Air Plan Partial Approval and Partial Disapproval; AK, Fairbanks North Star Borough; 2006 24-Hour PM2.5 Serious Area and 189(d) Plan

Federal RegisterJan 10, 2023

Ask Donna

What actually matters in this document.

Text

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 52

[EPA-R10-OAR-2022-0115; FRL-9755-01-R10]

Air Plan Partial Approval and Partial Disapproval; AK, Fairbanks North Star Borough; 2006 24-Hour PM

2.5

Serious Area and 189(d) Plan

AGENCY:

Environmental Protection Agency (EPA).

ACTION:

Proposed rule.

SUMMARY:

The Environmental Protection Agency (EPA) is proposing to approve in part and disapprove in part the state implementation plan (SIP) revisions, submitted by the State of Alaska (Alaska or the State) to address Clean Air Act (CAA or Act) requirements for the 2006 24-hour fine particulate matter (PM

2.5

) national ambient air quality standards (NAAQS) in the Fairbanks North Star Borough PM

2.5

nonattainment area (Fairbanks PM

2.5

Nonattainment Area). Alaska made these submissions on December 13, 2019, and December 15, 2020.

DATES:

Comments.

Written comments must be received on or before March 13, 2023.

Public Hearing.

EPA plans to hold one public hearing concerning the proposed rule in Fairbanks, Alaska. The date, time and location will be announced separately.

ADDRESSES:

Submit your comments, identified by Docket ID No. EPA-R10-OAR-2022-0115, at

https://www.regulations.gov.

Follow the online instructions for submitting comments. Once submitted, comments cannot be edited or removed from

regulations.gov.

EPA may publish any comment received to its public docket. Do not submit electronically any information you consider to be Confidential Business Information (CBI) or other information the disclosure of which is restricted by statute. Multimedia submissions (audio, video, etc.) must be accompanied by a written comment. The written comment is considered the official comment and should include discussion of all points you wish to make. EPA will generally not consider comments or comment contents located outside of the primary submission (

i.e.,

on the web, cloud, or other file sharing system). For additional submission methods, the full EPA public comment policy, information about CBI or multimedia submissions, and general guidance on making effective comments, please visit

https://www.epa.gov/dockets/commenting-epa-dockets.

FOR FURTHER INFORMATION CONTACT:

Matthew Jentgen, EPA Region 10, 1200 Sixth Avenue—Suite 155, Seattle, WA 98101, (206) 553-0340,

jentgen.matthew@epa.gov.

SUPPLEMENTARY INFORMATION:

Throughout this document wherever “we,” “us,” or “our” is used, it is intended to refer to EPA.

Table of Contents

I. Background

A. Environmental Justice Considerations

II. Clean Air Act Requirements for PM

2.5

Serious Area Plans and for PM

2.5

Serious Areas That Fail To Attain

A. Requirements for PM

2.5

Serious Area Plans

B. Requirements for PM

2.5

Serious Areas That Fail To Attain

C. Combined Requirements for PM

2.5

Serious Areas and Serious Areas That Fail To Attain

III. Review of the Fairbanks Serious Plan and Fairbanks 189(d) Plan

A. Emission Inventories

B. Pollutants Addressed

C. Control Strategy

D. Attainment Demonstration and Modeling

E. Reasonable Further Progress

F. Quantitative Milestones

G. Contingency Measures

H. Motor Vehicle Emissions Budgets for Transportation Conformity

I. Nonattainment New Source Review Requirements Under CAA section 189(e)

IV. Consequences of a Disapproval

A. The Act's Provisions for Sanctions

B. Federal Implementation Plan Provisions That Apply If a State Fails To Submit an Approvable Plan

C. Ramifications Regarding Transportation Conformity

V. Summary of Proposed Action

A. Proposed Approval

B. Proposed Disapproval

VI. Incorporation by Reference

VII. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: Improving Regulation and Regulatory Review

B. Paperwork Reduction Act (PRA)

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Coordination With Indian Tribal Governments

G. Executive Order 13045: Protection of Children From Environmental Health Risks and Safety Risks

H. Executive Order 13211: Actions That Significantly Affect Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act (NTTAA)

J. Executive Order 12898: Federal Actions To Address Environmental Justice in Minority Populations and Low-Income Population

I. Background

In 2009, EPA designated a portion of the Fairbanks North Star Borough as “nonattainment” for the 2006 24-hour PM

2.5

NAAQS, which is set at the level of 35 micrograms per cubic meter (μg/m

) (Fairbanks PM

2.5

Nonattainment Area) (74 FR 58688, November 13, 2009).

Effective July 2, 2014, EPA classified the area as “Moderate” (79 FR 31566, June 2, 2014). Subsequently, Alaska submitted, and EPA approved, a plan to meet Moderate nonattainment area requirements (82 FR 42457, September 8, 2017) (“Fairbanks Moderate Plan”).

See 40 CFR 81.302.

On May 10, 2017, EPA determined that the Fairbanks PM

2.5

Nonattainment Area failed to attain the 2006 24-hour PM

2.5

NAAQS in the area by the outermost statutory Moderate area attainment date of December 31, 2015 (82 FR 21711). As a result, the Fairbanks PM

2.5

Nonattainment Area was reclassified as a “Serious” nonattainment area by operation of law.

Upon reclassification as a Serious PM

2.5

nonattainment area, the State was required to submit a Serious area attainment plan satisfying the requirements of CAA sections 172, 189(b), and 189(c) and 40 CFR 51.1003(b). In accordance with CAA section 188(c)(2), the outermost attainment date for a Serious area is no later than the end of the tenth calendar year following designation (

i.e.,

December 31, 2019).

Alaska submitted a plan to address the Serious PM

2.5

nonattainment area requirements on December 13, 2019 (Fairbanks Serious Plan).

Along with the required planning elements, the Fairbanks Serious Plan includes more stringent performance and operating requirements for residential and commercial heating devices, new regulations for wood sellers, and some requirements for stationary sources in the nonattainment area. The Fairbanks Serious Plan is comprised of revisions to Title 18, Chapter 50, of the Alaska Administrative Code (18 AAC 50) and the State Air Quality Control Plan, adopted and incorporated by reference into State law at 18 AAC 50.030(a).

On January 9, 2020, in accordance with CAA section 110(k)(1)(B), EPA determined that the Fairbanks Serious

Plan was administratively and technically complete (85 FR 7760, February 11, 2020).

Alaska SIP revision submitted October 25, 2018, to address the nonattainment NSR element for the Fairbanks Serious area, among other things. EPA approved as meeting the nonattainment NSR element for the Serious Plan on August 29, 2019 (84 FR 45419).

We note that 18 AAC 50.030(a) is not submitted, rather Alaska submits the adopted provisions separately for EPA approval.

Within the Fairbanks Serious Plan, the State sought an extension of the otherwise applicable attainment date through CAA section 188(e). On September 2, 2020, EPA determined that the area failed to attain by the Serious area attainment date and denied the State's Serious area attainment date extension request (85 FR 54509). As a result, Alaska was required to submit a revised SIP submission to meet both the Serious area attainment plan requirements and the additional CAA requirements set forth in CAA section 189(d) by December 31, 2020.

Alaska submitted the revised plan on December 15, 2020 (Fairbanks 189(d) Plan). The Fairbanks 189(d) Plan updated a number of chapters of the State Air Quality Control Plan (

i.e.,

narrative portions of the SIP), adopted and incorporated by reference into State law at 18 AAC 50.030(a). Prior to EPA taking action to approve or disapprove the Fairbanks Serious Plan, Alaska withdrew and replaced several chapters of the Fairbanks Serious Plan with the Fairbanks 189(d) Plan submission.

In this proposed action, EPA is not proposing to act on the withdrawn elements of the prior Fairbanks Serious Plan, only those elements that remain as revised by Alaska in the Fairbanks 189(d) Plan.

40 CFR 51.1003(c).

See SIP submission cover letter, submitted by Alaska Department of Environmental Conservation (ADEC) Commissioner Jason Brune to EPA Regional Administrator, Chris Hladick, on December 15, 2020.

On September 24, 2021, EPA approved as meeting the Serious area planning requirements the 2013 base year emissions inventory and the PM

2.5

precursor demonstration elements of the Fairbanks Serious Plan (86 FR 52997). In the same action, EPA approved other plan components as SIP strengthening, including (1) the updated Fairbanks Emergency Episode Plan

that the State adopted on November 18, 2020 and submitted on December 15, 2020; and (2) emission control measures included in the SIP submissions on October 25, 2018 and November 28, 2018 (in addition to the December 13, 2019 submission).

EPA did not determine as part of the September 24, 2021, approval whether these SIP strengthening components met specific nonattainment plan requirements, including control strategy requirements in CAA section 189 and 40 CFR 51.1010 or the contingency measure requirements in CAA section 172(c)(9) and 40 CFR 51.1014. EPA's proposed determination on whether these components meet the nonattainment plan requirements is contained in this document.

State Air Quality Control Plan, Vol II, III.D.7.12 (

i.e.,

Alaska's planning chapter related to air quality forecasting and curtailment levels).

For a description of the specific control measures addressed across the State's SIP submissions, see 86 FR 52997, September 24, 2021.

Alaska's air quality monitoring network for the Fairbanks PM

2.5

Nonattainment Area has included four regulatory monitor site locations. Table 1 in this document includes the site names, identification number, monitor data, and design values for the PM

2.5

monitor site locations in Fairbanks. With EPA approval, the State discontinued the monitor location at the State Office Building and established the A Street monitor as a monitor location in 2019. Alaska established the A Street monitor location as a State or Local Air Monitoring Station (SLAMS) PM

2.5

monitoring station to characterize PM

2.5

concentrations in the City of Fairbanks. The Hurst Road monitor measures expected maximum concentrations for the nonattainment area.

We note Alaska flagged monitor data in 2019 influenced by wildfire smoke. We discuss in section III.3 of this document how Alaska's demonstration was considered for attainment modeling, but this wildfire-influenced data in 2019 was not regulatory significant under 40 CFR 50.14(a), so the monitor data has not been excluded from the official design value in EPA's Air Quality System (AQS).

For further details of the air quality monitoring network in the Fairbanks PM

2.5

Nonattainment Area, EPA's approval letters of Alaska's Annual Monitoring Network Plans for each year between 2019 to 2022 are included in the docket for this action.

Alaska Department of Environmental Conservation. (April 14, 2021).

Exceptional Events Waiver Request, For Exceptional PM

2.5

Events Between May 26, and July 26, 2019, in the Fairbanks North Star Borough, Alaska.

Alaska Department of Environmental Conservation, Air Quality Division

Table 1—Fairbanks PM

2.5

Monitoring Locations and Recent Site-Level Design Values

Local site name

Site location

AQS ID

98th percentile

(µg/m

)

2019 **

2020

2021

2019-2021

24-hour

design value **

Hurst Road *

3288 Hurst Road, North Pole

02-090-0035

78.3

71.4

65.5

A Street

397 Hamilton Ave., Fairbanks

02-090-0040

*** 34.1

36.1

*** 29.6

*** 33

NCore

809 Pioneer Road, Fairbanks

02-090-0034

60.0

26.6

27.5

State Office Building

675 7th Avenue, Fairbanks

02-090-0010

*** 34.7

n/a

*** 35

* Monitor location previously referred to as North Pole Fire Station.

** Data in this table includes state-flagged monitor days in 2019 that were influenced by wildfires.

*** Incomplete monitor data and/or invalid 3-year design value. In July 2019, Alaska shut down the regulatory PM

2.5

monitor at the State Office Building and established a new maximum impact PM

2.5

monitoring site at the A Street location. Due to data issues in 2021, an official 98th percentile measurement for A Street could not be calculated.

Source: EPA 2021 AQS Design Value Report.

A. Environmental Justice Considerations

Executive Order 12898 (59 FR 7629, February 16, 1994) requires that Federal agencies, to the greatest extent practicable and permitted by law, identify and address disproportionately high and adverse human health or environmental effects of their actions on minority and low-income populations. Additionally, Executive Order 13985 (86 FR 7009, January 25, 2021) directs Federal government agencies to assess whether, and to what extent, their programs and policies perpetuate systemic barriers to opportunities and benefits for people of color and other underserved groups, and Executive Order 14008 (86 FR 7619, February 1, 2021) directs Federal agencies to develop programs, policies, and activities to address the disproportionate health, environmental, economic, and climate impacts on disadvantaged communities.

