alcoa Wenatchee Works

Primary Aluminum Ore Reduction Plants.

BP Cherry Point Refinery (Ferndale)

Petroleum Refineries.

Tesoro Refining and Marketing (Anacortes)

Petroleum Refineries.

Puget Sound Refining Company

Petroleum Refineries.

Conoco-Philips Company (Ferndale)

Petroleum Refineries.

2. Sources Subject to BART

The second phase of the BART determination process is to identify those BART-eligible sources that may reasonably be anticipated to cause or contribute to any impairment of visibility at any Class I area and are, therefore, subject to BART. As explained above, EPA has issued guidelines that provide states with guidance for addressing the BART requirements. 40 CFR part 51 appendix Y; see also 70 FR 39104 (July 6, 2005). The BART Guidelines describe how states may consider exempting some BART-eligible sources from further BART review based on dispersion modeling showing that the sources contribute to visibility impairment below a certain threshold. Washington conducted dispersion modeling for all the BART-eligible sources to determine the visibility impacts on Class I areas.

The BART Guidelines advises states to set a contribution threshold to assess whether the impact of a single BART-eligible source is sufficient to cause or contribute to visibility impairment at a Class I area. Generally, states may not establish a contribution threshold that exceeds 0.5 dv impact. 70 FR 39161. Washington established a contribution threshold of 0.5 dv. The 0.5 dv threshold is consistent with the threshold used by all other states in the WRAP. Any BART-eligible source with an impact of greater than 0.5 dv in any mandatory Class I area, including Class I areas in other states, would be subject to a BART analysis and BART emission limitations.

To determine those sources exceeding this contribution threshold and thus subject to BART, Washington used the CALPUFF dispersion modeling. The dispersion modeling was conducted in accord with the “Washington, Oregon, Idaho BART Modeling Protocol”. This Protocol was jointly developed by the states of Idaho, Washington, Oregon and EPA and has undergone public review. The Protocol was used by all three states in determining which BART-eligible sources are subject to BART. See appendix H of the SIP submittal for details of the modeling protocol, its application and results.

The SIP submittal contained no rationale for adopting a 0.5 dv threshold for determining whether a BART-eligible source may be reasonably anticipated to cause or contribute to any visibility impairment in a mandatory Class I area. Although a number of stakeholders may have agreed that a 0.5 dv threshold is appropriate, and other states in the Region may have adopted such a threshold, such agreement does not provide sufficient basis for concluding that such a threshold was appropriate in the case of Washington. Based on EPA's review of the BART-eligible sources in Washington, however, and for the reasons discussed below, EPA is proposing to find that a 0.5 dv threshold is appropriate, given the specific facts in Washington.

Relying on modeling that each source conducted using the “Idaho-Oregon-Washington BART Modeling Protocol” that was reviewed by Washington, the visibility impact of each source was determined on all Class I areas within 300 km of all but one of the BART-eligible sources. See Table 11-3 of the SIP submittal for those sources with less than a 0.5 dv impact. The BART-eligible sources are generally widely distributed across the Washington. Given the relatively limited impact on visibility from these sources, Washington could have reasonably concluded that a 0.5 dv threshold was appropriate for capturing

those BART-eligible sources with significant impacts on visibility in Class I areas. For these reasons, EPA is proposing to approve the 0.5 dv threshold adopted by Washington in its Regional Haze SIP.

In the BART Guidelines, EPA recommended that states “consider the number of BART sources affecting the Class I areas at issue and the magnitude of the individual sources' impacts. In general, a larger number of BART sources causing impacts in a Class I area may warrant a lower contribution threshold.” 70 FR 39104, 39161 (July 6, 2005). In developing its Regional Haze SIP, Washington requested 14 of the 15 BART-eligible sources to model their respective impact on the Class I areas within a 300 km radius. For Goldendale Aluminum, Washington relied on modeling conducted by EPA, rather than requesting the source to model its impact because the facility has not operated since 2001.

Below is the list of sources that Washington determined were subject to BART and the Class I area for which the source has the greatest visibility impact (average of the three annual 8th highest daily value over 2003-2005 baseline):

BP Cherry Point Refinery, Blaine Wa

0.9 dv at Olympic National Park

Intalco Aluminum Corp. Ferndale

2.4 dv at Olympic National Park.

Tesoro Refining and Marketing Co

1.7 dv at Olympic National Park.

Port Townsend Paper Co

1.2 dv at Olympic National Park.

Lafarge North America

3.16 dv at Olympic National Park.

