1. 1 BART in California WRAP Stationary Sources Joint Forum November 15-16, 2006 Tempe, Arizona Air Resources Board California Environmental Protection Agency

2. 2 Overview BART-eligible facility categories BART-era unit winnowing process Applicable CA rules Very few reductions

3. 3 BART Categories Considerations at each facility Location and NAAQS attainment status Typical emissions of BART-era units Location of impacts (in & out of state) Applicable rules and permit limits Concerns for key BART types Refineries (SO 2 controls) Cement Plants (location and fuel) Power Plants (location and peaking units) Manufacturing plants (power source, fugitives) Pulp mill (consent decree)

4. 4 BART Process in California Q/D and Modeling Districts providing data CA modeler preparing the receptors Large units have been replaced since 1977 Permits and Rules Limits better than BART Confirm rules apply Amend Title V Permits

5. 5 California-Specific Rules Transport Mitigation Rule: BARCT Best Available Retrofit Control Technology Sources in upwind district must retrofit if impact to downwind attainment of state standards Doesn’t affect North Coast, Mojave Desert All Feasible Measures updated periodically for State Standards CAPCOA recently updated Stationary Source rules for SB656 Economic and Environmental Analysis built into Rule Development Process

6. 6 NAAQS RACT Requirement RACT analysis for PM2.5 SIPs South Coast and San Joaquin Valley South Coast 16 BART categories: VOC, NOx, PM, SO 2 RECLAIM and Emission Reduction Credits Future Issues: Plant Modernization concept in pending SIP San Joaquin Valley Manufacturing and chemical facilities under BARCT or AFM rules Oil and Gas exploration/production categories already tightly controlled

7. 7 Rule Stringency Cement Kilns (averaged over any 30 day consecutive period) Preheater-Precalciner Kilns: 6.4 lb NOx/ton of clinker produced Long Dry Kilns: 6.4 lb NOx/ton of clinker produced Short Dry Kilns: 7.2 lb NOx/ton of clinker produced Typical Cost-effectiveness Range: $470 - 1270 per ton NOx reduced PM emissions limit: 0.40 lb PM/ton of kiln feed for feed rates <75 tons/hour or 30.0 lb PM/hour for kiln feed rates >75 tons/hour Large Boilers (> 40 MMBTU/hr) Gaseous Fuel: 30-70 ppm NOx Non-gaseous fuel: 30-115 ppm NOx Cost-effectiveness Range: ~$7000 per ton NOx reduced in South Coast Bay Area requires gaseous fuels unless force majeure natural gas curtailment Petroleum Coke Calciner South Coast required 80% reduction of SO 2 emissions in 1979 Bay Area sets limits for effluent process gas containing sulfur dioxide

8. 8 Reductions Anticipated Bay Area Subject-to-BART modeling San Luis Obispo coastal plants –Refinery Calciner: reduce PTE 3000 TPY SO 2 –Power Plant Peaker Units: reduce PTE 600 TPY NOx –Current actual emissions <4000 tons combined NOx, SO 2, PM Eureka Bay in Humboldt County (North Coast) –Maybe reductions at Pulp Mill and Power Plant –Current actual emissions <1500 tons combined NOx, SO 2, PM Title V permits backed by district rules

9. 9 Take your “Pic”