Fact Sheet for Open House on EPA's Clean Air Plan Proposal for Texas

Regional Haze

January 10, 2017, Joe C. Thompson Conference Center, Austin, Texas

To view our proposal or submit a comment:

Our proposal was published in the Federal Register on January 4, 2017. It can be found on the

internet at www.regulations.gov (in regulations.gov, search for Docket number EPA-R06-

0AR- 2016- 0611 , then find document number EPA- R06- 0AR-2016-061 l-0001 which is the

proposal). Comments may be submitted electronically tlu·ough www.regulations.gov, emailed

toR6_TX-BART@epa.gov, or submitted at today' s public hearing. Comments must be received

on or before March 6, 2017.

Our proposal involves our review of certain portions of Texas' plans for improving regional

haze, and for controlling the transport of pollution that would impair visibility in other states.

This includes proposing air pollution controls for 16 Texas coal-fired power plant units. Some of

the main points of our proposal are included below.

Regional Haze

EPA and states must carry out Congress ' s direction under the federal Clean Air Act (CAA)

sections l 69A and l 69B to improve visibility at certain national parks and wilderness areas,

known as Class I areas. This includes a requirement to determine and implement the the Best

Available Retrofit Technology (BART) for certain older sources of pollution that contribute to

problems of haze and visibility impairment.

• Texas' regional haze State Implementation Plan (SIP) relied on participation in our Clean Air

Interstate Rule (CAIR) as an alternative to meeting the source-specific BART requirements

for sulfur dioxide and nitrogen oxides for power plants. At the time that Texas submitted its

SIP to EPA, however, the D.C. Circuit Court had remanded CAIR (without vacating the rule)

back to EPA.

• EPA intended to replace CAIR with the Cross State Air Pollution Rule (aka CSAPR). A

number of states, including Texas, challenged CSAPR in cou1i. On July 28, 2015, the D.C.

Circuit issued a decision generally upholding CSAPR but remanding without vacating the

CSAPR emissions budgets for a number of states, including Texas.

• We had earlier proposed to rely on CSAPR participation to address these BART-related

deficiencies in Texas' SIP submittals. Because of the uncertainty caused by the D.C. Circuit

Court' s partial remand, however, we could not finalize that action. We are in the process of

responding to the remand of these CSAPR budgets.

• On October 26, 2016, we finalized an update to the CSAPR rule that addresses the 1997

ozone N AAQS portion of the remand and the requirements of CAA section

110(a)(2)(D)(i)(I) for the 2008 ozone NAAQS. This rule promulgated a new FIP for Texas

(over)

that replaced the CSAPR ozone season NOx emission budget designed to address the 1997

ozone NAAQS for the State with a revised budget designed to address the requirements of

CAA section 11 O(a)(2)(D)(i)(I) for the 2008 ozone NAAQS.

• On November l 0, 2016, we proposed to withdraw the FIP provisions that require affected

power plants in Texas to participate in CSAPR for annual emissions of S02 and NOx with

regard to emissions after 2016. Withdrawal of these FIB requirements will address the D.C.

Circuit' s remand of the CSAPR Phase 2 S02 budget for Texas.

• We are proposing that Texas' Phase 2 ozone season NOx participation will provide it with

NOx BART coverage for power plants. However, in expectation that Texas would no longer

be included in CSAPR for S02, Texas will no longer have S02 BART coverage. We are also

unable to propose approval of the Texas Regional Haze SIP's PM BART evaluation, as

previously proposed, as that demonstration made underlying assumptions that are no longer

valid with the withdrawal of the CSAPR S02 budgets.

• The State of Texas has not acted to adopt an S02 budget that would allow us to approve an

S02 BART alternative, or to submit a S1P to otherwise address the outstanding PM and S02

BART requirements. As a result, the Clean Air Act requires the EPA to address the

requirements with a federal implementation plan (FIP). The proposed FIP includes BART

screening of sources and a source-by-source analysis for S02 and PM BART and controls for

these pollutants as appropriate.

Our Proposed Federal Implementation Plan

• Under the Clean Air Act, we must propose a Federal Implementation Plan to address those

parts of the Texas plan we propose to disapprove and previously disapproved.

• Our proposed plan will improve visibility and protect human health.

• We propose S02 emission limits for 29 Electricity Generating Units (EGUs). This includes

emission limits corresponding to the installation of Sulfur Dioxide (S02) scrubbers at 12

EGOs, emission limits corresponding to the upgrading of scrubbers at 4 EGUs, and an

emission limit corresponding to the maintenance of scrubbers at 2 EGUs.

• We propose PM limits for 11 EGUs that either fire gas exclusively, or fire gas in conjunction

with fuel oil. We do not anticipate that any additional controls will be needed.

• Our proposed limits are expected to reduce emissions of S02 from 16 EGUs and would cut

emissions from approximately 89 to 98 percent. We estimate our FIP will result in a

reduction of ove ~t£2 0 tons of S02 per year.

• We propose that these 16 units be required to meet the S02 emission limits listed in the

following table. These emissions limits would have to be met on the basis of a 30 boiler

operating day, which is similar to a monthly average, but considers the time the boiler

actually operates each month. Compliance would be within 3 years for those units with S02

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emission limits corresponding to scrubber upgrades, and within 5 years for those units with

S02 emission limits corresponding to scrubber retrofits. Compliance would be required

within one year for the Fayetre units, as we do not expect that they will have to install any

additional controls.

Proposed S02

emission limit

Unit (lbs/MMBtu)

Martin Lake 1 0.12

Scrubber Martin Lake 2 0.12

Upgrades Martin Lake 3 0.11

Monticello 3 0.05

Big Brown 1 0.04

Big Brown 2 0.04

Monticello 1 0.04

Monticello 2 0.04

Coleta Creek 1 0.04

Fayette 1 0.04

Scrubber Fayette 2 0.04

Retrofits Harrington 061 B 0.06

Harrington 062B 0.06

J T Deely 1 0.04

J T Deely 2 0.04

WA Parish 5 0.04

WA Parish 6 0.04

Welsh 1 0.04

• We believe S02 scrubbers and scrubber upgrades are a cost effective way to improve

visibility.

• S02 is toxic and can react with other chemicals to form small particles, which are harmful to

public health. S02 can cause adverse respiratory effects include narrowing of the airways

which can cause difficulty breathing (bronchoconstriction) and increased asthma symptoms.

• We are proposing monitoring, record-keeping, and reporting requirements to ensure

compliance with these emission limitations.

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Interstate Transport of Visibility Impairing Pollution

EPA must carry out Congress' s direction under the federal Clean Air Act that States prohibit

sources from emitting air pollution which interferes with other States' efforts to protect visibility.

We believe that the controls proposed under our FIP will satisfy this the Clean Air Act

requirement prohibiting a State's sources from emitting air pollution which interferes with other

States' efforts to protect visibility.

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