TransAlta Centralia Generation LLC

5.5 dv at Mt. Rainier National Park.

Weyerhaeuser Longview

1.0 dv at Mt. Rainier National Park.

3. Washington Source Specific BART Analyses

A BART determination was conducted for each of the sources subject to BART. At Washington's request, each source conducted its own BART analysis and prepared a report which Ecology then reviewed and used to make a case-by-case BART determination. In conducting the BART analysis, Washington considered all five BART factors. Washington explained that in order for it to select a specific control technology as BART, it must be technically feasible, cost effective, provide a visibility benefit, and have minimal potential for adverse non-air quality impacts. Washington further explained that normally visibility improvement is only one of the factors but if two available and technically feasible controls are essentially equivalent in cost effectiveness and collateral impacts then visibility may become the deciding factor. See e.g. Washington Regional Haze SIP submittal L-13. The BART determination, including controls, emission limits and compliance deadlines are reflected in an enforceable Order issued to each source. The BART Orders are included in the SIP submittal. Below is a table of compliance dates for each BART Order.

Facility

Compliance date

BP Cherry Point Refinery: Compliance for all PM, NO

, and SO

emission limits

July 7, 2010.

Intalco Aluminum Corp. Compliance with all PM, NO

, and SO

emission limits

November 15, 2010.

Tesoro Refining and Marketing Company

Compliance for all PM and SO

emission limits

July 7, 2010.

Compliance with NO

emission limits (unit F-103)

September 30, 2015.

Port Townsend Paper Corp.

Compliance with emission limits for PM, NO

, and SO

October 20, 2010.

Lafarge North America, Inc.

Compliance with all PM emission limits

July 28, 2010.

Compliance with SO

emission limits

No than April 30, 2011, or 90 days after the kiln is restarted if the kiln is in temporary cessation on February 1, 2011.

Compliance with NO

emission limits

No later than the date Lafarge completes optimization of the NO

control system per specified criteria.

Weyerhaeuser Corp.

Compliance with emission limits for PM, NO

, and SO

July 7, 2010.

Below is a summary of Washington's BART analysis and determination for each of the seven sources subject to BART. Additional detail regarding the analysis for each source, unit and pollutant may be found in the Washington Regional Haze SIP submittal, appendix L.

a. British Petroleum, Cherry Point Refinery

The BP Cherry Point Refinery located near Ferndale, Washington, is a BART-eligible source subject to BART. Its maximum visibility impact of 0.9 dv is at Olympic National Park. Impacts at all other Class I areas within 300 km are less than 0.5 dv. See Table 11-4 of the SIP submittal. As summarized below, Washington and BP completed a BART analysis for all BART-eligible units at the refinery. Washington's BART determination, issued to BP as BART Compliance Order No. 7836 (BP Cherry Point BART Compliance Order), is included in the Washington's Regional Haze SIP submission. See Washington Regional Haze SIP submittal, page L-47. Additionally, the operating permit No. 7836 included with the SIP submittal contains emission control requirements for non-BART units beyond those required for BART.

As a component of a national consent decree between BP and the EPA, (United States District Court for the Northern District of Indiana, Hammond Division; Civil No. 2:96CV 095RL) most of the refinery's heaters and boilers have been evaluated for upgraded and retrofit control technology. As required under the consent decree, many heaters had been retrofitted with low-NO

burners (LNBs) or ultra-low-NO

burners (ULNBs). Washington considered these federally enforceable upgrades as existing control in the BART analysis.

One general consideration in determining the cost effectiveness of all potential BART control technologies for BP is the ability to install the retrofit technology during a regularly scheduled turnaround or maintenance period at the facility. Turnaround is the term used to describe when the refinery is shutdown periodically, on approximately 5 year intervals, for routine maintenance and process equipment upgrades. A retrofit during a routine turnaround would not incur the extra costs associated with loss of revenues during shutdown. Washington determined the cost effectiveness values of installing controls both during routine turnaround and outside the normal turnaround period.

Table 1-1 of the BP Cherry Point BART determination of appendix L of the SIP submittal identifies all emitting units at the facility and indicates whether the units are BART-eligible. Twenty-one of the refinery's emission units were determined to be BART-eligible and subject to BART. These units are as follows:

Heaters and Boilers:

Power Boiler #1 and Power Boiler #3 were replaced in 2009 by Boilers #6 and #7. Boilers #6 and #7 were not considered in the BART determination as they are not BART-eligible and were permitted under PSD. The BART Order 7836 issued to BP July 7, 2010, Finding C and Condition 7 “Other Requirements” requires decommissioning of Boilers #1 and #3 no later than March 27, 2010.

