# Appendix 9.4

Guidance for Facilities Conducting a BART Analysis

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# Guidance for Facilities Conducting a BART Analysis

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This is a guidance document only. It does not have the force and effect of a rule and is not intended to supersede statutory and regulatory requirements. Questions on the guidance or the BART analysis process should be add ressed to KDHE early on. This guidance is for facilities performing a BART a nalysis. In June 2006, KDHE will be sending letters notifying facilities if they must c omplete a BART analysis. KDHE will use modeling to determine which units contribute to vis ibility impairment in a Class I area and are therefore “subject to BART.” Facilities wi th emission units that are subject to BART are requested to complete a BART analysis by J anuary 1, 2007. Section IV of EPA’s “Guidelines for BART Determinat ions under the Regional Haze Rules” [40 CFR Part 51, Appendix Y] is reprinted be low. EPA’s Guidelines were written for States to use in making BART determinations; however, KDH E is asking facilities to follow these Guidelines in completing their individ ual BART analyses. KDHE has inserted notes (in shaded areas) into the Guidelines text below to clarify expectations for your BART analysis. KDHE will use the analysis to make the actual BART determination, subject to EPA approval. In each step of the analysis, please clearly docume nt your rationale, data sources, etc.

IV. The BART Determination: Analysis of BART Option s **This section describes the process for the analysis of control options for sources subject to BART.** 

A. What factors must I address in the BART review?
**The visibility regulations define BART as follows:**
Best Available Retrofit Technology (BART) **means an emission limitation based on the degree o f reduction**  **achievable through the application of the best syst em of continuous emission reduction for each pollut**  **ant which is emitted by . . . [a BART-eligible source]. The emis**  **sion limitation must be established on a case-by-ca se basis, taking**  **into consideration the technology available, the co sts of compliance, the energy and non-air quality e**  **nvironmental impacts of compliance, any pollution control equipm**  **ent in use or in existence at the source, the remai ning useful life**  **of the source, and the degree of improvement in vis ibility which may reasonably be anticipated to resu**  **lt from the use of such technology.** 
**The BART analysis identifies the best system of con tinuous emission reduction taking into account:** 
**(1) The available retrofit control options,**
**(2) Any pollution control equipment in use at the s ource (which affects the availability of options an**  **d their impacts),** 
**(3) The costs of compliance with control options,**
**(4) The remaining useful life of the facility,**
**(5) The energy and non-air quality environmental im pacts of control options** 

## Page 3 3/31/2008 **(6) The visibility impacts analysis.**
B. What is the scope of the BART review?
**Once you determine that a source is subject to BART for a particular pollutant, then for each affected**  **emission unit, you must establish BART for that pollutant. The BAR**  **T determination must address air pollution control measures for**  **each emissions unit or pollutant emitting activity subject to review.** 
Example: **Plantwide emissions from emission units within t he listed categories that began operation within**  **the “time window” for BART 11**  **are 300 tons/yr of NO x**  **, 200 tons/yr of SO 2**  **, and 150 tons/yr of primary particulate. Emissions unit A emits 200 tons/yr of**  **NO x**  **, 100 tons/yr of SO 2**  **, and 100 tons/yr of primary particulate. Other emission units, units B through**  **H, which began operating in 1966, contribute lesser amounts of each pollutant. For this example, a BART**  **review is required for NO x**  **, SO 2**  **, and primary particulate, and control options must be analyzed f**  **or units B through H as well as unit A.**

**11 That is, emission units that were in existence on**  **August 7, 1977 and which began actual operation on or**  **after August 7, 1962.**

C. How does a BART review relate to Maximum Achieva ble Control Technology (MACT) Standards under CAA section 112, or to other emission limitations r equired under the CAA?
**For VOC and PM sources subject to MACT standards, S tates may streamline the analysis by including**  **a discussion of the MACT controls and whether any m ajor new technologies have been developed**  **subsequent to the MACT standards. We believe that t here are many VOC and PM sources that are well**  **controlled because they are regulated by the MACT s tandards, which EPA developed under CAA**  **section 112. For a few MACT standards, this may als o be true for SO**  **2 . Any source subject to MACT**  **standards must meet a level that is as stringent as the best-controlled 12% of sources in the industry** 

**. Examples of these hazardous air pollutant sources w**  **hich effectively control VOC and PM emissions include (among others) secondary lead facilities, o**  **rganic chemical plants subject to the hazardous organic NESHAP (HON), pharmaceutical production fac**  **ilities, and equipment leaks and wastewater operations at petroleum refineries. We believe that**  **, in many cases, it will be unlikely that States wi ll**  **identify emission controls more stringent than the MACT standards without identifying control options**  **that would cost many thousands of dollars per ton. Unless there are new technologies subsequent to**  **the MACT standards which would lead to cost-effecti ve increases in the level of control, you may rely**  **on the MACT standards for purposes of BART.** 

**We believe that the same rationale also holds true for emissions standards developed for municipal was**  **te incinerators under CAA section 111(d), and for many** **NSR/PSD determinations and NSR/PSD settlement agreements. However, we do not believe that technol**  **ogy determinations from the 1970s or early 1980s, i ncluding**  **new source performance standards (NSPS), should be considered to represent best control for existing s**  **ources, as best control levels for recent plant retrofits are**  **more stringent than these older levels.**
**Where you are relying on these standards to represe nt a BART level of control, you should provide the**  **public with a discussion of whether any new technologies have sub**  **sequently become available.**

**KDHE note: As recommended above, KDHE intends to st reamline the analysis of PM and VOC sources subject**  **to MACT standards in a BART analysis. KDHE will rely**  **on MACT standards to represent BART level of contro l for**  **those visibility-impairing pollutants addressed by the MACT standard. For example, if a BART-eligible**  **emissions unit emits PM**  **10 and NO**  **x and the unit is subject to a MACT limit for PM**  **10 , then a full BART analysis need only**  **address NO x**  **. If you have a BART eligible unit(s) emitting visibi**  **lity-impairing pollutants that are addressed by a M ACT standard(s),**  **then please list that unit(s) or groups of units in the BART analysis. Please include the MACT standa**  **rd and the limit, in lbs/day, imposed on the unit(s). KDHE will eval**  **uate the unit(s) and MACT standard to see if furthe r analysis is**  **needed of those unit(s) for that visibility-impairi ng pollutant.**  **If you believe that recent application of a BACT or NSPS standard represents BART for an emission unit**  **, please consult with KDHE staff early in the BART analysis**  **process for further guidance on the expected level of analysis.** 

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D. What Are the Five Basic Steps of a Case-by-Case B ART Analysis?
**The five steps are:**
**STEP 1—Identify All 12**  **Available Retrofit Control Technologies,**

**12 In identifying “all” options, you must identify th**  **e most stringent option and a reasonable set of opt ions**  **for analysis that reflects a comprehensive list of available technologies. It is not necessary to list**  **all permutations of available control levels that exist**  **for a given technology—the list is complete if it includes**  **the maximum level of control each technology is cap able of achieving.** 
**STEP 2— Eliminate Technically Infeasible Options,**
**STEP 3— Evaluate Control Effectiveness of Remaining Control Technologies,** 
**STEP 4— Evaluate Impacts and Document the Results, and** 
**STEP 5—Evaluate Visibility Impacts.**
1. STEP 1: How do I identify all available retrofit emission control techniques?
**1. Available retrofit control options are those air pollution control technologies with a practical po**  **tential for application to the emissions unit and the regulated pollutant u**  **nder evaluation. Air pollution control technologies can include a**  **wide variety of available methods, systems, and tec hniques for control of the affected pollutant. Tech**  **nologies required as BACT or LAER are available for BART pur**  **poses and must be included as control alternatives. The**  **control alternatives can include not only existing controls for the source category in question but al**  **so take into account technology transfer of controls that have b**  **een applied to similar source categories and gas st reams.**  **Technologies which have not yet been applied to (or permitted for) full scale operations need not be c**  **onsidered as available; we do not expect the source owner to pur** **chase or construct a process or control device that has not**  **already been demonstrated in practice.**
**2. Where a NSPS exists for a source category (which is the case for most of the categories affected by**  **BART), you should include a level of control equivalent to the**  **NSPS as one of the control options. 13** **The NSPS standards are codified in 40 CFR part 60. We note that there are**  **situations where NSPS standards do not require the most**  **stringent level of available control for all source s within a category. For example, post-combustion N**  **O x**  **controls (the most stringent controls for stationary gas turbines**  **) are not required under subpart GG of the NSPS for Stationary**  **Gas Turbines. However, such controls must still be considered available technologies for the BART sele**  **ction process.** 

**13 In EPA's 1980 BART guidelines for reasonably attri**  **butable visibility impairment, we concluded that NS PS**  **standards generally, at that time, represented the best level sources could install as BART. In the 20**  **year period since this guidance was developed, there hav**  **e been advances in SO 2**  **control technologies as well as technologies for the control of other pollutants**  **, confirmed by a number of recent retrofits at West ern**  **power plants. Accordingly, EPA no longer concludes that the NSPS level of controls automatically**  **represents “the best these sources can install.” An alysis of the BART factors could result in the sele**  **ction of a NSPS level of control, but you should reach this**  **conclusion only after considering the full range of control**  **options.**
**3. Potentially applicable retrofit control alternat ives can be categorized in three ways.** 
**• Pollution prevention: use of inherently lower emi tting processes/practices, including the use of con**  **trol techniques (**  e.g., **low-NO x**  **burners) and work practices that prevent emissions and result in lower**  **“production-specific” emissions (note that it is no t our intent to direct States to switch fuel forms,**  e.g., **from coal to gas);** 