To identify environmental burdens and susceptible populations in

underserved communities in the Fairbanks Nonattainment Area and to better understand the context of our proposed action on the Fairbanks Serious Plan and Fairbanks 189(d) Plan on these communities, we conducted a screening-level analysis using EPA's environmental justice (EJ) screening and mapping tool (“EJSCREEN”).

EJSCREEN provides a nationally consistent dataset and approach for combining environmental and demographic indicators. EJSCREEN is available at

https://www.epa.gov/ejscreen/what-ejscreen.

There are 12 environmental justice indices available on EJSCREEN,

each index combines demographic factors with a single environmental factor. Although the EJSCREEN indices for PM

2.5

and Ozone are not available for Fairbanks, Alaska, we note that the Fairbanks Nonattainment Area has some of the highest PM

2.5

concentrations in the country and has been designated a PM

2.5

nonattainment area since 2009. Residents in Fairbanks and North Pole have been subject to a high pollution burden for many years. Other health and socioeconomic indices, identified in EJSCREEN, that are impacted by elevated PM

2.5

concentrations include: low life expectancy (95-100 percentile) and asthma (90-95 percentile) in an area south of downtown Fairbanks and population under age 5 (95-100 percentile) in various areas in Fairbanks and North Pole. Most of Alaska, including the Fairbanks area, is considered “medically underserved.”

Environmental indices include: particulate matter PM

2.5

; Ozone; Diesel particulate matter; Air Toxics cancer risk; Air toxics respiratory hazard index; Traffic proximity and volume; Lead paint; Superfund proximity; Risk management plan (RMP) facility proximity; Hazardous waste proximity; Underground storage tanks (UST) and leaking UST (LUST); and Wastewater discharge.

Medically Underserved Areas are defined by the Health Resources and Services Administration as geographic areas with a lack of access to primary care services. For more information see:

https://bhw.hrsa.gov/workforce-shortage-areas/shortage-designation#mups.

A review of other environmental justice indices in EJSCREEN for the cities of Fairbanks, AK and North Pole, AK are below the 80th percentile, with some areas around downtown Fairbanks in the 80-90th percentile for the following indices: Superfund proximity, Hazardous waste proximity, Underground storage tanks. No indices are above the 90th percentile for the Fairbanks Nonattainment Area. EJSCREEN reports for Fairbanks and North Pole are included in the docket for this action.

As discussed in EPA's EJ technical guidance, people of color and low-income populations often experience greater exposure and disease burdens than the general population, which can increase their susceptibility to adverse health effects from environmental stressors.

Underserved communities may have a compromised ability to cope with or recover from such exposures due to a range of physical, chemical, biological, social, and cultural factors.

U.S. Environmental Protection Agency. (June 2016).

Technical Guidance for Assessing Environmental Justice in Regulatory Analysis.

Section 4.

Id.

at section 4.1.

If EPA were to finalize the proposed disapprovals described in section III of this proposed rulemaking, Alaska would be required to submit a plan revision for the Fairbanks Nonattainment Area to address the identified deficiencies. In addition, as summarized in section IV of this proposed rulemaking, such final action would trigger clocks for the Fairbanks Nonattainment Area for offset sanctions 18 months after the final rule effective date, highway funding sanctions six months after the offset sanctions, and the obligation for EPA to promulgate a Federal implementation plan (FIP) within two years of the final rule effective date. Alaska's expeditious submission of plan revisions that correct the deficiencies identified in this document will ensure the plan meets CAA requirements, and the measures in the plan when implemented achieves attainment as expeditiously as practicable. And in doing so, the plan revisions address harmful and disproportionate health and environmental effects on underserved and overburdened populations, consistent with the principles of environmental justice.

II. Clean Air Act Requirements for PM

2.5

Serious Area Plans and for PM

2.5

Serious Areas That Fail To Attain

A. Requirements for PM

2.5

Serious Area Plans

On August 24, 2016, EPA promulgated the final rule entitled, “Fine Particulate Matter National Ambient Air Quality Standards: State Implementation Plan Requirements” (PM

2.5

SIP Requirements Rule).

The PM

2.5

SIP Requirements Rule is codified at 40 CFR part 51, subpart Z. The PM

2.5

SIP Requirements Rule establishes regulatory requirements and provides interpretive guidance on the statutory SIP requirements that apply to states with areas designated nonattainment for the PM

2.5

standards. Because this action addresses planning requirements for Serious nonattainment areas and the planning requirements under CAA section 189(d) for Serious nonattainment areas that failed to attain by the attainment date, both planning requirements will be discussed here.

81 FR 58010, August 24, 2016. Prior to promulgating the PM

2.5

SIP Requirements Rule, EPA provided its interpretations of the CAA's requirements for particulate matter plans under part D, title I of the Act in the following guidance documents: (1) “State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990” (“General Preamble”); (2) “State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990; Supplemental” (“General Preamble Supplement”); and (3) “State Implementation Plans for Serious PM-10 Nonattainment Areas, and Attainment Date Waivers for PM-10 Nonattainment Areas Generally; Addendum to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990” (“General Preamble Addendum”).

Upon reclassification of a Moderate nonattainment area as a Serious nonattainment area under subpart 4 of part D, title I of the CAA, the Act requires the State to submit a Serious area nonattainment plan that addresses specific requirements.

In accordance with subpart 4 of part D, title I of the CAA and the PM

2.5

SIP Requirements Rule at 40 CFR 51.1003(b), Serious area nonattainment plans must address the following requirements:

CAA section 189(b), 42 U.S.C. 7513a(b);

See also

81 FR 58010, 58033. Courts have upheld this approach to the requirements of subpart 4 for PM

See, e.g.,

Assoc. of Irritated Residents v. EPA, et al., 423 F.3d 989 (9th Cir. 2005).

Under the PM

2.5

SIP Requirements Rule, a state may elect to submit to EPA a “comprehensive precursor demonstration” for a specific nonattainment area to show that emissions of a particular precursor from all existing sources located in the nonattainment area do not contribute significantly to PM

2.5

levels that exceed the NAAQS at issue in the nonattainment in the area.

If EPA determines that the contribution of the precursor to PM

2.5

levels in the area is not significant and approves the demonstration, then the state is not required to control emissions of the relevant precursor from existing sources in the attainment plan.

40 CFR 51.1006(a)(1).

In addition, in May 2019, EPA issued the “PM

2.5

Precursor Demonstration Guidance” (“PM

2.5

Precursor Guidance”), which provides recommendations to states for analyzing nonattainment area PM

2.5

emissions and developing such optional precursor demonstrations, consistent with the PM

2.5

SIP Requirements Rule.

“PM

2.5

Precursor Demonstration Guidance,” EPA-454/R-19-004, May 2019, including Memo dated May 30, 2019, from Scott Mathias, Acting Director, Air Quality Policy Division and Richard Wayland, Director, Air Quality Assessment Division, Office of Air Quality Planning and Standards (OAQPS), EPA to Regional Air Division Directors, Regions 1-10, EPA.

EPA is evaluating both the remaining elements of the Fairbanks Serious Plan before the agency and the Fairbanks 189(d) Plan in accordance with the presumption embodied within subpart 4 that the State must address all PM

2.5

precursors in the evaluation and implementation of potential control measures, unless the State adequately demonstrates that emissions of a particular precursor or precursors do not contribute significantly to ambient

2.5

levels that exceed the PM

2.5

NAAQS in the nonattainment area. In reviewing any determination by the state to exclude a PM

2.5

precursor from the required evaluation of potential control measures, we considered both the magnitude of the precursor's contribution to ambient PM

2.5

concentrations in the nonattainment area and the sensitivity of ambient PM

2.5

concentrations in the area to reductions in emissions of that precursor.

40 CFR 51.1006(a)(1)(i) and (ii).

2. Summary of State's Submission

On September 24, 2021, EPA approved Alaska's PM

2.5

precursor demonstration submitted as part of the Fairbanks Serious Plan for purposes of NO

and VOC emissions as it relates to control measure requirements (86 FR 52997). Alaska included its updated PM

2.5

precursor analysis in the SIP submission to meet CAA 189(d) requirements.

This submission included a new NO

model run that replaced a quantitative analysis conducted as part of the Fairbanks Serious Plan submission. Because there were no significant changes to the modeling platform during the short time period between the Fairbanks Serious Plan and 189(d) Plan submissions, the State reasoned that the other model runs and precursor analysis from the Fairbanks Serious Plan are still applicable as part of the updated precursor demonstration.

State Air Quality Control Plan, Vol II, Chapter III.D.7.8, section 7.8.14.3.

Alaska's precursor demonstration provided both concentration-based and sensitivity-based analyses of precursor contributions to ambient PM

2.5

concentrations in the Fairbanks PM

2.5

Nonattainment Area. For VOC emissions, Alaska's demonstration was based on a comprehensive precursor analysis where a baseline model run was compared to a control model run with a 100% reduction of VOC emissions from anthropogenic sources. These results are well below the 1.5 μg/m

significance threshold. For NO

emissions, Alaska included a baseline model run in the Fairbanks 189(d) Plan evaluating a 50% reduction in NO

as part of the 189(d) Plan. According to the State, this provides further evidence that NO

does not contribute significantly to PM

2.5

formation in the Fairbanks Nonattainment Area. The sensitivity precursor analysis showed that the maximum 24-hour average PM

2.5

concentrations due to anthropogenic NO

emissions were less than or equal to 1.22 μg/m

in 2019 for all model grid cells containing regulatory monitors, and therefore were below the 1.5 μg/m

threshold.

These analyses led the State to conclude that SO

and NH

emissions contribute significantly to ambient PM

2.5

levels that exceed the PM

2.5

NAAQS in the Fairbanks Nonattainment Area, while NO

and VOC do not contribute significantly to such exceedances. Consistent with this conclusion, the State focused the control strategy and attainment demonstration on sources of PM

2.5

, SO

, and NH

emissions. A technical summary of Alaska's updated PM

2.5

precursor demonstration is included in the docket for this action.

Briggs and Kotchenruther. (August 24, 2022).

Review of Fairbanks Nonattainment Area Precursor Demonstrations for Volatile Organic Compounds and Nitrogen Oxides in the 2020 State Implementation Plan Submission.

U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division.

Importantly, Alaska's precursor analysis in the 189(d) Plan did not address nonattainment NSR requirements. The State previously made the determination to regulate all four EPA-identified legal precursors to PM

2.5

in the nonattainment NSR regulations applicable to the Fairbanks PM

2.5

Nonattainment Area. EPA approved Alaska's October 25, 2018, SIP revision as meeting the nonattainment NSR requirements triggered upon reclassification of the area to Serious (84 FR 45419, August 29, 2019).

3. EPA's Evaluation and Proposed Action

EPA has evaluated the State's precursor demonstration included in the Fairbanks 189(d) Plan consistent with the PM

2.5

SIP Requirements Rule and the recommendations in the PM

2.5

Precursor Guidance. Noting that Alaska did not submit a precursor determination for SO

and NH

emissions,

EPA agrees that SO

and NH

emission sources, therefore, remain subject to control requirements under subparts 1 and 4 of part D, title I of the Act.

According to Alaska, there is a negligible amount of NH

associated with coal-fired boilers, fuel oil-fired turbines or diesel engine emissions and this amount is not in the emissions inventory.

See

State Air Quality Control Plan, Vol II, Chapter III.D.7.7.8.1.

EPA proposes to approve the State's demonstration that NO

and VOC emissions do not contribute significantly to ambient PM

2.5

levels that exceed the 2006 PM

2.5

NAAQS in the Fairbanks PM

2.5

Nonattainment Area for purposes other than NSR program requirements. If EPA finalizes this proposed approval, Alaska would not be required to identify and impose control measures for NO

and VOC emission sources in Fairbanks other than for NSR purposes or to impose motor vehicle emission budgets for NO

and VOC emissions. Our proposed approval of Alaska's precursor demonstration does not extend to nonattainment NSR requirements for the area. Alaska previously determined that it was appropriate to regulate NO

, SO

, VOCs, and NH

as precursors to PM

2.5

with respect to nonattainment NSR and submitted rule changes to that effect on October 25, 2018. EPA approved the submitted revised program as meeting nonattainment NSR requirements triggered upon reclassification of the Fairbanks PM

2.5

Nonattainment Area to Serious (84 FR 45419, August 29, 2019).