• Crude Charge Heater

• South Vacuum Heater

• Naphtha Hydrodesulfuriztion (HDS) Charge Heater

• Naphtha HDS Stripper Reboiler

• #1 Reformer Heaters

• Coker Charge Heater (#1 North)

• Coker Charge Heater (#2 South)

• 1st Stage Hydrocracker (HC) Fractionator Reboiler

• 2nd Stage HC Fractionator Reboiler

• R-1 HC Reactor Heater

• R-4 HC Reactor Heater

• #1 Diesel HDS Charge Heater

• Diesel HDS Stabilizer Reboiler

• Steam Reforming Furnace #1

• Steam Reforming Furnace #2

Sulfur Recovery Systems

• Two Sulfur Recovery Units (SRUs) and one of the associated Tail Gas Units (TGU)

Flares

• High Pressure Flare

• Low Pressure Flare

Material Handling

• Green Coke Load Out equipment

General Discussion of NO

Control Technologies Considered for Heaters and Boilers at BP

BP conducted a source category evaluation of all available control technologies for this source category to eliminate those that are infeasible. All available NO

control technologies identified for further evaluation were based on the EPA RACT/BACT/LAER Clearinghouse (RBLC). See appendix L of the SIP submittal at L-29. The table below identifies those NO

control technologies and indicates which were determined to generally be technically feasible:

Technology

Sources to which they would potentially be applicable

Is it technically Feasible?

Selective Catalytic Reduction (SCR)

All Heaters

Yes.

Low-NO

Burners (LNB) or Ultra Low NO

Burners (ULNB)

All Heaters

Yes.

Selective non-catalytic Reduction (SNCR)

All Heaters

No. Exhaust gas temperatures vary too much and temperatures not in range for SNCR operation.

External Flue Gas Recirculation (FGR)

All Heaters and Boilers

No—Potential safety Issues.

Low Excess Air

Operation—CO

Control

All Units

No—Potential safety issues and small operating range.

Steam Injection

All Units

Not feasible except 1st Stage HC Fractionator Reboiler.

Lower Combustion Air

Preheat

Units with air preheat

No. cooler air is introduced into the heater as combustion air, the heater has to utilize additional fuel to heat the air for the combustion process which ends up negating any NO

reductions generated.

CETEK—Descale & Coat Tubes

Units with externally scaled tubes

No. This technique is only applicable to units where the heat transfer tubes are externally scaled.

Modify Existing Burners to Improve NO

emissions

All

Yes.

Evaluation of Technically Feasible NO

Controls for specific heaters and boilers

Crude Charge Heater (NO

The Crude Charge Heater currently uses conventional burners. Washington determined that a LNB is technically infeasible for this specific emission unit due to the high flame temperatures and heat density needed for the process. LNB would lower the flame temperature below that needed for the process and flame impingement from LNB would de-rate the heater and reduce throughput. Washington determined that while SCR is technically feasible for the Crude Charge Heater, it is not cost effective at $14,658/ton during scheduled turnaround and $32,000/ton during non-scheduled turnaround. Washington determined BART for NO

for the Crude Heater is existing conventional burners.

South Vacuum Heater (NO

The South Vacuum Heater currently has ultra low-NO

burners. These burners were installed in 2005 in accordance with the national consent decree. Washington determined that SCR is not cost effective for the South Vacuum Heater regardless of whether it was installed during a scheduled turnaround or not. Cost effectiveness during a scheduled turnaround or outside turnaround is $54,551/ton and $82,643/ton respectively. Washington determined BART for this unit is the existing ULNB. The NO

emission limit is 0.08 lb/MMBtu.

Naphtha HDS Charge Heater & Naphtha HDS Stripper Reboiler (NO

Both of these boilers currently employ conventional burners in relatively small fire boxes. LNB is deemed infeasible on

both of these units due to small size of the heater and because, with LNBs, flame impingement on the boiler tubes would cause premature failure. SCR is not cost effective at $46,667/ton during turnaround and $31,467/ton during non-turnaround. Washington determined BART for NO

is the existing conventional burners.

#1 Reformer Heater (NO

The #1 Reformer Heater has a complex design with four independent fire boxes and two stacks. It is currently fitted with conventional burners. LNB is infeasible due to small size of firebox and because the longer flame length of LNB would cause flame impingement on the heater tubes and lead to premature failure. SCR is not cost effective at $15,253/ton during turnaround and $17,299/ton during non-turnaround. Washington determined BART for NO

is the current conventional burners.