## Page 5 3/31/2008 **• Use of (and where already in place, improvement i n the performance of) add-on controls, such as**  **scrubbers, fabric filters, thermal oxidizers and ot her devices that control and reduce emissions after**  **they are produced; and** 
**• Combinations of inherently lower-emitting process es and add-on controls.** 

Pollutant Description Comments **SCR IFGR Burners**  **Low-NO x**  **burners Including ultra-low NO x**  **burners Ported Kiln Only for rotary kilns**  Control Technologies:

**LoTOx NO**  **x CEM Also investigate other**  **forms of monitoring to ensure combustion**  **efficiency** NO x

Work Practices/

Operational Changes:

**Alternative fuels Evaluate use of biomass as fuel**  **High efficiency wet scrubber (> 90%**  **removal) Low efficiency wet scrubber (>**  **50% removal)**  Control Technologies:

**Lime/limestone wet slurry scrubbing Look at various alternatives to enhance**  **SO 2**  **collection efficiency of existing wet scrubbers**  SO 2

Work Practices/

Operational Changes: **Alternative fuels**

**4. In the course of the BART review, one or more of the available control options may be eliminated fr**  **om consideration because they are demonstrated to be t**  **echnically infeasible or to have unacceptable energ y, cost, or**  **non-air quality environmental impacts on a case-by- case (or site-specific) basis. However, at the outs**  **et you should identify all control options with potential applica**  **tion to the emissions unit under review.**
**5. We do not consider BART as a requirement to rede sign the source when considering available control**  **alternatives. For example, where the source subject to BART is a coal-fired electric generator, we do**  **not require the BART analysis to consider building a natural gas-fi**  **red electric turbine although the turbine may be in herently less**  **polluting on a per unit basis.**
**6. For emission units subject to a BART review, the re will often be control measures or devices alread**  **y in place. For such emission units, it is important to include con**  **trol options that involve improvements to existing controls and not**  **to limit the control options only to those measures that involve a complete replacement of control dev**  **ices.**
Example: **For a power plant with an existing wet scrubber, the current control efficiency is 66%. Part of the**  **reason for the relatively low control efficiency is that 22% of the gas stream bypasses the scrubber.**  **A BART review identifies options for improving the pe**  **rformance of the wet scrubber by redesigning the internal components of the scrubber and by eliminat**  **ing or reducing the percentage of the gas stream th at**  **bypasses the scrubber. Four control options are ide ntified: (1) 78% control based upon improved scrubb**  **er performance while maintaining the 22% bypass, (2) 8**  **3% control based upon improved scrubber performance while reducing the bypass to 15%, (3) 9**  **3% control based upon improving the scrubber performance while eliminating the bypass entirely,**  **(this option results in a “wet stack” operation in which the**  **gas leaving the stack is saturated with water) and (4) 93% as in option 3, with the addition of an ind**  **irect reheat system to reheat the stack gas above the sat**  **uration temperature. You must consider each of thes e** 

## Page 6 3/31/2008 **four options in a BART analysis for this source.**
**7. You are expected to identify potentially applica ble retrofit control technologies that represent th**  **e full range of demonstrated alternatives. Examples of general info**  **rmation sources to consider include:**
**• The EPA's Clean Air Technology Center, which incl udes the RACT/BACT/LAER Clearinghouse (RBLC);** 
**• State and Local Best Available Control Technology Guidelines—many agencies have online information—**  **for example South Coast Air Quality Management Dist rict, Bay Area Air Quality Management District, and**  **Texas Natural Resources Conservation Commission;**
**• Control technology vendors;**
**• Federal/State/Local NSR permits and associated in spection/performance test reports;** 
**• Environmental consultants;**
**• Technical journals, reports and newsletters, air pollution control seminars; and** 

**• The EPA's NSR bulletin board—** http://www.epa.gov/ttn/nsr;
**• Department of Energy's Clean Coal Program—technic al reports;** 

**• The NO x** 

**Control Technology “Cost Tool”—Clean Air Markets D ivision web page—**  http://www.epa.gov/airmarkets/arp/nox/controltech.h tml;
**• Performance of selective catalytic reduction on c oal-fired steam generating units—final report. OAR/** **ARD, June 1997 (also available at**  http://www.epa.gov/airmarkets/arp/nox/controltech.h tml **);**
**• Cost estimates for selected applications of NO x**  **control technologies on stationary combustion boil ers.**  **OAR/ARD June 1997. (Docket for NO x**  **SIP Call, A–96–56, item II–A–03);**
**• Investigation of performance and cost of NO x**  **controls as applied to group 2 boilers. OAR/ARD, A ugust**  **1996. (Docket for Phase II NO x**  **rule, A–95–28, item IV–A–4);**
**• Controlling SO 2**  **Emissions: A Review of Technologies. EPA–600/R–00– 093, USEPA/ORD/NRMRL,**  **October 2000; and**

**• The OAQPS Control Cost Manual.**
**You are expected to compile appropriate information from these information sources.** 
**8. There may be situations where a specific set of units within a facility constitutes the logical set**  **to which controls would apply and that set of units may or may not al**  **l be BART eligible. (For example, some units in tha t set may not**  **have been constructed between 1962 and 1977.)**
**9. If you find that a BART source has controls alre ady in place which are the most stringent controls**  **available (note that this means that all possible improvements to a**  **ny control devices have been made), then it is not necessary to**  **comprehensively complete each following step of the BART analysis in this section. As long these most**  **stringent controls available are made federally enforceable f**  **or the purpose of implementing BART for that source , you may**  **skip the remaining analyses in this section, includ ing the visibility analysis in step 5. Likewise, if**  **a source commits to a BART determination that consists of the most stri**  **ngent controls available, then there is no need to complete the**  **remaining analyses in this section.**

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**KDHE note: KDHE will consider on a case-by-case bas is whether a BACT determination or NSPS limit for a**  **particular pollutant at a BART-eligible unit satisf ies BART requirements. KDHE will take into account**  **the age of the BACT determination or NSPS limit, whether any new t**  **echnologies have subsequently become available (inc luding**  **work practices that reduce emissions), and the visi bility analysis that was performed for the BACT det**  **ermination. KDHE encourages facilities to consult with KDHE sta**  **ff during the development of their BART analysis if they believe**  **a BACT determination or NSPS limit represents BART and that no further analyses are required for a par**  **ticular visibility-impairing pollutant.** 

2. STEP 2: How do I determine whether the options i dentified in Step 1 are technically feasible?
**In Step 2, you evaluate the technical feasibility o f the control options you identified in Step 1. You**  **should document a demonstration of technical infeasibility and should**  **explain, based on physical, chemical, or engineeri ng principles,**  **why technical difficulties would preclude the succe ssful use of the control option on the emissions un**  **it under review. You may then eliminate such technically infeasible**  **control options from further consideration in the B ART analysis.** 
In general, what do we mean by technical feasibilit y?
**Control technologies are technically feasible if ei ther (1) they have been installed and operated succ**  **essfully for the type of source under review under similar condition**  **s, or (2) the technology could be applied to the so urce under**  **review. Two key concepts are important in determini ng whether a technology could be applied: “availabi**  **lity” and “applicability.” As explained in more detail below,**  **a technology is considered “available” if the sour ce owner may**  **obtain it through commercial channels, or it is oth erwise available within the common sense meaning of**  **the term. An available technology is “applicable” if it can reas**  **onably be installed and operated on the source type under**  **consideration. A technology that is available and a pplicable is technically feasible.** 
What do we mean by “available” technology?
**1. The typical stages for bringing a control techno logy concept to reality as a commercial product are**  **: • Concept stage,** 
**• Research and patenting,**
**• Bench scale or laboratory testing,**
**• Pilot scale testing,**
**• Licensing and commercial demonstration, and**

**• Commercial sales.**
**2. A control technique is considered available, wit hin the context presented above, if it has reached**  **the stage of licensing and commercial availability. Similarly, w**  **e do not expect a source owner to conduct extended trials to learn**  **how to apply a technology on a totally new and diss imilar source type. Consequently, you would not con**  **sider technologies in the pilot scale testing stages of d**  **evelopment as “available” for purposes of BART revi ew.**  **3. Commercial availability by itself, however, is n ot necessarily a sufficient basis for concluding a**  **technology to be applicable and therefore technically feasible. Tech**  **nical feasibility, as determined in Step 2, also me ans a control**  **option may reasonably be deployed on or “applicable ” to the source type under consideration.** 
**Because a new technology may become available at va rious points in time during the BART analysis proce**  **ss, we believe that guidelines are needed on when a techno**  **logy must be considered. For example, a technology may**  **become available during the public comment period o n the State's rule development process. Likewise, i**  **t is possible**

