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IN THE MA TIER OF COMPLIANCE WITH RCW 

70.94 AND THE GENERAL REGULATIONS FOR 

AIR POLLUTION SOURCES OF THE SOUTHWEST 

AIR POLLUTION CONTROL AUTHORITY 

Centralia Plant 

PacifiCorp, _et. al. 

Centralia, Washington 

RESPONDENT 

INTRODUCTION 

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SW APCA 97-2057R1 

REGULATORY ORDER TO 

ESTABLISH RACT 

EMISSION LIMITS AND 

·oRDER OF APPROVAL 

1. Under RCW 70.94.154 ofthe Washington Clean Air Act, "reasonably available control 

technology" or "RACT" is required for all existing sources in Washington. All sources 

are required to achieve the lowest emission limit that the source or source category is 

capable of meeting by the application of control teclulology that is reasonably available 

considering technological and economic feasibility. See RCW 70.94.154(1). In setting 

RACT, SW APCA is required to consider the following factors: (1) the impact of the 

source upon air quality, (2) the availability of additio:n\1.1 controls, (3) the emission 

reduction to be achieved by additional controls, (4) the impact of additional controls on 

air quality, and (5) the capital and operating costs ofthe additional controls. See RCW 

70.94.030(19). 

2. An important consideration in SW APCA's determination of source-specific RACT for the 

Centralia Plant's sulfur dioxide (802) emissions is Centralia Plant's agreement to achieve 

certain significant reductions in emissions of sulfur dioxide, which are discussed below 

in Item 7. Because the Centralia Plant has already agreed as part of the COM process 

to accept these emission reductions once required .in a Regulatory Order, it is not 

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necessary for SWAPCA to assess whether a less string~nt S02 emission-limit will meet 

the requirements for RACT. Instead, in the RACT determination for S02 as provided in 

the Technical Support Document, SW APCA has considered whether RACT requires a 

more stringent emissio~ limit than. the CDM target solution. 

The Washington State legislature's decision to grant certain tax relief to the Centralia 

Plant bas changed the economic feasibility determination analysis under RACT that woi.dd 

otherwise apply to this or similar sources. Thus, RACT .for the Centralia Plant's S02 

emission limit may not be easily transferred to other sources ·or source c~tegories. 

In addition to determining RACT for sulfur dioxide emissions, S W APCA bas also 

determined RACT emission limits for nitrogen oxides, particulate matter, and carbon 

monoxide. 

SW APCA has considered visibility impairment in Mount Rainier National Park and other 

Class I areas. While no formal BART determination has been made, SWAPCA has 

considered the federal "best available retrofit technology" (BART) guidelines for large 

coal-fired power plants, and specifically how the RACT emission limits compare with the 

new source ~rformance standards (NSPS) ( 40 'CFR 60.40a, Subpart Da). 

REGULATORYBACKGRQUND 

RACT Order SWAPCA 95-1787. 

SWAPCA issued RACT Order SW APCA 95-1787 in August 1995 establishing plant-wide 

S02 emission limits of 1.1 pounds per million Btu (lb/MBtu), annual average and 55,000 

21 tons/yr. Comments from the National Park Service and USDA Forest Service concerning 

22 BART prompted on-going discussions about additional S02 reductions. The 1995 RACT 

3 Order was withdrawn in September 1996 to facilitate another review of RACT and to 

Page 2 SWAPCA 97-2057RI 

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.... l determine whether the collaborative decision making (COM) target solution exceeds 

- 2 ·emission limits consistent with RACT. 

3 CDM Target Solution 

4 7. A collaborative decision making (CDM) process during 1996 led to agreement among the 

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5 Centralia Plant owners, federal land managers, and regulatory agencies to seek further 

6 . emission reductions. The outcome of this process was a proposal to limit so2 emissions 

7 to no more than 10,000 tons/yr after December 31, 2002 and install NOx controls. In· 

. 8 addition, proposed criteria were developed for: (a) Current Standards - Hourly 

- 9 Concentrations; (b) Operating Conditions with Controls - Good Operating Practices, 

10 Scrubber Outages, Unit Startup/Shutdown, Emissions Accounting, and Modifications; (c) 

11 Emission Limits - Control System Deadline, Hourly Concentrations in 2002, Hourly 

r 2 Concentration 2003 Onward, Annual Limit, and Bypass Stacks; (d) Monitoring . and 

- 13 Reporting - CEMs, Compliance Data, Interim Compliance, Compliance Evaluation, Data 

14 Availability, and Reporting Frequency; and (e) Exceedances and Penalties - Hourly 

,... 15 Exceedance, Annual Exceedance, Excess Emission, Defmition of Violation, and General 

,... 16 Enforcement and Allowance Forfeiture. Documentation from the CDM group 

17 collaborative process is provided in Appendix B of the Technical Support Document. 

r 

18 LEGAL AUTHORITY 

,.. 19 8. ' RCW 70.94.154 specifies that all sources in Washington State are required to meet 

20 emission limitations consistent with RACT. SWAPCA may issue a Regulatory Order to ,.... 

21 define emission limitations that constitute RACT and require compliance with such 

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22 emission limitations. RACT means the lowest emission limit that a particular source or 

r 3 source category is capable of meeting by the application of control technology that is 

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reasonably available considering technological feasibility and economic 

(SW APCA 400-030(68)). 