Coker Charge Heater (#1 North) and Coker Charge Heater (#2 South) (NO

The Coker Heaters are both currently using early design (1999) LNB which incorporate staged air combustion and flue gas recirculation. LNB of a newer design is not cost effective at $31,301/ton for the #1 North Heater and $30,762/ton for the #2 South Heater. SCR is not cost effective at $35,202/ton for the #1 North Heater and $34,597/ton for the #2 South Heater. Washington found that BART for NO

is the existing LNB with staged air combustion and flue gas recirculation. The NO

emission limit for these units is 0.08 lb/MMBtu

#1 Diesel HDS Charge Heater and Diesel HDS Stabilizer Reboiler (NO

The heater and reboiler are currently fitted with ULNBs to comply with the consent decree. SCR is not cost effective at $192,585/ton for the #1 Diesel HDS Charge Heater and $145,094/ton for the Diesel HDS Stabilizer Reboiler. Washington determined BART for NO

for the Diesel HDS Charge Heater is the existing ULNB with an emission limit of 0.040 lb/MMBtu.

Washington determined BART for NO

for the Stabilizer Reboiler Heater is existing ULNBs with an emission limit of 26 ppmv (dry basis corrected to 7% O

) based on a 24-hour rolling average. If this concentration is exceeded, a secondary limit to demonstrate compliance is 2.2 lb/hour based on a 24-hour rolling average.

Steam Reforming Furnace #1 (North H2 Plant) and Steam Reforming Furnace #2 (South H2 Plant) (NO

These units currently use conventional burners. LNB is not cost effective for these two furnaces at $21,234/ton for the North H2 Plant and $21,682/ton for the South H2 Plant. SCR is not cost effective at $28,378/ton for the North Plant and $28,900/ton for the South Plant. LNB with SCR is not cost effective at $29,555/ton and $30,104/ton. Washington determined that BART for NO

for these units is the existing conventional burners.

R-1 HC Reactor Heater (NO

This heater currently operates with ULNB in accord with consent decree. In the general evaluation of control technologies for heaters and boilers BP determined that the only feasible technology with greater control efficiency than ULNB is SCR. SCR is not cost effective at $214,726/ton NO

removed. Washington determined BART is the existing ULNB with a NO

emission limit of 26 ppm by volume dry basis corrected to 7% O

on a 24-hour rolling average. Should the concentration limit be exceeded, the mass emission limit is 3.6 lb/hr on a 24-hour rolling average.

R-4 HC Reactor Heater (NO

The R-4 HC Reactor Heater is currently operating with conventional burners. LNBs are not technically feasible due to high heat density, flame impingement, and flame shape that would exceed the American Petroleum Institute (API) guidelines for burner spacing. SCR is not cost effective at $36,620/ton. Washington determined that BART is the current burners.

1st Stage HC Fractionator Reboiler (NO

BART):

The 1st stage HC Fractionator Reboiler is currently operating with conventional burners. The BART cost effectiveness analysis to install ULNBs is estimated by BP to be $12,044/ton. Washington determined this value to not be cost effective, however BP volunteered to install ULNB on this unit to achieve 0.05 lb NO

/MMBtu. Washington did not propose ULNB as BART, but rather said in the BART analysis report the emission reductions would be considered in a future SIP submittal as further reasonable progress. (appendix L, at L-41) SCR is determined to be not cost effective at $19,470/ton. Washington determined BART to be the current conventional burners. The BART Order for BP, submitted with the Plan, includes a NO

emission limit for this emission unit of 0.07 lb/MMBtu monthly average, or 56.2 tons per calendar year.

2nd Stage HC Fractionator Reboiler:

This reboiler is currently fitted with LNBs. Washington found that ULNB is not cost effective at $36,395/ton and SCR is not cost effective at $37,810/ton. LNB with SCR is not cost effective at $40,768/ton. Washington determined BART to be the existing LNBs with an emission limit for NO

of 0.07 lb/MMBtu based on a 24-hour average not to exceed 56.2 t/y on a calendar year rolling average.

General Discussion of SO

Control Technologies Considered and Those Technically Feasible for Heaters and Other Combustion Devices

Washington and BP identified four add-on SO

control technologies from the RBLC as described below; Emerachem EMX, Dry Scrubbing, Fuel Gas Conditioning (sulfur content reduction), and wet flue gas desulfurization (wet-FGD). In addition, the combination of fuel gas conditioning and wet flue gas desulfurization (wet-FGD) was considered. See SIP submittal, appendix L at L-28.