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**that new technologies may become available after th e close of the State's public comment period and be**  **fore submittal of the SIP to EPA, or during EPA's review**  **process on the SIP submittal. In order to provide certainty in the**  **process, all technologies should be considered if a vailable before the close of the State's public com**  **ment period. You need not consider technologies that become avai**  **lable after this date. As part of your analysis, yo u should**  **consider any technologies brought to your attention in public comments. If you disagree with public co**  **mments asserting that the technology is available, you sho**  **uld provide an explanation for the public record as to the basis for**  **your conclusion.**
**KDHE note: For the purpose of the BART analysis, pl ease consider all available technologies as of the**  **date of submittal of the BART analysis. Please be aware, ho**  **wever, that any technologies that become available up to the**  **close of the State’s public comment period will be considered available.** 
What do we mean by “applicable” technology?
**You need to exercise technical judgment in determin ing whether a control alternative is applicable to**  **the source type under consideration. In general, a commercially ava**  **ilable control option will be presumed applicable i f it has been**  **used on the same or a similar source type. Absent a showing of this type, you evaluate technical feasi**  **bility by examining the physical and chemical characteristics**  **of the pollutant-bearing gas stream, and comparing them to the**  **gas stream characteristics of the source types to w hich the technology had been applied previously. De**  **ployment of the control technology on a new or existing source**  **with similar gas stream characteristics is generall y a sufficient**  **basis for concluding the technology is technically feasible barring a demonstration to the contrary as**  **described below.** 
What type of demonstration is required if I conclude that an option is not technically feasible?
**1. Where you conclude that a control option identif ied in Step 1 is technically infeasible, you should**  **demonstrate that the option is either commercially unavailable, or t**  **hat specific circumstances preclude its application to a particular**  **emission unit. Generally, such a demonstration invo lves an evaluation of the characteristics of the po**  **llutant-bearing gas stream and the capabilities of the technology.**  **Alternatively, a demonstration of technical infeasi bility may involve**  **a showing that there are unresolvable technical dif ficulties with applying the control to the source (**  e.g. **, size of the unit, location of the proposed site, operating prob**  **lems related to specific circumstances of the sourc e, space**  **constraints, reliability, and adverse side effects on the rest of the facility). Where the resolution**  **of technical difficulties is merely a matter of increased cost,**  **you should consider the technology to be technicall y feasible. The**  **cost of a control alternative is considered later i n the process.** 
**2. The determination of technical feasibility is so metimes influenced by recent air quality permits. I**  **n some cases, an air quality permit may require a certain level of c**  **ontrol, but the level of control in a permit is not expected to be**  **achieved in practice (** e.g. **, a source has received a permit but the project wa s canceled, or every operating source at**  **that permitted level has been physically unable to achieve compliance with the limit). Where this is t**  **he case, you should provide supporting documentation showing why**  **such limits are not technically feasible, and, the refore, why**  **the level of control (but not necessarily the techn ology) may be eliminated from further consideration**  **. However, if there is a permit requiring the application of a ce**  **rtain technology or emission limit to be achieved f or such**  **technology, this usually is sufficient justificatio n for you to assume the technical feasibility of th**  **at technology or emission limit.** 
**3. Physical modifications needed to resolve technic al obstacles do not, in and of themselves, provide**  **a justification for eliminating the control technique on the basis**  **of technical infeasibility. However, you may consid er the cost of**  **such modifications in estimating costs. This, in tu rn, may form the basis for eliminating a control te**  **chnology (see later discussion).** 
**4. Vendor guarantees may provide an indication of c ommercial availability and the technical feasibilit**  **y of a control technique and could contribute to a determination o**  **f technical feasibility or technical infeasibility, depending on**  **circumstances. However, we do not consider a vendor guarantee alone to be sufficient justification tha**  **t a control option will work. Conversely, lack of a vendor guar** **antee by itself does not present sufficient justifi cation that a**  **control option or an emissions limit is technically infeasible. Generally, you should make decisions a**  **bout technical feasibility based on chemical, and engineering anal**  **yses (as discussed above), in conjunction with info rmation about**  **vendor guarantees.**

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**5. A possible outcome of the BART procedures discus sed in these guidelines is the evaluation of multip**  **le control technology alternatives which result in essentially**  **equivalent emissions. It is not our intent to enco urage evaluation**  **of unnecessarily large numbers of control alternati ves for every emissions unit. Consequently, you sho**  **uld use judgment in deciding on those alternatives for whic**  **h you will conduct the detailed impacts analysis (S tep 4 below).**  **For example, if two or more control techniques resu lt in control levels that are essentially identical**  **, considering the uncertainties of emissions factors and other parame** **ters pertinent to estimating performance, you may e valuate only**  **the less costly of these options. You should narrow the scope of the BART analysis in this way only if**  **there is a negligible difference in emissions and energy and n**  **on-air quality environmental impacts between contro l**  **alternatives.**
3. STEP 3: How do I evaluate technically feasible a lternatives?
**Step 3 involves evaluating the control effectivenes s of all the technically feasible control alternati**  **ves identified in Step 2 for the pollutant and emissions unit under r**  **eview.**
**Two key issues in this process include:**
**(1) Making sure that you express the degree of cont rol using a metric that ensures an “apples to apple**  **s” comparison of emissions performance levels among op**  **tions, and**
**(2) Giving appropriate treatment and consideration of control techniques that can operate over a wide**  **range of emission performance levels.**
What are the appropriate metrics for comparison?
**This issue is especially important when you compare inherently lower-polluting processes to one anothe**  **r or to add on controls. In such cases, it is generally most ef**  **fective to express emissions performance as an aver age steady**  **state emissions level per unit of product produced or processed.** 
**Examples of common metrics:**

**• Pounds of SO 2**  **emissions per million Btu heat input, and**

**• Pounds of NO x** 

**emissions per ton of cement produced.**
**KDHE note: For EGUs, please provide emissions value s in units of pounds per million Btu heat input.** 
How do I evaluate control techniques with a wide ra nge of emission performance levels?
**1. Many control techniques, including both add-on c ontrols and inherently lower polluting processes, c**  **an perform at a wide range of levels. Scrubbers and high and low**  **efficiency electrostatic precipitators (ESPs) are t wo of the many**  **examples of such control techniques that can perfor m at a wide range of levels. It is not our intent t**  **o require analysis of each possible level of efficiency for a control**  **technique as such an analysis would result in a lar ge number of**  **options. It is important, however, that in analyzin g the technology you take into account the most str**  **ingent emission control level that the technology is capable of ach**  **ieving. You should consider recent regulatory decis ions and**  **performance data (** e.g. **, manufacturer's data, engineering estimates and th e experience of other sources) when**  **identifying an emissions performance level or level s to evaluate.** 
**2. In assessing the capability of the control alter native, latitude exists to consider special circums**  **tances pertinent to the specific source under review, or regarding the**  **prior application of the control alternative. Howev er, you should**  **explain the basis for choosing the alternate level (or range) of control in the BART analysis. Without**  **a showing of differences between the source and other sources th**  **at have achieved more stringent emissions limits, y ou should**  **conclude that the level being achieved by those oth er sources is representative of the achievable leve**  **l for the source being analyzed.** 

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**3. You may encounter cases where you may wish to ev aluate other levels of control in addition to the m**  **ost stringent level for a given device. While you must consider t**  **he most stringent level as one of the control optio ns, you may**  **consider less stringent levels of control as additi onal options. This would be useful, particularly in**  **cases where the selection of additional options would have widely v**  **arying costs and other impacts.**
**4. Finally, we note that for retrofitting existing sources in addressing BART, you should consider way**  **s to improve the performance of existing control devices, particular**  **ly when a control device is not achieving the level of control that**  **other similar sources are achieving in practice wit h the same device. For example, you should consider**  **requiring those sources with ESPs performing below currently**  **achievable levels to improve their performance.**
4. STEP 4: For a BART review, what impacts am I exp ected to calculate and report? What methods does EP A recommend for the impacts analysis?
**After you identify the available and technically fe asible control technology options, you are expected**  **to conduct the following analyses when you make a BART determinati**  **on:**

**Impact analysis part 1: Costs of compliance,**
**Impact analysis part 2: Energy impacts,**
**Impact analysis part 3: Non-air quality environment al impacts, and** 
**Impact analysis part 4: Remaining useful life.**
**In this section, we describe how to conduct each of these three analyses. You are responsible for pres**  **enting an evaluation of each impact along with appropriate su**  **pporting information. You should discuss and, where possible,**  **quantify both beneficial and adverse impacts. In ge neral, the analysis should focus on the direct impa**  **ct of the control alternative.** 
**KDHE note: The Guidelines do not explicitly mention how to deal with collateral increases in another r**  **egulated pollutant as a result of a control alternative.**  **For example, use of furnace sorbent injection to co ntrol SO**  **2 in a boiler**  **could result in an increase in PM emissions. This i ncrease could trigger other air quality requirement**  **s such as NSPS or NSR. KDHE asks that you identify any collateral**  **increases in other regulated pollutants in your an alysis. If you**  **select a control that has collateral increases as p roposed BART, then KDHE asks that your BART analysi**  **s also identify any regulatory requirements that are trigg**  **ered.**
a. Impact analysis part 1: how do I estimate the co sts of control?
**1. To conduct a cost analysis, you:**
**(1) Identify the emissions units being controlled,**
**(2) Identify design parameters for emission control s, and** 
**(3) Develop cost estimates based upon those design parameters.** 
**2. It is important to identify clearly the emission units being controlled, that is, to specify a well**  **defined area or process segment within the plant. In some cases, mu**  **ltiple emission units can be controlled jointly. Ho wever, in other**  **cases, it may be appropriate in the cost analysis t o consider whether multiple units will be required**  **to install separate and/or different control devices. The analysis shou**  **ld provide a clear summary list of equipment and th e associated**  **control costs. Inadequate documentation of the equi pment whose emissions are being controlled is a pot**  **ential cause for confusion in comparison of costs of the same co**  **ntrols applied to similar sources.**
**3. You then specify the control system design param eters. Potential sources of these design parameters**  **include equipment vendors, background information documents**  **used to support NSPS development, control techniqu e** 

## Page 11 3/31/2008

**guidelines documents, cost manuals developed by EPA , control data in trade publications, and engineeri**  **ng and performance test data. The following are a few exam**  **ples of design parameters for two example control m easures:** 



