REVISIONS TO THE STATE IMPLEMENTATION PLAN (SIP)
CONCERNING REGIONAL HAZE

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

PROJECT NO. 2007-016-SIP-NR

Proposed

December 5, 2007 Adopted

February 25, 2009SECTION VI. CONTROL STRATEGY

A. Introduction (No change.)

B. Ozone (No change.)

C. Particulate Matter (No change.)

D. Carbon Monoxide (No change.)

E. Lead (No change.)

F. Oxides of Nitrogen (No change.)

G. Sulfur Dioxide (No change.)

H. Conformity with the National Ambient Air Quality Standards (No change.)

I. Site Specific (No change.)

J. Mobile Source Strategies (No change.)

K. Clean Air Interstate Rule (No change.)

L. Transport (Proposed.)

M. Regional Haze (New.)ES- 1 EXECUTIVE SUMMARY The Federal Clean Air Act (FCAA) and United States Environmental Protection Agency ( EPA ) regulations require states to submit State Implementation Plan ( SIPs ) to make “reasonable progress” in reducing visibility impairment at Federal Class I Federal areas resulting from anthropogenic pollution. FCAA, 169A(a)(1), “declares as a national goal the prevention of any future, and the remedying of any existing impairment of visibility in mandatory Federal Class I
Federal areas which impairment results from man-made air pollution.” Class I areas are national parks over 6,000 acres and wilderness areas over 5,000 acres that Congress has recognized at significant sites . These SIPs must “contain such emission limits, schedules of compliance and other measures as may be necessary to make reasonable progress toward meeting the national goal” including requiring installation, operation, and maintenance of Best Available Retrofit Technology (BART), “as determined by the State” on certain existing stationary sources.

The EPA Regional Haze Rule strongly encourages states to work together in regional partnerships to reduce haze. There are five regional planning organizations in the United States. Texas is a member of the Central Regional Air Planning Association (CENRAP), which includes nine states, Texas, Louisiana, Oklahoma, Arkansas, Kansas, Missouri, Nebraska, Iowa, and Minnesota. CENRAP provides analysis, modeling results, and informational exchange among states, but each state submits its own regional haze SIP.

The FCAA, Section 169A and B require the EPA to adopt regulations to reduce visibility impairment resulting “from man-made air pollution” in 156 Federal Class I Federal areas. The regulations require each state SIP to contain control measures, including BART, to make reasonable progress toward the national goal of natural visibility conditions by 2064 in all Class I areas. The two Class I areas in Texas are Big Bend and Guadalupe Mountains National Parks. Each state bordering Texas has one or more Federal Class I Federal areas designated for visibility protection. Where Texas’ emissions impact visibility in Federal Class I Federal areas in other states, the Texas SIP must include plans to reduce Texas’ visibility impacts in those areas too.

The EPA adopted Regional Haze regulations in 40 Code of Federal Regulations (CFR) Part 51, subpart P, on July 1, 1999, and adopted amendments to Subpart P and a new Appendix Y (BART guidelines) to Part 51 on July 6, 2005.

The 1990 FCAA Amendments together with EPA’s Regional Haze Rule set the goal of reducing “man-made” impacts on visibility in Class I areas to zero (i.e., to “natural” conditions) by 2064 for the worst 20 percent visibility days and prev enting any degradation for the best 20 percent visibility days. CENRAP and other Regional Air Planning Organizations have cooperated to calculate the base period (2000-2004) worst 20 percent and best 20 percent visibility for each Class I area. CENRAP is contracting has developed projections of visibility impairment in 2018, the initial year for which each state’s long-term stra tegy is to be evaluated. The state must reduce its visibility impairment impact at all Class I areas it impacts by as much as is reasonable. The format of this SIP revision follows a prescribed template developed by the CENRAP states.

The TCEQ used a refined estimate of natural cond itions for Class I areas in Texas and other states as permitted by EPA guidance. These refined estimates account for natural dust storms, which explain a significant number of impaired days at the Texas Class I areas.

The Clean Air Interstate Rule (CAIR) program is expected was designed to reduce interstate transport of emissions that affect fine particulate matter and ozone. Because these precursor emissions affect visibility, the CAIR program is also an integral part of reducing regional haze impact . Following the legislature’s statutory direction, the TCEQ adopted CAIR requirements applicable to electric generating units in Texas. Interstate trading of CAIR emission reduction credits makes the prediction of CAIR’s visibility improvement benefits uncertain for each Class I

area.ES- 2 Additionally On July 11, 2008 , the United States Court of Appeals for the District of Columbia Circuit vacated CAIR in its entirety. Upon a motion for rehearing, the appeals court issued a decision remanding CAIR to EPA to initiate rulemaking consistent with its opinion, but the court did not vacate CAIR, allowing it to remain in effect until replaced by EPA rule. The TCEQ expects that a replacement program will be in place that makes comparable reductions in pollutants causing regional haze prior to 2018.

The commission has also adopted the requirements of the BART program, which requires certain older sources with a visibility impairment impact on a Class I area to apply BART to the source to reduce its impact on a nearby Class I area. This SIP revision contains a list of BART-eligible
sources and the determination another list of BART for each source t hat is modeling outcomes. The appendix contains modeling summaries of sources that were reasonably anticipated to contribute to visibility impairment (BART

- subject). ; however, after modeling, these sources were
below the EPA threshold.

Each state must evaluate and determine if additional emissions reductions are necessary. The statute and EPA rules and guidance set criteria for determining whether additional reductions are reasonable. These criteria are based on the cost of controls and other related factors. The TCEQ has determined that no additional controls will be implemented with this SIP revision.

Reductions at Big Bend are dependent upon reducing emissions from Mexico and Central America. The TCEQ specifically asks the EPA for federal efforts to reduce the international transport impacts on regional haze coming into the United States across Texas’ southern border. CENRAP modeling estimates of the base period visibility impairment at the two Texas Class I areas from the United States and foreign contributions indicate 52 percent of the visibility impairment at Big Bend National Park and 20 perc ent of the visibility impairment at Guadalupe Mountains National Park on the worst 20 percent of regional haze days comes from international transport. The preamble to the July 1, 1999, issuance of the Regional Haze Rule clearly says that states are not required to carry out compensatory overcontrol to make up for the lack of progress in reducing the impacts of international transport. The TCEQ expects that the EPA will pursue international emission reductions to improv e visibility at Texas’ Class 1 areas.

In conclusion, the TCEQ has implemented rules that limit and minimize emissions causing both
local Texas and regional visibility impairment. The Texas SIP includes numerous rules that
minimize emissions that cause or contribute to local Texas and regional visibility impairment. The TCEQ plans to continue to im plement all these rules that protect visibility at Class I areas in
Texas and other states.i SECTION V: LEGAL AUTHORITY

A. General The TCEQ has the legal authority to implement, maintain and enforce the National Ambient Air Quality Standards (NAAQS) and to control the qu ality of the state’s air, including maintaining adequate visibility.

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s Texas Civil Statutes. The Legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003 and 2005. In 1989, the TCAA was codified as Chapter 382 of the Texas Health & Safety Code.

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution control agency and is the principal authority in the state on matters relating to the quality of air resources. In 1991, the Legislature abolished the TACB effective September 1, 1993, and its powers, duties, responsibilities and functions were transferred to the Texas Natural Resource Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the general provisions, organization and general powers and duties of the TNRCC, and the responsibilities and authority of the Executive Director. This Chapter also authorizes the TNRCC to implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 77 th Texas Legislature continued the existence of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas Commission on Environmental Quality (TCEQ).

The TCAA specifically authorizes the TCEQ to es tablish the level of quality to be maintained in the state’s air and to control the quality of the st ate’s air by preparing and developing a general, comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect information to enable the commission to develop an inventory of emissions; conduct research and investigations; enter property and examine records; prescribe monitoring requirements; institute enforcement proceedings; enter into contracts and execute instruments; formulate rules; issue orders taking into consideration factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; conduct hearings; establish air quality control regions; encourage cooperation with citizens’ groups and other agencies and political subdivisions of the state as well as with industries and the Federal Government; and establish and operate a system of permits for construction or modification of facilities.

Local government authority is found in Subchapter E of the TCAA. Local governments have the same power as the TCEQ to enter property and make inspections. They also may make recommendations to the commission concerning any action of the TCEQ that affects their territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements with the TCEQ or other local governments. In addition, a city or town may enact and enforce ordinances for the control and abatement of air pollution not inconsistent with the provisions of
the TCAA or the rules or orders of the commission.

Subchapters F, G, and H of the TCAA authorize the TCEQ to establish low emission vehicle requirements for mass transit authorities, local government fleets, and private fleets; create a mobile emissions reduction credit program; establish vehicle inspection and maintenance programs in certain areas of the state, consistent with the requirements of the F ederal Clean Air Act; establish gasoline volatility and low emission diesel standards; and fund and authorize participating counties to implement low-income ve hicle repair assistance, retrofit and accelerated vehicle retirement programs.ii B. Applicable Law The following statutes and rules provide necessary authority to adopt and implement the SIP. The rules listed below have previously been submitted as part of the SIP.

Statutes TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2005

TEXAS WATER CODE September 1, 2005

All sections of each subchapter are included, unless otherwise noted.

Chapter 5: Texas Natural Resource Conservation Commission Subchapter A: General Provisions Subchapter B: Organization of the Texas Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties of the Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§ 5.225, 5.226, 5.227, 5. 2275, 5.232, and 5.236) Subchapter H: Delegation of Hearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency and Temporary Orders (§§ 5.514, 5.5145 and 5.515 only)

Chapter 7: Enforcement Subchapter A: General Provisions (§§ 7.001, 7.002, 7.0025, 7.004, 7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§ 7.032 only) Subchapter C: Administrative Penalties Subchapter E Criminal Offenses and Penalties: §§ 7.177, 7.179-7.181

Rules All of the following rules are found in Title 30, Texas Administrative Code, as of the following
effective dates:

Chapter 7, Memoranda of Understanding, §§ 7.110 and 7.119 May 2, 2002

Chapter 35, Subchapters A-C, K: Emergency and Temporary December 10, 1998 Orders and Permits; Temporary Suspension or Amendment of
Permit Conditions

Chapter 39, Public Notice, §§ 39.201; 39.401; 39.403(a) and August 15, 2002 (b)(8)-(10); 39.405(f)(1) and (g); 39.409; 39.411 (a), (b)(1)-(6) and (8)-(10) and (c)(1)-(6) and (d); 39.413(9), (11), (12) and (14); 39.418(a) and (b)(3) and (4); 39.419(a), (b),(d) and (e); 39.420(a), (b) and (c)(3) and (4); 39.423 (a) and (b); 39.601; 39.602; 39.603; 39.604; and 39.605

Chapter 55, Request for Contested Case Hearings; Public August 29, 2002 Comment, §§ 55.1; 55.21(a) - (d), (e)(2), (3) and (12), (f) and (g); 55.101(a), (b), (c)(6) - (8); 55.103; 55.150; 55.152(a)(1), (2) and (6) and (b); 55.154; 55.156; 55.200; 55.201(a) - (h); 55.203; 55.205; 55.206; 55.209 and 55.211

Chapter 101: General Air Quality Rules August 16, 2007iii Chapter 106: Permits by Rule, Subchapter A June 30, 2004

Chapter 111: Control of Air Pollution from Visible Emissions July 19, 2006
and Particulate Matter

Chapter 112: Control of Air Pollution from Sulfur Compounds July 12, 2001

Chapter 113: Standards of Performance for Hazardous Air Pollutants June 15, 2005 and for Designated Facilities and Pollutants

Chapter 114: Control of Air Pollution from Motor Vehicles July 19, 2007

Chapter 115: Control of Air Pollution from Volatile Organic Compounds July 19, 2007

Chapter 116: Permits for New Construction or Modification March 15, 2007

Chapter 117: Control of Air Pollution from Nitrogen Compounds June 14, 2007

Chapter 118: Control of Air Pollution Episodes March 5, 2000

Chapter 122, § 122.122: Potential to Emit December 11, 2002

Chapter 122, § 122.215: Minor Permit Revisions June 3, 2001

Chapter 122, § 122.216: Applications for Minor Permit Revisions June 3, 2001

Chapter 122, § 122.217: Procedures for Minor Permit Revisions December 11, 2002

Chapter 122, § 122.218: Minor Permit Revision Procedures for Permit Revisions June 3, 2001 Involving the Use of Economic Incentives, Marketable Permits, and Emissions Tradingiv TABLE OF CONTENTS

LIST OF TABLES................................................................................. vii
LIST OF FIGURES................................................................................. ix
LIST OF APPENDICES........................................................................... xi
LIST OF ACRONYMS........................................................................... xii

CHAPTER 1. BACKGROUND AND OVERVIEW OF THE FEDERAL REGIONAL
HAZE REGULATION.................................................................. 1-1
1.1 GENERAL BACKGROUND............................................................... 1-1
1.2 VISIBILITY-IMPAIRING EMISSIONS................................................... 1-1
1.3 HISTORY OF FEDERAL REGIONAL HAZE RULE................................. 1-4
1.4 CLASS I AREAS.............................................................................. 1-4

CHAPTER 2. GENERAL PLANNING PROVISIONS .................................... 2-1
2.1 INTRODUCTION.............................................................................. 2-1
2.2 PUBLIC HEARING AND COMMENT INFORMATION............................... 2-1

CHAPTER 3. REGIONAL PLANNING...................................................... 3-1
3.1 OVERVIEW.................................................................................... 3-1
3.2 HISTORY OF TEXAS PARTICIPATION................................................ 3-3

CHAPTER 4. STATE, TRIBE, AND FEDERAL LAND MANAGER
CONSULTATION........................................................................ 4-1
4.1 INTRODUCTION............................................................................... 4-1
4.2 CONSULTATION ON CLASS I AREAS IN TEXAS.................................... 4-1
4.3 CONSULTATIONS ON CLASS I AREAS IN OTHER STATES..................... 4-2

CHAPTER 5. ASSESSMENT OF BASELINE AND CURRENT CONDITIONS AND
ESTIMATE OF NATURAL CONDITIONS IN CLASS I AREAS............... 5-1 5.1 VISIBILITY REQUIREMENTS............................................................ 5-1 5.1.1 Default and Refined Values for Natural Visibility Conditions........................ 5-2 5.1.2 Consultation Regarding the Vi sibility Metrics.......................................... 5-2

5.2 BASELINE VISIBILITY CONDITIONS................................................ 5-3
5.3 NATURAL VISIBILITY CONDITIONS................................................... 5-3
5.3 NATURAL VISIBILITY CONDITIONS ONGOING EFFORTS..................... 5-6

