WRAP UpdateWRAP UpdatePatrick CumminsPatrick Cummins

WESTAR MeetingWESTAR Meeting

September 23, 2005September 23, 2005

Where We’ve BeenWhere We’ve Been

Western states take leadership Western states take leadership role on regional hazerole on regional haze

–Grand Canyon CommissionGrand Canyon Commission–WRAP formed as successor organizationWRAP formed as successor organization–309 option included in final 1999 regs309 option included in final 1999 regs–Annex submitted Sept 30, 2000Annex submitted Sept 30, 2000–5 309 SIPs submitted December 20035 309 SIPs submitted December 2003–Completing state-of-the-art technical analysisCompleting state-of-the-art technical analysis

Laws, Regulations and LawsuitsLaws, Regulations and LawsuitsJuly 1999: Regional Haze RuleJuly 1999: Regional Haze RuleJuly 2001: BART guidelines proposedJuly 2001: BART guidelines proposedMay 2002: Decision in May 2002: Decision in Corn GrowersCorn Growers vacates BART vacates BARTJun 2003: Haze rule revised to incorporate AnnexJun 2003: Haze rule revised to incorporate AnnexJuly 2003: EPA revises mobile source section of 309July 2003: EPA revises mobile source section of 309Apr 2004: BART rule and guidelines reproposedApr 2004: BART rule and guidelines reproposedFeb 2005: Decision in Feb 2005: Decision in CEED CEED vacates WRAP Annexvacates WRAP AnnexJuly 2005: BART rule finalizedJuly 2005: BART rule finalizedAug 2005: BART alternatives & 309 reproposedAug 2005: BART alternatives & 309 reproposedSep 2005: CEED & others file suit on final BART ruleSep 2005: CEED & others file suit on final BART ruleSep 2005: Comments on alternatives proposalSep 2005: Comments on alternatives proposalNov 2005: Final Trading & 309 ruleNov 2005: Final Trading & 309 rule2000-2004: No revisions to the Clean Air Act2000-2004: No revisions to the Clean Air Act2004-2005: EPA elects not to extend CAIR to the West2004-2005: EPA elects not to extend CAIR to the West2006 and beyond: More lawsuits and revisions2006 and beyond: More lawsuits and revisions

But What About Emissions?But What About Emissions?

1998-2004 (11 Western states):1998-2004 (11 Western states):–35% reduction in SO2 from EGU’s35% reduction in SO2 from EGU’s–202,500 tons per year202,500 tons per year–15% increase in heat input15% increase in heat input

How’d that happen?How’d that happen?–CentraliaCentralia–4 Corners and San Juan4 Corners and San Juan–Craig, Hayden and Metro Denver PlantsCraig, Hayden and Metro Denver Plants–NavajoNavajo

More on the way!More on the way!

SpringervilleSpringervilleCommancheCommancheSan JuanSan JuanFour CornersFour CornersMohaveMohavePacifiCorp PlantsPacifiCorp Plants

–Huntington 2Huntington 2–Cholla 4Cholla 4–Dave Johnston 3 & 4Dave Johnston 3 & 4–Upgrades at other plants (Jim Bridger – WY)Upgrades at other plants (Jim Bridger – WY)

Addl. reduction: 135,000 tpy SO2Addl. reduction: 135,000 tpy SO2

What’s LeftWhat’s Left

Not muchNot much–Pawnee (CO)Pawnee (CO)–Colorado Springs (4 units)Colorado Springs (4 units)–Boardman (OR)Boardman (OR)

Total reduction = 30,000 tpyTotal reduction = 30,000 tpy

Where does that leave us?Where does that leave us?

309 Milestones309 Milestones

–2018 Milestone (5 states)=309,0002018 Milestone (5 states)=309,000–Current emissions = 316,000 (incl. CEM adj.)Current emissions = 316,000 (incl. CEM adj.)–After planned reductions = 235,000After planned reductions = 235,000–Need to add back some growth and new Need to add back some growth and new sources (25-35K?)sources (25-35K?)–Boardman only plant left in 309 statesBoardman only plant left in 309 states

Annex milestones need to be reevaluated Annex milestones need to be reevaluated in order to show better than BART and in order to show better than BART and resubmit 309 SIPsresubmit 309 SIPs

Where does that leave us?Where does that leave us?

Utilities-only look:Utilities-only look:–9-state EGU target from Annex=271 K tpy SO2 9-state EGU target from Annex=271 K tpy SO2 (including new)(including new)–300 K with WA & MT (a good better than BART 300 K with WA & MT (a good better than BART number)number)

–Current 11-state emissions: Current 11-state emissions: 371 K371 K–After planned reductions: After planned reductions: 235 K235 K–With remaining sources: With remaining sources: 205 K205 K–Add growth and new sourcesAdd growth and new sources

What about NOx?What about NOx?

EGU emissions = about 15% of inventoryEGU emissions = about 15% of inventory

NOx generally contributes < 10% of hazeNOx generally contributes < 10% of haze

Some areas have larger NOx contributionsSome areas have larger NOx contributions–Greater contribution on clean days, but NOx will go down Greater contribution on clean days, but NOx will go down under any scenariounder any scenario

NOx emissions are of concern for other NOx emissions are of concern for other reasons (ozone, acid deposition, etc.)reasons (ozone, acid deposition, etc.)

What about NOx?What about NOx?

46 BART-eligible units >200 MW in 13 46 BART-eligible units >200 MW in 13 states that exceed presumptive limits states that exceed presumptive limits

Achieving presumptive limits at BART-Achieving presumptive limits at BART-eligible units = 30% reductioneligible units = 30% reduction

Plants > 750 MW = 16% reductionPlants > 750 MW = 16% reduction

Presumptive limits on all units (including Presumptive limits on all units (including non-BART) = 40% reductionnon-BART) = 40% reduction

Questions and IssuesQuestions and IssuesRevisions to 309 SIPsRevisions to 309 SIPs

–How to do better than BART demonstrationHow to do better than BART demonstration–3 options, all have problems3 options, all have problems–309 states need to get together and determine 309 states need to get together and determine next stepsnext steps

BART for 308 and NOx?BART for 308 and NOx?–Unlikely that SO2 program will be expandedUnlikely that SO2 program will be expanded–Trading alternative may have value for NOx. Trading alternative may have value for NOx. Possible expansion to all non-CAIR states.Possible expansion to all non-CAIR states.–Utility only program?Utility only program?

Are there non-utility sources of concern Are there non-utility sources of concern (BART and non-BART)?(BART and non-BART)?

–How many, what kind, where?How many, what kind, where?

In conclusion…….In conclusion…….Most of the progress through 2018 will be in the Most of the progress through 2018 will be in the base case (incl., federal mobile source controls)base case (incl., federal mobile source controls)

Biggest effect will be from SO2 reductions that are Biggest effect will be from SO2 reductions that are already in the pipealready in the pipe

–How do we package our success to meet the How do we package our success to meet the requirements (especially when BART remains a moving requirements (especially when BART remains a moving target)target)

Work with EPA to address outstanding issues with Work with EPA to address outstanding issues with alternative programs and 309.alternative programs and 309.

–Reaffirm state leadership role, working with stakeholders, Reaffirm state leadership role, working with stakeholders, to establish solutions that work for the Westto establish solutions that work for the West

NOx is a question that effects more sourcesNOx is a question that effects more sources–Presumptive limits on 750 MW plants is ½ the battlePresumptive limits on 750 MW plants is ½ the battle–Several options exist. What do sources and states want?Several options exist. What do sources and states want?–Can do some sensitivity runsCan do some sensitivity runs