Raven Environmental Consulting, LLC.

Standard Coal-Fired Power Plant is defined in 18 AAC 50.400(i)(11) as a Title V source that is not within 10 miles of Denali National Park, that contains a coal-fired boiler used for purposes of generating electrical power, to include cogeneration, and that has the potential to emit a total greater than or equal to 500 tons per year of regulated air pollutants in aggregate.

40 CFR 60

Permittees must comply with applicable New Source Performance Standard (NSPS) provisions. NSPS requirements are included in the applicable requirement definition under 40 CFR 71.2, which has been adopted by the Department under 18 AAC 50.040(j)(1).

Coal-Fired Power Plants can be subject to a variety of NSPS Subparts for affected facilities based on a variety of factors and can include, but are not limited to 40 C.F.R. 60 Subparts A, Y, and IIII.

Subpart A - General Provisions

Subpart A of the NSPS sets forth the general provisions that apply to all affected facilities subject to any subpart of the NSPS. Key requirements under Subpart A include:

• Compliance Testing: Facilities must perform initial and periodic performance tests to demonstrate compliance with the applicable standards.

• Monitoring and Recordkeeping: Continuous monitoring systems must be installed, operated, and maintained to track emissions. Facilities must keep detailed records of their emissions and control equipment.

• Notification and Reporting: Facilities are required to submit notifications of construction, reconstruction, and modifications, as well as regular reports of performance test results and any deviations from the standards.

• General Duty Clause: Facilities must operate and maintain their equipment in a manner consistent with good air pollution control practices.

Subpart Y - Standards of Performance for Coal Preparation and Processing Plants

Subpart Y specifically addresses coal preparation and processing plants, which are integral to the operation of coal-fired power plants. The requirements under this subpart include:

• Particulate Matter (PM) Standards: Facilities must limit emissions of particulate matter from various sources, including thermal dryers, pneumatic coal-cleaning equipment, and conveying systems.

• Opacity Limits: Visible emissions from affected sources must not exceed specified opacity limits, which indicate the density of the emissions and their potential impact on air quality.

• Control Technology: Facilities may be required to use control technologies to minimize emissions of particulate matter.

• Monitoring and Testing: Facilities must conduct regular monitoring and testing of their emissions to ensure compliance with the standards. This includes performing visible emissions observations and continuous monitoring requirements.

Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI-ICE)

While Subpart IIII primarily targets stationary compression ignition (CI) internal combustion engines, its provisions are relevant to coal-fired power plants that utilize such engines for backup power generation or other auxiliary functions. Key requirements under Subpart IIII include:

• Emission Limits: Engines must meet specified emission limits for nitrogen oxides (NOx), carbon monoxide (CO), particulate matter (PM), and nonmethane hydrocarbons (NMHC). These limits vary based on engine size, type, and date of manufacture.

• Certification and Testing: Engines must be certified to meet the applicable emission standards by the manufacturer. Facilities must perform initial performance testing to verify compliance.

• Fuel Requirements: Engines must use ultra-low sulfur diesel (ULSD) fuel with a sulfur content of 15 parts per million (ppm) or less to minimize sulfur dioxide (SO2) emissions.

• Maintenance and Operation: Engines must be properly maintained and operated to ensure compliance with the emission standards. This includes following the manufacturer's recommended maintenance practices and operating guidelines.

• Monitoring and Recordkeeping: Facilities must keep detailed records of their engine operations, maintenance activities, and emissions testing results. Continuous monitoring systems may be required for certain engines.

40 CFR 63

The Alaska Department of Environmental Conservation (ADEC) has incorporated by reference the National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements for specific industrial activities, as listed in 18 AAC 50.040(c). NESHAP Subpart ZZZZ applies to owners and operators of any existing, new, or reconstructed stationary RICE located at major and area sources of Hazardous Air Pollution (HAP) emissions.

Coal-Fired Power Plants can include NESHAP Subparts A, ZZZZ, DDDDD, and Case-by-Case Boiler Boiler MACT rules.

NESHAP Subpart A: General Compliance Requirements

Performance Testing

Facilities are required to conduct performance testing of their coal-fired boilers to demonstrate compliance with emission limits. The results of these tests must be submitted to the EPA within 60 days of completion. These tests must be repeated periodically as specified by the EPA.