CHAPTER 6. MONITORING STRATEGY..................................................... 6-1
6.1 INTRODUCTION.............................................................................. 6-1
6.2 MONITORING AT CLASS I AREAS IN TEXAS....................................... 6-1
6.3 ASSESSMENT OF VISIBILITY IMPROVEMENT AT CLASS I AREAS............ 6-1
6.4 REPORTING VISIBILITY MONITORI NG DATA TO THE ADMINISTRATOR... 6-3
6.5 ASSESSING THE IMPACT OF EMISSIONS FROM TEXAS ON CLASS I
AREAS.................................................................................... 6-3

CHAPTER 7. EMISSIONS INVENTORY................................................... 7-1

CHAPTER 8. MODELING ASSESSMENT................................................... 8-1
8.1 OVERVIEW.................................................................................... 8-1
8.2 BACKGROUND.............................................................................. 8-1
8.3 CENRAP MODELING TEAM............................................................... 8-2 8.4 THE 2002 ANNUAL EMISSIONS AND AIR QUALITY MODELING............... 8-3 8.4.1 Modeling Protocol........................................................................... 8-3 8.4.2 Quality Assurance Project Plan (QAPP)................................................... 8-3v 8.4.3 Model Selection.............................................................................. 8-3 8.4.4 MM5 Meteorological Model Configuration................................................ 8-4 8.4.5 SMOKE Emissions Model Configuration ................................................ 8-5 8.4.6 CMAQ Air Quality Model Configuration ................................................ 8-5 8.4.7 CAMx Air Quality Model Configuration ................................................ 8-5 8.4.8 Modeling Domains........................................................................... 8-6 8.4.9 Vertical Structure of Modeling Domain................................................... 8-7
8.4.10 2002 Calendar Year Selection............................................................ 8-8 8.4.11 Initial Concentrations and Boundary Conditions ....................................... 8-9 8.4.12 Emission Input Preparation............................................................... 8-10 8.4.13 Meteorological Data Input Preparation................................................... 8-11 8.4.14 Photolysis Rate Model Input............................................................ 8-12 8.4.15 Air Quality Data Input Preparation....................................................... 8-12 8.4.16 2002 Base Case Modeling and Model Performance Evaluation .................. 8-13 8.4.17 2018 Modeling and Visibilit y Projections ................................................ 8-15 8.4.18 Additional Supporting Analysis .......................................................... 8-19

CHAPTER 9. BEST AVAILABLE RETROFIT TECHNOLOGY........................ 9-1 9.1 BART-Eligible Sources in Texas.............................................................. 9-1 9.2 Determination of Sources Subject to BART .............................................. 9-6 9.2.1 Cumulative Modeling Using CAMx PSAT............................................. 9-6 9.2.2 Individual Source Attribution Approach.................................................. 9-13

9.3 SITES REMOVED FROM FURTHER BART CONSIDERATION.................... 9-15
9.4 POST

- BART EMISSIONS REDUCTIONS 9.4 DETERMINATION OF BART FOR
SOURCES SUBJECT TO BART ....................................................... 9-17
9.5 SITES REMOVED FROM FURTHER BART CONSIDERATION 9.5 POST-BART
EMISSIONS REDUCTIONS

.......................................... .................. 9-21

CHAPTER 10. REASONABLE PROGRESS GOALS......................................... 10-1
10.1 INTRODUCTION ............................................................................ 10-1
10.2 REASONABLE PROGRESS GOALS FOR TEXAS CLASS I AREAS.............. 10-1
10.3 CONSIDERATION OF ADDITIONAL POLLUTION CONTROL .................. 10-4
10.4 FOUR FACTOR ANALYSIS ................................................................ 10-6 10.4.1 Applying the Statutory Factors ........................................................ 10-8 10.4.2 Four Factor Analysis Process............................................................. 10-8
10.5 UNCERTAINTY IN THE REASONABLE PROGRESS GOALS..................... 10-10
10.6 INTERNATIONAL SOURCES OF VISIBILITY IMPAIRMENT.................... 10-11 10.7 REDUCTIONS REQUIRED TO MEET THE UNIFORM RATE OF PROGRESS... 10-11
10.8 CONSULTATION........................................................................ 10-12
10.9 REPORTING................................................................................. 10-12

CHAPTER 11. LONG-TERM STRATEGY TO REACH REASONABLE
PROGRESS GOALS....................................................................... 11-1
11.1 INTRODUCTION............................................................................ 11-1 11.1.1 Reasonably Attributable Visibility Impairment..................................... 11-6

11.2 CONSULTATION............................................................................ 11-6
11.2.1 Consultation on Class I Areas in Texas.............................................. 11-7 11.2.2 Consultation on Class I Areas Impacted by Emissions from Texas ................ 11-7 11.2.3 Texas’ Impacts and 2018 Impact Reduction for Class I Areas Outside Texas...... 11-7 11.3 REQUEST FOR FEDERAL EFFORTS TO REDUCE INTERNATIONAL
TRANSPORT.............................................................................. 11-29
11.4 MINIMIZING VISIBILITY IMPAIRMENT FROM TEXAS EMISSIONS......... 11-30 11.4.1 Opacity Limitations........................................................................ 11-30
11.4.2 Sulfur Emission Limitations............................................................. 11-30 11.4.3 Best Available Control Technology (BACT) Requirements........................ 11-30vi 11.4.4 Programs to Manage Smoke Im pacts on Class I Areas.............................. 11-31 11.4.5 Program to Lower the Impact of Constr uction Activity on Air and Water Quality...11-31

11.5 FEDERAL PROGRAMS THAT REDUCE EMISSIONS.............................. 11-32 11.5.1 Texas Vehicle Inspection and Maintenance Programs................................ 11-32 11.5.2 Air Check Texas Repair and Replacement Assistance Program.................... 11-32

11.6 EMISSION REDUCTIONS SINCE ISSUANCE OF THE REGIONAL
HAZE RULE.............................................................................. 11-33
11.6.1 NO X Emission Reduction Requirements in Texas Ozone SIP Revisions......... 11-33

11.6.2 SO 2 and NO X Reduction Requirements under Senate Bill 7......................... 11-33
11.6.3 CAIR Reductions for NO X and SO 2 ...................................................... 11-34 11.6.4 Best Available Retrofit Technology (BART) Requirements......................... 11-36 11.6.5 Comparison of the NO X Emission Limits for EGUs with CAIR Limits............. 11-37 11.6.6 Sulfur Dioxide Reductions under the EPA Refinery Consent Decrees............. 11-38 11.6.7 Texas Low Emissions Diesel (TxLED) Program ...................................... 11-38
11.6.8 The Texas Emission Reducti on Plan (TERP).......................................... 11-38

CHAPTER 12. COMPREHENSIVE PERIODIC IMPLEMENTATION PLAN REVISIONS AND ADEQUACY OF THE EXISTING PLAN..................................... 12-1vii LIST OF TABLES

Table 1-1: Visibility-Impairing Pollutants....................................................... 1-2 Table 1-2: Comparison of Ambient Fine Particles (Ultrafine plus Accumulation-Mode)
and Coarse Particles............................................................... 1-3
Table 4-1: Consultation Calls .................................................................. 4-1
Table 5-1: Baseline Haze Indices............................................................... 5-3 Table 5-2: Visibility Metrics for the Class I Areas in Texas................................. 5-4 Table 7-1: CENRAP’s 2002 Base Year Emissions Inventory Summary for Texas...... 7-1 Table 7-2: Statewide Biogenic Emissions...................................................... 7-2 Table 7-3: CENRAP’s 2018 Emissions Inventory Summary for Texas.................. 7-3
Table 8-1: Federal Mandated Class I Area s in the CENRAP States.......................... 8-2 Table 8-2: MM5 34 Vertical Layer Definitions............................................... 8-8 Table 8-3: Ground-level Ambient Data Monitoring Networks and Stations for 2002.... 8-13
Table 9-1: BART

- T able Emissions from Companies Surveyed as a Percentage
of State Total Point Source Emissions .......................................... 9-2 Table 9-2: BART-Eligible Sources Based on Results of TCEQ Survey................... 9-3
Table 9-3: BART-Eligible Sources Screened Out Using Cumulative CAMx Modeling . . 9- 7
Table 9-4: BART-Eligible Source Distance to Each Class I Area ......................... 9- 9
Table 9-5: BART-Eligible Sources Exempted Based on CALPUFF Modeling ........ 9- 14 Table 9-6: BART-Eligible Sources Screened Out on Individual Basis Using

CAMx................................................................................ 9-15 Table 9-7: Sites Removed From BART Due to Exemption Requests ....................... 9-16 Table 9-8: Summary of BART-Eligible Source Determinations ............................. 9-17
Table 9-9: Post-BART Emissions Reductions at Texas Sources............................. 9-21 Table 10-1: Uniform Rate of Progress for Class I Areas in Texas on Worst 20 Percent Days......................................................................... 10-1 Table 10-2: Reasonable Progress Goals for Class I Areas on Worst 20 Percent Days.................................................................................... 10-1 Table 10-3: Reasonable Progress Goals for Class I Areas on Best 20 Percent Days....... 10-4
Table 10-4: Cost of Controls for Class I Areas ................................................. 10-5
Table 10-5: TCEQ Point Source Control Strategy Summary ................................. 10-5
Table 10-6: Estimated Haze Index Improvements for Affected Class I Areas .............. 10-6 Table 10-7: Comparison of Sulfur Dioxide Emissions ..................................... 10-10 Table 10-8: Contributions to Visibility in the Texas Class I Areas on Worst 20 Percent Days..................................................................... 10-11 Table 10-9: Emissions Reductions Required to Meet Uniform Rate of Progress.......... 10-11
Table 11-1: Pollutant Contributions to Extinction at Big Bend from Texas and from All Areas on Worst 20 Percent Days in 2002 and 2018................. 11-4 Table 11-2: Pollutant Contributions to Extinction at Guadalupe Mountains from Texas and from All Areas on Worst 20 Percent Days in 2002 and 2018 .... 11-6
Table 11-3: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Carlsbad Caverns National Park on Worst 20 Percent Days ............................................................ 11-10 Table 11-4: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Salt Creek Wilderness Area on Worst 20 Percent Days ...................................................................... 11-12 Table 11-5: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at White Mountain Wilderness Area on Worst 20 Percent Days............................................................. 11-13 Table 11-6: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Wheeler Peak Wilderness Area on Worst 20 Percent Days.......................................................... 11-15viii Table 11-7: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Wichita Mountains Wilderness Area on Worst 20 Percent Days................................................... 11-16 Table 11-8: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Great Sand Dunes Wilderness Area on Worst 20 Percent Days......................................................... 11-19 Table 11-9: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Rocky Mountain National Park on Worst 20 Percent Days............................................................ 11-20 Table 11-10: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Caney Creek Wilderness Area on Worst 20 Percent Days..................................................................... 11-23 Table 11-11: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Upper Buffalo Wilderness Area on Worst 20 Percent Days............................................................ 11-24 Table 11-12: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Hercules-Glades Wilderness Area on Worst 20 Percent Days............................................................ 11-26 Table 11-13: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Mingo Wilderness Area on Worst 20 Percent Days.................................................................... 11-27 Table 11-14: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Breton Wilderness Area on Worst 20 Percent Days...................................................................... 11-29 Table 11-15: EGU Emission Allowances in Texas under the CAIR Program............ 11-34
Table 11-16: Texas Elec tric Generating Utility NO X Control Strategies Compared

to CAIR.............................................................................. 11-37
Table 11-17: Annual SO 2 Emissions at Consent Decree Impacted Sources............... 11-38ix LIST OF FIGURES

Figure 1-1: Regional Class I Areas............................................................. 1-5 Figure 3-1: Map of the Regional Plan ning Organizations ................................... 3-2 Figure 5-1: Generic Glide Path to Achieve Natural Conditions in 60 Years................. 5-2 Figure 5-2: Big Bend Uniform Rate of Progress (URP)...................................... 5-5 Figure 5-3: Guadalupe Mountains Uniform Rate of Progress............................... 5-5 Figure 7-1: Comparison of Base and Projected Annual Emissions by Source Category... 7-3 Figure 8-1: National Inter-RPO Modeling Domain............................................. 8-7 Figure 8-2: Observed and Base Case Modeled Concentrations at Big Bend.............. 8-14 Figure 8-3: Observed and Base Case Modeled Concentrations at Guadalupe
Mountains............................................................................. 8-15 Figure 8-4: 2018 Visibility Projections E xpressed as Percent of Meeting the 2018
URP Point............................................................................ 8-18 Figure 10-1: Glide Path for Big Bend Worst 20 Percent Days................................ 10-3 Figure 10-2: Glide Path for Guadalupe Mountains Worst 20 Percent Days................ 10-3 Figure 11-1: Comparison of Extinction, Deciviews and Visual Range....................... 11-2 Figure 11-2: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) Worst 20 Percent Days in 2002.................................................... 11-2 Figure 11-3: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) on Best 20 Percent Days in 2002 .................................................. 11-3 Figure 11-4: Areas and Pollutants Causing Regional Haze at Guadalupe Mountains (GUMO) on the Worst 20 Percent Days in 2002 ................ 11-5 Figure 11-5: Areas and Pollutants Causing Regional Haze at Guadalupe Mountains (GUMO) on Best 20 Percent Days in 2002 ....................... 11-5 Figure 11-6: Calculated Regional Haze Impacts of Emissions from Western Areas
of Texas at Each Class I Area in New Mexico on Worst 20 Percent Days in 2002........................................................................ 11-8 Figure 11-7: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns National Park on Worst 20 Percent Days in 2002............................... 11-9 Figure 11-8: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns National Park on Best 20 Percent Days in 2002 ................................. 11-10 Figure 11-9: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) in New Mexico on Worst 20 Percent Days in 2002............................ 11-11 Figure 11-10: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) in New Mexico on Best 20 Percent Days in 2002 .............................. 11-11 Figure 11-11: Areas and Pollutants Causing Regional Haze at White Mountain (WHIT) in New Mexico on Worst 20 Percent Days in 2002 ............... 11-12 Figure 11-12: Areas and Pollutants Causing Regional Haze at White Mountain (WHIT) in New Mexico on Best 20 Percent Days in 2002..................... 11-13 Figure 11-13: Areas and Pollutants Causing Regional Haze at Wheeler Peak Wilderness Area on Worst 20 Percent Days in 2002 ........................... 11-14 Figure 11-14: Areas and Pollutants Causing Regional Haze at Wheeler Peak Wilderness Area on Best 20 Percent Days in 2002............................... 11-14 Figure 11-15: Areas and Pollutants Causing Regional Haze at Wichita Mountains (WIMO) in Oklahoma on Worst 20 Percent Days in 2002................... 11-15 Figure 11-16: Areas and Pollutants Causing Regional Haze at Wichita Mountains (WIMO) in Oklahoma on Best 20 Percent Days in 2002..................... 11-16 Figure 11-17: Calculated Regional Haze Impacts of West Texas Emissions at Each Class I Area in Colorado Included in CENRAP PSAT Modeling on Worst 20 Percent Days in 2002.............................................. 11-17 Figure 11-18: Areas and Pollutants Causing Regional Haze at Great Sand Dunes (GRSA) in Colorado on Worst 20 Percent Days in 2002................... 11-18 Figure 11-19: Areas and Pollutants Causing Regional Haze at Great Sand Dunes (GRSA) in Colorado on Best 20 Percent Days in 2002........................ 11-18x Figure 11-20: Areas and Pollutants Causing Regional Haze at Rocky Mountains National Park (ROMO) in Colorado on Worst 20 Percent Days
in 2002................................................................................. 11-19 Figure 11-21: Areas and Pollutants Causing Regional Haze at Rocky Mountains National Park (ROMO) in Colorado on Best 20 Percent Days in 2002..... 11-20 Figure 11-22: Areas and Pollutants Causing Regional Haze at Caney Creek (CACR) in Arkansas on Worst 20 Percent Days in 2002....................... 11-21 Figure 11-23: Areas and Pollutants Causing Regional Haze at Caney Creek (CACR) in Arkansas on Best 20 Percent of Days in 2002..................... 11-22 Figure 11-24: Areas and Pollutants Causing Regional Haze at Upper Buffalo (UPBU) in Arkansas on Worst 20 Percent Days in 2002....................... 11-23 Figure 11-25: Areas and Pollutants Causing Regional Haze at Upper Buffalo (UPBU) in Arkansas on Best 20 Percent Days in 2002......................... 11-24 Figure 11-26: Areas and Pollutants Causing Regional Haze at Hercules-Glades (HEGL) in Missouri on Worst 20 Percent Days in 2002...................... 11-25 Figure 11-27: Areas and Pollutants Causing Regional Haze at Hercules-Glades (HEGL) in Missouri on the Best 20 Percent of Days 2002.................... 11-25 Figure 11-28: Areas and Pollutants Causing Regional Haze at Mingo (MING) in Missouri on Worst 20 Percent Days in 2002................................... 11-26 Figure 11-29: Areas and Pollutants Causing Regional Haze at Mingo (MING) in Missouri on Best 20 Percent Days in 2002..................................... 11-27 Figure 11-30: Areas and Pollutants Causing Regional Haze at Breton Wilderness Area (BRET) in Louisiana on Worst 20 Percent Days in 2002.............. 11-28 Figure 11-31: Areas and Pollutants Causing Regional Haze at Breton Wilderness Area (BRET) in Louisiana on Best 20 Percent Days in 2002