Regarding the State's analytical approach, EPA proposes to find that the State used appropriate methods and data to evaluate PM

2.5

formation in the Fairbanks PM

2.5

Nonattainment Area from precursor emissions. Alaska began with concentration-based analyses for the precursors and proceeded with sensitivity-based analyses if necessary, which is an acceptable progression of analyses under the PM

2.5

SIP Requirements Rule. The State utilized the appropriate threshold recommended in EPA's guidance (1.5 μg/m

) in evaluating the significance of precursor emissions to the formation of 24-hour PM

2.5

and utilized data from all four monitors in the Fairbanks PM

2.5

Nonattainment Area (see Table 1 of this document).

Regarding the results of the State's analysis, the concentration-based modeling analysis of VOC emissions demonstrates that anthropogenic VOCs have impacts on PM

2.5

concentrations in the Fairbanks PM

2.5

Nonattainment Area that are well below the 1.5 μg/m

significance threshold. Therefore, we propose to concur with the State's conclusion that VOCs are not significant for PM

2.5

formation in the Fairbanks PM

2.5

Nonattainment Area.

Further, we propose to find that the weight of evidence presented in the Fairbanks Serious Plan and Fairbanks 189(d) Plan suggests that NO

emitted from all sources is an insignificant contributor to local PM

2.5

concentrations. Additional details of EPA's evaluation of Alaska's precursor PM

2.5

analyses are included in EPA's PM

2.5

precursor Technical Support Document in the docket for this action.

Briggs and Kotchenruther. (August 24, 2022).

Review of Fairbanks Nonattainment Area Precursor Demonstrations for Volatile Organic Compounds and Nitrogen Oxides in the 2020 State Implementation Plan Submission.

U.S.

Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division.

C. Control Strategy

1. Statutory and Regulatory Requirements

CAA section 189(b) and 40 CFR 51.1010(a) contain the control measure requirements for Serious areas. CAA section 189(d) and 40 CFR 51.1010(c) contain the control measure requirements for Serious areas that fail to attain. EPA summarizes these statutory and regulatory provisions in this section.

Pursuant to CAA section 189(b) and 40 CFR 51.1010(a), the state must identify, adopt, and implement best available control measures, including best available control technologies, on sources of direct PM

2.5

emissions and sources of emissions of PM

2.5

plan precursors located in any Serious PM

2.5

nonattainment area or portion thereof located within the state. This level of control stringency is commonly called “BACM” and “BACT.” The regulation at 40 CFR 51.1010(a) specifies the requirements states must meet to identify potential control measures and in determining the measures states must include in the control strategy as BACM or BACT for the nonattainment area:

The state must identify all sources of direct PM

2.5

emissions and sources of emissions of PM

2.5

precursors in the nonattainment area, in accordance with the emissions inventory requirements in 40 CFR 51.1008(b).

The state must identify all potential control measures to reduce emissions from all sources of direct PM

2.5

emissions and sources of emissions of PM

2.5

plan precursors in the nonattainment area. The state must survey other NAAQS nonattainment areas in the U.S. and identify any measures for direct PM

2.5

and PM

2.5

plan precursors not previously identified by the state during the development of the Moderate area attainment plan for the area.

The state must identify, adopt, and implement the best available control measures for each emission source. However, the state may demonstrate that any measure identified under 40 CFR 51.1010(a)(2) is not technologically or economically feasible to implement in whole or in part by the end of the tenth calendar year following the effective date of designation of the area and may eliminate such whole or partial measure from further consideration. Overall, economic feasibility is a less significant factor in the BACM and BACT determination process.

There are considerations for technological feasibility of a potential control measure, where a state may consider factors including but not limited to a source's processes and operating procedures, raw materials, physical plant layout, and potential environmental impacts such as increased water pollution, waste disposal, and energy requirements.

There are also considerations for economic feasibility of a potential control measure where a state may consider capital costs, operating and maintenance costs, and cost effectiveness of the measure.

In assessing whether a control measure or technology is BACM or BACT, the state must consider emission reduction measures with higher costs per ton compared to the economic feasibility criteria applied in their RACM or RACT analysis.

With respect to determining BACT pursuant to CAA section 189(b), EPA expects that states use the top-down BACT analysis process used in the Prevention of Significant Deterioration Program.

Id.

40 CFR 51.1010(a)(3)(i); 81 FR 58010, 58084.

40 CFR 51.1010(a)(3)(ii); 81 FR 58010, 58085.

81 FR 58010, 58085.

Id.

58010, 58080 (“Consistent with past policy, BACT determinations for PM

2.5

NAAQS implementation are to follow the same process and criteria that are applied to the BACT determination process for the PSD program.”).

Pursuant to CAA section 189(b), a state with a Serious nonattainment area must include provisions to assure that the implementation of BACM and BACT level controls on sources of direct PM

2.5

and PM

2.5

plan precursors no later than 4 years after the date the area is classified (or reclassified) as a Serious area.

In the preamble to the final PM

2.5

SIP Requirements Rule, EPA recommended the following 5-Step BACM/BACT selection process states should follow to satisfy the analytical and substantive requirements of 40 CFR 51.1010(a) and CAA section 189(b):

81 FR 58010, 58084-85.

Step 1: Develop a comprehensive inventory of sources and source categories of directly emitted PM

2.5

and PM

2.5

precursors.

Step 2: Identify potential control measures for all such sources.

Step 3: Determine whether an available control measure or technology is technologically feasible.

Step 4: Determine whether an available control measure or technology is economically feasible.

Step 5: Determine the earliest date by which a control measure or technology can be implemented in whole or in part in the area.

EPA's interprets CAA section 189(b) to require the state to determine what is BACM or BACT for a particular source or source category.

EPA's longstanding interpretation of the CAA is that BACM and BACT determinations are to be generally independent of attainment for purposes of implementing the PM

2.5

NAAQS.

EPA interprets the CAA requirement to impose BACM/BACT level control as requiring more emphasis on what controls are the best for the relevant source and whether those controls are feasible rather than on the attainment needs of the area.

States also may not decline to evaluate, or to control as necessary, sources or source categories on the basis that they are de minimis.

81 FR 58010, 58081.

Addendum to the General Preamble, 59 FR 41998, 42011 (August 16, 1994); 81 FR 58010, 58081.

Id.

58010, 58082.

Subsequently, for a state with a Serious PM

2.5

nonattainment area that has failed to attain by the applicable attainment date, the state must submit a revised attainment plan with a control strategy that demonstrates that each year the area will achieve at least a 5 percent reduction in emissions of direct PM

2.5

or a 5 percent reduction in emissions of a PM

2.5

plan precursor based on the most recent emissions inventory for the area; and that the area will attain the standard as expeditiously as practicable consistent with the attainment date requirements under 40 CFR 51.1004(a)(3).

The regulation at 40 CFR 51.1010(c) specifies the following process the state must follow in determining which measures must be included in the control strategy:

CAA section 189(d), 42 U.S.C. 7513a(d), and 40 CFR 51.1010(c).

The state shall identify all sources of direct PM

2.5

emissions and sources of emissions of PM

2.5

precursors in the nonattainment area in accordance with the emissions inventory requirements in 40 CFR 51.1008(b).

The state shall identify all potential control measures to reduce emissions from all sources of direct PM

2.5

emissions and sources of emissions of PM

2.5

plan precursors in the nonattainment area. For the sources and source categories represented in the emission inventory for the nonattainment area, the state shall identify the most stringent measures for reducing direct PM

2.5

and PM

2.5

plan precursors adopted into any SIP or used in practice to control emissions in any state, as applicable.

The state shall also reconsider and reassess any measures previously

rejected by the state during the development of any Moderate area or Serious area attainment plan control strategy for the area.

Similar to the requirements for Serious area plans, the state may make a demonstration for a 189(d) plan that a measure is not technologically or economically feasible to implement in whole or in part within 5 years or such longer period as EPA may determine is appropriate after EPA's determination that the area failed to attain by the Serious area attainment date and may eliminate such whole or partial measure from further consideration. There are considerations for technological feasibility of a potential control measure, as described under 40 CFR 51.1010(c)(3)(i), where a state may consider factors including but not limited to a source's processes and operating procedures, raw materials, physical plant layout, and potential environmental impacts such as increased water pollution, waste disposal, and energy requirements. There are also considerations for economic feasibility of a potential control measure, under 40 CFR 51.1010(c)(3)(ii), where a state may consider capital costs, operating and maintenance costs, and cost effectiveness of the measure.

Unless the state has demonstrated that the measure is not technologically or economically feasible, the state shall adopt and implement all potential control measures identified.

Finally, control measures adopted as part of the state's control strategy must be permanent, enforceable as a practical matter, and quantifiable.

In order to be enforceable as a practical matter, the state must adopt into the SIP not only the control measure or emission limit itself but also appropriate monitoring, recordkeeping, and reporting requirements to ensure compliance with the control measure.

Without appropriate monitoring, recordkeeping, and reporting requirements, violations of the control measure could go undetected.

Control measures must be incorporated by reference into the regulatory portion of the SIP (52.70(c) and (d)) with appropriate monitoring and reporting requirements.

See

CAA section 110(a)(2)(A); 42 U.S.C. 7410(a)(2)(A); 81 FR 58010, at pp. 58046-47; 57 FR 13498, at pp.13567-68.

81 FR at 58046-47; 57 FR 13498, at p. 13567-68; 67 FR 22168, at p. 22170; 80 FR 33840 at pp. 33843, 33865;

Montana Sulphur & Chemical Co.

EPA,

666 F.3d 1174, at pp. 1189-1190 (9th Cir. 2012).

67 FR 22168, at p. 22170;

Montana Sulphur & Chemical Co.

EPA,

666 F.3d 1174, at pp. 1189-1190 (9th Cir. 2012).

Therefore, we will evaluate whether Alaska met the applicable planning requirements as part of the Fairbanks Serious Plan and Fairbanks 189(d) Plan.

2. Summary of State's Submission

a. Identification and Adoption of BACM

We note that Alaska included its initial BACM analysis in the Fairbanks Serious Plan, submitted in 2019. EPA approved a number of specific control measures as SIP strengthening but did not approve them as meeting the BACM/BACT requirement at that time.

100

Subsequently, Alaska updated its BACM analysis and resubmitted the updated analysis in 2020 as part of the Fairbanks 189(d) Plan, to meet Serious area and 189(d) requirements. Even though the State made a SIP submission intended to meet the requirements of CAA section 189(d), it remains obligated to meet the BACM/BACT level controls required as part of a Serious area nonattainment plan for the area. The State did not withdraw some parts of the Serious area plan with respect to the BACM/BACT requirements for certain sources. Accordingly, we are evaluating the Fairbanks 189(d) Plan submission where the State has updated parts of the BACM analysis, and otherwise evaluating the information the State initially included in the Fairbanks Serious Plan.

100

86 FR 52997.

Alaska followed EPA's recommended 5-step process to evaluate BACM-level controls for sources of PM

2.5

and PM

2.5

precursors. Alaska also analyzed controls for stationary sources of PM

2.5

and PM

2.5

precursors to satisfy BACT requirements. Alaska's process for analyzing BACT-level controls is discussed separately in this section following the BACM discussion.

For Step 1, Alaska developed a comprehensive inventory of sources and source categories of PM

2.5

and PM

2.5

precursors.

101

Alaska identified the following source categories in the Fairbanks nonattainment area: solid fuel burning (outdoor hydronic heaters, solid fuel-fired heaters, fireplaces, burn barrels and open burning, and agricultural and forest burns); residential and commercial fuel oil combustion; transportation (automobiles and heavy-duty vehicles); and small area/commercial sources (coffee roasters, charbroilers, incinerators, and used oil burners).

101

State Air Quality Control Plan, Vol II, Chapter III.D.7.6.6.

For Step 2, Alaska identified potential control measures for the source categories identified in Step 1. First, Alaska reviewed the control measures that were implemented under the Fairbanks Moderate Plan and discussed their implementation status.