Regulations have been established for the control of air pollutants emitt~d to the ambient 

air. · Regulations applicable to the Centralia Plant which have been considered in 

establishing RACT emission limits and control requirements include, but are not limited 

to, the following regulations, codes or requirements. These items establish minimally 

acceptable emission limits that could be allowed for exi~g facilities. More stringent 

limits may be established in this Order consistent with implementation of RACT: 

a. Title 40 Code of Federal Regulations (CFR) Part 60.40 et ~ (Subpart D) 

ustandards ofPerformap.ce for Fossil-Fuel-Fired Steam Generators" applies to each 

steam generating unit of more than 250 million Btu per·hour heat input for which 

construction commenced after August 17, 1971. This regulation does not apply 

to the Centralia Plant because construction of the Centralia Plant commenced in 

1968. SW APCA approved construction of the Centralia Plant in a letter dated 

November 7, 1969. 

b. Title '40 Code of Federal Regulations (CFR) Part 60.40a et seq. (Subpart Da) 

"Standards of Performance for Electric Utility Steam Generating Units for Which 

Construction Is Commenced After September 18, 197 8" applies to each steam· 

generating unit of more than 250 million Btu per hour heat input for which 

construction commenced after September 18, 1978. This regulation does not 

apply to the Centralia Plant because construction of the Centralia · Plant 

commenced in 1968 and has not since been modified. SWAPCA approved 

construction of the Centralia Plant in a letter dated November 7, 1969. 

SWAPCA 97-2057R 1 

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'-. 1 c. WAC 173-400-151 "Retrofit Requirements for Visibility· Protection" requires the ,_ 

2 owner or operator of any source to which significant visibility impairment of a 

,.... 3 mandatory Class I area is reasonably attributable, to apply BART for each 

4 contaminant contributing to visibility impairment that is emitted at more than 250 

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5 tons per year. 

6 d. WAC 173-470 "Ambient Air Quality Standards for Particulate Matter" establishes 

7 ambient air quality standards for total suspend~ particulate matter and for ,... 

8 particulate matter smaller than 10 microns (PMuJ, which may not be exceeded 

9 more than one day per year. 

,.... 10 e. WAC 173-474 "Ambient Air Quality Standards for Sulfur Oxides" established 

11 ambient air quality standards for sulfur oxides, measured as sulfur dioxide. (S02), 

r 2 of 0.4 parts per million {1-hour average) .and 0.1 parts per million (24-hour 

r 13 average) which may not be exceeded more than once in a one-year period, and 

14 

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0.25 parts per million (1-hour average) which may not be exceeded more than 

15 twice in a consecutive seven-day period. 

16 f. WAC 173-475 "Ambient Air Quality Standards for Carbon Monoxide, Ozone, and 

,) 

17 Nitrogen Dioxide" establishes an ambient air quality standard of 0.05 part per 

18 million (ppm), annual arithmetic mean for nitrogen dioxide; an ambient air quality 

r 19 standard of 0.12 ppm, one hour average, for ozone; and ambient air quality 

20 standards of 9.0 ppm, eight hour average, and 35.0. ppm, one hour average, for 

21 carbon monoxide. 

,... 22 g. S W APCA 400-040 "General Standards for Maximum Emissions" Section 6 i,....... 

,. 3 requires that no person shall cause or permit the emission of a gas containing 

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sulfur dioxide from any emission unit in excess of 1000 ppm dry vtv corrected to 

7% 0 2 or 12% C02 average for any consecutive 60 minutes. 

h. · SW APCA 400-091 "Voluntary Limits on Emissions" requires that SWAPCA 

i. 

establish enforceable limits on emissions or limitations on potential to emit upon 

request by a sourCe to an amount agreed to by the owner or operator and 

SW APCA. SW APCA shall issue a Regulatory Order to reduce. that source's 

· potential. to emit whereby the terms and conditions of such Order sha11 be 

federally enforceable. Such Order shall be subject to public notice and comment. . 

SW APCA 400-114 "Requirements for Replacement or Substantial Alteration of 

Emission Control Technology at an Existing Stationary Source" requires that the 

owner/operator of a source submit a Notice. of Construction application to 

SW APCA and that an Order of Approval/Regulatory Order be issued prior to 

making the replacement or alteration. For projects not otherwise reviewable under 

SWAPCA 400-110; SWAPCA may require the owner or operator to employ 

RACT. SW APCA 400-114 applies to fuel modifications strictly for control of 

emissions, as. well as to the installation of pollution control equipment. 

REGULATORY FINDINGS 

Emission Units 

SW APCA evaluated all emission units at the Centralia Plant to determine those units that 

should be considered for inclusion in a RACT evaluation. There were eight emission 

units identified as major plant components. In addition, the Title V application further 

22 identified four additional emission units. These four additional emission units were 

3 identified to be insignificant emission units in accordance with Title Y requirements. 

24 Based on the RACT criteria of RCW 70.94.154 and RCW 70.94.030, only the main 

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boilers (Boilers #I and #2) were determined to be of significant nature such that a RACT 

evaluation and establishinent of RACT emission limits would be practicable at this time. 

The full evaluation of the emission units are documented in the Technical Support 

Document in Section 2.2. 

Pollutants Deemed to be of Concern 

·swAPCA evaluated certain pollutants to determine whether they are "of concern .. and 

whether it would be practicable to set RACT emission ~imits for ·them at this .time. 

SW APCA evaluated each of the criteria pollutants (sulfur dioxide, particulate matter, 

oxides of nitrogen, an.d ca:rbon monoxide) to determine if they qualified as contaminants 

of concern for the Centralia Plant. Ozone was not directly evaluated because it is not a 

pollutant directly emitted by the Centralia Plant, however, ozone was evaluated as a 

byproduct of oxides of nitrogen and volatile organic compounds. In addition volatile 

organic compounds, hazardous air pollutants (HAPs) and toxic air· pollutants (TAPs), and 

carbon dioxide were evaluated. Lead was not evaluated separately as a criteria pollutant 

but was considered under the category of hazardous air pollutant. SW APCA applied 

criteria contained in RCW 70.94.154 and RCW 70.94.030 to each pollutant to arrive at 

a conclusion of which pollutants should be evaluated for RACT. Only those pollutants 

emitted from the emission units of concern that were identified above were evaluated. 

The pollutants of concern for which a RACT determination was deemed to be practicable 

20 

rare: sulfur dioxide, oxides of nitrogen, particulate matter and carbon monoxide. The full 

21 evaluation of the pollutants of concern are documented in the Technical Support 

r 22 Document in Section 2.3. 