Emerachem EMX (previously known as SCONO

This technology has not been proven to run longer than one year without major maintenance. It has only been used on a small number of natural gas combustion turbines for NO

control, and to date has not been used on oil refinery heaters to reduce SO

emissions. BP requires the refinery heaters to be able to operate five years between turnarounds. This technology is technically infeasible for use on the refinery heaters. Therefore, Washington agreed with BP that the technology is considered technically infeasible at this facility.

Dry Scrubbing:

This technology requires a maintenance turnaround approximately every two years due to equipment plugging and wear. This level of needed maintenance is inconsistent with the refinery's turnaround schedule of every 5 years. Therefore, Washington agreed with BP that the technology is considered technically infeasible at this facility.

Fuel Gas Conditioning:

This technology would reduce the concentration of sulfur in the refinery fuel gas from the current NSPS Subpart J limit of 162 ppmv hydrogen sulfide (H

S) to 50 ppmv and this would reduce the average sulfur concentration in the fuel gas combusted by BART-eligible units by 89%. Cost effectiveness to upgrade the fuel gas treatment system to meet a 50 ppmv concentration limit is $22,282/ton when the costs are applied only to the BART units. Because fuel gas conditioning would be used for all the combustion sources at the refinery (both BART and non-BART), the technology would also reduce emissions from the non-BART units. When cost effectiveness calculations are applied to all emission units at the BP refinery the cost effectiveness is $14,428/ton. Washington determined this technology to not be cost effective.

Wet FGD:

The cost effectiveness of wet flue gas desulfurization is

calculated to be between $29,982/ton and $102,068/ton because the fuel gas already meets the existing fuel gas limit of 162 ppmH

S. Washington has determined this technology is not cost effective.

Fuel Gas Conditioning and Wet FGD:

The cost effectiveness of combined fuel gas conditioning and wet flue gas desulfurization is $49,743/ton and $179,151/ton. Washington has determined this technology is not cost effective.

Conclusions for SO

BART:

Washington determined that the existing fuel gas sulfur removal system is BART for SO

for the refinery heaters.

Particulate Matter Control Technologies Considered for Heaters:

BP reviewed information in EPA's RBLC database and control technology literature to find available technologies to control particulate emissions from refinery heaters. The most promising and thus those considered for further evaluation were fuel gas conditioning and wet electrostatic precipitators (WESP).

Fuel Gas conditioning:

This control technology is discussed above in the BART determination for SO

and was determined to be not cost effective for PM control at this facility.

WESP:

Using this technology would require a wet electrostatic precipitator (WESP) to be added to each heater and boiler. The cost effectiveness is determined to be $24,280/ton and determined to not be cost effective.

Since there are no technically or economically feasible PM control measures, Washington found that BART for PM for the heaters is good operating practices and the current refinery fuel gas treatment system.

Control Technologies Considered for NO

and PM and Those Technically Feasible for High and Low Pressure Flares:

BP currently operates both a high pressure and low pressure flare. After a review of the RBLC, no add-on control technologies were identified. Currently both flares meet the applicable NSPS requirements for flares which emit NO

, SO

, and PM

2.5

(40 CFR 60.18 General control device and work practice requirements). Both flares are of smokeless design and steam assisted. A flare gas recovery system was installed in 1984 that significantly decreased the total volume of gas routinely sent to the flare. In addition, a coker blow down vapor recovery system was installed in 2007 that further reduced both the volume and sulfur content of the routinely flared gas. According to BP's analysis, as relied on by Washington, no add-on control technologies for flares were identified or known to be in commercial use for additional control of NO

, SO

, or PM.

Washington determined and required by BART Order 7836, BART for NO

, SO

, and PM control is the continued operation and maintenance of the existing high and low pressure flares, including the continued use of the flare gas recovery system, limiting pilot light fuel to pipeline grade natural gas, operating in accordance with 40 CFR 60.18, and conversion from steam assisted to air assisted flares. Additionally, sources using flares to comply with Refinery MACT equipment leak provisions shall monitor flares to assure they are maintained and operated properly to reduce the emissions of organic HAPS from miscellaneous process vents by 98% or to 20 ppmv. Flares shall be operated at all times when emissions may be vented to them.

emissions from the high and low pressure flares shall not exceed 1000 ppm corrected to 7% O

averaged over a 60-minute period.