102

Alaska then reconsidered and reassessed the measures that the State rejected as potential RACM/RACT for the Fairbanks Moderate Plan. As a means of identifying additional potential BACM/BACT measures for the Fairbanks area, Alaska surveyed rules and regulations in other states and local governments and identified measures for reducing direct PM

2.5

and PM

2.5

plan precursors adopted into any nonattainment plan or used in practice to control emissions. Alaska also created a stakeholder group to identify, evaluate, and recommend community-based solutions to bring the area into compliance with Federal air quality standards for PM

2.5

see

State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-3 and Table 7.7-4. Overall, Alaska identified 84 control measures for analysis which are included in State Air Quality Control Plan, Vol III, Appendix III.D.7.7. EPA's review of each of the 84 control measures is included as a Technical Support Document in the docket for this action.

103

102

See

State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-1

103

Jentgen, M. (September 27, 2022).

Technical support document for Alaska Department of Environmental Conservation's (ADEC) control measure analysis, under 40 CFR 1010(a) and (c).

U.S. Environmental Protection Agency, Region 10, Air and Radiation Division.

With respect to controls for NH

emissions, Alaska stated that processes that emit NH

(biomass burning, mobile, home heating) differ in Fairbanks from those in the rest of the country, where NH

from agricultural activities, vehicles, and other industrial activities form ammonium nitrate. Alaska conducted a literature review to identify potential controls for the sources of NH

in the emissions inventory. Alaska was unable to identify any potential controls to control NH

emissions specifically.

104

As discussed further in this section, Alaska included in the Fairbanks 189(d) Plan an analysis that demonstrates that certain measures and technologies designed to reduce emissions of direct PM

2.5

have the co-benefit of reducing emissions of NH

104

See

State Air Quality Control Plan, Vol III, Appendix III.D.7.7 at 5354. Alaska also notes that in the Fairbanks Nonattainment Area, there is only a limited amount of particulate matter-nitrate measured at the monitors.

For Step 3, Alaska evaluated technical feasibility for the potential control measures and identified and rejected certain control measures that the State determined to be technically infeasible.

105

State Air Quality Control Plan, Vol III, Appendix III.D.7.7-5355.

For Step 4, Alaska evaluated the economic feasibility of the control measures that it determined to be technically feasible. Alaska included these economic evaluations of potential emission control technologies in the Fairbanks 189(d) Plan.

106

State Air Quality Control Plan, Vol III, Appendix III.D.7.7-5440.

For Step 5, Alaska determined whether it could implement a control measure or technology in whole or in part no later than four years after reclassification of the area to Serious nonattainment, which would be June 2021.

107

State Air Quality Control Plan, Vol III, Appendix III.D.7.7-5442; State Air Quality Control Plan, Vol III, Appendix III.D.7.7-174.

Below is a summary of the regulations adopted by Alaska, organized by source category, resulting from the BACM analyses included in the Fairbanks Serious Plan and Fairbanks 189(d) Plan, included in State Air Quality Control Plan, Vol II, Chapter III.D.7.7 and State Air Quality Control Plan, Vol III, Appendix III.D.7.7.

i. Solid-Fuel Burning

The solid-fuel burning source category includes a number of measures that the State adopted as part of the Fairbanks Serious Plan. These measures address direct PM

2.5

, and NH

emissions. As discussed in Step 2, Alaska researched potential controls measures for NH

for this source category and did not identify any ammonia-specific controls.

108

However, according to Alaska, some measures identified and adopted by the State to control emissions of direct PM

2.5

have the co-benefit of reducing emissions of NH

108

State Air Quality Control Plan, Vol III, Appendix III.D.7.7-5353-5354; State Air Quality Control Plan, Vol. II, Chapter III.D.7.10-5—10-7.

• The owner, vendor, or dealer of a wood-fired heating device must register the device with Alaska upon the occurrence of events such as new device sale, home sale, or participating in a curtailment waiver program. 18 AAC 50.077(h).

• Commercial wood sellers must register with Alaska and ensure that wood being sold must have a moisture content less than 20 percent. Non-commercial wood sellers are not permitted to sell wet wood. 18 AAC 50.076(d), (e), (g), (j), (k), and (l). According to the Fairbanks 189(d) Plan, this measure reduces both direct PM

2.5

emissions as well as SO

and NH

emissions.

• Wood-fired heating devices are prohibited in the nonattainment area unless specific device performance criteria are met, and outdoor hydronic heaters are not permitted except for pellet-fueled hydronic heaters that also meet specific performance criteria. New woodstoves and pellet-fueled woodstoves must be EPA-certified and meet specific performance criteria. A person may not install a new pellet-fueled hydronic heaters within 300 feet from the closest property line or within 660 feet from a school, clinic, hospital, or senior housing unit. 18 AAC 50.077(a), (b), (c), (d), and (j). According to the Fairbanks 189(d) Plan, this measure reduces both direct PM

2.5

and NH

emissions as well as accounting for SO

emissions. Alaska acknowledges that there is a resulting increase in SO

emissions since measures designed to reduce direct PM

2.5

through removal, curtailment, or replacement of solid-fuel devices trigger a shift in heating energy to heating oil, which has greater SO

emissions compared to wood fuels.

109

State Air Quality Control Plan, Vol II, Chapter III.D.7.10.3.3.

• Regulations that give Alaska the authority to review manufacturer test results and place a model on the department's list of devices, which identifies what devices that are approved for operation in the Fairbanks PM

2.5

Nonattainment Area. 18 AAC 50.077(e). According to the Fairbanks 189(d) Plan, this measure reduces both direct PM

2.5

emissions as well as SO

and NH

emissions.

• Alaska revised the woodstove curtailment program rules to lower curtailment thresholds and further restrict curtailment waivers. Specifically, Alaska revised the requirements for the exemption process to ensure a waiver is temporary and objective criteria are used to determine economic hardship. Alaska continues to implement this program. Fairbanks Emergency Episode Plan, State Air Quality Control Plan, Vol. II, Chapter III.D.7.12; 18 AAC 50.030(a) and 18 AAC 50.075(e).

• When Alaska issues a curtailment alert, fuel to non-exempt devices must be withheld, and combustion in these devices—as evidenced by visible smoke from a chimney—must cease within three hours after the effective time of a curtailment of operation under an emergency episode. Solid fuel fired heating device shall be operated so that visible emissions do not cross property lines.18 AAC 50.075(e)(3) and (f)(2). Alaska has revised the requirements for curtailment program advisories and alerts. Now, an advisory is called when PM

2.5

concentrations are expected to reach 15 μg/m

. A stage 1 alert is called when PM

2.5

concentrations are expected to reach 20 μg/m

(this alert stage allows for specific exemptions). A stage 2 alert is called when PM

2.5

concentrations are expected to reach 30 μg/m

. Fairbanks Emergency Episode Plan, State Air Quality Control Plan, Vol. II, Chapter III.D.7.12. According to the Fairbanks 189(d) Plan, this measure reduces both direct PM

2.5

and NH

emissions as well as accounting for SO

emissions. Alaska acknowledges that there is a resulting increase in SO

emissions since measures designed to reduce direct PM

2.5

through removal, curtailment, or replacement of solid-fuel devices trigger a shift in heating energy to heating oil, which has greater SO

emissions compared to wood fuels.

110

State Air Quality Control Plan, Vol. II, Chapter III.D.7.10.3.3.

• Wood-fired heating devices and wood fired retrofit control devices must be professionally sized and professionally installed with confirmation of proper installation and location. 18 AAC 50.077(i).

• New woodstoves cannot serve as the primary or only source of heat, unless the device is installed in a “dry cabin” or existing rental units that have qualified for No Other Adequate Source of Heat (NOASH) waivers. 18 AAC 50.077(j). According to the Fairbanks 189(d) Plan, this measure reduces both direct PM

2.5

emissions as well as SO

and NH

emissions.

• Wood-fired device vendors in the nonattainment area are required to provide curtailment information to the buyer at time of sale and review proper operating instructions. Wood-fired device vendors may not advertise devices prohibited for sale within the nonattainment area. 18 AAC 50.077(l).

• All EPA uncertified devices, non-pellet fueled hydronic heaters, and coal-fired heating devices must be removed or replaced by December 31, 2024, or upon sale, lease, or conveyance of an existing building, whichever is earlier; and these devices that may not be reinstalled within the area shall be rendered inoperable. 18 AAC 50.077(l) and (m); 18 AAC 50.079(f). According to the Fairbanks 189(d) Plan, this measure reduces both direct PM

2.5

emissions as well as SO

and NH

emissions.

ii. Residential and Commercial Fuel Oil Combustion

The State developed and adopted these measures to address fuel oil combustion to reduce SO

emissions. The State researched potential controls measures for NH

for this source category and did not identify any ammonia-specific controls. Starting September 1, 2022, an individual or

business may only sell or purchase fuel oil containing no more than 1,000 parts per million (ppm) sulfur may be sold for use in fuel oil-fired equipment, including space heating devices.

111

As part of its BACM analysis included in the Fairbanks Serious Plan and updated in the Fairbanks 189(d) Plan, Alaska evaluated requirements to use ULSD heating oil in homes.

112

Alaska determined that the switch to ULSD is technologically feasible, while the economic analysis showed this change would result in a cost of $1,819 per ton of SO

removed. As described in detail in the “Pollutants Addressed” section III.B of this document, SO

is a significant precursor of PM

2.5

concentrations in the Fairbanks PM

2.5

Nonattainment Area. After completing the BACM analysis, Alaska stated that, while the ULSD measure appears to be technically and economically feasible, Alaska declined to adopt and implement the measure.

111

18 AAC 50.078(b).

112

State Air Quality Control Plan, Vol II, Chapter III.D.7.7; State Air Quality Control Plan, Vol. III, Appendix III.D.7.7.

Rather than mandate an area-wide fuel switch from Diesel #2 (2,566 ppm) to ULSD (15 ppm), Alaska elected to mandate a fuel switch to Diesel #1 (1,000 ppm) by September 1, 2022. The State determined that this initial step down, meant to be more economically feasible for local residents, reduced the environmental risks associated with the transport of an increased volume of fuel into the community and still provides a large sulfur reduction. As support for its rejection of mandating ULSD as BACM, Alaska cited a University of Alaska Fairbanks/Alaska cost analysis. This analysis estimated an increase in annual household heating expenditures of $68.31 (a 3 percent increase) under the selected measure, while the same cost analysis estimated an increase between $311.96 and $374.86 (a 13.5 to 16.5 percent increase) in annual household heating expenditures if Alaska mandated a switch to ULSD.

113

Alaska also cited concerns from local residents that the increased cost in fuel oil could drive more residents to burning less expensive and higher PM emitting solid fuels.

113

Alaska Department of Environmental Conservation. (February 2019).

Residential Fuel Expenditure Assessment of a Transition to Ultra-Low Sulfur and High Sulfur No. 1 Heating Oil for the Fairbanks PM-2.5 Serious Nonattainment Area.

State Air Quality Control Plan, Vol II, Appendix III.D.7.7, at p. III.D.7.7-226.

Alaska determined that the earliest date to implement the fuel switch to #1 Diesel was September 1, 2022. Alaska selected this date, in part, due to comments received during the public comment period. Also, Alaska stated that there is an inadequate supply of locally produced Diesel #1 and additional time was required to allow for the local refinery to modify its processes. Alaska also noted that the additional time allows residents to budget and prepare for the increased cost. Alaska received requests through the comment process to delay the conversion until 2024, but Alaska felt that was too long a delay and that the approximate two years provided should be sufficient to allow the local refinery and residents to plan and prepare for the change in fuel oil.

Alaska did not reevaluate its rejection of mandating switching to use of ULSD as part of the Fairbanks 189(d) Plan submission. Alaska reasoned that circumstances did not change sufficiently between submission of the Fairbanks Serious Plan to warrant revisiting its decision. Alaska noted that after implementation of the fuel switch to Diesel #1 in 2022, Alaska will evaluate whether the fuel switch results in significant sulfur reduction and whether the additional expense to homeowners of requiring the use of ULSD heating oil is needed to further address the air pollution problem.