................. 11-28 Figure 11-32: CAIR Emission Reduction States................................................ 11-34xi LIST OF APPENDICES

Appendix 1-1 EPA Regional Haze Rule 1999 Appendix 2-1 Public Participation Process (after proposal) Appendix 2-2 Public Comments and Responses on SIP Draft (after proposal) Appendix 4-1 Summary of Three Texas Consultation Calls Appendix 4-2 Contact List for Consultation Calls Appendix 4-3 Additional Consultation Letters to Adjacent States Appendix 5-1 Discussion of the Original and Revised IMPROVE Algorithms Appendix 5-2 Estimate of Natural Visibility Conditions Appendix 5-2a Natural Events: Dust Storms in West Texas Appendix 5-2b Estimating Natural Conditions Based on Revised IMPROVE Algorithim Appendix 5-2c Texas Natural Conditions SAS Program File and Data Appendix 7-1 Texas Emissions Inventory Development: Base Year 2002 and Projected Year 2018 Appendix 7-2 Integrated Planning Model Projections of Electric Generating Unit Emissions for the Regional Haze State Implementation Plan Appendix 8-1 Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support Regional Haze SIP Appendix 8-2 Big Bend Model Performance Analysis Appendix 8-3 Modeling Protocol for the CENRAP 2002 Annual Emissions and Air Quality Modeling Appendix 8- 4 Quality Assurance Project Plan for Central Regional Air Planning Association Emissions and Air Quality Modeling Appendix 9-1 U.S. EPA BART Rule Appendix 9-2 Texas BART Rule Appendix 9-3 Texas Survey for BART-Eligibility CAMx Modeling Protocol, Screening Analysis of Potentially BART

- Eligible Sources in Texas (online) Appendix 9-4 CAMx Modeling Pro tocol, Screening Analysis of Potentially BART- Eligible Sources in Texas Appendix 9- 5 CAMx Modeling Report, Final Report, Screening Analysis of Potential BART-Eligib le Sources in Texas (online) Appendix 9- 6 CAMx Screening Modeling Report and Addendums 1 and 2 (online) Appendix 9- 7 Certification of Screening Modeling Data Appendix 9- 8 CALPUFF Modeling Guidelines and Modeling Summaries (online) Appendix 9

- 8 CAMx Modeling Guidelines (online) Appendix 9-9 CAMx Modeling Guidelines Appendix 9-10 BART Engineering Guidance Documents and Forms Appendix 9- 11 Documentation of Emission Reductions Appendix 9- 12 County Abbreviations Appendix 9- 13 BART-Eligible List Appendix 10-1 Analysis of Control Strategies RPG Appendix 10-2 Estimating Visibility Impacts from Additional Point Source Controls Appendix 10-3 Uniform Rate of Progress Curves Using Default Natural Conditions
Estimates Appendix 10-4 Detailed Calculations for Estimating Visibility Impacts Appendix 11-1 Fire Management Plans Appendix 11-2 Federal and Texas Programs Related to On-road and Non-road
Mobile Sources Appendix 11-3 Major Point Source NO X Rules and Reductions Promulgated in Texas
Since 2000 Appendix 11-4 ASARCO El Paso Deleted: 3

Deleted: 4

Deleted: 5

Deleted: 6

Deleted: 7

Deleted: 10

Deleted: 11

Deleted: 12xii LIST OF ACRONYMS

AEO Annual Energy Outlook, forecasts by Department of Energy

AOI Area of influence B20% Best 20 percent (days of visibility) BACT Best Available Control Technology

BADL Badlands Wilderness Area
BAND Bandelier Wilderness Area BART Best Available Retrofit Technology BC Boundary conditions BEIS3 Biogenic Emissions Inventory System Version 3 Bext Light extinction BIBE Big Bend National Park

bnatural Clean natural conditions BOAP Bosque del Apache Wilderness Area BOWA Boundary Waters Canoe Area Wilderness BRAVO Big Bend Regional Aerosol and Visibility Observational study

BRET Breton Wilderness Area bsource Total light extinction due to a source CACR Caney Creek Wilderness Area
CAIR Clean Air Interstate Rule

CALPUFF California Puff Model

CAMR Clean Air Mercury Rule CAMx Comprehensive Air Quality Model with extensions CENRAP Central Regional Air Planning Association CFR Code of Federal Regulations

CM Coarse mass CMAQ Community Multiscale Air Quality Modeling System

DRI Desert Research Institute

dv deciviews

EC Elemental carbon EGAS Economic Growth Analysis System EGU Electric generating unit ENVIRON ENVIRON International Corporation EPA United States Environmental Protection Agency

ERCOT Electric Reliability Council of Texas f(RH) Relative Humidity adjustment factor

FCAA Federal Clean Air Act FIPS Federal Information Processing Standard FLAG Federal Land Managers’ Air Quality Related Values Work Group FLM Federal Land Manager

FS United States Forest Service

FWS United States Fish and Wildlife Service

FR Federal Register

GEOSCHE M Chem Goddard Earth Observing System - Chemistry model

GICL Gila Wilderness Area

GRSA Great Sand Dunes Wilderness Area GUMO Guadalupe Mountains National Park

HEGL Hercules-Glades Wilderness Area Deleted:xiii HI Haze Index

IC Initial conditions IDNR Iowa Department of Natural Resources IMPROVE Interagency Monitoring of Protected Visual Environments IPM Integrated Planning Model ISLE Isle Royale National Park JPROC Photolysis Rates Processor

km kilometers

LAER Lowest Achievable Emission Rate

LOST Lostwood Wilderness Area LTS Long-term strategy

MACA Mammoth Cave National Park
MATS Modeled Attainment Test Software

mb millibars

MEVE Mesa Verde National Park MING Mingo Wilderness Area

Mm -1 Inverse Megameters
MM5 Mesoscale Meteorological Model, 5 th Generation (developed by Pennsylvania State University / National Center for Atmospheric Research PSU/NCAR)

MMS Minerals Management Service

MOBILE5 MOBILE Vehicle Emission Modeling Software Version 5

MOZI Mount Zirkel Wilderness Area MPE Model performance evaluation MPI Message passing interface MRPO Midwest Regional Planning Organization NAAQS National ambient air quality standards NARSTO North American Research Strategy for Tropospheric Ozone

NH

4 Ammonium

NO

3 Nitrate

NO

x Nitrogen oxides
non-EGU Non-electrical generating units

NPS National Park Service, United States Department of the Interior NSPS New source performance standards

NSR New Source Review OC Organic carbon OMC Organic mass carbon

PGM Photochemical Grid Model

PiG Plume-in-Grid PLUVUE Plume Visibility Model

PM Particulate matter

PM
10 Particulate matter with aerodynamic diameters less than 10
microns

PM
2.5 Particulate matter with aerodynamic diameters less than 2.5
microns POA Primary organic aerosol

PPM Piecewise-Parabolic Method PSAT Particulate Matter Source Apportionment Technology PSD Prevention of significant deterioration Deleted: MOBILE6

Deleted: MOBILE Vehicle Emission Modeling Software
Version 6xiv PTE Potential to emit Q/D Emissions over distance (to Class I area) QA/QC Quality Assurance/Quality Control QAPP Quality Assurance Program Plan RH Relative Humidity ROMO Rocky Mountain National Park RPG Reasonable progress goal RPO Regional Planning Organization RRF Relative response factor (s?)

SACR Salt Creek Wilderness Area

SAPE San Pedro Parks Wilderness Area

SIP State Implementation Plan SIPS Sipsey Wilderness Area SMOKE Sparse Matrix Operator Kernel Emissions

SO

2 Sulfur dioxide

SO

4 Sulfate
SOA Secondary organic aerosol SOAA Secondary organic aerosols anthropogenic (human-made) SOAB Secondary organic aerosols biogenic (from plants)

TAC Texas Administrative Code

TCAA Texas Clean Air Act TCEQ Texas Commission on Environmental Quality

TEOM Tapered Element Oscillating Microbalance TERP Texas Emissions Reduction Program

THRO Theodore Roosevelt National Park TIP Tribal Implementation Plan TOMS Total Ozone Mapping Spectrometer satellite data

tpy tons per year TSD Technical Support Document TUV Tropospheric Ultraviolet and Visible (Radiation Model) UCR University of California at Riverside UPBU Upper Buffalo Wilderness Area URP Uniform rate of progress

VIEWS Visibility Information Exchange Web System VISTAS Visibility Improvement State and Tribal Association of the
Southeast VOC Volatile organic compounds VOYA Voyageurs National Park W20% Worst 20 percent (days of visibility)

WEMI Weminuche Wilderness Area

WHIT White Mountain Wilderness Area

WHPE Wheeler Peak Wilderness Area

WHRI White River National Forest

WICA Wind Cave National Park

WIMO Wichita Mountains 

### Wilderness Area WRAP Western Regional Air Partnership1-1 CHAPTER 1. BACKGROUND AND OVERVIEW OF THE FEDERAL

R EGIONAL HAZE REGULATION

1.1 GENERAL BACKGROUND Regional haze is visibility impairment that is produced by a multitude of sources and activities.
These emission sources and activities are loca ted across a broad geographical area. The emissions consist of fine particles and their pr ecursors. Visibility impairment caused by air pollution occurs virtually all of the time at most Class I visibility protected national park and wilderness area monitoring stations (VIEWS 2007) . A significant factor in visibility impairment is regional transport of fine particles that contribute to elevated particulate matter (PM) levels and regional haze impairment of visibility

. .

Haze-forming pollution comes from both human and natural sources. Windblown dust and soot from wildfires contribute to haze, as do motor ve hicles, electric generating facilities, industrial fuel burning, and manufacturing operations. PM and PM precursor emissions are the major cause of reduced visibility (haze) in the United States and at many of our national parks and wilderness areas. Some haze-forming particles are directly emitted into the air. The usual term for directly emitted particles is primary particles. Secondary particles, created when emitted gases form particles downwind of the emission sources, usually dominate the causes of regional haze.
Nitrates and sulfates , which result from NO 2 and SO 2 emissions, are examples of secondary particles that contribu te to regional haze.

In many scenic areas, haze substantially reduces visual range. In eastern Class I areas, haze from human activity reduces average visual range from the natural condition of approximately 90 miles to 15-to-25 miles. In the West, haze from human activity reduces visual range from the natural condition of approximately 140 miles to 35-to-90 miles. Haze Visibility impairment is
measured expressed in deciviews (dv). A deciview is a unit of visibility impairment proportional to the logarithm of the atmospheric light extincti on. One deciview is approximately the minimum amount of change in visibility impairment that a human observer can detect.

1.2 VISIBILITY-IMPAIRING EMISSIONS The Central Regional Air Planning Association (CENRAP) and the Texas Commission on Environmental Quality (TCEQ) data analysis and modeling show that several types of emissions are involved in reducing visibility, including sulfur dioxide (SO 2 ), nitrogen oxides (NO X ), and particulate matter (PM). Table 1-1: Visibility-Impairing Pollutants and Table 1-2: Comparison of Ambient Fine Particles (Ultrafine plus Accumulation-Mode) and Coarse Particles discuss some of the emissions, different variations of the molecules in the atmosphere, and various sources of the emissions. Visibility improvement is not a Unlike pollutants like ozone, PM 2.5 , and carbon monoxide, visibility is not a measurable c oncentration for which a standard, like the national ambient air quality standard (NAAQS) that states must not exceed , like the ones for ozone, PM 2.5 , and carbon monoxide could be set . Instead, the Regional Haze Rule sets out procedures states
must follow to decide how much emission reduction is emissions reductions are reasonable to move toward the national goal that Congress has established under the Federal Clean Air Act (FCAA): returning Class I areas to natural visibility conditions. The United States Environmental Protection Agency (EPA) has set 2064 as the target date to reach the goal set by Congress to reach natural conditions at all Class I areas. To accomplish this goal, a state must first determine what “natural conditions” are and then plan how to reach those conditions.

Table 1-1 provides information about particulate matter components that contribute to regional
haze.1-2 Table 1-1: Visibility-Impairing Pollutants

Major Components
of Particles Symbol Directly
Emitted? Formed
in
the Air? Formed
From In which Size Range?
micrometers (μm) Major Sources

Sulfates SO 4 (Yes)* Yes SO 2 PM 2.5 Coal

- fired power plants,
oil fields and

refineries, paper mills

Nitrates NO 3 (No)* Yes NO 2 PM 2.5 All combustion

Secondary

Organic
Carbon OC No Yes VOC** PM 2.5 Gasoline, organic solvents,

evergreen
trees biogenics Primary Organic
Carbon OC Yes No -- PM 2.5 Incomplete
combustion

Elemental

Carbon (i.e., black

carbon) EC Yes No -- PM 2.5 Incomplete
combustion

Fine Soil

Dust FS Yes No -- PM 2.5 Wind blowing over loose soil,
motor vehicles running on paved and unpaved roads Coarse Mass,

which is normally
~ 100%
Coarse Soil

Dust CM Yes No -- PM COARSE , i.e.