### ------------------------------------------------------------------------ **Control device Examples o f design parameters** 

**------------------------------------------------------------------------ Wet Scrubbers............................... Type of**  **sorbent used (lime, limestone, etc.) Gas pressu**  **re drop Liquid/ga**  **s ratio Selective Catalytic Reduction......... Ammonia to**  **NO x**  

### molar ratio **Pressure dro p**  **Catalyst life** 

**------------------------------------------------------------------------**
**4. The value selected for the design parameter shou ld ensure that the control option will achieve the**  **level of emission control being evaluated. You should includ**  **e in your analysis documentation of your assumption s**  **regarding design parameters. Examples of supporting references would include the EPA**  OAQPS Control Cost Manual

**(see below) and background information documents u sed for NSPS and hazardous pollutant**  **emission standards. If the design parameters you sp ecified differ from typical designs, you should doc**  **ument the difference by supplying performance test data f** **or the control technology in question applied to th e same**  **source or a similar source.**
**5. Once the control technology alternatives and ach ievable emissions performance levels have been**  **identified, you then develop estimates of capital a nd annual costs. The basis for equipment cost estim**  **ates also should be documented, either with data supplie**  **d by an equipment vendor (** i.e. **, budget estimates or bids) or by a referenced source (such as the**  OAQPS Control Cost Manual, **Fifth Edition, February 1996, EPA 453/B–96–001).**  **14 In order to maintain and improve consistency, cost**  **estimates should be based on the** OAQPS Control Cost Manual, **where possible. 15**  **The** Control Cost Manual **addresses most control technologies in sufficient detail for a BART analys**  **is. The cost analysis should also take into account any site**  **specific design or other conditions identified abov e that affect the cost of a particular BART technol**  **ogy option.** 

**14 The**  OAQPS Control Cost Manual **is updated periodically. While this citation refer s to the latest**  **version at the time this guidance was written, you should use the version that is current as of when**  **you conduct your impact analysis. This document is available at the following web site:**  http://www.epa.gov/ttn/catc/dir1/cs1ch2.pdf.

**15 You should include documentation for any additiona**  **l information you used for the cost calculations, including any information supplied by**  **vendors that affects your assumptions regarding purchased equipment costs, equipment life, replacem**  **ent of major components, and any other element of the calculation that differs from the**  Control Cost Manual.

**KDHE note: Please reflect all costs in year 2005 d ollars.** 
b. What do we mean by cost effectiveness?
**Cost effectiveness, in general, is a criterion used to assess the potential for achieving an objective**  **in the most economical way. For purposes of air pollutant**  **analysis, “effectiveness” is measured in terms of t ons of**  **pollutant emissions removed, and “cost” is measured in terms of annualized control costs. We recommend**  **two types of cost-effectiveness calculations—averag e cost effectiveness, and incremental cost effectiv**  **eness.**

## Page 12 3/31/2008

c. How do I calculate average cost effectiveness?
**Average cost effectiveness means the total annualiz ed costs of control divided by annual emissions**  **reductions (the difference between baseline annual emissions and the estimate of emissions after contr**  **ols), using the following formula:** 
**Average cost effectiveness (dollars per ton removed ) =**  Control option annualized cost **16**

**16 Whenever you calculate or report annual costs, you**  **should indicate the year for which the costs are estimated. For example, if you use the year 200**  **0 as the basis for cost comparisons, you would report that an annualized cost of $20 million would**  **be: $20 million (year 2000 dollars).**

**Baseline annual emissions—Annual emissions with con trol option** 
**Because you calculate costs in (annualized) dollars per year ($/yr) and because you calculate emission**  **s rates in tons per year (tons/yr), the result is an**  **average cost-effectiveness number in (annualized) d ollars per**  **ton ($/ton) of pollutant removed.**

d. How do I calculate baseline emissions?
**1. The baseline emissions rate should represent a r ealistic depiction of anticipated annual emissions**  **for the source. In general, for the existing sources subjec**  **t to BART, you will estimate the anticipated annual emissions based upon actual emissions from a baseli**  **ne period.**
**2. When you project that future operating parameter s (**  e.g. **, limited hours of operation or capacity utilizatio n,**  **type of fuel, raw materials or product mix or type) will differ from past practice, and if this projec**  **tion has a deciding effect in the BART determination, then you**  **must make these parameters or assumptions into enforceable limitations. In the absence of enforcea**  **ble limitations, you calculate baseline emissions b ased**  **upon continuation of past practice.**
**3. For example, the baseline emissions calculation for an emergency standby generator may consider the**  **fact that the source owner would not operate more t han past practice of 2 weeks a year. On the other h**  **and, baseline emissions associated with a base-loaded tu**  **rbine should be based on its past practice which wo uld**  **indicate a large number of hours of operation. This produces a significantly higher level of baseline**  **emissions than in the case of the emergency/standby unit and**  **results in more cost-effective controls. As a conse quence**  **of the dissimilar baseline emissions, BART for the two cases could be very different.** 

**KDHE note: In estimating the baseline tons per year emitted, K**  **DHE asks that you use the average hourly emission rate, as calculated from the maximum 24-ho**  **ur emission rate, multiplied by the utilization rat e of the**  **highest year during the 3-year period from 2002 to 2004. KDHE is suggesting this method so that the**  **baseline tons value is closer to the upper bound of expected future emissions in any given year. If th**  **is method results in an unrealistic depiction of futur**  **e annual emissions, then please consult with KDHE s taff to**  **develop an alternative acceptable method.**

e. How do I calculate incremental cost effectivenes s?
**1. In addition to the average cost effectiveness of a control option, you should also calculate increm**  **ental cost effectiveness. You should consider the incremental**  **cost effectiveness in combination with the average cost**  **effectiveness when considering whether to eliminate a control option. The incremental cost effectivene**  **ss calculation compares the costs and performance leve**  **l of a control option to those of the next most str ingent**  **option, as shown in the following formula (with res pect to cost per emissions reduction):** 
**Incremental Cost Effectiveness (dollars per increme ntal ton removed) = [(Total annualized costs** 

## Page 13 3/31/2008 **of control option)** − (Total annualized costs of next control option) **] ÷ [(Control option annual emissions)**  − (Next control option annual emissions) **]**
Example 1: **Assume that Option F on Figure 2 has total annua lized costs of $1 million to reduce**  **2000 tons of a pollutant, and that Option D on Figu re 2 has total annualized costs of $500,000 to**  **reduce 1000 tons of the same pollutant. The increme ntal cost effectiveness of Option F relative to**  **Option D is ($1 million** − $500,000) divided by (2000 tons − 1000 ton **s), or $500,000 divided by 1000 tons, which is $500/ton.** 
Example 2: **Assume that two control options exist: Option 1 and Option 2. Option 1 achieves a**  **1,000 ton/yr reduction at an annualized cost of $1, 900,000. This represents an average cost of**  **($1,900,000/1,000 tons) = $1,900/ton. Option 2 achi eves a 980 tons/yr reduction at an annualized**  **cost of $1,500,000. This represents an average cost of ($1,500,000/980 tons) = $1,531/ton. The**  **incremental cost effectiveness of Option 1 relative to Option 2 is ($1,900,000**  − $1,500,000) divided **by (1,000 tons** − 980 tons). The adoption of Option 1 instead of Op tion 2 results in an incremental **emission reduction of 20 tons per year at an additi onal cost of $400,000 per year. The incremental**  **cost of Option 1, then, is $20,000 per ton** − 11 times the average cost of $1,900 per ton. Whil e **$1,900 per ton may still be deemed reasonable, it i s useful to consider both the average and**  **incremental cost in making an overall cost-effectiv eness finding. Of course, there may be other**  **differences between these options, such as, energy or water use, or non-air environmental effects,**  **which also should be considered in selecting a BART technology.** 
**2. You should exercise care in deriving incremental costs of candidate control options. Incremental co**  **st effectiveness comparisons should focus on annualize**  **d cost and emission reduction differences between “dominant” alternatives. To identify dominant alter**  **natives, you generate a graphical plot of total ann ualized**  **costs for total emissions reductions for all contro l alternatives identified in the BART analysis, and**  **by identifying a “least-cost envelope” as shown in Fig**  **ure 2. (A “least-cost envelope” represents the set of**  **options that should be dominant in the choice of a specific option.)** 

**View or download PDF**
Example: **Eight technically feasible control options for a nalysis are listed. These are represented**  **as A through H in Figure 2. The dominant set of con trol options, B, D, F, G, and H, represent the**  **least-cost envelope, as we depict by the cost curve connecting them. Points A, C and E are inferior**  **options, and you should not use them in calculating incremental cost effectiveness. Points A, C and**  **E represent inferior controls because B will buy mo re emissions reductions for less money than A;** 

## Page 14 3/31/2008 **and similarly, D and F will buy more reductions for less money than C and E, respectively.** 
**3. In calculating incremental costs, you:**
**(1) Array the control options in ascending order of annualized total costs;** 
**(2) Develop a graph of the most reasonable smooth c urve of the control options, as shown in Figure**  **2. This is to show the “least-cost envelope” discus sed above; and** 
**(3) Calculate the incremental cost effectiveness fo r each dominant option, which is the difference in**  **total annual costs between that option and the next most stringent option, divided by the difference**  **in emissions, after controls have been applied, bet ween those two control options. For example,**  **using Figure 2, you would calculate incremental cos t effectiveness for the difference between**  **options B and D, options D and F, options F and G, and options G and H.** 
**4. A comparison of incremental costs can also be us eful in evaluating the viability of a specific cont**  **rol option over a range of efficiencies. For example, dependin**  **g on the capital and operational cost of a control device,**  **total and incremental cost may vary significantly ( either increasing or decreasing) over the operation**  **al range of a control device. Also, the greater the number o**  **f possible control options that exist, the more wei ght**  **should be given to the incremental costs vs. averag e costs. It should be noted that average and increm**  **ental cost effectiveness are identical when only one cand**  **idate control option is known to exist.**