114

State Air Quality Control Plan, Vol. II, Chapter III.D.7.7, at pp. III.D.7.7-129—III.D.7.7-131.

iii. Small Commercial Area Sources

The State evaluated potential measures from these sources to address direct PM

2.5

, SO

, and NH

emissions. After a literature review, Alaska did not identify any NH

-specific controls for this source category.

115

Thus, Alaska identified and evaluated potential measures from these sources to address direct PM

2.5

and SO

. For small area sources, Alaska identified coffee roasters, charbroilers, incinerators, and waste oil burners. Initially, as part of the Fairbanks Serious Plan, Alaska adopted regulations 18 AAC 50.078(c) and (d) that required information from charbroilers, incinerators, and waste oil burners. Coffee roasters, per 18 AAC 50.078(d), are required to install a pollution control device on any unit that emits 24 pounds or more of particulate matter in a 12-month period and either install controls or demonstrate technological or economic infeasibility, not later than one year from effective date of regulation. As an update in the Fairbanks 189(d) Plan, Alaska conducted an economic evaluation of charbroilers (catalyst oxidizers) and found the cost to be $47,786 per ton of PM

2.5

removed, concluding that installing catalyst oxidizers on charbroiling facilities is not cost effective. Regarding incinerators, Alaska states that, in fact, there are no incinerators within the Fairbanks PM

2.5

Nonattainment Area so no additional controls are required. For used oil burners, Alaska presented a technological infeasibility determination in the 189(d) Plan. According to the State, the only acceptable disposal method available in the nonattainment area is through burning. Shipping the used oil to the continental United States, another potential disposal method, would require risky overland transport and cost $2.51 per gallon to pick up, ship, and dispose. Another factor the State considered is that restricting burning of used oil would likely lead to dumping the used oil on land or water. Therefore, the State determined that this measure is technologically infeasible in the Fairbanks PM

2.5

Nonattainment Area.

115

State Air Quality Control Plan, Vol. III, Appendix III.7.7-5353-5354.

iv. Mobile Emissions

The State evaluated measures from mobile sources to address direct PM

2.5

, SO

, and NH

emissions. After a literature review, Alaska did not identify any NH

-specific controls for this source category.

116

Thus, Alaska identified and evaluated potential measures from these sources to address direct PM

2.5

, SO

. Alaska considered mobile sources and transportation measures as part of the BACM analysis, including high occupancy vehicle (HOV) lanes, traffic flow improvement, vehicle inspection and maintenance (I/M) programs, low-emission vehicle (LEV) program, retrofit diesel program, and van pools.

117

Alaska noted that Fairbanks has expanded the availability of plug-ins and required electrification of certain parking lots. Fairbanks has also expanded transit service and a commuter van pool program. Alaska also has an anti-idle program. Alaska concluded that, due to relatively light traffic congestion in Fairbanks, low population and employment density, any additional transportation control measures would provide limited emission reduction benefits.

116

State Air Quality Control Plan, Vol. III, Appendix III.7.7-5353-5354.

117

State Air Quality Control Plan, Vol III, Appendix III.D.7.7, Measures 57, 59, and R20.

b. Summary of Control Measures Selected by Alaska To Meet BACM Requirements

Based on the BACM analysis, Alaska identified and implemented emissions controls, as described in Table 4.

Alaska's identification and adoption of BACT is discussed in the next section.

Table 4—Alaska's List of Emission Control Measures With Quantifiable Emission Benefits and Projected Emissions Reductions in 2024

[First year all control measures are implemented]

Control measure

State rule

2024 emission reductions (tons per day)

Implementation date

2.5

Woodstove changeout program

Targeted Airshed Grant terms and conditions 18 AAC 50.077(a), (b), (c), (d), (e), (j), (m)

0.68

0.01

Ongoing, through 2025.

Solid fuel burning curtailment program (Stage 1 and Stage 2 Alerts)

Fairbanks Emergency Episode Plan, State Air Quality Control Plan, Vol. II, Chapter III.D.7.12; 18 AAC 50.030(a); 18 AAC 50.075(e)

0.68

: −0.23

Ongoing.

Shift from #2 to #1 oil for residential/commercial space heating

18 AAC 50.078(b)

0.01

1.95

2023.

Dry wood requirements for commercial wood sales

18 AAC 50.076(d), (e), (g), (j), (k), and (l)

0.10

<0.01

2022.

Removal of all uncertified device and cordwood outdoor hydronic heaters

18 AAC 50.077(l) and (m)

0.16

<0.01

2024.

New wood-fired device requirements (

i.e.,

2.0 g/hr)

18 AAC 50.077(c)

0.39

0.01

2020.

Removal of coal heaters

18 AAC 50.079(f)

0.02

2024.

Wood-fired devices may not be primary or only heating source

18 AAC 50.077(j)

0.35

−0.01

2020.

NOASH/exemption requirements

Fairbanks Emergency Episode Plan, State Air Quality Control Plan, Vol. II, Chapter III.D.7.12; 18 AAC 50.077(g)

<0.01

2020.

Combined BACM emissions reductions

2.39

1.74

Source: State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Tables 7.7-28 and 7.7-29.

c. Alaska's Identification and Adoption of BACT

Alaska noted that large stationary sources are a subgroup of emissions sources that have specific requirements in the BACM analysis. Alaska evaluated all stationary sources with potential to emit (PTE) greater than 70 tons per year (tpy) of PM

2.5

or PM

2.5

precursors for potential BACT-level controls. According to Alaska, sources with emissions below the 70 tpy threshold only require evaluation for BACM. Alaska states that this emissions threshold is in place to distinguish between the planning requirements for certain sources emitting above and below this threshold and is consistent with an emissions threshold in the 2016 PM

2.5

Implementation Rule.

118

We note that Alaska applied this threshold to emissions sources at the GVEA Zehnder facility.

We note that EPA disagrees with this assessment. All emissions sources identified in the emissions inventory are subject to BACM requirements, and the BACT evaluation process is merely a sub-set of BACM that includes a process to evaluate emissions control technologies that are the best available control measures for the emission source category. Accordingly, all sources of direct PM

2.5

and PM

2.5

precursors are subject to BACM and BACT requirements regardless of PTE. There is no PTE threshold below which BACT requirements do not apply. The 70 tons per year PTE threshold cited by Alaska only has relevance in determining whether a new stationary source proposed to be constructed in a nonattainment area meets the definition of a major stationary source pursuant to the nonattainment new source review provisions.

119

40 CFR 51.165(a)(1)(iv)(A)(

Alaska identified five stationary sources that it evaluated for potential BACT controls, see State Air Quality Control Plan, Vol II, Chapter III.D.7, section 7.7.8. Table 5 includes the annual emissions (tons/year) for each of the facilities:

Table 5—Annual Emissions (Tons/Year), by Facility, in 2019

Facility

2.5

VOC

Chena Power Plant

55.63

507.39

623.70

1.96

0.06

Fort Wainwright

66.58

481.13

485.30

4.91

0.06

UAF Campus Power Plant

9.08

154.52

246.51

1.56

GVEA Zehnder

1.04

27.98

76.32

0.04

0.50

GVEA North Pole

26.45

247.31

1,046.50

0.90

14.98

Source: State Air Quality Control Plan, Vol III, Appendix III.D.7.7-6-9-10-2020 fairbanks-5-percent-plan-sip-sector-emission-summary-calculation-spreadsheet.

Below is a summary of Alaska's BACT analysis for each source. Each source is comprised of multiple emission units, and the State performed the BACT analysis for each emission unit. After a literature review, Alaska did not identify any NH

-specific controls for this source category.

120

Thus, Alaska identified and evaluated potential measures from these sources to address direct PM

2.5

and SO

emissions. Alaska's BACT determinations are evaluated by EPA on an independent basis. Details of EPA's analysis of Alaska's BACT evaluation and determination are included as BACT

Technical Support Documents in the docket for this action.

121

120

State Air Quality Control Plan, Vol. III, Appendix III.7.7-5353-5354.

121

See

Hedgpeth and Sorrels. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for the Aurora Energy, LLC Chena Power Plant as part of the Fairbanks PM

2.5

Nonattainment SIP

. U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division; Hedgpeth, Z. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for Fort Wainwright-US Army Garrison Alaska (FWA) and Doyon Utilities, LLC (DU) as part of the Fairbanks PM

2.5

Nonattainment SIP

. U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division; Hedgpeth and Sorrels. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for the University of Alaska, Fairbanks as part of the Fairbanks PM

2.5

Nonattainment SIP

. U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division; Hedgpeth, Z. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for the Golden Valley Electric Association (GVEA) Zehnder and North Pole Power Plants as part of the Fairbanks PM

2.5

Nonattainment SIP

. U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division.

i. Chena Power Plant

Chena Power Plant is an existing stationary source owned and operated by Aurora Energy, LLC, which consists of four existing coal-fired boilers: three 76 million British Thermal Units (MMBtu)/hour overfeed traveling grate stoker type boilers and one 269 MMBtu/hr spreader-stoker type boiler that burn coal to produce steam for heating and power (497 MMBtu/hr combined).

The State's BACT Determination for the Chena Power Plant evaluated potential controls to reduce NO

, PM

2.5

, and SO

emissions from its four coal-fired boilers.

122

Alaska evaluated potential NO

controls for each emission unit, but because Alaska determined and EPA is proposing to approve in this proposed action that NO

emissions are not significant for PM

2.5

formation in the Fairbanks nonattainment area, ADEC does not plan to require implementation of BACT for NO

. Thus, EPA is not discussing ADEC's BACT analysis for NO

here.

Table 6—Chena Power Plant BACT Summary

Chena Power Plant, Aurora Energy, LLC

Pollutant

Alaska's BACT determination, by source category

Coal-fired boilers (EUs 4-7)—3 boilers rated 76 MMBtu per hour and 1 boiler rated 269 MMBtu per hour

2.5

N/A (Alaska claims installed single full steam baghouse is highest rated control available, but no PM

2.5

BACT analysis or emission limitation was submitted).

By June 9, 2021, Aurora Energy shall limit the sulfur content of coal to 0.25% sulfur by weight and limit SO

emissions from the coal-fired boilers to no more than 0.301 lb/MMBtu.

* Alaska found it economically infeasible for Aurora Energy to implement retrofit SO

controls on emission units at the Chena Power Plant.

Source: State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-10 and Section 7.7.8.2.5.

Regarding PM

2.5

controls, Alaska claimed that, because the Chena Power Plant has direct PM

2.5

emissions less than 70 tons per year, a PM

2.5

BACT analysis was not prepared or submitted by the State. EPA notes our disagreement with this interpretation. Nevertheless, Alaska states that the Chena Power Plant is already equipped with a single full stream baghouse for controlling particulate emissions from the four coal-fired boilers. Baghouses/fabric filters are the highest rated control available (99.9% control efficiency) for PM

2.5

emissions from coal-fired boilers. As noted in the paragraph above, while this would appear to be an efficient control measure for PM

2.5

emissions, Alaska did not submit any further information regarding the PM

2.5

BACT requirement for the Chena Power Plant or any further documentation to ensure use of the existing single full stream baghouse is adopted as a permanent and enforceable requirement of the EPA-approved SIP.

Alaska identified SO

as a significant precursor to PM

2.5

formation in Fairbanks. Accordingly, the state evaluated potential SO

controls for the Chena Power Plant. Alaska identified five technologies as technologically feasible for reduction of SO

emissions from the industrial coal-fired boilers: (1) wet scrubbers; (2) spray dry absorber (SDA); (3) dry sorbent injection (DSI); (4) low sulfur coal; and (5) good combustion practices. Neither Alaska nor Aurora evaluated the circulating dry scrubber (CDS) technology, as EPA suggested in comments.

123

For a detailed summary and evaluation of Alaska's BACT submission, see EPA's Technical Support Document.

124

123

See

EPA comments regarding site-specific quotes for high performing SO

control technologies, such as a wet scrubber (WFGD), spray dry absorber (SDA), and circulating dry scrubber (CDS); “EPA Comments on 2020 Department of Environmental Conservation (DEC) Proposed Regulations and SIP Amendments” Letter from Krishna Viswanathan, Director, EPA Region 10 Air and Radiation Division to Alice Edwards, Director, ADEC Division of Air Quality, October 29, 2020; “EPA Comments on 2019 DEC Proposed Regulations and SIP—Fairbanks North Star Borough Fine Particulate Matter” Letter from Krishna Viswanathan, Director, EPA Region 10 Air and Radiation Division to Alice Edwards, Director, ADEC Division of Air Quality, July 19, 2019.