PM 10 – 2.5 Wind blowing over loose soil,
motor vehicles running on paved and unpaved roads

*There are few significant, direct sulfate sources; direct nitrate sources are rare. **Volatile organic compounds

Table 1-2 provides additional information about particles. The table breaks down the fine particles into ultrafine particles that are less than 0.1 μm in diameter and accumulation mode particles that are generally between 0.1 and 1.0 μm in diameter. Ultrafine particles agglomerate to form accumulation mode particles. Some of the accumulation mode particles, most notably sulfates, grow above 1.0 μm in diameter, as the humidity becomes high. A relatively small percentage of the coarse soil and dust particles are smaller than 2.5 μm in aerodynamic diameter, so samplers collect them with the fine particles. Table 1-1 lists only typical, major sources of each component. Table 1-2 provides a more inclusive listing of sources. Deleted:1-3 Table 1-2: Comparison of Ambient Fine Particles (Ultrafine plus Accumulation-Mode) and
Coarse Particles

Ultrafine Accumulation Coarse

Formation

Processes: Combustion, high-temperature processes, and atmospheric reactions Break-up of large solids/droplets

Formed by: • Nucleation

• Condensation

• Coagulation • Condensation

• Coagulation

• Reactions of gases in or on particles

• Evaporation of fog and cloud droplets in which gases have
dissolved and reacted • Mechanical disruption (crushing, grinding, abrasion of surfaces)

• Evaporation of sprays

• Suspension of dusts

• Reactions of gases in or on particles

Composed of: • Sulfate

• Elemental carbon

• Metal compounds

• Organic compounds with very low saturation vapor pressure at ambient
temperature • Sulfate, nitrate ammonium, and hydrogen ions

• Elemental carbon

• Large variety of organic compounds

• Metals: compounds of Pb, Cd, V, Ni, Cu, Zn, Mn, Fe, etc.

• Particle-bound water • Suspended soil or street dust

• Fly ash from uncontrolled combustion of coal, oil, and
wood

• Nitrates/chlorides/sulfates from
HNO 3 ,/HCI/SO 2 reactions with coarse particles

• Oxides of crustal elements (Si, Al, Ti, Fe)

• CaCO 3 , CaSO 4 , NaC1, sea salt

• Pollen, mold, fungal spores

• Plant and animal fragments

• Tire, brake pad, and road wear
debris

Sources: • Combustion

• Atmospheric
transformation of

SO 2 and some organic compounds

• High temperature

processes • Combustion of coal, oil, gasoline, diesel fuel, wood

• Atmospheric
transformation products of NO

x , SO 2 , and organic compounds, including biogenic organic species (e.g., terpenes)

• High-temperature processes, smelters, steel mills, etc. • Resuspension of industrial dust
and soil tracked onto roads and

streets

• Suspension from disturbed soil (e.g., farming, mining, unpaved roads)

• Construction and demolition

• Uncontrolled coal and oil
combustion

• Ocean spray

• Biological sources

Atmospheric
half-life: Minutes to hours Days to weeks Minutes to hours

Atmospheric
Removal

Processes: • Grows into
accumulation mode

• Diffuses to raindrops • Forms cloud droplets and rains out (Organic
carbon and elemental carbon particles may not take up water until they have aged.)

• Dry deposition • Dry deposition by fallout

• Scavenging by falling rain drops

Travel distance: <1 to 10s of km 100s to 1000s of km <1 to 10s of km (small size tail, 100s to 1000s in dust storms)

Source: Adapted from Wilson and Suh (1997), CD, p. 2-52.1-4 1.3 HISTORY OF FEDERAL REGIONAL HAZE RULE In the FCAA amendments of 1977, Congress added §169 (42 United States Code (USC), §7491), setting forth a national visibility goal of restoring natural conditions in certain national parks and wilderness areas. The EPA designated national parks and wilderness areas meeting certain criteria and containing vistas as an important feature, as Class I areas for visibility protection under regional haze state implementation plan (SIP) provisions.

In response to the 1977 FCAA amendments, the EPA required control measures to address plume blight and reasonably attributable visibility impairment. These plume blight and reasonably attributable visibility impairment control measures did little to address regional haze throughout the contiguous 48 states.

When Congress amended the FCAA again in 1990, it added §169B (42 USC, §§7492) requiring further research and regular assessments of the progress made toward visibility goals. In 1993, the National Academy of Sciences concluded that “current scientific knowledge is adequate and control technologies are available for taking regulatory action to improve and protect visibility” (NRC 1993).

In addition to authorizing the creation of visibi lity transport commissions and setting forth their duties, §169B(f) of the FCAA specifically mandated the creation of the Grand Canyon Visibility Transport Commission (GCVTC) to make recommendations to the EPA for the region affecting visibility in Grand Canyon National Park. After f our years of research and policy development, the GCVTC submitted its report to the EPA in June 1996 (GCVTC 1996). This report, as well as other research reports prepared by the GCVTC, contributed information to the EPA’s development of the federal Regional Haze Rule.

The EPA promulgated the Regional Haze Rule on July 1, 1999 (Appendix 1-1: EPA Regional Haze Rule 1999) . The federal rule’s objective is to achieve the national visibility goal of restoring natural visibility conditions to Class I areas by 2064. Generally, the EPA’s default
estimates of natural conditions are 8 deciviews for the western states and 12 deciviews for the eastern states. States may calculate the natural conditions for each Class I area instead of using the default goal. Chapter 5: Assessment of Baseline and Current Conditions and Estimate of
Natural Conditions in Class I Areas discusses natural conditions in more detail. The rulemaking addressed the combined visibility effects of sources over a broad geographic region, meaning that many states, including all those without Class I areas, must participate in haze reduction efforts.

The EPA designated five Regional Planning Organizations (RPOs) to assist with the coordination and cooperation needed to address visibility and haze issues. Those states and tribes that make up the midsection of the contiguous United States, including Texas, were designated as the

CENRAP.

1.4 CLASS I AREAS Texas has two Class I areas within its borders, both located in West Texas (Figure 1-1: Regional
Class I Areas ). Big Bend National Park (Big Bend), in Brewster County, borders the Rio Grande and Mexico. Guadalupe Mountains National Park (Guadalupe Mountains), in Culberson County,
borders New Mexico. Chapter 11: Long-Term Strategies addresses Texas’ impacts and longterm strategies for Class I areas outside of Texas.1-5 Figure 1-1: Regional Class I Areas

Big Bend National Park Big Bend was authorized as a national park on June 20, 1935, and then established and signed into law on June 12, 1944, as the nation’s 27th national park. The park gets its name from the course of the Rio Grande, which makes a great bend from a southeasterly to a northerly direction in the western portion of Texas. Big Bend receives approximately 350,000 visitors annually.

The park is slightly larger than Rhode Island and comprises more than 801,000 acres (1,252 square miles). The boundary includes 118 miles of the Rio Grande, which is also the international border between the United States and Mexico. In 1978, Congress designated a 196- mile portion of the Rio Grande, from the Chihuahua and Coahuila state line to the Terrell and Val Verde county line, as a Wild and Scenic River. The upper 69 miles are within the boundaries of Big Bend.

The park exhibits dramatic contrasts; its climate is one of extremes. As a result of the range in altitude from 1,700 feet along the river to 7,800 feet in the Chisos Mountains, a wide variation in available moisture and in temperatures exists throughout the park. These variations contribute to the great diversity in plant and animal habitats.

Big Bend has national significance as the largest protected area of Chihuahuan Desert in the continental United States. The park’s river, desert, and mountain environments support an extraordinary richness of biological diversity and provide unparallel recreation opportunities. Few areas exceed the park’s values for the protection and study of geologic and paleontologic resources. Archeologists have discovered artifacts estimated to be 9,000 years old, and historic buildings and landscapes offer graphic illustration of life along the international border at the turn of the century. Big Bend is rich in economic, cultural, and military history from its extensive use by the Comanches, miners, farmers, ranchers, United States cavalry units, and Poncho Villa’s
revolutionaries.1-6 Big Bend was designated a Biosphere Reserve in 1976, under the Man and the Biosphere Program. Big Bend is one of only 250 such areas in the world whose ecosystems are particularly well preserved (National Park Service (NPS) 2007).

Guadalupe Mountains National Park Guadalupe Mountains was established on September 30, 1972, and contains Guadalupe Peak, the highest point in Texas at 8,749 feet (2,667 meters) in elevation, as well as the next three highest peaks in the state. The park covers 86,416 acres and is in the same mountain range as Carlsbad Caverns National Park, which is located about 40 miles to the northeast in New Mexico. The park also contains the only a congressionally designated wilderness in Texas, of 46,850 acres
called the Guadalupe Mountains Wilderness at 46,850 acres . The terrain is rough and natural with mountain peaks steeply rising up to 3,000 feet above the canyon floors.

The mountains are a “sky island” rising more than a mile above the floor of the Salt Basin on the west. The slopes extend through three major ecological zones from desert to remnants of a high altitude forest. Ponderosa pine, Douglas fir, white pine, and quaking aspen grow side by side with desert species such as agaves and cacti. The altitude encourages relatively high amounts of rainfall that quickly drain into the porous limestone bedrock and recharges the Capitan Aquifer.

The Guadalupe Mountains preserve the 2,000-foot thick limestone layer of the Capitan Reef, one of the finest examples of an ancient marine fossil reef on earth. Outcrops in the park expose rocks from the entire range of associated depositional environments from shallow lagoon to reef, forereef debris slopes, and deep basin deposits. The park contains the world standard section that represents the middle part of the Permian Period of geologic time. Geologists from around the world study the 280 to 260 million year old rocks preserved there (NPS 2007).2-1 CHAPTER 2. GENERAL PLANNING PROVISIONS

2.1 INTRODUCTION In accordance with 40 CFR §51.308(a) and (b), the TCEQ submits this state implementation plan (SIP) revision to meet the requirements of the EPA’s Regional Haze Rule. This plan addresses the core requirements of 40 CFR §51.308(d) and the Best Available Retrofit Technology (BART) components of 40 CFR §50.308(e). In addition, this SIP revision addresses coordination with regional planning groups, states and tribes, and the Federal Land Managers (FLMs). Texas also commits to plan revisions and adequacy determinations as outlined in this SIP.

2.2 PUBLIC HEARING AND COMMENT INFORMATION The TCEQ will provide provided notice to the public of the opportunity to comment on the proposed Regional Haze SIP after the commission approval for publication on December 5, 2007. The TCEQ will al so announce announced and hold held a public hearing. Notice of both the public hearing and the comment period will be were published in newspapers around the state (Appendix 2-1: Public Participation Process ) . The public comment period will begin began December 21, 2007, and end ended February 22, 2008. The public hearing will be was held in Austin on February 19, 2008. The length of the comment period will was longer to give sufficient time for the FLMs to provide recommendations on the proposed SIP revision that

can could be provided to the general public, as well as meet the requirement that FLMs are consulted at least 60 days prior to the public hearing on the SIP revision. The FLM comment period begins on was November 16, 2007, through January 16, 2008. The TCEQ web site will provide a summary of provided the complete FLM comments at least 30 days prior to the hearing
date.

The TCEQ will accept accepted comments electronically through the eComments system or by

, fax or , and mail. All comments should re ference referenced the “Regional Haze SIP” and project number 2007-016-SIP-NR. Electronic comments may be submitted at

< http://www5.tceq.state.tx.us/rules/ecomments/ > . File size restrictions m ay apply to comments being submitted via the eComments system. All eComments are acknowledged with a
confirmation e

- mail.

Fax or mail comments C omments went to:

Margaret Earnest
MC 206 State Implementation Plan Team, Chief Engineer’s Office
Texas Commi ssion on Environmental Quality

P. O. Box 13087
Austin TX 78711

- 3087 Fax: (512)

- 239

- 5687

Public Hearing

City Date Time Location

Austin February 19, 2008 2:00 PM Texas Commission on Environmental Quality 12100 Park 35 Circles, Austin TX 78753 Building E, Room 201S

Public comments, including those made by staff of federal agencies, will be were summarized and addressed in Appendix 2-2: Public Comments and Responses on SIP Draft . The final SIP will incorporate incorporated public comments as appropriate and will be published on the TCEQ’s
web site at <http://www.tceq.state.tx.us/implementation/air/sip/bart/haze.html>

.3-1 CHAPTER 3. REGIONAL PLANNING

3.1 OVERVIEW In the preamble to the Regional Haze Rule, the EPA acknowledged the key role of regional pollutant transport in contributing to haze in federal Class I areas and recognized the value of multi-state coordination for planning and implementing regional haze programs (EPA 1999). The EPA established grant funding for five RPOs as follows:

• Central Regional Air Planning Association

• Western Regional Air Partnership

• Midwest Regional Planning Organization

• Visibility Improvement State and Tribal Association of the Southeast

• Mid-Atlantic/Northeast Visibility Union.

Figure 3-1: Map of the Regional Planning Organizations shows the geographic areas of the five RPOs. Texas is a member of CENRAP, as are Oklahoma, Louisiana, Arkansas, Missouri, Kansas, Nebraska, Iowa, and Minnesota. Some tribes, including the Alabama Coushatta of eastern Texas, also participate in CENRAP.

The CENRAP’s planning process was initiated in late 1999 with the first in a series of workshops held to develop the organization’s charter and bylaws, to conduct initial long-range planning, and to prepare its first grant application. The organization’s charter can be found at CENRAP’s web
site: <www.cenrap.org>

.

The CENRAP defines the purposes of the organization as follows.

• Identify regional, common air management issues, and develop and identify strategies to
address these issues.

• Promote policies that ensure fair and equita ble treatment of all participating members.

• Coordinate science and technology to support air quality policy issues in the central

states.

• Promote the implementation of federal visibility rules.

• Recommend strategies on regional haze and other air quality issues for use by member states and tribes in developing implementation programs, regulations, and laws.

• Conduct research and undertake other activities as necessary to provide the membership with information to support the development of sound state and tribal air pollution policies.

In concurrence with EPA policy, the CENRAP’s bylaws state that “the CENRAP has no regulatory authority and recognizes that its members, in accordance with existing law, retain all legal authority” (CENRAP 2000). While Texas participates in CENRAP and benefits from the technical work coordinated by the RPO, Texas has sole responsibility and authority for the development and content of its Regional Haze SIP.3-2 Figure 3-1: Map of the Regional Planning Organizations

The Policy Oversight Group (POG) is the governing body for CENRAP. The POG establishes internal policies, protocols, strategies, and budgets and provides guidance to the various CENRAP workgroups. Voting membership on the POG includes:

• designee of governor or environmental commissioner from each member state; and

• one tribal representative for each of the EPA Regions V, VI, and VII.