**5. You should exercise caution not to misuse these techniques. For example, you may be faced with a ch**  **oice between two available control devices at a source,**  **control A and control B, where control B achieves s lightly**  **greater emission reductions. The average cost (tota l annual cost/total annual emission reductions) for**  **each may be deemed to be reasonable. However, the increm**  **ental cost (total annual cost A-B**  **/total annual emission reductions**  **A-B ) of the additional emission reductions to be achie**  **ved by control B may be very great. In such an instance, it may be inappropriate to choose control**  **B, based on its high incremental costs, even thoug h its**  **average cost may be considered reasonable.**
**6. In addition, when you evaluate the average or in cremental cost effectiveness of a control alternati**  **ve, you should make reasonable and supportable assumptions**  **regarding control efficiencies. An unrealistically low**  **assessment of the emission reduction potential of a certain technology could result in inflated cost**  **effectiveness figures.**
**KDHE note: KDHE does not require that you develop a least-cost envelope such as that shown in the figu**  **re. KDHE expects that the top-down nature of the BART a**  **nalysis and the information requested in the analys is**  **will be sufficient for BART determination purposes.**
f. What other information should I provide in the c ost impacts analysis?
**You should provide documentation of any unusual cir cumstances that exist for the source that would lea**  **d to cost-effectiveness estimates that would exceed that**  **for recent retrofits. This is especially important in cases**  **where recent retrofits have cost-effectiveness valu es that are within what has been considered a reaso**  **nable range, but your analysis concludes that costs for t**  **he source being analyzed are not considered reasona ble.**  **(A reasonable range would be a range that is consis tent with the range of cost effectiveness values us**  **ed in other similar permit decisions over a period of tim**  **e.)**
Example: **In an arid region, large amounts of water are ne eded for a scrubbing system. Acquiring**  **water from a distant location could greatly increas e the cost per ton of emissions reduced of wet**  **scrubbing as a control option.**
g. What other things are important to consider in t he cost impacts analysis?
**In the cost analysis, you should take care not to f ocus on incomplete results or partial calculations.**  **For example, large capital costs for a control option a**  **lone would not preclude selection of a control meas ure if** 

## Page 15 3/31/2008

**large emissions reductions are projected. In such a case, low or reasonable cost effectiveness numbers**  **may validate the option as an appropriate BART alternat**  **ive irrespective of the large capital costs. Simila rly,**  **projects with relatively low capital costs may not be cost effective if there are few emissions reduce**  **d.**
h. Impact analysis part 2: How should I analyze and report energy impacts?
**1. You should examine the energy requirements of th e control technology and determine whether the use**  **of that technology results in energy penalties or bene**  **fits. A source owner may, for example, benefit from the**  **combustion of a concentrated gas stream rich in vol atile organic compounds; on the other hand, more of**  **ten extra fuel or electricity is required to power a co**  **ntrol device or incinerate a dilute gas stream. If such benefits**  **or penalties exist, they should be quantified to th e extent practicable. Because energy penalties or b**  **enefits can usually be quantified in terms of additional co**  **st or income to the source, the energy impacts anal ysis**  **can, in most cases, simply be factored into the cos t impacts analysis. The fact of energy use in and o**  **f itself does not disqualify a technology.** 
**2. Your energy impact analysis should consider only direct energy consumption and not indirect energy**  **impacts. For example, you could estimate the direct energy impacts of the control alternative in units**  **of energy consumption at the source (**  e.g. **, BTU, kWh, barrels of oil, tons of coal). The ener gy requirements of**  **the control options should be shown in terms of tot al (and in certain cases, also incremental) energy**  **costs per ton of pollutant removed. You can then convert**  **these units into dollar costs and, where appropriat e,**  **factor these costs into the control cost analysis.**
**3. You generally do not consider indirect energy im pacts (such as energy to produce raw materials for**  **construction of control equipment). However, if you determine, either independently or based on a show**  **ing by the source owner, that the indirect energy impac**  **t is unusual or significant and that the impact can be well**  **quantified, you may consider the indirect impact.**
**4. The energy impact analysis may also address conc erns over the use of locally scarce fuels. The**  **designation of a scarce fuel may vary from region t o region. However, in general, a scarce fuel is one**  **which is in short supply locally and can be better used f**  **or alternative purposes, or one which may not be reasonably available to the source either at the pr**  **esent time or in the near future.**
**5. Finally, the energy impacts analysis may conside r whether there are relative differences between**  **alternatives regarding the use of locally or region ally available coal, and whether a given alternativ**  **e would result in significant economic disruption or unempl**  **oyment. For example, where two options are equally cost**  **effective and achieve equivalent or similar emissio ns reductions, one option may be preferred if the o**  **ther alternative results in significant disruption or un**  **employment.**
**KDHE note: Please report energy impacts on a dollar per ton of pollutant removed basis. Please documen**  **t all assumptions made in calculating energy costs.**  **Please reflect all costs in year 2005 dollars.**
i. Impact analysis part 3: How do I analyze “non-ai r quality environmental impacts?”
**1. In the non-air quality related environmental imp acts portion of the BART analysis, you address**  **environmental impacts other than air quality due to emissions of the pollutant in question. Such**  **environmental impacts include solid or hazardous wa ste generation and discharges of polluted water fro**  **m a control device.** 
**2. You should identify any significant or unusual e nvironmental impacts associated with a control alte**  **rnative that have the potential to affect the selection or**  **elimination of a control alternative. Some control technologies**  **may have potentially significant secondary environm ental impacts. Scrubber effluent, for example, may**  **affect water quality and land use. Alternatively, water av**  **ailability may affect the feasibility and costs of wet**  **scrubbers. Other examples of secondary environmenta l impacts could include hazardous waste discharges,**  **such as spent catalysts or contaminated carbon. Gen erally, these types of environmental concerns becom**  **e important when sensitive site-specific receptors ex**  **ist or when the incremental emissions reductions po tential**  **of the more stringent control is only marginally gr eater than the next most-effective option. However,**  **the fact that a control device creates liquid and solid wast**  **e that must be disposed of does not necessarily arg ue** 

## Page 16 3/31/2008

**against selection of that technology as BART, parti cularly if the control device has been applied to s**  **imilar facilities elsewhere and the solid or liquid waste**  **is similar to those other applications. On the othe r hand,**  **where you or the source owner can show that unusual circumstances at the proposed facility create grea**  **ter problems than experienced elsewhere, this may provi**  **de a basis for the elimination of that control alte rnative**  **as BART.**
**3. The procedure for conducting an analysis of non- air quality environmental impacts should be made ba**  **sed on a consideration of site-specific circumstances.**  **If you propose to adopt the most stringent alternat ive, then**  **it is not necessary to perform this analysis of env ironmental impacts for the entire list of technolog**  **ies you ranked in Step 3. In general, the analysis need onl**  **y address those control alternatives with any signi ficant or**  **unusual environmental impacts that have the potenti al to affect the selection of a control alternative**  **, or elimination of a more stringent control alternative**  **. Thus, any important relative environmental impact s (both**  **positive and negative) of alternatives can be compa red with each other.** 
**4. In general, the analysis of impacts starts with the identification and quantification of the solid,**  **liquid, and gaseous discharges from the control device or devic**  **es under review. Initially, you should perform a qualitative or semi-quantitative screening to narro**  **w the analysis to discharges with potential for cau sing**  **adverse environmental effects. Next, you should ass ess the mass and composition of any such discharges**  **and quantify them to the extent possible, based on readily available information. You should also asse**  **mble pertinent information about the public or environme**  **ntal consequences of releasing these materials.**
j. Impact analysis part 4: What are examples of non -air quality environmental impacts?
**The following are examples of how to conduct non-ai r quality environmental impacts:** 
**(1)** Water impact
**You should identify the relative quantities of wate r used and water pollutants produced and**  **discharged as a result of the use of each alternati ve emission control system. Where possible, you**  **should assess the effect on ground water and such l ocal surface water quality parameters as ph,**  **turbidity, dissolved oxygen, salinity, toxic chemic al levels, temperature, and any other important**  **considerations. The analysis could consider whether applicable water quality standards will be met**  **and the availability and effectiveness of various t echniques to reduce potential adverse effects.** 
**(2)** Solid waste disposal impact
**You could also compare the quality and quantity of solid waste (**  e.g. **, sludges, solids) that must be stored and disposed of or recycled as a result of t**  **he application of each alternative emission control system. You should consider the composition and var**  **ious other characteristics of the solid waste (such as permeability, water retention, rewatering**  **of dried material, compression strength, leachability of dissolved ions, bulk density, abili**  **ty to support vegetation growth and hazardous characteristics) which are significant with regard**  **to potential surface water pollution or transport i nto**  **and contamination of subsurface waters or aquifers.**
**(3)** Irreversible or irretrievable commitment of resourc es
**You may consider the extent to which the alternativ e emission control systems may involve a trade**  **off between short-term environmental gains at the e xpense of long-term environmental losses and**  **the extent to which the alternative systems may res ult in irreversible or irretrievable commitment of**  **resources (for example, use of scarce water resourc es).** 
**(4)** Other adverse environmental impacts
**You may consider significant differences in noise l evels, radiant heat, or dissipated static electrica**  **l energy of pollution control alternatives. Other exa**  **mples of non-air quality environmental impacts**