124

Hedgpeth and Sorrels. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for the Aurora Energy, LLC Chena Power Plant as part of the Fairbanks PM

2.5

Nonattainment SIP

. U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division.

On November 19, 2018, Aurora proposed a BACT alternative to the State, contending that DSI, the least expensive SO

control option, should not be required as BACT because Aurora cannot afford this control technology despite the fact it has been demonstrated to be economically feasible.] Aurora included information regarding the economic impact of requiring DSI based on the following financial indicators, consistent with the PM

2.5

Implementation Rule and longstanding EPA policy:

125

(1) fixed and variable production costs; (2) product supply and demand elasticity; (3) product prices (cost absorption vs. cost pass-through); (4) expected costs incurred by competitors; (5) company profits; (6) employment costs; (7) and other costs (

e.g.,

for BACM implemented by public sector entities).

126

Aurora concluded that even installing the least expensive SO

control, DSI, is economically infeasible and would do very little to solve the air quality problem in the nonattainment area.

127

125

57 FR 18070, April 28, 1992.

126

Proposed BACT Alternative, Aurora Energy, November 19, 2018, State Air Quality Control Plan, Appendix III.D.7.7-4851 (PDF page 995).

127

Proposed BACT Alternative, Aurora Energy, November 19, 2018, State Air Quality Control Plan, Appendix III.D.7.7-4869 (PDF page 1014).

Ultimately, Alaska determined that it would be economically infeasible for Aurora Energy to implement retrofit SO

controls on its emission units at the Chena Power Plant. Alaska instead identified BACT for this source as the existing requirements to operate good combustion practices and to use a low sulfur coal as a fuel source. Alaska also

required as BACT that, by June 9, 2021, Aurora Energy shall limit the sulfur content of coal to 0.25% sulfur by weight and limit SO

emissions from the coal-fired boilers to no more than 0.301 lb/MMBtu.

ii. Fort Wainwright

Fort Wainwright is an existing U.S. Army installation. Emission units located within the military installation include units such as boilers and generators that are owned and operated by the U.S. Army Garrison Alaska (referred to as FWA). The Central Heating and Power Plant (CHPP), also located within the installation footprint, is owned and operated by Doyon Utilities, LLC (DU), the regional Alaska Native corporation for Interior Alaska. The two entities, DU and FWA, comprise a single stationary source operating under two permits.

In addition to the CHPP, the source contains additional emission units comprised of small and large emergency engines, fire pumps, and generators, diesel-fired boilers, and material handling equipment. Alaska included a BACT analysis for the CHPP and all other emission units at the Fort Wainwright source as part of the Fairbanks Serious Plan under State Air Quality Control Plan, Vol II, Chapter III.D.7.7 and Appendix III.D.7.7, Part 2. The CHPP is comprised of six spreader-stoker type coal-fired boilers each rated at 230 MMBtu/hr, that burn coal to produce steam for stationary source-wide heating and power. Alaska's BACT analysis for Fort Wainwright source evaluated potential controls to reduce NO

, PM

2.5

, and SO

emissions from each of these emissions units at the stationary source.

128

Alaska evaluated potential NO

controls for each emission unit, but because Alaska determined and EPA proposed to approve in this action that NO

emissions are not significant for PM

2.5

formation in the Fairbanks nonattainment area, ADEC does not plan to require implementation of BACT for NO

. Thus, EPA is not discussing ADEC's BACT analysis for NO

here.

Table 7—Fort Wainwright BACT Summary

Fort Wainwright, Doyon Utilities

Pollutant

Alaska's BACT determination, by source category

Coal-fired boilers (EUs 1-6)—each unit rated 230 MMBtu per hour

2.5

• Operate and maintain a full stream baghouse at all times the units are in operation;

• PM

2.5

emissions from DU EUs 1 through 6 shall not exceed 0.045 lb/MMBtu over a 3-hour averaging period; and

• Conduct an initial performance test to obtain an emission rate.

• On or before June 9, 2021, DU shall limit the gross as received sulfur content of coal to no greater than 0.25% sulfur by weight.

• On or before June 9, 2021, DU shall submit a Title I permit application to DEC that requires the permittee to install and operate a DSI pollution control system on the coal-fired boilers at CHPP effective no later than October 1, 2023.

• DEC intends to issue the minor permit and incorporate the Title I requirements into the operating permit within one year of receiving a complete application.

• On or before October 1, 2023, DU shall install and operate a DSI pollution control system on the coal-fired boilers at CHPP.

• The SO

BACT limit for EUs 1 through 6 shall not exceed 0.12 lb/MMBtu averaged over a 3-hour period.

Diesel-fired oil boilers (27 emissions units)

2.5

• PM

2.5

emissions from the diesel-fired boilers shall not exceed 0.012 lb/MMBtu averaged over a 3-hour period, with the exception of the waste fuel boilers which must comply with the State particulate matter emissions standard of 0.05 grains per dry standard cubic foot under 18 AAC 50.055(b)(1);

• Limit combined operation of FWA EUs 8, 9, and 10 to 600 hours per year; and

• Maintain good combustion practices by following the manufacturer's maintenance procedures at all times of operation.

• SO

emissions from the diesel-fired boilers shall be controlled by only combusting ULSD, with the exception of the waste fuel boilers;

• Combined operating limit of 600 hours per year for FWA EUs 8, 9, and 10; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

Large diesel-fired engines, fire pumps, and generators (8 emissions units; greater than 500 horsepower)

2.5

• Limit combined operation of FWA EUs 11, 12, and 13 to 600 hours per year;

• Limit operation of DU EU 8 to 500 hours per year;

• PM

2.5

emissions from DU EU 8, FWA EUs 50, 51, and 53 shall not exceed 0.15 g/hp-hr;

• PM

2.5

emissions from FWA EUs 11 through 13 and 54 shall not exceed 0.32 g/hp-hr;

• Limit non-emergency operation of FWA EUs 50, 51, 53, and 54 to no more than 100 hours each per year;

• Combust only ULSD; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• SO

emissions from DU EU 8, and FWA EUs 11, 12, 13, 50, 51, 53, and 54 shall be controlled by only combusting ULSD;

• Limit operation of DU EU 8 to 500 hours per year;

• Combined operating limit of 600 hours per year for FWA EUs 11, 12, and 13;

• Limit non-emergency operation of FWA EUs 50, 51, 53, and 54 to no more than 100 hours each per year; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

Small emergency engines, fire pumps, and generators (41 emissions units)

2.5

• Combust only ULSD;

• Limit non-emergency operation of DU EUs 9, 12, 14, 22, 23, 29a, 30, 31a, 32, 33, 34, 35, 36, FWA EUs 26 through 39, and 55 through 65 to no more than 100 hours each per year;

• For engines manufactured after the applicability dates of 40 CFR part 60 subpart IIII, comply with the applicable particulate matter emission standards in 40 CFR part 60 subpart IIII;

• Maintain good combustion practices by following the manufacturer's operating procedures at all times of operation; and

• Demonstrate compliance with the numerical BACT emission limits (emission limit of 0.015−1 g/hp-hr (3-hour average) varies by emission unit, listed in the State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-13) by maintaining records of maintenance procedures conducted in accordance with 40 CFR subparts 60 and 63, and the EU operating manuals.

• Limit non-emergency operation of DU EUs 9, 12, 14, 22, 23, 29a, 30, 31a, 32, 33, 34, 35, 36, FWA EUs 26 through 39, and 55 through 65 to no more than 100 hours each per year;

• Combust only ULSD; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

Material handling sources (6 emissions units; coal prep and ash handling)

2.5

• PM

2.5

emissions from the material handling equipment EUs 7a-7c, 51a, and 51b shall be controlled by operating and maintaining fabric filters at all times the units are in operation;

• PM

2.5

emissions from DU EU 7a shall not exceed 0.0025 gr/dscf;

• PM

2.5

emissions from DU EUs 7b, 7c, 51a, and 51 b shall not exceed 0.02 gr/dscf;

• PM

2.5

emissions from DU EU 52 shall not exceed 1.42 tpy. Continuous compliance with the PM

2.5

emissions limit shall be demonstrated by complying with the fugitive dust control plan identified in the applicable operating permit issued to the source in accordance with 18 AAC 50 and AS 46.14; and

• Compliance with the PM

2.5

emission rates for the material handling units shall be demonstrated by following the fugitive dust control plan and the manufacturer's operating and maintenance procedures at all times of operation.

n/a.

Source: State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-11 and Chapter III.D.7.7.8.3.4.

For the coal-fired boilers, Alaska stated that three SO

emission controls were evaluated: wet scrubbers, spray dry absorber (SDA), and DSI. Alaska estimated the economic cost of installing wet scrubbers to be $16,356 per SO

ton removed. Alaska estimated the economic cost of installing SDA to be $16,748 per SO

ton removed. Lastly, Alaska estimated the economic cost of installing DSI to be $11,383 per SO

ton removed. Based on this evaluation, Alaska selected DSI as BACT and required DSI to be installed at Fort Wainwright by October 1, 2023. Alaska also included in the SIP submission the emission limits, emission controls, and operational limitations the State determined constituted BACT for the emission units in Fort Wainwright. However, Alaska did not submit as part of the Fairbanks Serious Plan all the monitoring, recordkeeping, and reporting (MRR) requirements for determining compliance with these BACT limits or requirements. Rather, Alaska indicated that such detailed requirements are already embodied in state-issued construction or operating permits or would be embodied in a state-issued Title I permit separate from the SIP. For a detailed summary and evaluation of Alaska's BACT submission, see EPA's Technical Support Document.

129

Hedgpeth, Z. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for Fort Wainwright-US Army Garrison Alaska (FWA) and Doyon Utilities, LLC (DU) as part of the Fairbanks PM

2.5

Nonattainment SIP

. U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division.

iii. University of Alaska Fairbanks Campus Power Plant

The Fairbanks Campus Power Plant is an existing stationary source owned and operated by University of Alaska Fairbanks, which consists of two coal-fired boilers installed in 1962 that were later replaced by a circulating fluidized bed (CFB) dual fuel-fired boiler (coal and biomass) rated at 295.6 MMBtu/hr. Other emission units at the source include a 13,266 hp backup diesel generator, 13 diesel-fired boilers, one classroom engine, one diesel engine permitted but not yet installed, and a coal handling system for the new dual-fuel fired boiler.

The State's BACT determination for the Fairbanks Campus Power Plant evaluated potential controls to reduce NO

, PM

2.5

, and SO

emissions from each of the emissions units at the source.

130

Alaska evaluated potential NO

controls for each emission unit, but because Alaska determined and EPA proposed to approve in this action that NO

emissions are not significant for PM

2.5

formation in the Fairbanks nonattainment area, ADEC does not plan to require implementation of BACT for NO

. Thus, EPA is not discussing ADEC's BACT analysis for NO

here.

Table 8—University of Alaska Fairbanks Campus Power Plant—BACT Summary

University of Alaska Fairbanks

Pollutant

Alaska's BACT determination, by source category

Dual fuel-fired boiler (EU 113)—unit rated at 295 MMBtu per hour; coal and woody biomass fuel; constructed in 2019

2.5

• Operate and maintain fabric filters at all times the unit is in operation;

• PM

2.5

emissions from EU 113 shall not exceed 0.012 lb/MMBtu over a 3-hour averaging period; and

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures.

• Conduct an initial performance test to obtain an emission rate.

• Maintaining good combustion practices by following the manufacturer's operating and maintenance procedures, combustion of low sulfur coal as a fuel source, and the existing SO

emission limit of 0.20 lb/MMBtu determined on a 30-day rolling average.

• By June 9, 2021, UAF shall limit the gross as received sulfur content of coal delivered to the stationary source to 0.25% sulfur by weight.

Mid-sized diesel-fired boilers (EUs 3 and 4)—each unit rated 180 MMBtu per hour

2.5

• PM

2.5

emissions from EUs 3 and 4 shall not exceed 0.012 lb/MMBtu averaged over a 3-hour period while firing diesel fuel;

• PM

2.5

emissions from EU 4 shall not exceed 0.0075 lb/MMBtu averaged over a 3-hour period while firing natural gas;

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures; and

• Limit NO

emissions from EUs 4 and 8 to no more than 40 tons per year combined.

