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Preliminary Drafts – Serious SIP Development

The Alaska Department of Environmental Conservation (ADEC) is providing preliminary drafts of the following documents for public discussion. Please note the Preliminary Draft Step in the simplified State Implementation Plan (SIP) development and opportunities for public input below. These documents are a work in progress. DEC hopes to receive additional information from the public due to the release of the preliminary draft documents and expects to make changes to documents based upon this input. It is likely that the version of these documents released for formal public comment as part of the draft Serious SIP will have changes.

Important Points

  • No decisions yet, no regulations in this package
  • Very early in the SIP Development
  • Broad look at all possible measures for all sources
  • Looking for additional data from Point Sources, Businesses, and Public
  • Seeking additional data to assist in the overall analysis of the economic impacts and overall benefits of controls
  • Work continues on assessing possible solutions and how the area can achieve attainment
  • Additional information, to assist in completing the documents, may be submitted to: until May 23, 2018.

(Select image for larger view - PDF)

These documents, once finalized, will be used to produce the SIP for the Fairbanks North Star Borough (FNSB) Serious nonattainment area:

  1. Preliminary Draft Concepts and Approaches
  2. Preliminary Draft Baseline Emission Inventory
  3. Preliminary Draft Technical Analysis Protocol (TAP)
    1. Preliminary Draft Modeling Protocol
  4. Preliminary Draft Precursor Demonstrations
  5. Preliminary Draft Best Available Control Technology (BACT)/Most Stringent Measure (MSM) Analysis for Stationary Sources in the affected area
  6. Preliminary Draft Best Available Control Measure (BACM) Analysis for sources in the affected area
    1. Preliminary Draft: “Residential Fuel Expenditure Assessment of a Transition to Ultra-Low Sulfur Heating Oil for the Fairbanks PM2.5 Serious Nonattainment Area”

The Environmental Protection Agency (EPA) reclassified the Fairbanks North Star Borough nonattainment area as a Serious Area with an effective date of June 9, 2017. Reclassification requires an update to the SIP to meet additional requirements that were triggered upon the reclassification. The preliminary draft documents are based upon information submitted to or obtained by ADEC to date. Some of the documents fulfill explicit EPA requirements for a Serious Area SIP while others are optional supporting materials.

ADEC is releasing preliminary drafts as an opportunity for additional data and information collection. Additional information that could assist in the finalization of the preliminary drafts is appreciated and may be incorporated into the final drafts. Individuals with additional information are encouraged to submit by sending to: by May 23, 2018. Preliminary drafts are outside the formal public review process and therefore, there will be no formal responsiveness summary or hearing. Substantive information received may be included in the appendices, in final drafts, and cited where appropriate.

The following overview provides a brief summary of each of the documents, their importance to the Serious SIP, and initial approaches and concepts ADEC is considering.

Final drafts will be released as part of the formal public review process when the full Serious SIP is released later in 2018.

NOTE: DEC does not expect that all of the various ideas and measures presented will be part of the final plan, but it is important to open the dialogue with the full range of options. Also, there is no preliminary information completed yet on: economic analysis of control measures outside what is presented for #5 and #6a, emission benefits for control measures, modeling, or attainment scenarios.

Draft Concept and Approaches

The Draft Concept and Approaches document provides an initial view of how the information included in the various preliminary drafts may be used in the development of the Serious SIP. It provides an overview of how the data could be used over the entire nonattainment area.

  1. Draft Baseline Emission Inventory

    The Draft Baseline Emission Inventory preliminary document is the technical document that will ultimately reside in the SIP emission inventory appendix and will be used to update the SIP Emission Inventory chapter to meet the Serious Area requirements.

    The baseline inventory is an important product as it identifies the sources of particulate matter that are under 2.5 micrograms in size (PM2.5) and its precursors. It also quantifies source contributions to emitted PM2.5 and precursors and is the first step in the development of control strategies. This baseline inventory and subsequently-developed inventories reflecting these control strategies will be used for air quality modeling to assess attainment in the SIP.

  2. Draft Technical Analysis Protocol

    The Draft Technical Analysis Protocol (TAP) provides an overview and outline of the technical analyses required for the development of the Serious SIP. Included in the TAP are the methods used to the complete technical requirements as well as the identification of any unresolved issues. This is a living document that is updated over the course of the Serious SIP and there are a number of sections that are still in development.