## Page 17 3/31/2008 **would include hazardous waste discharges such as sp ent catalysts or contaminated carbon.** 
k. How do I take into account a project's “remainin g useful life” in calculating control costs?
**1. You may decide to treat the requirement to consi der the source's “remaining useful life” of the sou**  **rce for BART determinations as one element of the overall c**  **ost analysis. The “remaining useful life” of a sour ce, if it**  **represents a relatively short time period, may affe ct the annualized costs of retrofit controls. For e**  **xample, the methods for calculating annualized costs in EPA's**  OAQPS Control Cost Manual **require the use of a specified time period for amortization that varies**  **based upon the type of control. If the remaining us eful life**  **will clearly exceed this time period, the remaining useful life has essentially no effect on control c**  **osts and on the BART determination process. Where the remaining**  **useful life is less than the time period for amort izing**  **costs, you should use this shorter time period in y our cost calculations.** 
**KDHE note: For units being evaluated in the** OAQPS Control Cost Manual**, any time period that is less than the lifetime of the control equipment set in the Ma**  **nual (** i.e **., the remaining life of the equipment) should be supported with a rationale that includes an assessm**  **ent of why it is not reasonable to assume the facil ity will**  **maintain or reconstruct for continued operation, th us allowing the control equipment to be used for an**  **extended period.**
**2. For purposes of these guidelines, the remaining useful life is the difference between:** 
**(1) The date that controls will be put in place (ca pital and other construction costs incurred before**  **controls are put in place can be rolled into the fi rst year, as suggested in EPA's**  OAQPS Control Cost Manual

**); and**
**(2) The date the facility permanently stops operati ons. Where this affects the BART determination,**  **this date should be assured by a federally or State -enforceable restriction preventing further**  **operation.**
**3. We recognize that there may be situations where a source operator intends to shut down a source by**  **a given date, but wishes to retain the flexibility to**  **continue operating beyond that date in the event, for**  **example, that market conditions change. Where this is the case, your BART analysis may account for thi**  **s, but it must maintain consistency with the statutory** **requirement to install BART within 5 years. Where the**  **source chooses not to accept a federally enforceabl e condition requiring the source to shut down by a**  **given date, it is necessary to determine whether a reduce**  **d time period for the remaining useful life changes the**  **level of controls that would have been required as BART.** 
**If the reduced time period does change the level of BART controls, you may identify, and include as pa**  **rt of the BART emission limitation, the more stringent le**  **vel of control that would be required as BART if th ere**  **were no assumption that reduced the remaining usefu l life. You may incorporate into the BART emission**  **limit this more stringent level, which would serve as a c**  **ontingency should the source continue operating mor e**  **than 5 years after the date EPA approves the releva nt SIP. The source would not be allowed to operate**  **after the 5-year mark without such controls. If a source**  **does operate after the 5-year mark without BART in place,**  **the source is considered to be in violation of the BART emissions limit for each day of operation.** 
5. Step 5: How should I determine visibility impact s in the BART determination?
**The following is an approach you may use to determi ne visibility impacts (the degree of visibility imp**  **rovement for each source subject to BART) for the BART deter**  **mination. Once you have determined that your source or**  **sources are subject to BART, you must conduct a vis ibility improvement determination for the source(s)**  **as part of the BART determination. When making this de**  **termination, we believe you have flexibility in set ting**  **absolute thresholds, target levels of improvement, or**  de minimis **levels, since the deciview improvement must be weighed among the five factors, and you are free**  **to determine the weight and significance to be ass igned**  **to each factor. For example, a 0.3 dv improvement m ay merit a stronger weighting in one case versus**  **another, so one “bright line” may not be appropriat e. [Note that if sources have elected to apply the**  **most stringent controls available, consistent with the d**  **iscussion in section E step 1 below, you need not c onduct,**  **or require the source to conduct, an air quality mo deling analysis for the purpose of determining its**  **visibility**

## Page 18 3/31/2008

**impacts.]**

**Use CALPUFF 17**  **or other appropriate dispersion model to determine the visibility improvement expected at a**  **Class I area from the potential BART control techno logy applied to the source. Modeling should be**  **conducted for SO 2**  **, NO x**  **, and direct PM emissions (PM 2.5**  **and/or PM 10**  **). If the source is making the visibility determination, you should review and approve or dis**  **approve of the source's analysis before making the expected improvement determination. There are sever**  **al steps for determining the visibility impacts fro m an**  **individual source using a dispersion model:**

**17 The model code and its documentation are available**  **from** http://www.epa.gov/scram001/tt22.htm#calpuff.
• Develop a modeling protocol.
**Some critical items to include in a modeling protoc ol are meteorological and terrain data, as well as**  **source specific information (stack height, temperature, ex**  **it velocity, elevation, and allowable and actual em ission**  **rates of applicable pollutants), and receptor data from appropriate Class I areas. We recommend follow**  **ing EPA's**  Interagency Workgroup on Air Quality Modeling (IWAQM ) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport I mpacts **18 for parameter settings and meteorological**  **data inputs; the use of other settings from those i n IWAQM should be identified and explained in the p**  **rotocol.**

**18** Interagency Workgroup on Air Quality Modeling (IWAQM ) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport I mpacts, **U.S. Environmental Protection Agency, EPA–454/R–98–019, December 1998.** 
**One important element of the protocol is in establi shing the receptors that will be used in the model.**  **The receptors that you use should be located in the nea**  **rest Class I area with sufficient density to identi fy the**  **likely visibility effects of the source. For other Class I areas in relatively close proximity to a BA**  **RT-eligible source, you may model a few strategic receptors to**  **determine whether effects at those areas may be gre ater**  **than at the nearest Class I area. For example, you might chose to locate receptors at these areas at t**  **he closest point to the source, at the highest and low**  **est elevation in the Class I area, at the IMPROVE m onitor,**  **and at the approximate expected plume release heigh t. If the highest modeled effects are observed at t**  **he nearest Class I area, you may choose not to analyze**  **the other Class I areas any further as additional analyses might be unwarranted.** 
**You should bear in mind that some receptors within the relevant Class I area may be less than 50 km fr**  **om the source while other receptors within that same C**  **lass I area may be greater than 50 km from the same source. As indicated by the**  Guideline on Air Quality Models, **this situation may call for the use of two differe nt**  **modeling approaches for the same Class I area and s ource, depending upon the State's chosen method for**  **modeling sources less than 50 km. In situations whe re you are assessing visibility impacts for source**  **receptor distances less than 50 km, you should use expert modeling judgment in determining visibility**  **impacts, giving consideration to both CALPUFF and o ther EPA-approved methods.** 
**In developing your modeling protocol, you may want to consult with EPA and your regional planning**  **organization (RPO). Up-front consultation will ensu re that key technical issues are addressed before y**  **ou conduct your modeling.** 
**KDHE note: Determining visibility impacts of the va rious control alternatives should conform to the mo**  **deling protocol developed by KDHE, in most cases. This KD**  **HE protocol also relies on the CENRAP modeling guidelines, titled “CENRAP BART Modeling Guidelines**  **.” It is available at http://www.cenrap.org/modeling_document.asp**  The specific emissions and stack parameter inputs used for each facility in the subject-to-BART modeling are a vailable from KDHE. For those sources that will be performing refined CALPUFF modeling, or proposing a n alternative model, you should work closely with KDHE on settings and assumptions that will be allowed. For sources that choose to follow the current KDHE protocol and data sets, no additional modeling docu mentation is required other than the stack and emis sions changes due to the proposed controls.

## Page 19 3/31/2008

**Since the 2002 BART Information Request Form (sent to facilities by KDHE) requested only PM**  **10 information**  **per EPA’s then-current proposed Regional Haze Rule, KDHE has estimated a maximum 24-hour average**  **actual PM 2.5**  **emission rate using the PM 10** **potential-to-emit (PTE) values supplied, and apply ing a PM**  **2.5 /PM**  **10 ratio calculated by KDHE for the 2002 emissions inv**  **entory. To quantify PM 2.5** **emissions in the 2002 emissions inventory, KDHE used three different meth**  **ods: (1) if the facility didn’t submit PM 10**  **stack test data, KDHE estimated both the PM**  **2.5 and PM**  **10 primary emissions (filterable +condensable) using**  **uncontrolled emission factors from EPA’s FIRE database and apply**  **ing KDHE default control efficiencies; (2) if the f acility**  **did submit PM 10**  **stack test data, KDHE estimated the PM 2.5**  **by scaling the existing ratio of PM 2.5**  **/PM 10**  **primary emissions derived from method 1; or (3) if the facility’s source classification codes (SCCs) w**  **ere not available in FIRE, KDHE estimated the PM**  **2.5 using EPA’s PM Calculator (see**  