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SW APCA's Discretion to Not Determine RACT Where Not Practicable 

12. Volatile organic compounds,. hazardous air pollutants and toxic air pollutants, and carbon 

dioxide were determined to not be subject to· RACT for the Centralia Plant based on 

individual factors explained in the Technical Support Document. The hazardous air 

pollutants were found to be ilisignificant (not of concern) or determined to not be 

practicable to have a RACT emission limit established at this time. One hazardous air 

pollutant, mercury (Hg), was determined to be potentially of concern and was evaluated 

in more ·detail than the other hazardous -~ pollutants. The U.S. EPA is currently 

evaltiating merctiry emissions from all power plants to establish the need: for max.in;lUm 

achievable control technology (MACT) controls. Because the concentration of mercury 

emissions from the Centralia Plant are significantly below the Washington State· 

established acceptable source _impact level (ASIL) of WAC 173-460 and the fact that 

mercury is being considered for a federal MACT standard, mercury is not yet a pollutant 

of concern. Therefore, establishment of a RACT emission limit for mercury was not 

considered to be practicable at this time. 

Basis for Order 

13. This Order, in part, is issued in accordance with SWAPCA 400-091, upon request by the 

Respondent, to limit the potential to emit from the auxiliary boiler. The emission 

limitation is based on establishing an annual total fuel consumption limit for the auxiliary 

boiler of 600,000 gallons per year and AP-42 emission factors. 

14. This Order, in part, is issued .in accordance with SWAPCA 400..:ll4(2)(a) requiring 

installation of RACT and is deemed to meet the requirements of SW APCA 400-114(3) 

for Notice of Construction subminal and approval of replacement or substantial alteration 

of emission control technology at an existing stationary source. Respondent shall notify 

Page 8 SWAPCA 97-2057R1 

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SW APCA of the selected control technology upon its final selection. Any additional 

monitoring and operating requirements necessary to ensure continuous compliance with 

applicable requirements shall be incorporated into the Title V permit at the time of its 

issuance or renewal, as appropriate. 

RACT and BART Findings 

15. SWAPCA finds that the 10,000 tons per year emission limit for S02 required in this 

Order meets or exceeds the requirement for an S02 RACT ~ission limit for the Centralia 

Plant. 

16. SW APCA fmds that a 0.30 lb!MBtu, annual average, both units combined, emission limit 

for oxides of nitrogen, a 0.010 gr/dscf and 200/o opacity emission limits for particulate 

matter, and 200 ppm, annual average, both units combined, emission limit for carbon 

monoxide, are levels of emissions that can be achieved by the Centralia Plant by 

application of RACT control technology, thereby establishing RACT emission limits as 

provided under RCW 70.94.154. 

17. SW APCA finds that, while no formal BART determination has been made, based on the 

requirements in this Order and documentation in the Technical Support Document, the 

emission limits in this RACT Order represent BART under 40 CFR 51 Subpart P, WAC 

173-400-151 and SW APCA 400-151 for emissions of sulfur dioxide, particulate matter 

and nitrogen oxides by meeting the BART requirements for those pollutants. 

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NOW HAVING. CONSIDERED 'THIS MAlTER AND· BEING DULY ADVISED, IT IS 

HEREBY ORDERED: 

18. 

19. 

20. 

SQLFUR DIOXIDE 

THAT; unless otherwise provided below, no later than January I, 2003 total S02 

emissions from units #1 and #2, the auxiliary boiler (as described in Item 45), and other 

emission points throughout the facility' combined, shall not exceed .1 0,000 tons/yr in any 

rolling 12-month period. The determination of annual ~issions shall be based on a 

rolling monthly calculation from the· recorded hourly 802 emissions used for Acid Rain 

Program compliance evaluation. An annual average shall be computed for the preceding 

l2 ... month period which ends with each month ·of the quarter, to be reported quarterly by 

the end of the month following the end of the calendar quarter. 

THAT, the s~lected 802 emission control technology shall be operational no later than 

December 31, 2001 for one ofthe Plant units, and shall be operational no later than 

December 31, 2002 for the other Plant unit. However, if the selected 802 emission 

control method is fuel supply modification or a post-combustion control system applied 

to only one of the two units, neither of the ·units, or no controls, the emission limit for 

the entire Plant shall be effective after December 31, · 2001. 

THAT, the annual 802 exhaust gas emissions, during and after installation of control 

technology according to the schedule in Item 19 above, shall not exceed the following: 

a. 7,500 tons per year, annual average, for the controlled unit including any bypass, 

and no annual limit for the uncontrolled unit, if discharged through separate stacks 

(flues), effective only in calendar year 2002; 

b. l 0,000 tons per year, annual average, for all exhaust gases discharged through a 

new flue (and bypass for the controlled unit) if this flue is to be common for both 

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1 units once control technology is applied to b~th units. The exhaust stream to 

r2 which this limit applies consists of emissions from the first controlled unit for the 

,... 3 entire year of 2002 and emissions from the second controlled unit for only that 

4 portion of the year 2002 that the second unit is in startup testing and discharges 

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5 its exhaust through the new common flue. Compliance evaluation periods that 

,.. 6 span startup of the second unit shall use the monthly emissions calculated by the 

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,.. appropriate accounting method for each month; 

8 c. 10,000 tons per year, annual average, both units combmed, if both units have 

r- 9 control technology installed (operational) by December 31, 2001, effective in 

- 10 calendar year 2002 and beyond; 

11 -d. 10,000 tons per year, annual average, both units combined, both units controlled, 

r .2 one or two stacks, effective _in calendar year 2003 and beyond; 

,... 13 e. The Centralia Plant shall, within its operation and maintenance constraints, use all 

14 best efforts to preferentiallyload the unit first equipped with so2 emission control 

- 15 technology when the Plant is operating at less than maximum capacity from 

,.. 16 December 31, 2001 through December 30, 2002. Daily generation records for ' 

17 / 

both units will be made available during calendar ye_ar 2002 to assess the relative 

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18 loading of the scrubbed and unscrubbed units. 