    Several sections of the Draft Technical Analysis Protocol serve as a Draft Modeling Protocol which provide draft documentation of all models used for the attainment demonstration. This includes details on the model version, configuration, development of inputs, and any updates made for the Serious SIP. The draft updated modeling protocol is also used in the development of supplemental analysis outside of the attainment demonstration including the Precursor Demonstrations.

  3. Draft Precursor Demonstrations

    The Draft Precursor Demonstrations document summarizes an optional analysis that identifies those precursors which are not significant and therefore not required to be controlled as part of the Serious SIP. This element of the SIP adheres to EPA’s draft precursor guidance. Precursor demonstrations can be conducted for all sources or specifically for major stationary sources. A successful precursor demonstration for all sources means that controls for that precursor from both stationary and non-stationary sources need not be applied. A successful demonstration for only the major stationary sources means that only those controls for major stationary sources can be excluded. The four main precursor gases that can be included in a precursor demonstration are: Nitrogen oxides (NOx), Sulfur dioxide (SO2), Ammonia (NH3), Volatile Organic Carbons (VOCs). If a pollutant is deemed to pass the precursor demonstration for all sources then ADEC would propose to not implement BACT/BACM or MSMs for that precursor. If a pollutant is deemed to pass only the major stationary source demonstration then ADEC would propose to not implement BACT or major stationary source or MSMs for that precursor.

  4. Draft Best Available Control Technology (BACT) Analysis – Stationary Sources

    Stationary sources that have a potential to emit over 70 tons per year (tpy) of either direct PM2.5 or a precursor must undergo a BACT analysis. This analysis identifies all the potential control technologies for each source based upon their specific types of equipment and determines a cost per ton and an efficiency rate. Based on the analysis, ADEC must determine what control strategies to require that are technologically and economically feasible for the area and still meet the intent of EPA requirements for BACT and Most Stringent Measure (MSM).

Aurora Energy, LLC. ‐ Chena Power Plant Documents U.S. Army Fort Wainwright Garrison and Doyon Utilities LLC. ‐ Fort Wainwright Documents GVEA ‐ North Pole Power Plant Documents GVEA ‐ Zehnder Facility Documents UAF ‐ Campus Power Plant Documents
Preliminary Draft BACT Analysis-Chena Power Plant (PDF) Preliminary Draft BACT Analysis-Fort Wainwright (PDF) Preliminary Draft BACT Analysis-North Pole (PDF) Preliminary Draft BACT Analysis-Zehnder Facility (PDF) Preliminary Draft BACT Analysis-UAF (PDF)
Preliminary Draft-Chena Large Boiler SO2 Economic Analysis-ADEC (XLSM) Preliminary Draft-Fort Wainwright SCR Economic Analysis-ADEC (XLSM) Preliminary Draft-North Pole Sect 3 NOx (XLSM) Preliminary Draft-Zehnder SCR Water Injection Economic Analysis-ADEC (XLSM) Preliminary Draft-UAF EU3 LNB Economic Analysis-ADEC (XLSM)
Preliminary Draft-Chena SCR Economic Analysis-ADEC (XLSM) Preliminary Draft-Fort Wainwright SNCR Economic Analysis-ADEC (XLSM) Preliminary Draft-North Pole Sect 4 PM (XLSM) Preliminary Draft-Zehnder ULSD Economic Analysis-ADEC (XLSM) Preliminary Draft-UAF EU3 SCR Economic Analysis (XLSM)
Preliminary Draft-SNCR Economic Analysis-ADEC (XLSM) Preliminary Draft-Fort Wainwright SO2 Economic Analyses-ADEC (XLSM) Preliminary Draft-North Pole Sect 5-SO2 (XLSM)   Preliminary Draft-UAF SNCR Economic Analysis-ADEC (XLSM)
Preliminary Draft-SO2 Economic Analyses-ADEC (XLSM)        
  1. Draft Best Available Control Measure (BACM) Analysis

    Every control measure included in a State Implementation Plan (SIP) anywhere in the United States to control PM2.5 and its precursors must be reviewed for technical and economic feasibility. The BACM analysis has reviewed control programs from 29 separate communities and evaluated the technological feasibility of 71 separate measures. Those measures determined to be technologically feasible will be analyzed for economic feasibility and evaluated for implementation timing. The results of the analysis will ultimately assist the FNSB Assembly and ADEC in developing regulations for the Serious SIP and additional control measures for the area.

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