### http://www.epa.gov/ttn/chief/software/pmcalc/index.h **tml ).** 
**Thus, PM 2.5**  **emissions will be the scaled PM 2.5** **(fine PM) and the remainder (PM 2.5-10**  **) will be assigned to PM**  **10 (coarse PM). It is possible the PM**  **2.5 /PM**  **10 ratio for the control alternative will not be the**  **same as the base case ratio. If the ratio is not the same, it i**  **s recommended that you use the method used by KDHE to**  **estimate PM 2.5**  **emissions for the various control alternatives eva luated. The National Park Service has**  **developed PM 10**  **speciation methods for various emission units (lar ge coal-fired boilers, thermal dryers, oil**  **boilers, and cement kilns) with control applied. If you have a BART-eligible emission unit for which P**  **M 10**  **speciation data is available, then you may use that method instead.**  <These methods are still under development and not yet available on-line. Contact Don Sheperd at don_shepherd@nps.gov if you would like the most recent drafts.>
• For each source, run the model at pre-control and post-control emission rates according to the accepted methodology in the protocol.
**Use the 24-hour average actual emission rate from t he highest emitting day of the meteorological perio**  **d modeled (for the pre-control scenario). Calculate t**  **he model results for each receptor as the change in deciviews compared against natural visibility condi**  **tions. Post-control emission rates are calculated a s a**  **percentage of pre-control emission rates. For examp le, if the 24-hr pre-control emission rate is 100 l**  **b/hr of SO**  **2 , then the post control rate is 5 lb/hr if the cont**  **rol efficiency being evaluated is 95%.**

**KDHE note: Provide tables with the pre-control and post-control stack and emissions inputs used for th**  **e modeling runs.** 

**•** Make the net visibility improvement determination.
**Assess the visibility improvement based on the mode led change in visibility impacts for the pre-contro**  **l and post-control emission scenarios. You have flexibili**  **ty to assess visibility improvements due to BART co ntrols**  **by one or more methods. You may consider the freque ncy, magnitude, and duration components of**  **impairment. Suggestions for making the determinatio n are:** 

• Use of a comparison threshold **, as is done for determining if BART-eligible sourc es should be**  **subject to a BART determination. Comparison thresho lds can be used in a number of ways in**  **evaluating visibility improvement (** e.g., **the number of days or hours that the threshold was exceeded, a single threshold for determining whethe**  **r a change in impacts is significant, or a threshold representing an x% change in improvement)** 

**. KDHE note: KDHE is recommending that for each Class**  **I area you were shown to impact in the subject-to BART modeling, compare the highest modeled delta-de**  **ciview value from all modeled receptors at a given Class I area for each year simulated, compare the n**  **umber of days of impacts > 0.5 dv, and compare the number of days impacts > 1.0 dv. These comparisons**  **should be performed for pre- and post-control runs**

**. You may also recommend additional comparison thresh**  **olds to evaluate visibility improvement.**
• Compare the 98th percentile days for the pre- and post-control runs, **noting that each of the**

## Page 20 3/31/2008 **modeling options may be supplemented with source ap portionment data or source apportionment**  **modeling.**
E. How do I select the “best” alternative using the results of Steps 1 through 5?
1. Summary of the impacts analysis
**From the alternatives you evaluated in Step 3, we r ecommend you develop a chart (or charts) displaying**  **for each of the alternatives:** 
**(1) Expected emission rate (tons per year, pounds p er hour);** 
**(2) Emissions performance level (** e.g. **, percent pollutant removed, emissions per unit pro duct,**  **lb/MMBtu, ppm);**
**(3) Expected emissions reductions (tons per year); (4) Costs of compliance—total annualized costs ($),**  **cost effectiveness ($/ton), and incremental cost effectiveness ($/ton), and/or any other cost-effect**  **iveness measures (such as $/deciview);**
**(5) Energy impacts;**
**(6) Non-air quality environmental impacts; and**
**(7) Modeled visibility impacts.**
2. Selecting a “best” alternative

**1. You have discretion to determine the order in wh ich you should evaluate control options for BART.**  **Whatever the order in which you choose to evaluate options, you should always (1) display the options**  **evaluated; (2) identify the average and incremental costs of each option; (3) consider the energy and**  **non-air quality environmental impacts of each option; (4) c**  **onsider the remaining useful life; and (5) consider the**  **modeled visibility impacts. You should provide a ju stification for adopting the technology that you se**  **lect as the “best” level of control, including an explanati**  **on of the CAA factors that led you to choose that o ption over**  **other control levels.**
**KDHE note: KDHE would like you to use a top-down ap proach to evaluate control strategies. If you**  **determine that the most stringent alternative in th e ranking does not impose unreasonable costs of**  **compliance, taking into account both average and in cremental costs, the analysis begins with the**  **presumption that this level is selected. Under thi s, you would then proceed to consider whether energ**  **y and non-air quality environmental impacts would justify**  **selection of an alternative control option. If the re are no**  **outstanding issues regarding energy and non-air qua lity environmental impacts, the analysis is ended a**  **nd the most stringent alternative is identified as the**  **“best system of continuous reduction.” If you determine that the most stringent alternativ**  **e is unacceptable due to such impacts, this approac h would**  **require you to document the rationale for this find ing. Then, the next most effective alternative in**  **the listing becomes the new control candidate and is similarly**  **evaluated. This process continues until you identi fy a**  **technology which does not pose unacceptable costs o f compliance, energy, and/or non-air quality**  **environmental impacts. KDHE staff will be available to work with you during your BART analysis prepara**  **tion to address your questions and concerns, such as the**  **specific concern that a particular technology favo red by**  **you would be eliminated under a top-down approach. In making the BART determination itself, all factor**  **s will be considered, including the degree of visibility i**  **mprovement.**
**2. In the case where you are conducting a BART dete rmination for two regulated pollutants on the same**  **source, if the result is two different BART technol ogies that do not work well together, you could the**  **n**

## Page 21 3/31/2008

**substitute a different technology or combination of technologies.** 
**3. In selecting a “best” alternative, should I cons ider the affordability of controls?** 

**1. Even if the control technology is cost effective , there may be cases where the installation of**  **controls would affect the viability of continued pl ant operations.** 
**2. There may be unusual circumstances that justify taking into consideration the conditions of the**  **plant and the economic effects of requiring the use of a given control technology. These effects**  **would include effects on product prices, the market share, and profitability of the source. Where**  **there are such unusual circumstances that are judge d to affect plant operations, you may take into**  **consideration the conditions of the plant and the e conomic effects of requiring the use of a control**  **technology. Where these effects are judged to have a severe impact on plant operations you may**  **consider them in the selection process, but you may wish to provide an economic analysis that**  **demonstrates, in sufficient detail for public revie w, the specific economic effects, parameters, and**  **reasoning. (We recognize that this review process m ust preserve the confidentiality of sensitive**  **business information). Any analysis may also consid er whether other competing plants in the same**  **industry have been required to install BART control s if this information is available.** 
**4. Sulfur dioxide limits for utility boilers**
**You must require 750 MW power plants to meet specif ic control levels for SO**  **2 of either 95% control or 0.15**  **lbs/MMBtu, for each EGU greater than 200 MW that is currently uncontrolled unless you determine that a**  **n alternative control level is justified based on a c**  **areful consideration of the statutory factors. Thus , for**  **example, if the source demonstrates circumstances a ffecting its ability to cost-effectively reduce its**  **emissions, you should take that into account in det ermining whether the presumptive levels of control**  **are appropriate for that facility. For a currently unco**  **ntrolled EGU greater than 200 MW in size, but locat ed at a**  **power plant smaller than 750 MW in size, such contr ols are generally cost-effective and could be used**  **in your BART determination considering the five factor**  **s specified in CAA section 169A(g)(2). While these levels**  **may represent current control capabilities, we expe ct that scrubber technology will continue to improv**  **e and control costs continue to decline. You should be su**  **re to consider the level of control that is current ly best**  **achievable at the time that you are conducting your BART analysis.** 
**For coal-fired EGUs with existing post-combustion S O**  **2 controls achieving less than 50% removal**  **efficiencies, we recommend that you evaluate constr ucting a new FGD system to meet the same emission**  **limits as above (95% removal or 0.15 lb/mmBtu), in addition to the evaluation of scrubber upgrades**  **discussed below. For oil-fired units, regardless of size, you should evaluate limiting the sulfur cont**  **ent of the fuel oil burned to 1% or less by weight.** 
**For those BART-eligible EGUs with pre-existing post -combustion SO**  **2 controls achieving removal efficiencies**  **of at least 50%, your BART determination should con sider cost effective scrubber upgrades designed to**  **improve the system's overall SO 2**  **removal efficiency. There are numerous scrubber en hancements available**  **to upgrade the average removal efficiencies of all types of existing scrubber systems. We recommend th**  **at as you evaluate the definition of “upgrade,” you evalu**  **ate options that not only improve the design remova l**  **efficiency of the scrubber vessel itself, but also consider upgrades that can improve the overall SO**  **2 removal**  **efficiency of the scrubber system. Increasing a scr ubber system's reliability, and conversely decreasi**  **ng its downtime, by way of optimizing operation procedures**  **, improving maintenance practices, adjusting scrubb er**  **chemistry, and increasing auxiliary equipment redun dancy, are all ways to improve average SO**  **2 removal**  **efficiencies.**
**We recommend that as you evaluate the performance o f existing wet scrubber systems, you consider some**  **of the following upgrades, in no particular order, as potential scrubber upgrades that have been prove**  **n in the industry as cost-effective means to increase overal**  **l SO 2**  **removal of wet systems:**
**(a) Elimination of bypass reheat,**

