Proposed Reasonable Progress Rule Workshop Second Public Workshop August 1, 2007 Tallahassee,...

Proposed Reasonable Progress Rule Workshop

Second Public Workshop

August 1, 2007

Tallahassee, Florida

Comments From 1st Workshop

Extend the permit application deadline (April 30, 2008, Dec 31, 2008) Extended to September 30, 2008

Change the compliance deadline date (Dec 31, 2017) Extended to December 31, 2014

Increase significant contribution threshold (1%) Considered, developed new criteria

Allow consideration of visibility impact Changed rule language to reflect visibility impact

analysis not required

Comments From 1st Workshop (cont.)

Take out the “responsibility to comply” applicability statement Retained – makes sense with new selection criteria

Produce area of influence document Document no longer necessary with new selection

criteria “Reasonable progress” already made, no additional

reductions needed Reasonable progress only determined after four-factor

analysis – state cannot bypass this requirement

Comments From 1st Workshop (cont.)

Provide justification for selection of various thresholds or cutpoints Provided at this workshop

Change BART-equivalent determination submittal application deadline to coincide with the RP application Extended deadline to June 30, 2008 – still

does not coincide with application

Jun 14 Proposed Selection Criteria

Selection based on modified Georgia criteria with RTmax*Q/d: VISTAS residence time data (within 5% for

EGU’s and 10% non-EGU’s) 2002 actual emissions (units > 250 tpy) >= 0.5% unit contribution, considering only

Florida units Selection based on each Class I area

potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

Considered Changes to Selection Based on Comments Increase contribution threshold from 0.5% to

1% Include units in all states to determine

contribution Take out EGU/non-EGU selection criterion

based on RTMax See handout for results

Considerations for Changing to a Q/d Selection Criteria The inclusion of residence time (RTMax),

while logical, is somewhat complicated, and when used with Q/d to develop a relative contribution surrogate at each Class I area, results in some seemingly illogical conclusions.

The use of Q/d alone as a surrogate for visibility impact is easy to understand and produces a similar selection of sources as does a Q/d*RTMax relative contribution criterion.

Proposed New Selection Criteria

All SO2 units having >= 250 tpy (2002 actual) and having an emissions Q (tons) to distance d (km) ratio of 50 or greater.

Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

Why Q/d >= 50?

Selection of sources close to those under the 1% Q/d*RTMax criteria.

Q/d of 50 is five times the exemption threshold used for BART. Provides that sources selected are important contributors to visibility impairment.

Recognize that visibility improvement at the Class I areas in or near Florida is projected to be near the uniform rate of progress, thus justifying selection of only the largest sources for four-factor review.

Plant NamePoint

ID Class I Areas Affected

CITY OF GAINESVILLE, GRU DEERHAVEN GENER 5 CHAS OKEF

FLORIDA POWER & LIGHT (PPE) PORT EVERGLA 3 EVER

4 EVER

PROGRESS ENERGY FLORIDA, INC. CRYSTAL RI 1 CHAS OKEF SAMA WOLF

2 CHAS OKEF SAMA WOLF

3 CHAS EVER OKEF SAMA WOLF

4 CHAS EVER OKEF SAMA WOLF

FLORIDA POWER & LIGHT (PTF) TURKEY POINT 1 EVER

2 EVER

SAINT JOHNS RIVER 16 CHAS OKEF WOLF

17 OKEF WOLF

NORTHSIDE 27 OKEF

3 OKEF WOLF

GULF POWER COMPANY CRIST ELECTRIC GENERA 7 BRET SAMA

FLORIDA CRUSHED STONE CO., INC. 18 CHAS

TAMPA ELECTRIC COMPANY F.J. GANNON STATI 1 CHAS

2 CHAS

3 CHAS

4 CHAS

5 CHAS

6 CHAS OKEF SAMA

Sources Selected Under the Q/d Criteria

Plant NamePoint

ID Class I Areas Affected

FLORIDA POWER & LIGHT (PMT) MANATEE POWE 1 CHAS

2 CHAS EVER

JEFFERSON SMURFIT CORPORATION (US) 15 OKEF

PROGRESS ENERGY FLORIDA, INC. ANCLOTE PO 1 CHAS SAMA

2 CHAS SAMA

PROGRESS ENERGY FLORIDA, INC. BARTOW PLA 1 CHAS

2 CHAS

3 CHAS

LAKELAND ELECTRIC C.D. MCINTOSH, JR. POW 6 CHAS

SEMINOLE ELECTRIC COOPERATIVE, INC. 1 CHAS OKEF WOLF

2 CHAS OKEF SAMA WOLF

Sources Selected Under the Q/d Criteria

Comparison of Selection Criteria

Proposal No. of Facilities Selected

No. of Units Selected

June 14 Workshop

30 69

Modifications to June 14 Workshop (1%)