Ex-officio membership on the POG includes the following:

• United States Secretary of the Interior or designee;

• United States Secretary of Agriculture or designee;

• Administrator of the EPA or designee;

• two representatives from local programs that are members of the Central States Air Resources Agencies (CenSARA); and

• additional tribal representatives design ated in accordance with the bylaws

The POG established five CENRAP workgroups that work in particular disciplines and facilitate the development of the regional haze implementation plans. The workgroups are as follows.

• Modeling

• Emissions Inventory

• Monitoring

• Implementation and Control Strategies

• Communications

The Communications workgroup establishes internal communication protocols, assists with contract development, manages the CENRAP web site, and conducts public outreach. The other four workgroups conduct strategic planning for their subject matter areas and conduct and
document the work of contractors or the in -kind services of CE NRAP participants.3-3 A Technical Steering Committee comprised of repr esentatives from the states, tribes, and other stakeholder groups discusses complex technical issues and provides technical guidance to the workgroups. Also, representatives from CENRAP participate in discussions with other RPOs about issues that affect some or all of the RPOs and that require close communication among these organizations.

The POG and workgroups meet quarterly or biannually, depending on the need. The technical steering committee meets biannually. The POG usually holds conference calls once per month. The frequency of workgroup and steering committee conference calls varies.

The CENRAP may remain active following the initial submission of implementation plans by the states, since the Regional Haze Rule requires periodic progress reports and implementation plan
revisions. The extent to which the CENRAP re mains active will depend on the usefulness of the organization to its members and the availability of continuing, adequate funding to cover the organization’s expenses.

3.2 HISTORY OF TEXAS PARTICIPATION The TCEQ has participated in the planning process for regional haze since December 1999, whena workshop was convened by CenSARA to begin developing the charter, bylaws, and initial longrange plan for the CENRAP. After workgroups were formed, the TCEQ participated in the Modeling, Emissions Inventory, Monitoring, and Implementation and Control Strategies workgroups. The TCEQ designated appropriate workgroup representatives based on their areas of expertise. For approximately three years, a TCEQ staff member dedicated time as co-chair of the Emissions Inventory workgroup. For more than two years, four TCEQ staff members have dedicated time to monthly CENRAP conference calls with four of the technical workgroups and
dedicated additional time to activities that include analyzing modeling changes, participating in quality control checks, and more. In addition, the TCEQ has one SIP coordinator dedicated solely to regional haze issues. The TCEQ has represented the state on the POG and technical steering committee from their inceptions.

Significant portions of this SIP were developed based on emissions inventories, modeling, and SIP protocols created by the CENRAP and its contractors. Through its participation, the TCEQ provided data to the CENRAP in order to produce emissions inventories and modeling that the states could use when drafting their Regional Haze SIPs.

The Regional Haze Rule does not require states and tribes to participate in RPOs. However, Texas will continue participation in the CENR AP as necessary to fulfill the state’s legal obligations in meeting the requirements of the rule. Texas’ continued participation is contingent on CENRAP’s receiving continued, adequate funding from the EPA.4-1 CHAPTER 4. STATE, TRIBE, AND FEDERAL LAND
MANAGER CONSULTATION

4.1 INTRODUCTION Title 40 CFR §51.308(i) requires each state to consult with identified FLMs prior to the proposal of the Regional Haze SIP. In development of this plan, the FLMs were consulted in accordance with the provisions of §51.308(i)(2). In developing its reasonable progress goals (RPGs), states are required to consult with other states reasonabl y anticipated to cause or contribute to visibility impairment in their Class I areas. If a state determines it has emissions that are reasonably anticipated to contribute to visibility impairment in any Class I area in another state, that state must consult with the other states when developing its long-term strategy. The TCEQ provided other states, tribes, FLMs, and other stakeholders an opportunity for consultation through teleconference calls and notified the FLMs of their opportunity to consult in person at least 60 days prior to holding public hearings.

During the consultation process, the states, FLMs, and stakeholders were given the opportunity to
address the assessment of the visibility impairment of visibility in any Class I areas

, materials presented to stakeholders prior to the consultation calls

, recommendations on the development of

RPGs

, and recommendations on the development of strategies to address visibility impairment. Throughout the consultation calls, the TCEQ encouraged participants to continue coordination and consultation during the development of the SIP prior to adoption. The FLMs must be consulted in the following instances: development and review of implementation plan revisions; review of five-year progress reports; and development and implementation of other programs that may contribute to impairment of visibility in Class I areas.

4.2 CONSULTATION ON CLASS I AREAS IN TEXAS The TCEQ held Regional Haze SIP consultation meetings by conference call with FLMs for the Class I visibility areas in Texas, Big Bend and Guad alupe Mountains, other states that impact the Texas Class I areas, the EPA, and stakeholders such as industry and environmental representatives. Table 4-1: Consultation Calls contains the dates and times of the consultation
calls.

Table 4-1: Consultation Calls

Call Date Time

1 st Consultation call July 11, 2007 2:30-4:00 p.m.

2 nd Consultation call July 18, 2007 10:00-11:30 p.m.

3 rd Consultation call July 31, 2007 10:00-11:30 p.m.

The first consultation call primarily addressed four technical papers. These papers discussed natural conditions, the impacts of dust storms in Big Bend and Guadalupe Mountains, Integrated Planning Model (IPM) emission projections, and glide path and RPGs. A summary paper of these technical papers was provided to consultation participants.

The second and third consultation calls consisted of open dialogue between the states and FLMs to gather input on the content of the technical pa pers. Additionally, the FLMs suggested that the TCEQ revise the prevention of significant deterioration (PSD) permit process to include FLM notification provisions. Texas has committed to further consu ltations with the FLMs aimed at a mutually agreeable set of procedures to address their concerns about the Texas PSD program. Deleted: :

Deleted: ;

Deleted: ;

Deleted: ;4-2 More detailed summaries from all three calls are provided in Appendix 4-1: Summary of Three
Texas Consultation Calls

.

A list of persons or entities contacted to particip ate in the consultation process is provided in Appendix 4-2: Contact List for Consultation Calls . Chapter 11 of this SIP also discusses the consultation process regarding development of the long-term strategy.

The TCEQ has determined which states contribute to visibility impairment at the Texas Class I area by using the results from the CENRAP particulate matter source apportionment technology (PSAT) modeling. These states are New Mexico, Oklahoma, Kansas, and Louisiana. Appendix

8-1: Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support Regional Haze State Implementation Plans shows the pertinent modeling results. Texas is not requesting additional reductions from other states at this time.

4.3 CONSULTATIONS ON CLASS I AREAS IN OTHER STATES The TCEQ has participated in the CENRAP since its inception in 1999. The TCEQ has cooperated with all CENRAP states, tribes, and FLMs that participated in:

• developing information on base period 2002 visibility impairment;

• developing projections of 2018 emissions and visibility impairment considering all adopted emissions reductions required in Texas and federal rules; and

• developing estimates of 2064 natural conditions.

Texas and federal rules that specifically reduce visibility-impairing pollutants include the Clean Air Interstate Rule (CAIR), BART requirements, the emissions reductions from the federal motor vehicle emission control program (FMVCP), the EPA refinery consent decrees, and the EPA requirements for cleaner non-road diesel and gasoline-powered engines.

The TCEQ participated in the Modeling, Emissions Inventory, Monitoring, and Implementation and Control Strategies workgroups of CENRAP . The TCEQ designated appropriate workgroup representatives based on their areas of expertis e. For more than two years, the TCEQ has dedicated time to monthly technical workgroups through CENRAP conference calls. Since 1999, Texas has actively participated in regional planning (Chapter 3). The TCEQ also participated in inter-regional planning organization calls that related to modeling. The FLMs, EPA, tribes, states, and industry were encouraged to participate in workgroup calls, workshops, and meetings.

A rkansas and Missouri have begun consultation with Texas about the impact of Texas’ emissions on regional haze at the Class I areas in those states. They have accepted Texas’ planned
emission s and regional haze impact reductions as adequate for their Class I areas.

Oklahoma has invited Texas to consult about Oklahoma’s Class I area, the Wichita Mountains National Wildlife Refuge. The TCEQ attended Oklahoma’s three consultat ion calls held in August and September 2007.

The TCEQ has reviewed CENRAP modeling to assess which Class I areas in other states might be impacted by Texas’ emissions. Modeling indicated that Texas impacts Breton Wilderness Area in Louisiana, the Great Sand Dunes in Colorado, and several Class I sites in New Mexico. At this time, these states have not invited Texas The TCEQ also consulted the adjacent states in which the modeling data indicated no significant impact by Texas, including Arkansas, Missouri,
and Oklahoma.

Through conference calls, Arkansas and Missouri consulted with Texas about the impact of Texas’ emissions on regional haze at the Class I areas in those states. They accepted Texas’ planned emissions and regional haze impact reductions as adequate for their Class I areas for this initial SIP (Appendix 4-3).4-3 Oklahoma invited Texas to consult about Oklahoma’s Class I area, the Wichita Mountains National Wildlife Refuge. The TCEQ attended Ok lahoma’s three consultation calls held in August and September 2007. In August 2007, the TCEQ received a letter from Oklahoma regarding visibility improvements in the Wichita Mountains National Wildlife Refuge. The letter requested that Oklahoma be able to formal participation in their comment on best available control technology determinations for PSD sources that significantly impact Wichita Mountains and a request that Class I impact reviews by required for all proposed PSD sources within 300 kilometers of a Class I area. In an October 2007, response letter the TCEQ has agreed to notify Oklahoma, along with the relevant FLM, whenever modeling indicates that a proposed source significantly impacts Wichita Mountains. In regards to the 300 kilometer request, the TCEQ is urging the EPA to adopt significant impact levels for Class I reviews so that there is a standard review process across the country. During the interim, the TCEQ is committed to working with the FLMs on mutually acceptable criteria for determining when a proposed PSD source should conduct a Class I review. Appendix 4-3: Additional Consultation with States contains a copy of
these letters.

In response to comments from the EPA and FLMs in March 2008, the TCEQ sent consultation letters to Oklahoma, Louisiana, Missouri, Arkansas, Colorado and New Mexico. Included with the letters were a discussion and data of the CENRAP Particulate Matter Source Apportionment Technology (PSAT) modeling determining the contribution from each Texas source area to visibility impairment at Class I areas in the given state. The TCEQ participated fully in the analysis of this data, base period visibility im pairment, natural visibility condition estimates, and 2018 projections based on current and anticipated future state and federal controls. The PSAT modeling indicates that the probable impact of Texas sources will be reduced by 2018 in all of the affected Class I Areas due to the expected emissions reductions from current and planned
controls. Also included with the consultation process letter, where applicable, were area of influence maps for each Class I area in the CENRAP states. For reference purposes, the map showed the portions of Texas that are in the first and second order sulfate and nitrate areas of influence for the given Class I Area. The sulfur dioxide and nitrogen oxide sources shown on the map are Texas sources the TCEQ identified as high priority due to the fact that they have an emissions over distance equal to or greater than five (q/d ≥ 5) for one or more Class I areas. Also included was a table of sources of particular interest to the affected Class I Area(s) due to their emissions and their positions within the area of influence. The TCEQ also requested recipients of the letters to confirm they are not expecting any additional emission reductions. These letters and associated documents are included in Appendix 4-3

.

In an April 21, 2008, letter, Missouri’s Department of Natural Resources responded that no further emissions reductions were requested of Texas (Appendix 4-3). In a June 10, 2008, letter, Arkansas’ Department of Environmental Quality responded that no further emissions reductions were requested of Texas (Appendix 4-3). In a June 24, 2008 letter, Colorado’s Department of Public Health and Environment responded that no further emissions reductions were requested of Texas at this time (Appendix 4-3). Louisiana sent confirmation that “the Louisiana Department of Environmental Quality has determined that emissions form the State of Texas do not contribute to visibility impairment at Breton Wilderness Class I Area.” New Mexico has not responded to
the letter as of December 2008.5-1 CHAPTER 5. ASSESSMENT OF BASELINE AND CURRENT CONDITIONS AND
ESTIMATE OF NATURAL CONDITIONS IN CLASS I AREAS

5.1 VISIBILITY REQUIREMENTS The goal of the Regional Haze Rule is to restore natural visibility conditions to the 156 Class I
areas identified in the 1977 FCAA Federal Clean Air Act Amendments. Title 40 Code of Federal Regulations ( CFR ) §51.301 defines natural conditions as including “naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration.” State regional haze plans must contain measures that make “reasonable progress” toward this goal by reducing anthropogenic emissions that cause haze. Three metrics of visibility are part of the determination of progress toward this goal:

• baseline conditions, i.e., conditions observed during the baseline period, 2000 through 2004;

• natural conditions, i.e., those conditions existing in the absence of human-induced visibility impairment; and

• current conditions, i.e., conditions observed during the current period, which is the same as the baseline, for this initial period.

To calculate these metrics the concentrations of visibility-impairing pollutants are included as distinct terms in a light extinction algorithm with respective extinction coefficients and relative humidity factors. Total light extinction when conve rted to a haze index in deciviews is calculated for the average of the best 20 percent and worst 20 percent visibility days. Title 40 CFR §51.301 defines a deciview as “a haze index derived from calculated light extinction, such that uniform changes in haziness correspond to uniform incremental changes in perception across the entire range of conditions, from pristine to highly impaired.”

Texas and other CENRAP states have elected to perform their primary visibility projections using the new Interagency Monitoring of Protected Visual Environments (IMPROVE) algorithm to calculate visibility metrics for developing RPGs because this algorithm is based on more recent
science and the updated algorithm better fits the observed light extinction values. Appendix 5-1: Discussion of the Original and Revised IMPROVE Algorithms provides a discussion on the choice of the IMPROVE algorithm comparing the old and new equations. For more detailed documentation on the original (old) and revised (new) algorithm changes, please visit the
IMPROVE web site at http://vista.cira.colostate.edu/improve

.

Baseline visibility is

, the starting point for the improvement of visibility conditions. It

, is the average obtained from by using monitoring data for 2000 through 2004 and represents current visibility conditions for this initial period. Comparison of initial baseline conditions to natural visibility conditions reveals shows the improvement necessary to attain natural visibility by 2064. Natural visibility is determined by estimating the natural concentrations of visibility-impairing pollutants and then calculating total light extin ction with the chosen light extinction algorithm (Figure 5-1: Generic Glide Path to Achieve Natural Conditions in 60 Years ). Each state must estimate natural visibility levels for Class I area s within its borders in consultation with FLMs and other states that impact the Class I areas (40 CFR §51.308(d)(2)). Current conditions are assessed every five years as part of the plan review where actual progress in reducing visibility impairment is compared to reduction commitments in the plan.5-2 Figure 5-1: Generic Glide Path to Achieve Natural Conditions in 60 Years
Source: EPA

5.1.1 Default and Refined Values for Natural Visibility Conditions
The EPA’s Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program (EPA 2003) provides states a “default” estimate of natural visibility. The default values of concentrations of visibility pollutants are based on a 1990 National Acid Precipitation Assessment Program report (Trijonis

, 1990). In the EPA’s guidance, the United States is divided into East and West regions approximately along the western boundary of the states one tier west of the Mississippi River. This division divides the CENRAP states into its own East region (Arkansas, Iowa, Louisiana, Minnesota, and Missouri), containing seven Class I areas, and West region (Kansas, Nebraska, Oklahoma, and Texas), containing three Class I areas. In comparing the two regions, only sulfate (SO 4 ) and organic carbon have different values, but the calculated deciview difference is significant.