Monitoring and Recordkeeping

Continuous monitoring systems must be installed and operated to track emissions from coal-fired boilers. Facilities must keep detailed records of monitoring data, maintenance, and any deviations from standards. These records must be retained for at least five years and made available to the EPA upon request.

Reporting

Facilities must submit regular reports detailing their compliance status. This includes semiannual compliance reports, which summarize monitoring data, any deviations from standards, and actions taken to correct such deviations.

Emission Limits

Coal-fired boilers are subject to specific emission limits for various hazardous air pollutants. Some of the key pollutants regulated under NESHAP Subpart A include:

• Mercury

• Particulate Matter

• Acid Gases

• Carbon Monoxide

• Dioxins/Furans

The emission limits for these pollutants are defined in the specific subparts that apply to coal-fired boilers, and facilities must ensure that their emissions do not exceed these limits.

Startup, Shutdown, and Malfunction (SSM) Plan

Facilities must develop and implement an SSM plan, which outlines procedures for minimizing emissions during periods of startup, shutdown, and malfunction. This plan must be submitted to the EPA for approval and must be updated as necessary to reflect changes in operations or regulations.

Title V Operating Permit

Coal-fired boilers must obtain a Title V operating permit, which consolidates all air quality requirements into a single, comprehensive document. This permit must be renewed every five years, and facilities must demonstrate ongoing compliance with all applicable requirements as part of the renewal process.

NESHAP Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE)

Subpart ZZZZ regulates hazardous air pollutant emissions from stationary RICE, which include diesel engines used in power plants. The key requirements under this subpart include:

• Emission Limits: Establishes emission limits for pollutants such as formaldehyde, acrolein, methanol, and other HAPs.

• Operating Requirements: Specifies requirements for operating practices to minimize emissions, including work practice standards and management practices.

• Monitoring and Testing: Mandates regular performance testing and continuous monitoring of emissions to ensure compliance with the standards.

• Recordkeeping and Reporting: Requires detailed recordkeeping and reporting to the EPA to demonstrate compliance.

NESHAP Subpart DDDDD National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters

NESHAP Subpart DDDDD applies to major sources of HAPs, which are defined as facilities capable of emitting 10 tons or more per year of any single HAP or 25 tons or more per year of any combination of HAPs.

Coal-fired boilers must meet emission limitations for several key pollutants, including:

• Mercury (Hg): Emissions of mercury must be limited to reduce the risk of neurological damage associated with mercury exposure.

• Hydrogen Chloride (HCl): This pollutant contributes to acid rain and respiratory issues; hence, its emissions are strictly controlled.

• Particulate Matter (PM): Reductions in particulate matter emissions are essential to prevent respiratory and cardiovascular diseases.

• Carbon Monoxide (CO): CO emissions are regulated to mitigate the risk of cardiovascular effects from exposure to this pollutant.

Work Practice Standards

In addition to numerical emission limits, NESHAP Subpart DDDDD mandates specific work practice standards to ensure the continuous and proper operation of pollution control devices. These requirements include:

• Periodic Tune-Ups: Boilers must undergo regular tune-ups to optimize combustion efficiency and reduce emissions.

• Energy Assessments: Facilities are required to conduct energy assessments to identify opportunities for improving energy efficiency and reducing emissions.

Monitoring and Compliance

Facilities operating coal-fired boilers must implement continuous monitoring systems to track emissions and ensure compliance with the established limits. Key requirements include:

• Continuous Emission Monitoring Systems (CEMS), Continuous Opacity Monitoring System (COMS), and Continuous Monitoring System (CMS):These systems are used to measure and record pollutant and/or opacity parameters in real-time.

• Performance Testing: Regular performance tests are conducted to verify that the boilers meet emission standards.

• Recordkeeping and Reporting: Detailed records of emissions, maintenance activities, and performance tests must be maintained and submitted to the EPA as required.

Startup, Shutdown, and Malfunction (SSM) Requirements

NESHAP Subpart DDDDD includes specific provisions for periods of startup, shutdown, and malfunction to ensure that emissions are minimized during these events. Facilities must:

• Develop and implement SSM plans that outline procedures for maintaining compliance during these periods.

• Report any exceedances of emission limits that occur during startup, shutdown, or malfunction events.

Compliance Deadlines

Facilities are required to comply with the provisions of NESHAP Subpart DDDDD according to a specified timeline. Initial compliance dates were established based on the rule's effective date, with ongoing requirements for periodic testing, monitoring, and reporting.