,... 19 21. THAT, from January I, 2002 onward, the S02 exhaust gas concentration from units to 

20 which emission reduction technology has been applied, according to the schedule in Item 

""" 21 19 above, shall not exceed the following short-term levels: 

r 22 

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a. 250 ppm, 1-hour average measured on a dry basis corrected to 7% 0 2 for the 

r .3 controlled unit(s); 1000 ppm, 1-hour average measured on a dry basis corrected 

24 to 7% 0 2 for the uncontrolled unit for only 2002; 

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b. During planned or forced outages of the 802 emission control technology and 

during startups and/or shutdowns of a unit as defined in Section 25 below, if the 

selected sol emission control ~hnology cannot operate, the following alternative 

emission levels measured on a dry basis corrected to 7% 0 2 shall apply: 

(i) 1000 ppm, 1-hour average, if the exhaust gas from each unit is discharged 

through separate flues which are independently monitored; 

(ii) · If the exhaust gases from both units are diseh~ed through a new common 

flue in which only a combined exhaust mixture may be monitored, then the 

following outage and startup/shutdown levels shall apply: 

(a) In 2002, 1000 ppm, 1-hour average; and 

(b) In 2003 and onward, 750 ppm, 1-hour average if the outage or 

startup/shutdown condition exists for only one unit, and 1000 ppm, 

1-hour average if the condition exists for both units concurrently; 

c. If the exhaust gases from both units are discharged through a new common flue, 

during startup testing of the second unit's S02 emission control technology, 802 

concentrations ·shall not exceed 7 50 ppm, 1-hour average, only in 2002. 

22. THAT, prior to compliance with the 802 emission limit in Item 18 above, neither. Unit # 1 

nor Unit #2 shall exceed for any fixed hour at any time while fuel is being supplied to 

the unit, an S02 stack concentration of 1000 ppm, l-hour average, dry basis corrected to 

7% 0 2 as provided in S W APCA 400-040( 6). 

23. THAT, the duration of a forced outage of the S02 em iss ion control technology shall be 

minimized by returning the emission control system to operation as soon as practicable. 

A planned outage is defined as one that is scheduled in advance regardless of the length 

of the planning horizon. All other unanticipated system outages are defined to be forced. 

Page 12 SWAPCA 97-2057RI 

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1 The Centralia Plant is . responsible for demonstrating that a forced outage which occurs 

- 2 while the plant continues to operate is unavoidable and is being managed to minimize 

,... 3 emissions as provided in SWAPCA 400-107. Emission control system outages shall be 

4 reported to SWAPCA by telephone during the current business day or no later than the 

5 next business morning; a message may be left on an automatic answering machine outsi<,le 

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6 normal business hours. A written report may be requested by SW APCA, and shall be 

7 required for any forced outage longer than 72 hours. For outages exceeding 72 hours, the 

8 plant shall consider available means to reduce emissions of S02, including, -but not limited 

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9 to, a reduction in electrical output, use of reduced sulfur content coal, or taking one or 

10 both units off line. Planned emission control system outages shall be conducted to the 

11 maximum extent possible during daily or weekly plant load reduction periods. No 

i_,-.., "'2 planned emission control system outages shall occur during the period of June 15 through 

13 September 15 except when the plant is completely off line and no fuel is burned. 

14 24. THAT, all S02 emissions during startup, shutdown, equipment out of service, and upset 

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15 conditions shall be included in the summation of emissions to determine compliance with 

16 the annual (12 month) emissions limit of 10,000 tpy. 

17 25. THAT, during startup and shutdown, of the Centralia Plant units (for normal operations 

18 or planned outages), emissions control equipment shall be operated to minimize overall 

19 emissions, except to the extent equipment operation will cause degradation of its long20 term performance. Exceedances of the normal operation hourly S02 (250 ppm) and 

21 opacity limitations (20%) are excused under S W APCA 400-107 during startup and 

~ 22 ' ,.......__ shutdown when the electrostatic precipitators (ESPs) and S02 emission control system(s) 

!""' 1 are out of service. The shutdown period begins when the ESP temperature drops to 

24 220°F, the critical ESP de-energize temperature. When the critical temperature is 

,.. 

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attained, first the so2 control system, and then the ESPs are taken .out of service. For ' I ............. l 

peri,ods when all fuel is out of the boiler, so2 emissions shall be assumed to be zero. The J 

startup period begins when fuel is introduced in~o a boiler with the intent of raising its 

temperature to operating conditions. The ESPs are energized when they reach operationai 

temperature, or 220°F. The S02 control system(s) is( are) placed in service following ESP 

stabilization. The startup period ends when the earlier of the two operating events below 

occurs: 

a. Opacity in the gas path dpwnstream of the ESPs has stabilized below 10% for 30 

minutes (five consecutive 6-minute periods); or 

b. 8 hours have elapsed after the startup unit is synchronized to be electrica1Iy online. 

THAT, during equipment out of service and upsets (including forced outages), emissions 

in excess of the 250 ppm hourly so2 limitation are excused from the hourly limit 

provided they meet the burden of proof regarding unavoidable conditions that lead to 

excess emissions in accordance with S W APCA 400-1 07. Centralia Plant shall record 

equipment out of service and upset conditions in the operation log for periodic inspection 

by SWAPCA. For periods when all fuel is out of the boiler, S02 emissions shall be 

assumed to be zero. 

THAT, the compliance determination methodology for S02 emissions shall be as follows: 

a. S02 emissions from each unit, if emitted through separate flues, shall be measured 

by an S02 monitor and the diluent (02 or C02) monitor, which are continuous 

emission monitors (CEM) installed and operated to meet the requirements of 40 

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CFR Part 75 .. Hourly (over a fixed clock hour, e.g., 1:00 p.m. to 1:59 p.m.) S02 '-· ( 

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averages shall be calculated by the CEM. Compliance with the hourly S02 J 

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limitations shall be determined from the CEM data, collected in· compliance with 

40 CFR Part 75 separately for Centralia Plant Units #1 and #2 from separate flues, 

or a combined flue, if applicable. 