However, the ultimate responsibility for calc ulating natural conditions lies with the each state (40 CFR §51.308(d)(2)). The TCEQ determined that the default estimates were insufficiently accurate and that data and methods were available to improve these estimates, and . Therefore, TCEQ chose to develop its own refined estimates.

5.1.2 Consultation Regarding the Visibility Metrics Consultation among states is required by the Regional Haze Rule. As part of a long-term strategy for regional haze, a state whose emissions are “reasonably anticipated” to contribute to impairment in other states’ Class I areas must consult with those states (40 CFR §51.308(d)(3)). Likewise, states with Class I areas are to consult with any states whose emissions affect their Class I areas. Consultation among states is facilitated through RPOs, though some required consultations cross RPO boundaries. For example, Texas and New Mexico must collaborate on planning for the Guadalupe Mountains, though the two states participate in different RPOs.

A chief purpose of the RPOs is to provide a means for states to confer on all aspects of the regional haze issue, including consultation on RPGs and long-term strategies, which are based on the baseline, current, and natural visibility determ inations. This process is described in Chapter

3: Regional Planning . The CENRAP provides a forum for member states and tribes to consult on determinations of baseline and natural visibility conditions in subject Class I areas. States in the CENRAP have also conferred with neighboring Class I area states outside CENRAP, both individually and by way of the appropriate RPO.5-3 Title 40 CFR §51.308(i) requires Class I area states to coordinate with the FLMs, including consultation on implementation, assessment of visibility impairment, and recommendations regarding RPGs and strategies for improvement. This consultation requirement is discussed in Chapter 4: State, Tribe, And Federal Land Manager Consultation . Through participation in the CENRAP and individually, Texas has completed this regulatory requirement.

5.2 BASELINE VISIBILITY CONDITIONS For the five-year baseline period, 2000 through 2004, sites are required to have three valid years
of data from which baseline conditions can be c onstructed. The Visibility Information Exchange Web System (VIEWS) <http://vista.cira.colostate.edu/views/> has posted haze index values, based on the revised IMPROVE algorithm, for the 20 percent worst and best days for each complete year of the baseline period. From thes e values, the baseline haze index is calculated by averaging over the baseline period. Table 5-1: Baseline Haze Indices shows this calculation for both Big Bend and Guadalupe Mountains using the VIEWS summary data updated August 2007

.

Baseline visibility for the Big Bend Class I area is 5.78 deciviews for the best 20 percent of the sample days and 17.30 deciviews for the worst 20 percent of the sample days. This baseline visibility is based on sampling data collected at the Big Bend IMPROVE monitoring site.

Baseline visibility for the Guadalupe Mountains Class I area is 5.95 deciviews for the best 20 percent of the sample days and 17.19 deciviews for the worst 20 percent of the sample days. This baseline visibility is based on sampling data co llected at the Guadalupe Mountains IMPROVE monitoring site.

Table 5-1: Baseline Haze Indices Haze Index (deciviews) Class I Area Site ID Year Most Impaired Least Impaired

2001 17.31 7.09

2002 18.21 5.68

2003 17.18 5.74

2004 16.51 4.62 Big Bend * BIBE1

Average 17.30 5.78

2000 17.14 6.26

2001 16.61 6.34

2002 18.12 6.38

2003 18.50 5.91

2004 15.57 4.83 Guadalupe Mountains GUMO1

Average 17.19 5.95 * The fourth quarter of 2000 for Big Bend was not sufficiently complete for use in calculating a baseline average for regulatory purposes: The four th quarter had only ten complete days.

5.3 NATURAL VISIBILITY CONDITIONS Using the revised IMPROVE algorithm and the methodology detailed in Appendix 5-2: Estimate of Natural Visibility Conditions , the TCEQ has determined, subject to significant uncertainties in natural concentrations of organic carbon, that natural visibility conditions for the Big Bend Class I area are best represented by 10.09 deciviews for the worst 20 percent days. The Guadalupe Mountains Class I area is best represented by 12.26 deciviews for the worst 20 percent days. Appendix 5-2 provides calculations, methodologies, a discussion of the reasons for the selection of the methodology, and a demonstration of the appropriateness of these values for both Class I
areas. Table 5-2: Visibility Metrics for the Class I Areas in Texas reports the visibility metrics computed for Big Bend and Guadalupe Mountains.5-4 Table 5-2: Visibility Metrics for the Class I Areas in Texas Estimate of Natural Visibility Conditions
Haze Index (deciviews) Class I Area Most Impaired Least Impaired Big Bend 10.09 2.19 Guadalupe Mountains 12.26 2.10
Baseline Visibility Conditions, 2000–2004
Haze Index (deciviews) Class I Area Most Impaired Least Impaired Big Bend 17.30 5.78 Guadalupe Mountains 17.19 5.95

Estimate of Extent Baseline Exceeds Natural Visibility
Conditions
Haze Index (deciviews) Class I Area Most Impaired Least Impaired Big Bend 7.21 3.59 Guadalupe Mountains 4.93 3.85

Analysis of the dust storms that dominate high dust events at Guadalupe Mountains and significantly impact Big Bend suggests that the dust originates from dry desert and dry lake bed areas with little or no human activity, almost all of which are situated in the Chihuahuan Desert. For instance, Gill, et al. conclude that “Field campaigns revealed that ... the vast majority of source points were natural desert landscapes” (Gill et al. 2005).

The times when human-caused dust is likely to be more important at these sites are on days with less visibility impairment than on the worst dust impaired days, since the most dust impaired days are dominated by dust storms and other blowing dust from the surrounding desert landscape. As shown in the dust storm paper of Appendix 5-2a, there are enough dust storm days at Guadalupe Mountains to make a reasonable estimate of the worst 20 percent natural visibility conditions. In other words, there were enough dust storms documented at Guadalupe Mountains to account for all of the worst 20 percent days. This lends credence to the assumption that natural dust dominates on those days and that human-caused dust is of minimal importance for the low visibility days.

The situation at Big Bend is a little more uncertain because the dust impact is less from major dust storms and more from “locally” 1 windblown dust, as shown by the studies by Kavouras, et al. (2006 and 2007). However, the area of the park is approximately 801,000 acres, and broad restrictions on human use of the park are in place to minimize human impact on its desert environment. Additionally, the Big Bend IMPROVE monitoring site is surrounded by the park, with the closest park boundary approximately ten miles away, while land use and soil erodibility indicates the landscape surrounding Big Bend (and even Guadalupe Mountains) is overwhelmingly dominated by highly erodible soils in scrub/scrubland areas.

As explained in Appendix 5-2: Estimate of Natural Visibility Conditions , the estimates for what portion of each visibility component is to be considered as natural, at least for the estimation of natural visibility values for Texas’ Class I areas, is taken to be essentially the same as used by the Natural Conditions II (NC II) committee (Pitchford, et al. 2006), with the exception of fine soil (FS) and course mass (CM). As justified within that appendix and within the other referenced

1 Note that “local” as used in th e Kavouras work does not correspond with any distance measure, but with how well the dust dominated days in the 20 percent wo rst measured visibility days correlated with local wind speed and direction.5-5 10.1 15.6

9.2 15.4 17.3

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearsHaziness Index (Deciviews)

Observations - All URP - TX NC URP - 80% CM&FS 10.1 15.6

9.2 15.4 17.3

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearsHaziness Index (Deciviews)

10.1 15.6

9.2 15.4 17.3

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearsHaziness Index (Deciviews)

Observations - All URP - TX NC URP - 80% CM&FS Figure 5-2: Big Bend Uniform Rate of Progress (URP)

TX NC is Texas’ estimate of natural conditions. 80 % CM&FS is a comparison where 80 percent of fine soil and course mass is taken as natural.

12.3 16.0

11.0 15.7 17.2

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearsHaziness Index (Deciviews)

Observations - All URP - TX NC URP - 80% CM&FS 12.3 16.0

11.0 15.7 17.2

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearsHaziness Index (Deciviews)

12.3 16.0

11.0 15.7 17.2

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearsHaziness Index (Deciviews)

Observations - All URP - TX NC URP - 80% CM&FS Figure 5-3: Guadalupe Mountains Uniform Rate of Progress5-6 work, the TCEQ estimate takes essentially all fi ne soil and course mass concentrations to be approximated as natural, at least for the estimation of the least and most impaired natural visibility values for Texas’ Class I areas. (The actual computations are carried out using each area’s own data.)

Since the estimate has some degree of uncertainty, just as there is uncertainty in the estimates used by the NC II, the TCEQ provides in Figure 5-2: Big Bend Uniform Rate of Progress (URP )
and Figure 5-3: Guadalupe Mountains Uniform Rate of Progress graphs of the Uniform Rate of Progress (URP) for the worst 20 percent days both with the estimate approximating 100 percent fine soil and course mass as natural (TX NC) along with a calculation treating only 80 percent fine soil and course mass as natural (80% CM&FS), for both Texas Class I areas. This 80 percent calculation is displayed due to a request from some Federal Land Managers to illustrate how sensitive this natural visibility estimate is to approximating 100 percent of the fine soil and course mass as natural; there is no other significance to this 80 percent calculation for this SIP.

5.4 NATURAL VISIBILITY CONDITIONS ONGOING EFFORT S Because natural visibility estimates are calculated from complex environmental chemistry, require significant assumptions in the calculation and are ultimately calculated without a directly observable measurement, there remains considerable potential for improvement in estimation. Since the natural concentrations and statistics of all components important for Regional Haze have significant uncertainties, the TCEQ will be continuing to evaluate data, modeling, and any other sources of information, as well as potentially devising additional monitoring, sampling and/or analysis schemes, in order to further improve these estimates. Furthermore, the TCEQ plans to work with the EPA, FLMs, and other experts and researchers to refine natural conditions estimates for future five-year reports and major regional haze SIP revisions.

At this point, the component that most likely needs improved estimation is organic carbon. 2 Improved sampling and/or analysis techniques are likely methods in the pursuit of an improved characterization of the natural contributions to this component. However, the application of such methods will depend upon available resources and estimates of potential benefits.

2 Additionally, there is significant regulatory uncertainty with regard to what prescribed fires should or
should not be considered as “natural.” When the EPA revises the Interim Air Quality Policy on Wildland
and Prescribed Fires , it is expected such is sues will be clarified.6-1 CHAPTER 6. MONITORING STRATEGY

6.1 INTRODUCTION Title 40 CFR §51.308(d)(4) of the Regional Haze Rule requires a monitoring strategy for measuring, characterizing, and reporting regional haze visibility impairment that is representative of all mandatory Class I areas within Texas. The monitoring strategy relies upon data from the Interagency Monitoring of Protected Visual Environments ( IMPROVE ) program. A steering committee with representatives from federal, regional, and state organizations governs the program. These organizations include the United States Environmental Protection Agency ( EPA ) , the National Park Service ( NPS ) , the United States Fish and Wildlife Service (FWS) , the United States Forest Service, the Bureau of Land Management (BLM) , the National Association of Clean Air Agencies, and other entities. The IMPROVE Steering Committee allocates IMPROVE monitoring resources, which come from a number of agencies. Much of the funding
comes from including the EPA from funds appropriated by Congress to support state air quality

manage ment programs. Some funding comes from the

, NPS , FWS, and BLM . The IMPROVE program arranges for the operation of IMPROVE monitors, the analysis of samples from the monitors, and the validation and internet posting of the IMPROVE data as well as maintenance of the Visibility Information Exchange Web System (VIEWS) web site <http://vista.cira.colostate.edu/views> , which makes the data easily available to states, regional planning organizations, and the public. The state regional planning organizations (RPOs) contribute financial support to the VIEWS program and web site

.

6.2 MONITORING AT CLASS I AREAS IN TEXAS Currently, the IMPROVE program provides an IMPROVE monitor at each of the two Class I areas in Texas, Big Bend and Guadalupe Mountains. Because of their location, the monitors are appropriate for determining progress in reducing visibility impairment in the Texas Class I areas. The monitoring strategy relies on continuation of IMPROVE monitoring at these sites. The Texas Commission on Environmental Quality ( TCEQ will continue ) plans to continue to participate in the IMPROVE network through the financial support of the EPA. The TCEQ will also continue to participate in the IMPROVE program throug h its membership in plans to continue supporting the VIEWS work and the VIEWS web site by urging CENRAP as long as the
EPA continues to fund the CENRAP adequately to continue its funding of VIEWS . No additional monitoring beyond the IMPROVE network is required or necessary for assessing visibility
conditions at the two Class I areas in Texas or at the Class I areas that Texas’ emissions affect in
other states

.

The IMPROVE program reviewed its aerosol monitoring sites in 2006 to set priorities for maintaining the sites, in the event of federal budget cuts affecting the IMPROVE program. This review determined that the IMPROVE aerosol samplers at Texas’ two Class I areas represent
conditions different from the conditions at the nearest Class I area IMPROVE monitors. Texas’
two Class I IMPROVE monitors are not candidates for discontinuation since other IMPROVE monitors cannot represent conditions at Big Bend or Guadalupe Mountains.

The TCEQ considers that continued IMPROVE monitoring at all current Class I IMPROVE sites that Texas’ emissions impact and continued VIEWS services are all centrally important to the effort to monitor reductions in anthropogenic haze impacts at these sites. If funding for these IMPROVE sites or the VIEWS program is threatened, the TCEQ plans to work closely with the EPA, the FLMs, and neighboring states to attempt to find the funding to continue the current Class I IMPROVE monitoring and VIEWS services for these sites.

6.3 ASSESSMENT OF VISIBILITY IMPROVEMENT AT CLASS I AREAS Future assessments of visibility impairment and progress in reducing visibility impairment at Texas’ two Class I areas, and at Class I areas in other states that Texas’ emissions affect, will use the new IMPROVE equation and will use data as prescribed in the EPA’s Regional Haze Rule (40 CFR Part 51, Subpart P). The assessment will follow, as appropriate, the EPA’s official6-2 guidance including Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA 2007).6-3 6.4 REPORTING VISIBILITY MONITORING DATA TO THE ADMINISTRATOR The TCEQ does not directly collect or handle IMPROVE data. The TCEQ will plans to continue

to participate in the IMPROVE Visibility Information Exchange Web System ( VIEWS) through

CENRAP < http://vista.cira.colostate.edu/views > . The TCEQ considers VIEWS to be a core part of the overall IMPROVE program. The TCEQ will plans to continue to report IMPROVE data from the two Class I areas in Texas to the EPA by continuing to support its posting on the VIEWS web system. The TCEQ’s support will be through continuing membership in CENRAP and through requesting that both the EPA and this multi-state organization continue to support

VIEWS.