## Page 22 3/31/2008 **(b) Installation of liquid distribution rings,**
**(c) Installation of perforated trays,**
**(d) Use of organic acid additives,**
**(e) Improve or upgrade scrubber auxiliary system eq uipment, and/or** 
**(f) Redesign spray header or nozzle configuration.**
**We recommend that as you evaluate upgrade options f or dry scrubber systems, you should consider the**  **following cost effective upgrades, in no particular order:** 
**(a) Use of performance additives,**
**(b) Use of more reactive sorbent,**
**(c) Increase the pulverization level of sorbent, an d/or** 
**(d) Engineering redesign of atomizer or slurry inje ction system.** 
**You should evaluate scrubber upgrade options based on the 5-step BART analysis process.** 
**5. Nitrogen oxide limits for utility boilers**
**You should establish specific numerical limits for NO**  **x control for each BART determination. For power pla**  **nts with a generating capacity in excess of 750 MW curr**  **ently using selective catalytic reduction (SCR) or selective non-catalytic reduction (SNCR) for part o**  **f the year, you should presume that use of those sa me**  **controls year-round is BART. For other sources curr ently using SCR or SNCR to reduce NO**  **x emissions**  **during part of the year, you should carefully consi der requiring the use of these controls year-round**  **as the additional costs of operating the equipment through**  **out the year would be relatively modest.**
**For coal-fired EGUs greater than 200 MW located at greater than 750 MW power plants and operating**  **without post-combustion controls (** i.e., **SCR or SNCR), we have provided presumptive NO x**  **limits, differentiated by boiler design and type of coal bu**  **rned. You may determine that an alternative control level is**  **appropriate based on a careful consideration of the statutory factors. For coal-fired EGUs greater tha**  **n 200 MW located at power plants 750 MW or less in size a**  **nd operating without post-combustion controls, you should likewise presume that these same levels are**  **cost-effective. You should require such utility boi lers to**  **meet the following NO x** 

**emission limits, unless you determine that an alte rnative control level is justified**  **based on consideration of the statutory factors. Th e following NO**  **x emission rates were determined based on**  **a number of assumptions, including that the EGU boi ler has enough volume to allow for installation and**  **effective operation of separated overfire air ports . For boilers where these assumptions are incorrect**  **, these emission limits may not be cost-effective.** 

**Table 1. Presumptive NO x**  **Emission Limits for BART-Eligible Coal-Fired Units**

**. 19** 

**--------------------------------------------------- ---------------------**  **NO x**  **presumptive Unit type Coal type**  **limit (lb/MMbtu) 20** 

**--------------------------------------------------- ---------------------**  **Dry-bottom wall-fired............ Bituminous..... ......... 0.39**  **Subbituminous.... .... 0.23**  **Lignite.......... ........... 0.29**  **Tangential-fired.................... Bituminous.. ............ 0.28** 

## Page 23 3/31/2008

**Subbituminous.... .... 0.15**  **Lignite.......... ........... 0.17**  **Cell Burners.......................... Bituminous .............. 0.40**  **Subbituminous.... .... 0.45**  **Dry-turbo-fired....................... Bituminous .............. 0.32**  **Subbituminous.... .... 0.23**  **Wet-bottom tangential-fired... Bituminous........ ...... 0.62** 

**--------------------------------------------------- ---------------------** 

**19 No cell burners, dry-turbo-fired units, nor wet-bo**  **ttom tangential- fired units burning lignite were identified as BA**  **RT eligible, thus no presumptive limit was determined. Similarly, no w**  **et-bottom tangential- fired units burning subbituminous were identified**  **as BART eligible. 20**  **These limits reflect the design and technological assumptions**  **discussed in the technical support document for N O**  **x limits for these**  **guidelines. See Technical Support Document for BA RT NO**  **x Limits for**  **Electric Generating Units and Technical Support D ocument for BART NO**  **x Limits for Electric Generating Units Excel Spread**  **sheet, Memorandum to Docket OAR 2002-0076, April 15, 2005.** 

**Most EGUs can meet these presumptive NO x**  **limits through the use of current combustion contr ol**  **technology,** i.e **., the careful control of combustion air and low- N O**  **x burners. For units that cannot meet these**  **limits using such technologies, you should consider whether advanced combustion control technologies s**  **uch as rotating opposed fire air should be used to meet**  **these limits.**
**Because of the relatively high NO x**  **emission rates of cyclone units, SCR is more cost- effective than the use**  **of current combustion control technology for these units. The use of SCRs at cyclone units burning**  **bituminous coal, subbituminous coal, and lignite sh ould enable the units to cost-effectively meet NO**  **x rates of**  **0.10 lb/MMBtu. As a result, we are establishing a p resumptive NO**  **x limit of 0.10 lb/MMBtu based on the use**  **of SCR for coal-fired cyclone units greater than 20 0 MW located at 750 MW power plants. As with the ot**  **her presumptive limits established in this guideline, y**  **ou may determine that an alternative level of contr ol is**  **appropriate based on your consideration of the rele vant statutory factors. For other cyclone units, yo**  **u should review the use of SCR and consider whether these po**  **st-combustion controls should be required as BART.**
**For oil-fired and gas-fired EGUs larger than 200 MW , we believe that installation of current combustio**  **n control technology to control NO**  **x is generally highly cost-effective and should be c**  **onsidered in your determination of BART for these sources. Many such**  **units can make significant reductions in NO x**  **emissions which are highly cost-effective through the applica**  **tion of current combustion control technology. 21** 

**21 See Technical Support Document for BART NO**  **x Limits for Electric Generating Units and**  **Technical Support Document for BART NO x**  **Limits for Electric Generating Units Excel Spreads heet,**  **Memorandum to Docket OAR 2002–0076, April 15, 2005.**
**KDHE note: KDHE expects these presumptive levels of control will be cost effective in most cases. If**  **your facility falls in the EGU category described above**  **and you propose controls at or beyond these presump tive**  **levels, you need not take into account the remainin g statutory factors, as BART will be met. If you p**  **ropose controls above these presumptive levels, justificat**  **ion incorporating the statutory factors will be req uired.** 
V. Enforceable Limits/Compliance Date
**To complete the BART process, you must establish en forceable emission limits that reflect the BART**  **requirements and require compliance within a given period of time. In particular, you must establish a**  **n enforceable emission limit for each subject emissio**  **n unit at the source and for each pollutant subject to**  **review that is emitted from the source. In addition , you must require compliance with the BART emissio**  **n limitations no later than 5 years after EPA approve**  **s your regional haze SIP. If technological or econo mic**  **limitations in the application of a measurement met hodology to a particular emission unit make a**  **conventional emissions limit infeasible, you may in stead prescribe a design, equipment, work practice,**  **operation standard, or combination of these types o f standards. You should consider allowing sources t**  **o “average” emissions across any set of BART-eligible**  **emission units within a facility, so long as the e mission** 

## Page 24 3/31/2008

**reductions from each pollutant being controlled for BART would be equal to those reductions that would**  **be obtained by simply controlling each of the BART-eli**  **gible units that constitute a BART-eligible source.**
**You should ensure that any BART requirements are wr itten in a way that clearly specifies the individua**  **l emission unit(s) subject to BART regulation. Becaus**  **e the BART requirements themselves are “applicable” requirements of the CAA, they must be included as T**  **itle V permit conditions according to the procedure s**  **established in 40 CFR part 70 or 40 CFR part 71.**
**Section 302(k) of the CAA requires emissions limits such as BART to be met on a continuous basis. Alth**  **ough this provision does not necessarily require the use**  **of continuous emissions monitors (CEMs), it is imp ortant**  **that sources employ techniques that ensure complian ce on a continuous basis. Monitoring requirements**  **generally applicable to sources, including those th at are subject to BART, are governed by other regul**  **ations. See, e.g., 40 CFR part 64 (compliance assurance mon**  **itoring); 40 CFR 70.6(a)(3) (periodic monitoring); 40**  **CFR 70.6(c)(1) (sufficiency monitoring). Note also that while we do not believe that CEMs would necess**  **arily be required for all BART sources, the vast majority**  **of electric generating units potentially subject t o BART**  **already employ CEM technology for other programs, s uch as the acid rain program. In addition, emission**  **s limits must be enforceable as a practical matter (c**  **ontain appropriate averaging times, compliance veri fication**  **procedures, and recordkeeping requirements). In lig ht of the above, the permit must:** 
**• Be sufficient to show compliance or noncompliance (**  i.e **., through monitoring times of operation, fuel input, or other indices of operating condition**  **s and practices); and**
**• Specify a reasonable averaging time consistent wi th established reference methods, contain**  **reference methods for determining compliance, and p rovide for adequate reporting and**  **recordkeeping so that air quality agency personnel can determine the compliance status of the**  **source; and**
**• For EGUS, specify an averaging time of a 30-day r olling average, and contain a definition of “boiler**  **operating day” that is consistent with the definiti on in the proposed revisions to the NSPS for utilit**  **y boilers in 40 CFR Part 60, subpart Da.**  **22 You should consider a boiler operating day to be a**  **ny 24- hour period between 12:00 midnight and the followin**  **g midnight during which any fuel is combusted at any time at the steam generating unit. This woul**  **d allow 30-day rolling average emission rates to be calculated consistently across sources.** 
**KDHE note: KDHE expects to enter into agreements wi th facilities that will specify emissions limits an**  **d compliance schedules to address BART. These agreem**  **ents will become part of the Regional Haze SIP and will be federally enforceable. Emissions limits sp**  **ecified in the agreement will be incorporated into a facility’s**  **Title V operating permit during the first Title V r enewal period after the agreement is entered into.**  **While KDHE will determine the compliance date and emissio**  **n limit, we encourage you to suggest a compliance schedule and to propose a BART limit consistent wit**  **h the above guidance. KDHE will allow you to average emissions across any**  **set of BART-eligible emission units within a facil ity, so**  **long as facility-wide emission reductions from each pollutant being controlled for BART would be equal**  **or greater than those reductions expected by simply co**  **ntrolling each of the BART-eligible units at a BART**

  ** eligible source.**