• On or before June 9, 2020, UAF shall also submit a Title I permit application to Alaska that includes a BACT requirement to limit the sulfur content of fuel oil combusted in its diesel-fired boilers to no greater than 1,000 parts per million weight (ppmw) (S1000) from October 1 through March 31 with an effective date of no later than October 1, 2020.

• On or before June 9, 2021, UAF shall also submit a Title I permit application to DEC that includes a BACT requirement to limit the sulfur content of fuel oil combusted in its diesel-fired boilers to no greater than 15 ppmw (ULSD) from October 1 through March 31 with an effective date of no later than October 1, 2023;

• SO

emissions from EU 4 will be limited by complying with the combined annual SO

emission limit of 40 tons per 12 month rolling period for EUs 4 and 8;

• SO

emissions from EU 4 while firing natural gas shall not exceed 0.60 lb/MMscf;

• Maintain good combustion practices by following the manufacturer's maintenance procedures at all times of operation; and

• Compliance with the proposed SO

emission limit will be demonstrated through fuel shipment receipts and/or fuel testing for sulfur content.

Small-sized diesel-fired boilers (EUs 19-21)—each unit rated 6 MMBtu per hour

2.5

• Combined boilers operating limit of no more than 19,650 hours per year;

• PM

2.5

emissions from EUs 19-21 shall not exceed 0.012 lb/MMBtu; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• On or before June 9, 2020, UAF shall also submit a Title I permit application to DEC that includes a BACT requirement to limit the sulfur content of fuel oil combusted in its diesel-fired boilers to no greater than 1,000 ppmw (S1000) from October 1 through March 31 with an effective date of no later than October 1, 2020.

• Combined boilers operating limit of no more than 19,650 hours per year;

• Maintain good combustion practices by following the manufacturer's maintenance procedures at all times of operation; and

• Compliance with the proposed SO

emission limit will be demonstrated through fuel shipment receipts and/or fuel testing for sulfur content.

Large diesel-fired engine (EU 8)—unit rated 13,266 horsepower

2.5

• PM

2.5

emissions from EU 8 shall be controlled by operating positive crankcase ventilation and combusting only low ash diesel at all times of operation;

• Limit NO

emissions from EUs 4 and 8 to no more than 40 tons per year combined;

• Limit non-emergency operation of EU 8 to no more than 100 hours per year; and

• PM

2.5

emissions from EU 8 shall not exceed 0.32 g/hp-hr averaged over a 3-hour period.

• On or before June 9, 2020, UAF shall submit a Title I permit application to Alaska that includes a BACT requirement to combust only ULSD in its diesel-fired engines no later than June 9, 2021;

• Limit SO

emissions from EUs 4 and 8 to no more than 40 tons per year combined;

• Limit non-emergency operation of EU 8 to no more than 100 hours per year;

• Maintain good combustion practices by following the manufacturer's maintenance procedures at all times of operation; and

• Compliance with the proposed SO

emission limit will be demonstrated through fuel shipment receipts and/or fuel testing for sulfur content.

Small diesel-fired engines (EUs 23-24, 26-29)

2.5

• Limit the operation of EU 27 to no more than 4,380 hours per year;

• Limit non-emergency operation of EUs 24, 28, and 29 to no more than 100 hours per year each;

• EU 27 shall comply with the Federal emission standards of NSPS Subpart IIII, Tier 3;

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures; and Demonstrate compliance with the numerical BACT emission limits (emission limit of 0.015−1 g/hp-hr (3-hour average) varies by emission unit, listed in State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-18) by maintaining records of maintenance procedures conducted in accordance with 40 C.F.R. Subparts 60 and 63, and the EU operating manuals.

• On or before June 9, 2020, UAF shall submit a Title I permit application to Alaska that includes a BACT requirement to combust only ULSD in its diesel-fired engines no later than June 9, 2021.

• Limit the operation of EU 27 to no more than 4,380 hours per year;

• Limit non-emergency operation of EUs 24, 28, and 29 to no more than 100 hours per year each;

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures;

• Compliance will be demonstrated with fuel shipment receipts and/or fuel tests for sulfur content; and

• Compliance with the operating hours limit will be demonstrated by monitoring and recording the number of hours operated on a monthly basis.

Pathogenic waste incinerator (EU 9a)—unit rated 533 lb per hour

2.5

• PM

2.5

emissions from EU 9A shall be controlled with a multiple chamber design;

• Limit the operation of EU 9A to no more than 109 tons of waste combusted per year;

• PM

2.5

emissions from EU 9A shall not exceed 4.67 lb/ton;

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures; and

• Compliance with the proposed operational limit will be demonstrated by recording pounds of waste combusted for the pathogenic waste incinerator.

• Limit the operation of EU 9A to no more than 109 tons of waste combusted per year;

• SO

emissions from the operation of EU 9A shall be controlled by combusting ULSD at all times of operation;

• Maintain good combustion practices by following the manufacturer's operational procedures at all times of operation; and

• Compliance shall be demonstrated by obtaining fuel shipment receipts and/or fuel tests for sulfur content.

Material handling sources (EUs 105, 107, 109-111, 114, 128-130); coal prep and ash handling

2.5

• PM

2.5

emissions from EUs 105, 107, 109 through 111, 114, and 128 through 130 will be controlled by enclosing each EU;

• PM

2.5

emissions from the operation of the material handling units, except EU 111, will be controlled by installing, operating, and maintaining fabric filters and vents;

• Initial compliance with the emission rates for the material handling units, except EU 111, will be demonstrated with a performance test to obtain an emission rate; and

• Comply with the numerical emission limits (emission limit of 0.003-0.050 gr/dscf and .00005 lb/ton (EU 111) varies by emission unit listed in State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-18—note double citation)

n/a.

* Alaska finds it economically infeasible for the University of Alaska Fairbanks to implement retrofit SO

controls on emission units at the Campus Power Plant.

Source: State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-16 and Chapter III.D.7.7.8.6.

Alaska included in the SIP submission most of the emission limits, emission controls, and operational limitations the State determined constituted BACT for the emission units at the UAF Campus Power Plant. However, Alaska did not submit as part of the Fairbanks Serious Plan the emission limits corresponding to Alaska's SO

BACT findings for several emission units

131

nor all the MRR requirements for determining compliance with BACT limits or requirements. Rather, Alaska indicated that such requirements are already embodied in state-issued construction or operating permits or would be embodied in a state-issued Title I permit separate from the SIP.

131

Mid-sized diesel-fired boilers (EUs 3 and 4); Small-sized diesel-fired boilers (EUs 19-21); Large diesel-fired engine (EU 8); Small diesel-fired engines (EUs 23-24, 26-29).

Alaska identified SO

as a significant precursor to PM

2.5

formation in Fairbanks. Accordingly, Alaska identified six potential control measures as technologically feasible for reduction of SO

emissions from the industrial dual-fired boiler (EU-113) at this source: (1) wet scrubbers; (2) SDA; (3) DSI; (4) low sulfur coal; and (5) good combustion practices. Notably, neither Alaska nor UAF evaluated the circulating dry scrubber (CDS) technology that EPA has commented is a proven technology for coal boilers that the State should analyze for BACT.

132

See

EPA Comments regarding site-specific quotes for high performing SO

control technologies, such as a wet scrubber (WFGD), spray dry absorber (SDA), and circulating dry scrubber (CDS); “EPA Comments on 2020 DEC Proposed Regulations and SIP Amendments” Letter from Krishna Viswanathan, Director, EPA Region 10 Air and Radiation Division to Alice Edwards, Director, ADEC Division of Air Quality, October 29, 2020; “EPA Comments on 2019 DEC Proposed Regulations and SIP- Fairbanks North Star Borough Fine Particulate Matter” Letter from Krishna Viswanathan, Director, EPA Region 10 Air and Radiation Division to Alice Edwards, Director, ADEC Division of Air Quality, July 19, 2019.

On April 29, 2019, UAF submitted an economic infeasibility assessment to the State, contending that UAF could not afford to install DSI, the technology Alaska identified as BACT. UAF's assessment is based on the following financial indicators, consistent with the PM

2.5

Implementation Rule and longstanding EPA policy:

133

(1) fixed and variable production costs; (2) product supply and demand elasticity; (3) product prices (cost absorption vs. cost pass-through); (4) expected costs incurred by competitors; (5) company

profits; (6) employment costs; (7) and other costs (

e.g.,

for BACM implemented by public sector entities).

134

UAF contended that the Alaska proposed BACT is not financially feasible, given the proposed budget cuts in state funding impacting the university and that the duel fuel-fired boiler (EU-113) is an efficient and clean approach to generating electric power and heat from a single fuel source.

135

133

57 FR 18070, April 28, 1992.

134

Alaska Department of Environmental Conservation. (April 23, 2019).

Fairbanks Serious PM

2.5

Nonattainment Area Best Available Control Technology (BACT) Determination—Economic Infeasibility of Sulfur Dioxide (SO

) Emission Controls, University of Alaska Fairbanks,

State Air Quality Control Plan, Appendix, Part 3, III.D.7.7-1479 (PDF page 497).

135

Alaska Department of Environmental Conservation. (April 23, 2019).

Fairbanks Serious PM

2.5

Nonattainment Area Best Available Control Technology (BACT) Determination—Economic Infeasibility of Sulfur Dioxide (SO

) Emission Controls, University of Alaska Fairbanks.

State Air Quality Control Plan, Appendix, Part 3, III.D.7.7-1481 (PDF page 499).

Alaska ultimately found that it is economically infeasible for UAF to implement retrofit SO

controls on the dual fuel-fired boiler at the Fairbanks Campus Power Plant. Regarding the other emission sources at the UAF Campus Power Plant, we note that ULSD was identified as BACT for the diesel-fired boilers (EUs 3, 4, and 19-21), but Alaska delayed implementation of the requirement until 2023 and imposed an interim requirement (1000 ppmw sulfur content). Additionally, certain diesel-fired engines do not have hourly operation limits (EUs 23 and 26). For a detailed summary and evaluation of Alaska's BACT submission, see EPA's Technical Support Document.

136

Hedgpeth and Sorrels. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for the University of Alaska, Fairbanks as part of the Fairbanks PM

2.5

Nonattainment SIP.

U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division.

iv. Zehnder Facility

The Zehnder Facility (Zehnder) is an electric generating facility that combusts distillate fuel in combustion turbines to provide power to the Golden Valley Electric Association (GVEA) grid. The power plant contains two fuel oil-fired simple cycle gas combustion turbines and two diesel-fired generators (electro-motive diesels) used for emergency power and to serve as black start engines for the GVEA generation system. The primary fuel is stored in two 50,000 gallon above ground storage tanks. Turbine startup fuel and electro-motive diesels primary fuel is stored in a 12,000 gallon above ground storage tank.

Alaska's BACT analysis for the Zehnder evaluated potential controls to reduce NO

, PM

2.5

, and SO

emissions from its simple cycle gas turbines, large diesel-fired engines, and diesel-fired boilers.

137

Alaska evaluated potential NO

controls for each emission unit, but because Alaska determined and EPA proposed to approve in this action that NO

emissions are not significant for PM

2.5

formation in the Fairbanks nonattainment area, ADEC does not plan to require implementation of BACT for NO

. Thus, EPA is not discussing ADEC's BACT analysis for NO

here.

Table 9—Zehnder Facility BACT Summary

Zehnder facility, Golden Valley Electric Authority

Pollutant

Alaska's BACT determination, by source category

Fuel oil-fired simple cycle gas turbine (EUs 1 and 2)—each unit rated 268 MMBtu per hour

2.5

• Combust only low ash fuel;

• PM

2.5

emissions from EUs 1 & 2 shall not exceed 0.012 lb/MMBtu over a 3-hour averaging period;

• Initial compliance with the proposed PM

2.5

emission limit will be demonstrated by conducting a performance test to obtain an emission rate; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• On or before June 9, 2020, GVEA shall submit a Title I permit application to DEC limiting the PTE for SO

emissions from the Zehnder Facility to less than 70 tons per year.