If Texas collects any visibility monitoring data through the state’s air quality monitoring networks, the TCEQ will report those data to the EPA as specified under the Performance Partnership Grant agreement negotiated with the EPA Region 6. All validated data and data analysis results from any TCEQ visibility-related special studies are public information. TCEQ
will plans to continue its practice of sharing the data and information with the EPA , the Federal Land Managers, and the public.

The TCEQ currently has a TEOM (tapered elemen t oscillating microbalance) continuous monitor
for PM 2.5 , an every-sixth-day chemical speciation monitor, and meteorological equipment operating at Big Bend. The data from these monitors is available from the TCEQ. Additionally, the TCEQ hosts the National Park Service’s Big Bend ozone data on the TCEQ web site

.

6.5 ASSESSING THE IMPACT OF EMISSIONS FROM TEXAS ON CLASS I AREAS Chapters 5, 8, 10, and 11 describe the procedures used in developing this SIP revision. These chapters include the procedures to assess the quantitative impact of emissions from Texas on
Class I areas in Texas and on Class I areas that Texas’ emissions affect in other states.

Chapter 7 describes the procedures used for this SIP revision to produce the statewide emissions inventory of pollutants reasonably anticipated to cause or contribute to visibility impairment in all the mandatory Class I areas that Texas’ emissions affect. Chapter 12 describes the plans for the five-year implementation plan review and for the 2018 regional haze SIP revision.

The Performance Partnership Grant agreement negotiated with the EPA Region 6 and the quality assurance procedures for collecting and reporting periodic emissions inventories to the EPA describe the collection, quality assurance, record keeping, maintenance, availability, and reporting of emissions and monitoring data to the EPA.

Deleted:7-1 CHAPTER 7. EMISSIONS INVENTORY

Title 40 CFR §51.308(d)(4)(v) requires a statewide emissions inventory of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any Class I area. As specified in this section, the pollutants to be inventoried include volatile organic compounds (VOC), nitrogen oxides (NO X ), fine particulate matter (PM 2.5 ), particulate matter less than ten microns in diameter (PM 10 ), ammonia (NH 3 ), and sulfur dioxide (SO 2 ). In accordance with the EPA guidance, the TCEQ developed a baseline Texas inventory for the year 2002, and submitted the inventory to the Central Regional Air Planning Association (CENRAP) for use in photochemical modeling supporting the Regional Haze SIP. A summary of the CENRAP developed 2002 Texas inventory is provided in Table 7-1: CENRAP’s 2002 Base Year Emissions Inventory Summary for Texas . Details for the 2002 emissions inventory are provided in Appendix 7-1: Texas Emissions Inventory Development: Base Year 2002 and Projected Year
2018.

Table 7-1: CENRAP’s 2002 Base Year Emissions Inventory Summary for Texas

Category CO (tpy) NO X (tpy) SO 2 (tpy) TOG* (tpy) PM 2.5 (tpy) PM 10 (tpy) NH 3 (tpy)

Area 908,407 280,811 111,853 1,163,549 347,490 1,552,824 380,057

Point 498,467 600,725 821,961 207,695 46,789 80,947 2,609

NonRoad 1,210,158 242,551 21,828 148,952 15,089 15,556 56

On-Road 4,098,391 664,163 18,814 309,707 11,275 15,476 21,599

Total 6,715,423 1,788,250 974,457 1,829,902 420,642 1,664,803 404,321 *TOG is total organic gas, which includes total hydrocarbons.

The 2002 baseline inventory is composed of several different categories. The point sources are defined as industrial, commercial, or institutional sites that meet the reporting requirements of 30 Texas Administrative Code (TAC) §101.10. Area sources include commercial, small-scale industrial, and residential categories of sources that use materials or operate processes that can generate emissions. These sources of emissions fall below the point source reporting levels and are too numerous or too small to identify individually. The area source fires inventory is also included in the area source category. This category includes agricultural burning, prescribed burning of forests, and prescribed burning of rangeland. The fugitive dust inventory includes dust from construction, mining, quarrying, bulk materials storage (such as coal and gravel), and
feedlots.

The area source SO 2 emissions modeled used by the CENRAP in their modeling are significantly higher than the 15,633 tons per year (tpy) reported by the TCEQ. The difference is industrial and residential coal combustion which was erroneously included in the CENRAP inventory. The TCEQ has been working with CENRAP to correct this error for future modeling, but there was
not sufficient time to remodel with the more accurate TCEQ-supplied inventory. CENRAP’s modeled emissions estimate is not expected to significantly impact visibility estimates for 2018 because of the relatively small contribution from these Texas sources on Class I areas.

Non-road mobile sources include aircraft operations, marine vessels, recreational boats, railroad locomotives, and a broad category of non-road equipment that include everything from 600- horsepower engines mounted on construction equipment to one-horsepower string trimmers.

On-road mobile sources of emissions consist of automobiles, trucks, motorcycles, and other motor vehicles traveling on public roadways. On-road mobile source emissions are usually7-2 categorized as either combustion-related emissions or evaporative hydrocarbon emissions. Combustion-related emissions are estimated for vehicle engine exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on the
vehicle.

Biogenic sources include hydrocarbon emissions from crops, lawn grass, and trees as well as a
small amount of NO X emissions from soils. These emissions are listed in Table 7-2: Statewide Biogenic Emissions

.

Table 7-2: Statewide Biogenic Emissions Nitrogen Oxide (tpy) Carbon Monoxide (tpy) Volatile Organic Compounds (tpy) Biogenic 184,896 755,941 4,033,760

Methodologies used in developing the 2002 emissions inventory are documented in Appendix
7-1. Technical The technical support documents compiled by the CENRAP are available at
<www.cenrap.org> in Appendix 8-1: Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support Regional Haze SIP

.

The CENRAP projected the 2002 base year emissions for Texas and other central states to the 2018 future planning year primarily using the Economic Growth Analysis System (EGAS6 EGAS5 ) for non-electric generating unit point sources, area sources, and non-road mobile sources; MOBILE6 for on-road mobile sources; and the Integrated Planning Model Version (IPM) 2.19 for electric generating units (Appendix 7-2: Integrated Planning Model Projections of Electric Generating Unit Emissions for the Regional Haze State Implementation Plan). Emissions from recently permitted electric generating units were incorporated into the IPM file. Only the units that will be shut down under enforceable actions are removed from the future inventory.

This approach is likely to significantly over predict From 2002 to 2018, the CENRAP projected point source emissions increases in the organic compounds, CO, and particulate matter (PM) categories. For non-EGU industrial sources, CE NRAP predicted increase s in all contaminant categories (ranging from slight increases in NO X and SO 2 to significant increases in CO and organic compounds). The increases predicted by CENRAP’s inventory are contra-indicated by the actual decreases represented in the annual inventory data collected between 2002 and 2005. See Appendix 7-2 for a summary of the 2005 inventory. Between 2002 and 2005, the historical data indicate actual source emissions have decreased or held approximately constant for the point sources in all categories except CO from EGUs. Based on historical decreases in emissions, CENRAP’s predicted increase is consid ered conservative and likely over predicts Texas point source emissions for 2018 and therefore is a conservative approach to the inventory devel opment

. Statewide point source emissions have declined every year in Texas in an environment of significant economic growth. A summary of Texas emissions projected to 2018 is provided in
Table 7-3: CENRAP’s 2018 Emissions Inventory Summary for Texas

.7-3 Table 7-3: CENRAP’s 2018 Emissions Inventory Summary for Texas

Category CO (tpy) NO X (tpy) SO 2 (tpy) TOG (tpy) PM 2.5 (tpy) PM 10 (tpy) NH 3 (tpy)

Area 899,497 274,663 114,138 1,420,681 354,712 1,557,089 562,379

Point 542,128 525,174 625,068 283,290 80,577 121,733 6,790

NonRoad 1,921,674 167,451 6,988 119,855 10,588 11,498 239

On-Road 2,710,631 148,387 2,925 125,234 5,337 5,337 32,191

Total 6,073,930 1,115,676 749,119 1,949,060 451,214 1,695,657 601,598 *TOG is total organic gas, which includes total hydrocarbons

Methodologies used by the CENRAP in developing the 2018 emissions inventory are documented in Appendix 7-1. Technical support documents detailing the inventory development
are available but are not included in Appendix 8 -1. These documents are available at
<www.cenrap.org>

. <www.tceq.state.tx.us/implementation/air/sip/bart/haze_appendices.html>. A comparison of the change in emissions by source category is shown in Figure 7-1: Comparison of Base and Projected Annual Emissions by Source Category . Even though PM 2 5 is a subcategory of PM 10 , both are shown for purposes of comparison.

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

Area 2002 Area 2018 Point 2002 Point 2018 Non-road

2002 Non-road

2018 On-road

2002 On-road

2018Tons per year NH3

PM10

PM2.5

TOG

SO2

NOX

CO

Figure 7-1: Comparison of Base and Projected Annual Emissions by Source Category Deleted: 78-1 CHAPTER 8. MODELING ASSESSMENT

8.1 OVERVIEW The Texas Commission on Environmental Quality (T CEQ) participated in the Central Regional Air Planning Association (CENRAP) regional planning process, as described in Chapter 3: Regional Planning and is using the technical work conducted by CENRAP in support of this state implementation plan (SIP) revision (Table 8-1: Federal Mandated Class I Areas in the CENRAP

States ). The CENRAP 2002 and projected 2018 annual emissions and air quality modeling was performed by the CENRAP modeling team. Where necessary, the TCEQ also conducted analyses specific to Texas. For instance, the TCEQ conducted best available retrofit technology (BART) screening modeling analyses independently from CENRAP, but used the databases developed by CENRAP as the basis for the analyses. The BART screening modeling analyses are described further in Chapter 9: Best Available Retrofit Technology

.

This chapter describes CENRAP regional emissions and air quality modeling that was conducted to support the central states’ regional haze SIPs. The information contained in this chapter draws from the Technical Support Document (TSD) developed by the CENRAP modeling team. The TSD, contained in Appendix 8-1: Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support Regional Haze SIP, provides further detail on the modeling analyses. Chapter 1 of the TSD presents the background, an overview of the approach, and a summary of the results of the CENRAP meteorological, emissions, and air quality modeling. Appendix A of the TSD contains more details on the meteorological model evaluation. Details on the emissions modeling are provided in Chapter 2 and Appendix B of the TSD. The model performance evaluation is presented in Chapter 3 and Appendix C of the TSD. The 2018 visibility projections and comparisons with the 2018 uniform rate of progress (URP) point are provided in Chapter 4 of the TSD, with more details given in Appendix D. Chapter 5 of the TSD contains additional supporting analysis with details on the particulate matter (PM) source apportionment modeling and alternative projections provided in Appendices E and F of the TSD, respectively. Chapter 6 lists the references cited in TSD.

8.2 BACKGROUND The 1977 Federal Clean Air Act (FCAA) amendments added the protection of visibility in
Federal Class I areas and esta blished the national goal for visibility protection. The FCAA requires states to submit SIPs containing emission limits and schedules of compliance. In response to these mandates, the United States Environmental Protection Agency (EPA) promulgated the Regional Haze Rule requiring states to establish goals that provide for reasonable progress towards achieving natural visib ility conditions at Class I areas. CENRAP has used regional air quality models to determine th e level of visibility improvement expected by

2018.

The CENRAP Emissions and Air Quality Modeling Team consists of staff from ENVIRON and University of California at Riverside (UCR), with assistance and coordination from the CENRAP states, tribes, federal agencies, and stakeholders. The team performed the emissions and air quality modeling simulations for states and tribes within the CENRAP region, which provided analytical results used in developing implementation plans under the Regional Haze Rule. The CENRAP team performed emissions and air quality modeling used by the TCEQ to determine the 2018 reasonable progress goals (RPGs).8-2 Table 8-1: Federal Mandated Class I Areas in the CENRAP States

Class I Area Acreage Federal Land Manager Public Law

Arkansas Caney Creek Wilderness Area 14,460 USDA-FS 93-622 Upper Buffalo Wilderness Area 12,018 USDA-FS 93-622

Louisiana
Breton Wilderness Area 5,000+ USDI-FWS 93-632

Minnesota Boundary Waters Canoe Area Wilderness 810,088 USDA-FS 99-577 Voyageurs National Park 114,964 USDI-NPS 99-261

Missouri
Hercules-Glades Wilderness Area 12,314 USDA-FS 94-557 Mingo Wilderness Area 8,000 USDI-FWS 95-557

Oklahoma
Wichita Mountains Wilderness Area 8,900 USDI-FWS 91-504

Texas Big Bend National Park 708,118 USDI-NPS 74-157 Guadalupe Mountains National Park 76,292 USDI-NPS 89-667

8.3 CENRAP MODELING TEAM The CENRAP goals included support to states and tribes to meet the requirements of the Regional Haze Rule and development of scientifically supportable, cost-effective control strategies that the states and tribes may adopt to reduce anthropogenic effects on visibility impairment at Class I areas. One component of CENRAP’s support to states and tribes as part of compliance with the Regional Haze Rule is performing emissions and air quality modeling. The CENRAP implemented modeling projects to:

• obtain a better understanding of the causes of visibility impairment;

• identify potential mitigation measures for vi sibility impairment at Class I areas;

• evaluate the effects of alternative contro l strategies for improving visibility; and

• project future-year air quality and visibility conditions.

The CENRAP Emissions and Air Quality Modeling Team performed the following activities:

• emissions processing and modeling;

• air quality and visibility modeling simulations;

• analysis, display, and reporting of modeling results; and

• storage and quality assurance of the modeling input and output files.

The team performed work for the CENRAP Modeling Workgroup under the supervision from the CENRAP technical director, the CENRAP executive director, and the chair of the Modeling Workgroup.8-3 8.4 THE 2002 ANNUAL EMISSIONS AND AIR QUALITY MODELING The CENRAP 2002 annual emissions and air quality modeling started on October 16, 2004. The effort involved the preparation of numerous databases, model simulations, presentations, and reports. Many of the modeling analyses are posted on the CENRAP modeling website at: http://pah.cert.ucr.edu/aqm/cenrap/index.shtml

. The TCEQ also has many of these modeling analyses available on request only, as these are very large files http://www.tceq.state.tx.us/implementation/air/sip/sipcontact.html

.