All Control Technologies Considered and Those Technically Feasible for Sulfur Recovery Systems

The sulfur recovery units (SRU) convert hydrogen sulfide (H

S) to SO

and elemental sulfur. BP operates two SRUs in parallel with their exhaust gas streams combined and distributed to two tail gas units (TGU). One TGU utilizes the Shell Claus Off-gas Treating Process (SCOT) technology, a patented technology, and the other utilizes the CANSOLV (registered trademark of Cansolv Technologies Inc.) technology to assist in further collection of sulfur compounds and reducing the quantity of SO

discharged via the “incinerator stack.” The primary pollutant from the sulfur recovery unit is SO

. The SRUs are subject to the requirements of 40 CFR 63 Subpart UUU, which specifies 40 CFR 60, Subpart J compliance as a control option. The SRUs are currently controlled to this MACT standard.

BP and Washington's analysis found that the RBLC database and control technology literature lists available technologies to control NO

emissions from the SRUs and the TGU. In the RBLC, 24 entries were found regarding NO

control for SRUs and TGUs at refineries. Two categories of control methods for NO

were listed:

• Good Operating Practices (e.g., “proper equipment design and operation, good combustion practices, and use of gaseous fuels”, “optimized air-fuel ratio”, and “good operating practices”)

• LNBs: LNBs can be installed either within the SRU itself (usually only as part of the initial design) or in the TGU. Replacing the existing burner in the SRU with a LNB would increase the flame length causing flame impingement and possible damage to the SRU. Because of the flame impingement issues, a LNB within the SRU is technically infeasible.

The original TGU at the refinery was installed in 1977 and utilizes natural draft burners which are not suitable for the direct installation of a LNB. The natural draft design would require addition of fans to supply air to the LNBs. The cost to install LNBs and additional fans would not be cost effective.

Washington determined that the continued operation of the existing SRUs and TGUs is BART for NO

, SO

and PM

/PM

2.5

. The BART Order 7836 for BP, included in the SIP submittal, requires that SO

emitted from the SRU not exceed 135 tons during each consecutive 12-month rolling period. Supplemental fuel gas combusted in the No. 1 TGU is limited to a composition of H

S <230 mg/dscm (0.10 gr/dscf) which is equivalent to 162 ppmH

S, 3 hour rolling average. NO

emissions from No. 2 TGU Stack are limited to 2.5 lbs/hr. SO

emissions from No. 2 TGU Stack are limited to 24.0 lbs/hr. In accordance with NSPS Subpart J, SO

emissions from the TGU stacks is limited to 250 ppm dry basis corrected to 0% O

based on a 12-hour rolling average or 1500 ppm dry basis corrected to 0% O

based on a 1-hour average.

Control Technologies Considered and Those Technically Feasible for Green Coke Load Out

The Green Coke Load Out system was constructed as part of the original refinery. The equipment was functionally replaced in 1978 by installation of the #1 & #2 calciners and a new coke load out system. However, the old equipment still physically exists at the refinery as back up during an emergency because there is no storage capability at the facility. Washington recognizes that continued ability to use the Green Coke Load Out system in an emergency is appropriate. Due to the limited use of the Green Coke Load Out system, the cost of any control would result in a high cost effectiveness value and limited visibility improvement. Washington's BART determination allows its limited emergency usage.

Cooling Tower:

Cooling towers produce particulate from water droplet drift away from the towers. Washington evaluated droplet and particulate drift from cooling towers in the past and found that they produce relatively large particulate that does not drift far from

the tower. Washington has made a qualitative review of BART for the control of particulate from this cooling tower and determined that the existing drift controls satisfy BART for this unit.

Visibility Improvement Expected From BART

BP modeled the visibility improvement expected to result from the implementation of BART determinations for the #1 Diesel HDS Charge Heater, HDS Stabilizer Reboiler, R-1 HC Reactor Heater, and 1st Stage HC Fractionator Reboiler. Visibility at the most impacted Class I area, Olympic National Park, using the metric of the 3-year combined 98% value (22nd high), improved from 0.84 dv to 0.79 dv, and the 98% value (max annual 8th high) improved from 0.9 dv to 0.83 dv. EPA is proposing to approve the BART Order with emission limitations on SO

, NO

, and PM

2.5

for the BART-eligible units at BP as they are reasonable.

The Table summarizes the proposed BART determination technology for each BART emission unit:

Emission unit

Technology

Crude Charge Heater