Compliance with the annual emission limit in tons per year shaH be determined 

at the end of each calendar quarter from tons of 802 emitted during the three 12-

month periods ending in that .quarter. Emissions shall be calculated using the 

methodology in 40 CFR 75 for the Acid Rain Pro~. If prior to June 2000, the 

U.S. Environmental Protection Agency has not resolved the discrepancy that exists 

in calculating tons of 802 between the current 40 CFR Part 75 and coal burned 

methodologies, the Centralia Plant may propose to SW APCA, for review and 

modification of this .provision, alternative monjtoring and compliance evaluation 

methods that more accurately represent true emissions. 

The minimum data availability requirements of 40 CFR 75.20 to 75.34 shall be 

met. Periods of CEM malfunctions shall be subject to SW APCA 400-1 05(5)(h) 

which exempts the Centralia Plant from monitoring and reporting requirements if 

SW APCA determines that the CEM malfunction was unavoidable. When 

determining compliance with the S02 1imitations for monitor out-of-service periods 

of four hours or less in duration, the average of the hour before and the hour 

following a monitor out-C?f-service period, in accordance with 40 CFR 

75.33(b)(l)(i) shall be used. Because the missing data substitution procedures for 

40 CFR 75.30 to 75.34 may require the use of emission values that do not 

represent actual emissions, alternative data may be used for missing data periods. 

When determining compliance with S02 limitations for monitor out-of-service 

periods greater than four hours, data from the on-line coal analyzer operated by 

SWAPCA 97-2057R1 
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28. 

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the Centralia Mining Company, the as-burned coal analyses conducted by 

·Centralia Plant, and emission control system operating data shall be evaluated. 

The data or combination of data, that best 'representS actual emissions shall be 

used to determine compliance with the S02 limitations. Stack test data may be 

used, if available and approved by SW APCA. 

Quarterly reports for Centralia Plant Units #I and #2 shall be submitted to 

SW APCA by the end of the month following the c:nd of each calendar quarter. 

Each report shall include, but not be limited to, the following: 

{1) Hourly concentrations of S02 in ppni, dry basis corrected to 7% 0 2; 

{2) Tons ofS02 emitted from all relevant stacks {plus any extreme emergency 

bypasses through the old stacks) for each 12-month period, ending with the 

last day of each month in the quarter; 

(3) Complete 40 CFR Part 75 quarterly report on disk may be submitted under 

separate cover; 

(4) During 2002, daily megawatt generation from each boiler to allow 

confirmation of loading priority of the boilers. 

THAT; exceedances and violations of short-term and annual emissions limitations shall 

be deftned as described below: 

a. An exceedance of the hourly limitation (250 ppm and 1000 ppm) is defined as any 

fixed hour (e.g., 1:00 p.m. to 1:59 p.m.) with so2 concentration over the 

limitations as deftned and determined under Items 21 and 22 above; 

b. Exceedance of the hourly S02 limitations in Items 21 and 22 above shall.be 

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subject to S W APCA 400-107. The Centralia Plant shall have the burden of proof · . ......._.., ~ 

demonstrating unavoidable conditions that lead to excess emission in accordance J 

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with SWAPCA 400-107. Excess emissions shall be reported to SWAPCA by 

telephone during the current business day or next business morning; a message 

may be left .on an automatic answering machine outside normal business hours. 

A written report may be required by SWAPCA if determined necessary. 

Violations and penalties for exceedances of the hourly limits shall be determined 

in accordance with SW APCA 400-230 and RCW 70.94; 

c. An exceedance of the annual limitation is one 12-month period exceeding the 

tons/year S02 limitations as defmed- and determined und~r Items 18, 19, and 20 

above. All hourly so2 emission data. for startup, shutdown, upset and forced or 

planned emission control system outage. periods shall be included in the 

calculations of the annual tons of so2 emitted; 

d. Except as provided herein, ea?h exceedance of the annual (rolling 12-month) 

emission limitation shall constitute a continuing violation for the days in the last 

month of the 12-month (annual) period. Each day of violation shall be treated 

equally and be subject to penalty as allowed by law at the time of the noncompliance. The Centralia Plant may calculate 365-day emission summations 

ending on each day in the last month ofthe 12-month period to reduce the number 

of violation days subject to penalty. If adequately demonstrated, the number of 

violation days shall not include the number of 365-day periods ending within the 

last month of the exceedance period for which the emissions summation did not 

exceed the annual limit; 

e. SW APCA retains the authority to take enforcement action m response to 

deficiencies in plant operation and maintenance, equipment performance, or any 

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I other matter not explicitly i~entified in Items 25 and 26, consistent with SW APCA ~~ 

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2 400 General Regulations for Air Pollution Sources; ..J 

3 f. In addition to penalties that · may be assessed under statutory and regulatory I 

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4 authorities, beginning in calendar year 2002, the Centralia Plant shall forfeit . 

5 ownership of 802 allowances to SW APCA equal to 1.5 times the quantity of - 6 emissions in excess of the 10,000 ton annual limit calculated on a calendar year ! 

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7 basis. 

8 29. THAT, if the selected emission oontrol technology includes construction of a new stack( s) 

9 with one or two flues, the existing stack for each unit may remain for bypass situations 

10 

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provided that certified CEMs are maintained in the existing stacks. If there are no 

certified functioning CEMs in the existing stacks, these stacks shall only be used during J 

2 extreme emergency conditions, provided that a separate bypass duct. around the S02 

13 emission control technology is not constructed into the new stack. Examples of 

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14 emergency conditions are interruption of the exhaust gas flow path through that unit's 

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15 scrubber vessel, or other situations with the potential to result in personal injury or severe 

16 damage to the boiler, emission control systems, or new stack. Any bypass that is not 

17 monitored by a certified functional CEM 'is considered an upset condition and shall be 

18 reported to SWAPCA during the current business day or by the next business morning 

19 and shall be documented to SWAPCA within 5 days of the occurrence. All S02 

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20 emissions discharged from a bypa~s stack shall be included in the calculation of emissions 

21 for determining compliance with the annual limit. 