22 43

August 1 Workshop

15 32

Some Statistics

The 15 facilities included comprise ~⅔ of the total stationary point source SO2 emissions that occurred in 2002.

In rank order, these 15 facilities comprise the 1,2,3,4,5,6,7,8,9,15,18,19,26, and 30 largest facilities in the state as of 2002.

Plant Name Point ID Type

SO2 ALLOWABLE EMISSION

ALLOWABLE EMISSION

UNIT

2002 SO2 EMISSION (TON/YR)

PERCENT CONTROL EFFICIENC

YPRIMARY CONTROL

EQUIPMENT

GRU DEERHAVEN 5 coal-fired boiler 1.2 lb/MMBtu 6,969 Scrubber by 2010

FPL PORT EVER 3 oil/gas-fired boiler 2.75 lb/MMBtu 6,409

4 oil/gas-fired boiler 2.75 lb/MMBtu 6,205

PE CRYSTAL RIVER 1 coal-fired boiler 2.1 lb/MMBtu 18,998

2 coal-fired boiler 2.1 lb/MMBtu 20,728

3 coal-fired boiler 1.09 lb/MMBtu 26,436 Scrubber by 2010

4 coal-fired boiler 1.09 lb/MMBtu 24,635 Scrubber by 2010

FPL TURKEY POINT 1 oil/gas-fired boiler 1.1 lb/MMBtu 4,610


JEA ST JOHNS RIVER 16 coal-fired boiler 1.2 lb/MMBtu 11,076 90.0 Scubber

17 coal-fired boiler 1.2 lb/MMBtu 10,185 90.0 Scubber

JEA NORTHSIDE 27 coal-fired boiler 0.2 lb/MMBtu 5,090 98.0DRY LIMESTONE INJECTION


GULF POWER CRIST 7 coal-fired boiler 2.75 lb/MMBtu 21,546 Scrubber by 2010

FL CRUSHED STONE 18 coal-fired boiler 1.2 lb/MMBtu 2,906 50.0DRY LIMESTONE INJECTION

Plant Name Point ID Type

SO2 ALLOWABLE EMISSION

ALLOWABLE EMISSION

UNIT

2002 SO2 EMISSION (TON/YR)

PERCENT CONTROL EFFICIENC

YPRIMARY CONTROL

EQUIPMENT

TECO GANNON 1 coal-fired boiler 3017 lb/hr 5,157 Shutdown

2 coal-fired boiler 1.9 lb/MMBtu 4,942 Shutdown

3 coal-fired boiler 3838 lb/hr 5,602 Shutdown




FPL MANATEE 1 oil/gas-fired boiler 1 %S Fuel 13,930

2 oil/gas-fired boiler 1 %S Fuel 15,073

SMURFIT STONE FB 15 coal-fired boiler 1.2 lb/MMBtu 3,242

PE ANCLOTE 1 oil/gas-fired boiler 2.75 lb/MMBtu 13,879


PE BARTOW 1 oil/gas-fired boiler 2.75 lb/MMBtu 6,483 Re-powering to gas

2 oil/gas-fired boiler 2.75 lb/MMBtu 6,149 Re-powering to gas

3 oil/gas-fired boiler 2.75 lb/MMBtu 11,249 Re-powering to gas

LAKELAND MCINTOSH 6 coal-fired boiler 1.2 lb/MMBtu 6,994 85.0 Scubber

SEMINOLE ELECTRIC 1 coal-fired boiler 1.2 lb/MMBtu 10,912 90.0 Scubber

2 coal-fired boiler 1.2 lb/MMBtu 12,775 90.0 Scubber

Proposed Reasonable Progress Rule Workshop Second Public Workshop August 1, 2007 Tallahassee,...

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