○ According to Alaska, the facility will then be subject to the following requirement: After September 1, 2022, only fuel oil, containing no more than 1,000 parts per million sulfur, may be sold or purchased for use in fuel oil-fired equipment, in accordance with 18 AAC 50.078(b).

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation; and

• Compliance with the proposed fuel sulfur content limit will be demonstrated with fuel shipment receipts and/or fuel test results for sulfur content.

Diesel-fired emergency generators (EUs 3 and 4)—each unit rated 28 MMBtu per hour

2.5

• Limit non-emergency operation of the large diesel-fired engines to no more than 100 hours per year each;

• PM

2.5

emissions from EUs 3 and 4 shall not exceed 0.32 g/hp-hr over a 3-hour averaging period;

• Demonstrate compliance with the numerical BACT emission limit by complying with 40 CFR 63 Subpart ZZZZ; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• On or before June 9, 2020, GVEA shall submit a Title I permit application to DEC limiting the PTE for SO

emissions from the Zehnder Facility to less than 70 tons per year.

• Limit non-emergency operation of the large diesel-fired engines to no more than 100 hours per year each;

• Maintain good combustion practices by following the manufacturer's operating maintenance procedures at all times of operation; and

• Compliance with the proposed fuel sulfur content limit will be demonstrated with fuel shipment receipts and/or fuel test results for sulfur content.

Diesel-fired boilers (EUs 10 and 11)—each unit rated 1.7 MMBtu per hour

2.5

• PM

2.5

emissions shall not exceed 0.012 lb/MMBtu over a 3-hour averaging period;

• Demonstrate compliance with the numerical BACT emission limit by complying with 40 CFR 63 Subpart JJJJJJ; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• On or before June 9, 2020, GVEA shall submit a Title I permit application to DEC limiting the PTE for SO

emissions from the Zehnder Facility to less than 70 tons per year.

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation; and

• Compliance with the proposed fuel sulfur content limit will be demonstrated with fuel shipment receipts and/or fuel test results for sulfur content.

* Alaska's initial BACT finding: SO

emissions from EUs 1 and 2 shall be controlled by limiting the sulfur content of fuel combusted in the turbines to no more than 0.0015 percent by weight; requirements for the other emission units were to combust only ULSD.

Source: State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-14 and Chapter III.D.7.7.8.4.

Alaska included in the SIP submission the emission limits, emission controls, and operational limitations the State determined constituted BACT for the emission units at the Zehnder facility. However, Alaska did not submit as part of the Fairbanks Serious Plan all the associated MRR requirements for determining compliance with these BACT limits or requirements. Rather, Alaska indicated that such requirements are already embodied in state-issued construction or operating permits. Regarding SO

controls for each of the emission sources at this facility, Alaska evaluated four technologically feasible SO

controls: ultra-low sulfur diesel (99.7 percent control of SO

emissions); low-sulfur diesel (93 percent control of SO

emissions); good combustion practices (less than 40 percent control of SO

emissions); limited operation (0 percent control of SO

emissions). Alaska reviewed the cost information provided by GVEA to evaluate appropriately the total capital investment of installing two new 1.5 million gallon ULSD storage tanks at GVEA's North Pole Facility.

138

Alaska concluded that the level of SO

reduction justifies the required use of ULSD as BACT for the fuel oil-fired simple cycle gas turbines at an economic cost of $8,753 per ton of SO

removed.

138

Alaska Department of Environmental Conservation. (November 19, 2019).

Golden Valley Electric Association North Pole Power Plant and Zehnder Facility BACT Appendix.

State Air Quality Control Plan, Appendix, Part 4, III.D.7.7-1657 through 3855.

However, GVEA provided updated and supplemental information in an alternative BACT proposal submitted to Alaska on November 28, 2018.

139

GVEA proposed to limit emissions from the Zehnder Facility to less than 70 tons per year in place of BACT for SO

, and, according to Alaska, eliminating the Zehnder Facility as a major source of SO

. EPA notes here our disagreement with this approach. BACT is a subset of BACM requirements. All sources of direct PM

2.5

and PM

2.5

140

Thus, as part of selecting and adopting BACM for existing sources in Fairbanks, Alaska would need to select the best available measure that is technologically and economically feasible, which in this case is a requirement to use ULSD fuel. Nonetheless, Alaska relied on the approach to classify the Zehnder Facility as a “non-major” source and required GVEA to submit a Title I permit application no later than June 9, 2020, limiting the potential to emit of the Zehnder Facility to less than 70 tons per year. Once the Zehnder Facility's SO

limit goes into effect, Alaska will not consider the facility, including all emissions units, to be a major stationary source for SO

emissions subject to BACT limits. Instead, the Zehnder Facility will be subject to the BACM measures contained in Alaska regulations 18 AAC 50.078(b), that stipulate that after September 1, 2022, only fuel oil containing no more than 1,000 parts per million sulfur (

i.e.,

diesel #1), may be sold or purchased for use in fuel oil-fired equipment. We again note our disagreement with this approach, regardless of BACM or BACT distinction, the best available control measure should be adopted. For a detailed summary and evaluation of Alaska's BACT submission, see EPA Technical Support Document.

141

139

Alaska Department of Environmental Conservation. (November 19, 2019).

Golden Valley Electric Association North Pole Power Plant and Zehnder Facility BACT Appendix.

State Air Quality Control Plan, Appendix, Part 4, III.D.7.7-3636 (PDF page 1979).

140

40 CFR 51.165(a)(1)(iv)(A)(

141

Hedgpeth, Z. (August 24, 2022).

Review of Best Available Control Technology analyses submitted for the Golden Valley Electric Association (GVEA) Zehnder and North Pole Power Plants as part of the Fairbanks PM

2.5

Nonattainment SIP.

U.S. Environmental Protection Agency, Region 10, Laboratory Services and Applied Science Division

v. North Pole Power Plant

The North Pole Power Plant is an electric generating facility that combusts distillate fuel in combustion turbines to provide power to the Golden Valley Electric Association (GVEA) grid. The power plant contains two fuel oil-fired simple cycle gas combustion turbines, two fuel oil-fired combined cycle gas combustion turbines, one fuel oil-fired emergency generator, and two propane-fired boilers. The State's BACT determination for the North Pole Power Plant evaluated potential controls to reduce NO

, PM

2.5

, and SO

emissions from its simple cycle gas turbines, combined cycle gas turbines, large

diesel-fired engines, and propane-fired boilers.

142

Alaska evaluated potential NO

controls for each emission unit, but because Alaska determined and EPA proposed to approve in this action that NO

emissions are not significant for PM

2.5

formation in the Fairbanks nonattainment area, ADEC does not plan to require implementation of BACT for NO

. Thus, EPA is not discussing ADEC's BACT analysis for NO

here.

Table 10—North Pole Power Plant BACT Summary

North Pole Power Plant, Golden Valley Electric Authority

Pollutant

Alaska's BACT determination, by source category

Fuel oil-fired simple cycle gas turbine (EUs 1 and 2)—each unit rated 672 MMBtu

2.5

• Combust only low ash fuel;

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures;

• PM

2.5

emissions from EUs 1 & 2 shall not exceed 0.012 lb/MMBtu over a 3-hour averaging period; and

• Initial compliance with the proposed PM

2.5

emission limit will be demonstrated by conducting a performance test to obtain an emission rate.

• By October 1, 2020, BACT for EUs 1 and 2 is to begin taking delivery of fuel oil with a sulfur content no greater than 1,000 ppmw (S1000) immediately after the Air Quality Stage Alert 1 and 2 are announced and remain taking deliveries of exclusively S1000 for as long as the air episode exists.

• On or before June 9, 2022, GVEA shall submit a Title I permit application to DEC that includes a BACT requirement to limit the sulfur content of fuel combusted in EUs 1 and 2 to no greater than 15 ppmw (ULSD) from October 1 through March 31 to be effective no later than October 1, 2023.

• Compliance with the proposed fuel sulfur content limit will be demonstrated with fuel shipment receipts and/or fuel test results for sulfur content; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

Fuel oil-fired combined cycle gas turbine (EUs 5 and 6)—each unit rated 455 MMBtu per hour

2.5

• PM

2.5

emissions from EUs 5 and 6 shall be limited by complying with the combined annual NO

limit listed in Operating Permit AQ0110TVP03 Conditions 13 and 12, respectively;

• PM

2.5

emissions from EUs 5 & 6 shall not exceed 0.012 lb/MMBtu over a 3-hour averaging period;

• Initial compliance with the proposed PM

2.5

emission limit will be demonstrated by conducting a performance test to obtain an emission rate; and

• Maintain good combustion practices at all times of operation by following the manufacturer's operating and maintenance procedures.

• Except during startup, SO

emissions from EUs 5 and 6 shall be controlled by limiting the fuel combusted in the turbines to light straight run turbine fuel (50 ppm sulfur in fuel);

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation; and

• Compliance with the proposed fuel sulfur content limit will be demonstrated with fuel shipment receipts and/or fuel test results for sulfur content.

Large diesel-fired engine (EU 7)—unit rated 400 kW/619 horsepower

2.5

• PM

2.5

emissions from EU 7 shall be controlled by operating with positive crankcase ventilation;

• PM

2.5

emissions from EU 7 shall be controlled by limiting operation to no more than 52 hours per 12 month rolling period;

• PM

2.5

emissions from EU 7 shall not exceed 0.32 g/hp-hr over a 3-hour averaging period; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• SO

emissions from EU 7 shall be controlled by combusting fuel that does not exceed 0.05 weight percent sulfur at all time the unit is in operation;

• SO

emissions from EU 7 shall be controlled by limiting operation to no more than 52 hours per 12-month rolling period;

• Compliance with the SO

emission limit while firing diesel fuel will be demonstrated by fuel shipment receipts and/or fuel test results for sulfur content; and

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

Propane-fired boiler (EUs 11 and 12)—each unit rated 5 MMBtu per hour

2.5

• Burn only propane as fuel in EUs 11 and 12;

• PM

2.5

emissions from EUs 11 and 12 shall not exceed 0.008 lb/MMBtu over a 3-hour averaging period; and

• Compliance with the emission limit will be demonstrated with records of maintenance following original equipment manufacturer recommendations for operation and maintenance and periodic measurements of O2 balance.

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation.

• SO

emissions from EUs 11 and 12 shall be controlled by only combusting gas fuel (propane) with a total sulfur content of no more than 120 parts per million volume (ppmv), or direct emissions of 0.75 lb/1,000 gal;

• Maintain good combustion practices by following the manufacturer's operating and maintenance procedures at all times of operation; and

• Compliance with the preliminary emission rate limit will be demonstrated with fuel shipment receipts and/or fuel tests for sulfur content.

* Alaska's initial BACT finding: SO

emissions from EUs 1 and 2 shall be controlled by limiting the sulfur content of the fuel combusted in the turbines to no more than 0.0015 percent by weight (ULSD).

Source: State Air Quality Control Plan, Vol II, Chapter III.D.7.7, Table 7.7-14 and Chapter III.D.7.7.8.5.

Alaska included in the SIP submission most of the emission limits, emission controls, and operational limitations the State determined constituted BACT for the emission units at the North Pole Power Plant. However, Alaska did not submit as part of the Fairbanks Serious Plan the emission limits corresponding to Alaska's SO

or PM

2.5

BACT findings for some emission units

143

nor the MRR requirements for determining compliance with all BACT limits or requirements. Rather, Alaska indicated that such requirements are already embodied in state-issued construction or operating permits or would be embodied in a state-issued Title I permit separate from the SIP. Alaska did not submit as part of the Fairbanks Serious Plan the MRR requirements for determining compliance with these BACT limits or requirements.

143

Fuel oil-fired simple cycle gas turbine (EUs 1 and 2); Fuel oil-fired combined cycle gas turbine (EUs 5 and 6).

For SO

controls, Alaska evaluated four technologies as potential BACT for the simple cycle gas turbines: ultra-low sulfur diesel (controls 99.7 percent SO

emissions); low sulfur fuel (controls 93 percent SO

emissions); good combustion practices (controls less than 40 percent SO

emissions) and limited operation (controls 0 percent SO

emissions). Alaska reviewed the cost information provided by GVEA to evaluate the total capital investment of installing two new 1.5 million g

This text is long and has been trimmed here. Open the source document for the complete record.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.