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OXIDES OF NITROGEN 

30. THAT, the annual average (calendar year) emission rate for NOx shall not exceed 

0.30 lb/MBtu, both units averaged together, for those hours when a unit's generating load 

is 360 MW gross or greater. (This annual average emission rate is calculated· as the 

combined arithmetic sum of hourly emission ra~es for each unit when ·each unit's 

generating load is 360 MW gross, or greater, divided by the combined sum of the number 

of hours that each unit operated at 360 MW, or greater, d~ the calendar year.) For 

all operating hours, emissions ofNOx shall not exceed 0.35 lb NOxfMBtu annual average 

(calendar year), both units averaged together. These emission limits shall be. subject to 

the schedule in Items 31 and 32. All other provisions including compliance 

demonstration shall be consistent with the Acid Rain Program provisions. 

31. THAT, the selected NOx. emission control technology shall be operational no later than 

December 31, 2001 for the frrst unit and December 31, 2002 for the second unit. 

32. THAT, the NOx exhaust gas emission rate during installation of control technology 

according to the schedule in Item 31 above, shall not exceed the following: 

a. 0.31 lb!MBtu annual average for the controlled unit for all hours when the unit 

generating load is 360 MW gross or above, 0.36 lb!MBtu annual average for all 

operating hours for the controlled unit, 0.45 lb/MBtu annual average for the 

uncontrolled unit, if discharged through separate stacks, effective only in calendar 

year 2002; 

b. 0.40 lb/MBtu, annual average, both units combined, if the exhaust gases from both 

units (one unit controlled, one unit not controlled) are discharged through a new 

common flue, effective only in calendar year 2002; 

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c. If both units have 802 control technology installed by December 31, 2001, the / 

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emission limits.in Item 30 shall be effective m calendar year 2002 .and beyond; 

The emission limits in Item 30 shall be effective in calendar ye&- 2003 and 

beyond. 

THAT, for good cause, SWAPCA may, at its discretion and after meeting any public 

involvement requirements under SWAPCA 400-171 and any other applicable law or 

regulation, modifY the NOx emissions limitations of this 0r4er. Good cause may include, 

for example, higher NOx emissions than predicted by the manufacturer in the RACT 

submittal when operated in accordance with good industry practices or excessive boiler 

waterwall tube corrosion resulting from the installation and operation of the low NOx 

modifications. All causes resulting from installation of Level III low NOx technology 

shall be documented to SWAPCA no later than December 31, 2006, except excessive 

boiler waterwall tube corrosion which shall be documented to SWAPCA no later than 

December 31, 2008. A request to modifY the NOx conditions of this Order shall include 

an explanation of the reasons why the RACT NOx emissions limits established in this 

Order ~ot be met, why the reasons for such modification were beyond the control of 

the Centralia Plant, identification of ariy special operating conditions that may be the sole 

or principle reason for a modification, and what efforts were taken within the timelines 

specified above to avoid and/or mitigate the need for a modification. Nothing in this 

section shall be construed to limit S W APCA 's authority to revise this Order pursuant to 

Item 59 of this Order. 

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PARTICULATE MATTER 

34. THAT, emissions of front half particulate matter shall not exceed 0.010 .gr/dscf(Method 

5, or equivalent, front half only), as corrected to 7% 0 2, evaluated once per year for each 

stack (flue) by source testing effective after December 31, 2001. 

35. THAT, compliance with the grain loading limit shall be· based on an annual stack test 

using EPA Method j, or equivalent. The test method selected shall be consistent with 

the 802 control technology selected and shall be approp~ate. for the stack conditions 

existing for the selected 802 control technology (i.e., wet or dry stack and maximum 

temperature). Only the front half catch shall be used for compliance demonstration with 

this limit, however, the backhalf catch should continue to be performed to provide an 

indication of total (condensible and non-condensible) particulate matter emitted from the 

plant. 

36. THAT, the opacity of emissions shall be based on the continuous opacity monitoring 

system (COM8) if stack conditions allow accurate particulate matter readings without 

being adversely affected by moisture. Opacity shall not exceed 20% based on a 6-minute 

average, except for one 6-minute period per hour of not more than 27% opacity. See 40 

CFR 60.42a(b ). In addition, visible emissions as determined by a Certified Observer shall 

not exceed 20% opacity for more than 3 minutes in any one hour period as provided in 

SW APCA 400-040( 1 ). Both standards for opacity determination apply. If moisture is 

present in the gas stream to the extent that it interferes with the COMS providing accurate 

opacity data, then visual observations using EPA Method 9 shall be performed a 

minimum of once per quarter to demonstrate compliance. 

37. THAT, the particulate matter and opacity emission limits shall apply at all times but are 

excused for startup and shutdown, and may be excused for periods of malfuncti.on or 

Page 21 SWAPCA 97-2057R I 
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1 upset consistent with S\:V APCA 400-107. In addition, opacity exceedances shall be 

2 allowed during periods of manual precipitator rapping and are excused under SW APCA 

3 400-1 07(5). Such opacity exceedances shall be reported to SW APCA no later than the. 

4 next business day and shall be noted in the quarterly report. 

5 38. THAT, during startup and shutdown of the Centralia Plant boilers for phmned or forced 

6 unit outages, emissions control equipment shall be operated to minimize overall 

7 emissions,. except to. the extent equipment operation will cause degradation of its long- . ' . 

8 term performance. Exceedances of the normal operation particulate matter and opacity 

9 limitations are excused under WAC 173-400-107(4) and SWAPCA 400-107(4) during j 

10 startup and shutdown when the electrostatic precipitators (ESPs) and S02 emission·control 

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11 system(s) are out of service. The shutdown period begins when the ESP temperature ...J 

2 drops to the critical ESP de-energize temperature, 220°F. When the critical temperature 

13 is attained; first the S02 control system, and then the ESPs are taken out of service. The 

14 startup period begins when fuel is introduced into a boiler with the intent of raising its 

15 temperature to operating conditions. The ESPs are energized when they reach operational ' .....! 

16 temperature. The S02 control syst~(s) is(are) placed in service following ESP 

17 stabilization. The startup period ends when the earlier of the two operating events below 

18 occurs: 

19 a. Opacity in the gas path downstream of both ESPs has stabilized below 10% for 

20 30 minutes (five consecutive 6-minute periods); or 

21 b. 8 hours have elapsed after the startup unit is synchronized to be electrically on22 line. 

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CARBON MONOXIDE 

39. THAT, emissions of carbon monoxide·shall not exceed 200 ppm on an annual average 

(calendar year), combined. This emission limit is effective after December 31, 2001. 

40. THAT, compliance with the carbon monoxide emission concentration limit shall be 

determined annually using existin~ plant operating· data to identify average CO 

concentrations: For information purpose~, year-to-date average carbon monoxide 

concentrations shall be calculated .and reported quarterly. ~lant operating data collected 

by the CO monitors shall be validated once per year, for each stack (flue), by .source 

testing, using EPA Method 10, to confirm the representativeness of the CO monitor data. 

PROJECT MILESTONES 

41. THAT, to the extent applicable to the control technology selected, the following project 

milestones shall be met through reporting of progress to SW APCA: 

a. Demonstration of initial progress to install S02 air pollution control facilities shall 

be submitted by November 1, 1998. Initial progress may include, but is not 

limited to: engineering work, agreements to proceed with construction, contracts 

to purchase or contracts for construction of air pollution control facilities. 

b. A procurement contract for the first unit S02 emission control system(s) shall be 

awarded no later than March 31, ·1999. 

c. Commencement of physical onsite construction activity for the first unit S02 

emission control system(s) shall commence no later than August 31, 1999. 

d. A procurement contract for the second unit S02 emission control system(s) shall 

be awarded no later than March 31, 2000. 

e. Commencement of physical onsite construction activity for the second unit S02 

emission control system(s) shall commence no later than August 31, 2000. 

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ComJl!encement of startup testing of 802 control equipment for the first unit shall , 1 . ..........,., f. 

occur no later than October 31, 2001 and the second unit by no later than October 

31, 2002. Startup testing is considered to be the initiation of flue gas through the 

802 control system. 

g. The 802 control system shall be installed and fully operational for the first unit 

no later than· December 31, 2001 and for the second unit no later than December 

31, 2002. 

h. A procurement contract for the first unit NOx emission control system(s) shall be 

awarded no later than October 31, 2000. The second unit NOx emission control 

system(s) shall be awarded no later than October 31, 2001. 

i. Commencement of physical onsite construction activity for the first unit NOx 

emission control system(s) shall commence no later than August 31, 2001. 

Commencement of physical onsite construction activity for the second unit NO._ 

emission control system(s) shall commence no later than August 31, 2002. 

J. NOx control equipment startup testing shall be commenced no later than October 

31, 2001 and October 31, 2002, for the first and second units, respectively. 

k. The NOx controls shall be installed and fully operational for the first unit no later 

than December 3 1, 2001 and for the second unit no later than December 31, 2002. 

RECORDKEEPING AND REPORTING 

THAT, a comprehensive test plan shall be submitted to SWAPCA for revxew and 

approval at least five business days prior to performance of any periodic testing beyond 

CEMS monitoring required in this Order. S W APCA shall be notified at least three days 

in advance of any testing so that personnel may be present during testing. A minimum 

of three test runs shall be performed at a minim~m ·of 500 MW gross to establish that 

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collected data is representative of normal operation. Compliance shall be determined by 

·averaging the results of individual test runs. The results of required emissions testing 

shall be provided to 8W APCA by no later than 45 days followirig completion of testing.· 

All gaseous emissions shall, as a minimum, be reported in parts per million by volume, 

pounds per hour, and pounds per million Btu of heat input. Emissions data shall be 

reported as corrected to 7% 0 2• The test report shall include a summary of operating 

conditions for each test run to include, as a minimum: ~ l) estimated heat input into 

furnace (MBtulhr), (2) estimated fuel' consumption rate Oblhr), (3) air discharge flowrate 

in dry standard cubic feet, ( 4) exhatist temperature of emissions out the stack, (5) 

estimated sulfur content of coal, (6) estimated 802 reduction in percent, as a result of 

controls, and (7) unit load in megawatts on an hourly basis. Initial source testing of the 

so2 control system shall be completed no later than 90 days after demonstration of 

successful operation of that 802 technology. 

43. . THAT, Respondent shall submit quarterly emission reports by no later than the end ofthe 

month following the end of each calendar quarter of the calendar year. These reports 

shall contain, as a minimum, the following information: 

a. Total·gallons of fuel oil burned in each boiler (Boiler # 1, Boiler #2 and auxiliary 

boiler) and certification of sulfur content in fuel oil; 

b. Information required under 40 CFR 75; 

c. CEMS/DAHS data for NO, and S02 corrected to the units of measure and 

averaging times, including rolling averages, consistent with the emission limits 

established by this Order and applicable federal requirements. The date, time and 

measured oxygen content in percent shall be provided for each reported hourly 

value; 

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Quarterly average CO concentrations for each boiler; 

Quarterly opacity excess emissions over 20%, if opacity monitoring is possible 

under stack conditions,. otherwise report results of quarterly Method 9 test;. 

Year to date tot:S.Is for S02 emissions and average NOx emission rate for Units #1 

and #2 under all operating conditions; and 

Estimated monthly average fuel heating values (Btullb) for coal burned in Boiler 

#1 and Boiler #2 to assist with periodic complianc~ checks. 

HSB 1257 TAX ABATEMENT REQUIREMENTS. 

THAT~ Respondent shall report progress to SW APCA on meeting the requirements of 

House Substitute Bill (HSB) 1257 annually by June 1 of each year during the construction 

period of the so2 control equipment (both units) and then monthly after the so2 control 

equipment is operational. Such report shall contain sufficient data and/or documentation 

to demonstrate compliance with HSB 1257 for tax abatement purposes. 

VOLUNTARY EMISSION LIMIT 

THAT, the total annual fuel oil combusted in the auxiliary boiler shall not exceed 600,000 

gallons per year. Consumption shall be reported quarterly to SW APCA. The auxiliary 

boiler shall have a separate fuel meter to monitor the total amount of fuel it consumes in 

that boiler. Emissions of S02 from the auxiliary boiler shall be included in the 10,000 

tons per year emission limit of Item 18. Emissions shall be calculated based on fuel 

consumption and fuel sulfur content. 

GENERAL PROVISIONS 

THAT, the owners of the Centralia Plant shall have sole discretion to select the control 

technology which complies with the emission limitations herein specified. 

Page 26. SWAPCA 97-2057RI 

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51. 

THAT, any physical changes of the boilers and draft systems, including fans for the 

purpose of installing NOx and S02 emissions control equipment, will'not trigger New 

Source Performance Standards (NSPS) or BACT/PSD under New Source Review as a 

modification per 40 CFR 60.14(e), WAC 173-400-110, or SWAPCA 400-110. Any 

physical changes associated with the installation ofpolbition controls to meet the emission 

limitations of this Order shall not be major modifications because such changes are 

exempted for electric utility boilers in 40 CFR 52.21(b)(2)(iii)(h) from the Prevention of 

Significant Deterioration (l>SD) program under WA,C 173-400-141, SWAPCA 400-141, 

and 40 CFR 51 Subpart I and 40 CFR 52.21. 

THAT, at all times, including periods of startup, shutdown, and malfunction, the plant 

shall, to the extent practicable, maintain and operate air pollution control equipment in 

a manner consistent w.ith good air pollution control practice for minimizing emissions. 

Determination of whether acceptable operating and maintenance procedures are being used 

will be based on information available to SW APCA which may include, but is not limited 

to, monitoring. results, review of operating and maintenance procedures and records, and 

inspection of the source. 

THAT, the emission limits and conditions of this Order supersede all previously issued 

Regulatory Orders including SWAPCA 90-934E. 

THAT, the Centralia Plant shall submit an annual emission inventory to SWAPCA in 

accordance with SWAPCA 400-105. 

THAT, this RACT Regulatory Order is subject to SWAPCA's authority to review and 

revise this Order pursuant to RCW 70.94. I 53 and 70.94.154 and shall not limit 

SWAPCA's authority under RCW 70.94 or other applicable federal and state laws and 

regulations. 

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THAT, if any provision of this Regulatory Order shall be declared invalid by any court .........._,( 

of competent jurisdiction, . all unaffected . provisions shall remain m effect and be j 

enforceable. 

THAT, for the purpose of ensuring compliance with this Regulatory Order, duly 

au$orized representatives of the Southwest Air Pollution Control Authority shall be 

permitted access to Respondent's premises and the facilities being constructed, owned, 

operated and/or maintained by Respondent duritig regul~ ~usiness hotirs for the purpose 

of inspecting said facilities. These inspections are required to determine the· status of 

compliance with the terms of this Regulatory Order. 

THAT, the provisions, terms and conditions of this Regulatory Order shall be ·deemed to 

bind Respondent, its. officers, directors, agents, servants, employees, successors and 

assigns, and all persons, firms and corporations under or for it. 

THAT, the requirements of this Order shall survive any transfer of ownership of the 

Centralia Plant or any portion thereof. 

THAT, this Order does not supersede requirements of other agencies with jurisdiction and 

further, this Order does not relieve Respondent of any requirements of any other 

governmental agency. In addition to this Order, Respondent may be required to obtain 

other permits. or approvals from other Agencies with jurisdiction. 

THAT, compliance with this Order and its requirements does not relieve the Respondent 

from responsibility of compliance with Southwest Air Pollution Control Authority General 

Regulations for Air Pollution Sources, RCW 70.94, WAC Title 173 or any other 

applicable air contaminant emission control requirements, nor from the resulting liabilities 

and/or legal remedies for failure to comply. 

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rI "'-..,' 1 58. THAT, the Centralia Plant shall provide annual written certification that the requirements 

- 2 of this R~atory Order have been met. Certification of truth, accuracy and 

,... 3 completeness shall be provided by a responsible official, as defmed in WAC 173-401 

4 ~Operating Permit Regulation", andshall be su.bmitted with each report. This certification 

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5 shall state that, "based on the information and belief formed after reasonable inquiry, the 

- 6 statements and informa?on in the report· are true, accurate and complete." 

7 59. THAT, for good cause shown, SWAPCA may, in its disc;etion and after meeting any 

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8 public. involvement requirements under SWAPCA 400-171 and any other applicable law 

,.. 9 . or regulation, modify or stay the project milestones, effective dates, or Order .. A request 

10 to modify or stay the project milestones, effective dates, or Order should include an 

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11 explanation of the reasons why the current project milestones, effective dates, or Order 

r 12 cannot be met, whether the reasons for the modification or stay were beyond the control 

13 of the Centralia Plant, what efforts were taken to avoid and/or mitigate the need for a 

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14 modificatio11 or stay, and a proposed schedule that can be met. 

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60. THAT, this Order, once signed and issued, may be appealed pursuant tQ RCW 

43.21B.230 .. An appeal must be filed with the Pollution Control Hearings Board (PCHB) 

at PO Box 40903, ·olympia, WA 98504-0903, and shall be served on SW APCA within 

thirty (30) days from the date of the notice of this Order. This Order may also be 

appealed as provided in SW APCA 400-250. 

DATED this 26th day of February, 1998. 

Reviewed by:~~~ 

Paul T. Mairose, P .E. 

Chief Engineer 

Approved by: ---=~=-:::::...;;--=-· _..:...•;___~_....;._· .....;__ ___ _ 

Robert D. Elliott 

Executive Director 

Southwest Air Pollution Control Authority 

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