8.4.1 Modeling Protocol A modeling protocol following EPA guidance was prepared at the outset of the study to serve as an outline for performing the CENRAP emissions and air quality modeling and to communicate the modeling plans to the CENRAP participants. The modeling protocol took into account CENRAP’s long-term plan (CENRAP 2003) and the modeling needs of the regional haze SIPs. This modeling protocol is included in this SIP revision as Appendix 8-2: Modeling Protocol for the CENRAP 2002 Annual Emissions and Air Quality Modeling.

8.4.2 Quality Assurance Project Plan (QAPP) A QAPP was prepared for the CENRAP emissions and air quality modeling study (Appendix 8-3: Quality Assurance Project Plan for Central Regional Air Planning Association Emissions and Air Quality Modeling ) and describes the quality management functions performed by the modeling team. The QAPP is based on the nati onal consensus standards for quality assurance (ANSI/ASQC 1994). It follows EPA’s guidelines for quality assurance project plans for modeling (EPA 2002) and for QAPPs (EPA 2001), and takes into account the recommendations from the North American Research Strategy for Tropospheric Ozone (NARSTO) Quality Handbook for modeling projects (NARSTO 1998). The EPA and NARSTO guidance documents were developed specifically for modeling proj ects, which have diffe rent quality assurance concerns than environmental monitoring data collection projects. The work performed in this project involved modeling at the basic research level and for regulatory and planning applications. In order to use model outputs for these purposes, the modeling team must establish that each model is scientifically sound, robust, and defensible by following a project planning process that incorporates the following elements as described in the EPA modeling guidance
document.

• A systematic planning process including identification of assessments and related performance criteria.

• Peer-reviewed theory and equations.

• A carefully designed life-cycle development process that minimizes errors.

• Documentation of any changes from original plans.

• Clear documentation of assumptions, theory, and parameterization.

• Input data and parameters that are accurate and appropriate for the analysis.

• Output data.

A key component of the CENRAP emissions and air quality modeling QAPP is the graphical display of model inputs and outputs and multiple peer review of each step of the modeling process. Work products (e.g., emissions plots, model outputs, etc.) have been displayed on the CENRAP modeling website for review by the CENRAP modeling team, modeling workgroup,
and others. This website is at: http://pah.cert.ucr.edu/aqm/cenrap/index.shtml

.

8.4.3 Model Selection The selection of the meteorological, emissions, and air quality models fo r the CENRAP regional haze modeling was based on a review of previous regional haze modeling studies performed in the CENRAP region (e.g., Pitchford et al. 2004; Pun, Chen, and Seigneur 2004; Tonnesen and Morris 2004) as well as elsewhere in the United States (e.g., Morris et al 2004a; Tonnesen et al. 2003; Baker 2004). The CENRAP emissions and air quality modeling protocol (Morris et al.8-4 2004a) provides details on the justification for model selection and the formulation of the
different models.

Based on previous work by other Regional Planning Organizations (RPOs) and EPA, CENRAP selected the following models for use in modeling PM and regional haze in the central states:

• MM5: The Pennsylvania State University/National Center for Atmospheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5 Version 3.6 Massively Parallel Processing (MPP)) is a non-hydrostatic, prognostic meteorological model routinely used for urban- and regional-scale photochemical, fine particulate, and regional haze regulatory modeling studies (Anthes and Warner 1978; Chen and Dudhia 2001; Stauffer and Seaman 1990, 1991; Xiu and Pleim 2000).

• SMOKE: The Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system is an emissions modeling system that generates hourly gridded speciated emission inputs of mobile, non-road, area, point, fire, and biogenic emission sources for photochemical grid models (Coats 1995; Houyoux and Vukovich 1999). As with most "emissions models," SMOKE is principally an emission processing system and not a true emissions modeling

system . With the exception of mobile and biogenic sources, the purpose of SMOKE is to provide an efficient tool for converting existing base emissions inventory data into the hourly, gridded, speciated, and formatted emission files required by an air quality model.

• CMAQ: EPA’s Models-3/Community Multiscale Air Quality (CMAQ) modeling system is a "One-Atmosphere" photochemical grid model capable of simulating ozone, PM, visibility, and acid deposition at a regional scale for extended periods of time (Dennis, et al. 1996; Byun et al. 1998a; Byun and Ching 1999; Pleim et al. 2003).

• CAMx: ENVIRON’s Comprehensive Air Quality Model with Extensions (CAMx) modeling system is also a state-of-science "One-Atmosphere" photochemical grid model capable of simulating ozone, PM, visibility, and acid deposition at a regional scale for extended periods of time. (ENVIRON 2006).

8.4.4 MM5 Meteorological Model Configuration The Iowa Department of Natural Resources (IDNR) performed the 2002 annual MM5 modeling on a 36 kilometer (km) grid for the continental United States (Johnson 2007). The TCEQ and EPA Region VII carried out MM5 modeling on a 12 km grid covering the central states for portions of 2002.

The MM5 Version 3.63 configuration used in the generation of the meteorological modeling datasets consists of the following (see Table 8-2: MM5 34 Vertical Layer Definitions for more
details ):

• 36 km grid with 34 vertical layers;

• 12 km nested grid for episodic modeling;

• Two-way nesting (without feedback) within the 36 km grid for 12 km runs;

• Initialization and boundary conditions were established using analysis fields generated bythe Eta model. The Eta model is a hydrostatic mesoscale model that uses a pressurebased coordinate system, allowing for easier solutions to the equations of motion. The Eta model excels in capturing small-scale meteorological phenomena, especially those induced by terrain, thus improving precipitation forecasts compared to previous mesoscale models (Black 1994);

o Eta 3D and surface analysis data (ds609.2);

o NCEP global tropospheric SST data (ds083.0) not used;

o Observational enhancement (LITTLE_R);

 NCEP ADP surface obs (ds464.0);

 NCEP ADP upper-air obs (ds353.4);

• Pleim-Xiu (P-X) land-surface model (LSM);8-5 • Pleim-Chang Asymmetric Convective Mixing (ACM) PBL model;

• Kain-Fritsch 2 cumulus parameterization;

• Mixed phase (Reisner 1) cloud microphysics;

• Rapid Radiative Transfer Model (RRTM) radiation;

• No shallow convection (ISHALLO=0);

• standard Standard3D FDDA analysis nudging outside of PBL; and

• surface Surface nudging of the winds only.

8.4.5 SMOKE Emissions Model Configuration SMOKE supports area, mobile, fire, and point source emission processing and includes biogenic emissions modeling through a rewrite of the Biogenic Emission Inventory System, Version 3 (BEIS3) (see http://www.epa.gov/ttn/chief/software.html#pcbeis ). SMOKE has been available since 1996, and has been used for emissions processing in a number of regional air quality modeling applications. In 1998 and 1999, SMOKE was redesigned and improved with the support of the EPA, for use with EPA's Models-3/CMAQ ( http://www.epa.gov/asmdnerl/models3 ). The primary purposes of the SMOKE redesign were support of: (a) emissions processing with user-selected chemical mechanisms; and (b) emissions processing for reactivity assessments.

As an emissions processing system, SMOKE has far fewer "science configuration" options compared with the MM5 and CMAQ models. Appendix 8-1 summarizes the version of the SMOKE system used and the sources of data used in constructing the required modeling
inventories.

8.4.6 CMAQ Air Quality Model Configuration CENRAP used CMAQ Version 4.5 with the “SOAmods enhancement,” or modifications to the secondary organic aerosol (SOA) chemical mechanism as described below, and used the model configuration as shown in Table 8-4. The model was set up and exercised on the same 36 km RPO national grid that Western Regional Air Partnership (WRAP) and Visibility Improvements State and Tribal Association of the Southeast (VISTAS) used. CENRAP performed 12 km CMAQ sensitivity tests and found little change in model performance with a large penalty in computation time. Consequently, on February 7, 2006, the CENRAP Modeling Workgroup decided to proceed with the CENRAP emissions and air quality modeling using just the 36 km national RPO grid (Morris et al. 2006a).

Initial CMAQ 2002 simulations that VISTAS ran found that the model greatly underestimates organic mass carbon (OMC) concentrations, especially in the summer. A review of the CMAQ formulation found that it failed to treat SOA formation from sesquiterpenes and isoprene and also failed to account for the fact that SOA can become polymerized so that it is no longer volatile and stays in the particle form. Thus, VISTAS updated the CMAQ SOA module to include these missing processes and found much improved OMC model performance (Morris et al. 2006c). CENRAP tested the CMAQ Version 4.5 with SOA modification enhancement and found it performed much better for OMC than the standard versions of CMAQ Version 4.5. Therefore, CENRAP adopted CMAQ Version 4.5, with the enhanced SOA modifications (Morris et al. 2006c). CMAQ Version 4.5 is available from the CMAS center ( www.cmascenter.org ).

8.4.7 CAMx Air Quality Model Configuration The CENRAP used CAMx Version 4.40 options similar to those used for CMAQ. The CENRAP initially ran CAMx in side-by-side compar isons with CMAQ. The CENRAP reviewed comparative model performance results and other factors for CAMx Version 4 and CMAQ Version 4.4 with SOA modifications presented at the February 7, 2006, CENRAP Modeling Workgroup meeting. The results indicated that:8-6 • No one model consistently performed better than the other over all species and averaging times;

• Both models performed well for sulfate;

• CMAQ’s winter nitrate over-prediction tendency was not as large as CAMx’s;

• CAMx performed slightly better than CMAQ for elemental carbon (EC);

• CMAQ performed much better than CAMx for OMC;

• Both models over-predicted fine soil and under-predicted coarse mass (CM);

• CMAQ ran faster than CAMx due to message passing interface (MPI) multi-processing capability;

• CAMx required much less disk space than CMAQ (Morris et al. 2006b).

Based on these factors, the CE NRAP selected CMAQ as the lead air quality model for the CENRAP regional haze modeling with CAMx as the secondary corroborative model. However, CAMx also contained a PM Source Apportionment Technology (PSAT) capability that was used widely in the CENRAP modeling. CMAQ does not have this capability. Appendix 8-1 lists the main CAMx configuration for the annual modeling. The CENRAP selected it, in part, to be consistent with the CMAQ model configurati on. One exception was that the CAMx PSAT simulations used the Bott advection solver rather than the Piecewise-Parabolic Method (PPM) advection solver. The PPM advection solver is typically used in the standard CAMx and CMAQ runs. However, the Bott advection solver is more computationally efficient and the high computational requirements of the CAMx PSAT runs dictated this choice.

8.4.8 Modeling Domains The CENRAP conducted emissions and air quality modeling on the 36 km national RPO domain as depicted in Figure 8- 1 : National Inter-RPO Modeling Domain . This domain consists of a 148 by 112 array of 36 km by 36 km grid cells covering the continental United States. Sensitivity simulations were also performed for episodes on a 12 km modeling domain covering the central states; however, the results were very similar to the 36 km results so CENRAP elected to proceed with the 2002 annual modeling using the 36 km domain for computational efficiency (Morris et al. 2006a). Deleted: 28-7 Figure 8- 1 : National Inter-RPO Modeling Domain Note: 36 km grid used for the CENRAP 2002 annual SMOKE, CMAQ, and CAMx modeling

8.4.9 Vertical Structure of Modeling Domain The MM5 meteorological model ran using 34 vertical layers from the surface to a pressure level of 100 millibars (mb) (approximately 15 km above ground level). Both the CMAQ and CAMx air quality models can employ layer collapsing in which vertical layers in the MM5 are combined in the air quality model, which improves computational efficiency. WRAP and VISTAS evaluated the sensitivity of the CMAQ model estimates to the number of vertical layers (Tonnesen et al. 2005, 2006; Morris et al. 2004a). CMAQ model simulations were performed with no layer collapsing (i.e., the same 34 layers as used by MM5) and with various levels of layer collapsing. These studies found that using 19 vertical layers up to 100 mb (i.e., same model top as MM5) and matching the eight lowest MM5 vertical layers near the surface produced nearly identical results as with no layer collapsing. They also found that very aggressive layer collapsing (e.g., 34 to 12 layers) produced results with substantial differences compared to no layer collapsing. Therefore, based on the WR AP and VISTAS sensitivity analysis, CENRAP adopted the 19 vertical layer configuration up to the 100 mb model top. Figure 8- 2 displays the definition of the 34 MM5 vertical layers and how they collapsed to 19 vertical layers in the CENRAP air quality modeling. Deleted: 2

Deleted: 38-8 Table 8-2: MM5 34 Vertical Layer Definitions

Note: Scheme for collapsing the 34 layers down to 19 layers for the CENRAP CMAQ, and CAMx 2002 annual modeling.

8.4.10 2002 Calendar Year Selection The CENRAP selected the calendar year 2002 for regional haze annual modeling as described in the modeling protocol (Morris et al. 2004a). The EPA’s applicable guidance on PM 2.5 and regional haze modeling at that time (EPA 2001) identified specific goals to consider when selecting modeling periods for use in demonstrating reasonable progress in attaining the regional haze goals. Since there is much in common with the goals for selecting episodes for annual and episodic PM 2.5 attainment demonstrations as well as regional haze, EPA’s current guidance addresses all three in a common document (EPA 2007). At the time of the modeling period selection, EPA had also published an updated summary of PM 2.5 and Regional Haze Modeling Guidance (Timin 2002) that served, in some respects, as an interim placeholder until issuance of the final guidance as part of the PM 2.5 and regional haze National Ambient Air Quality Standards

MM 5 CMAQ 19L Layer Sigma Pres(mb) Height(m Depth(m) Layer Sigma Pres(mb) Height(m) Depth(m)

34 0.000 100 14662 1841 19 0.000 100 14662 6536

33 0.050 145 12822 1466 0.050 145

32 0.100 190 11356 1228 0.100 190

31 0.150 235 10127 1062 0.150 235

30 0.200 280 9066 939 0.200 280
29 0.250 325 8127 84 3 18 0.250 325 8127 2966

28 0.300 370 7284 767 0.300 370

27 0.350 415 6517 704 0.350 415

26 0.400 460 5812 652 0.400 460

2 5 0.450 505 5160 60 7 17 0.450 505 5160 1712

24 0.500 550 4553 569 0.500 550

23 0.550 595 3984 536 0.550 595
22 0.600 640 3448 506 16 0.600 640 3448 986

21 0.650 685 2942 480 0.650 685

20 0.700 730 2462 36 7 15 0.700 730 2462 633

19 0.740 766 2095 266 0.740 766

1 8 0.770 793 1828 259 14 0.770 793 1828 428

17 0.800 820 1569 169 0.800 820

16 0.820 838 1400 166 13 0.820 838 1400 329

15 0.840 856 1235 163 0.840 856
14 0.860 874 1071 160 12 0.860 874 1071 160

13 0.880 892 911 158 11 0.880 892 911 158

12 0.900 910 753 7 8 10 0.900 910 753 155

11 0.910 919 675 77 0.910 919
10 0.920 928 598 7 7 9 0.920 928 598 153

9 0.930 937 521 76 0.930 937
8 0.940 946 445 76 8 0.940 946 445 76

7 0.950 955 369 7 5 7 0.950 955 369 75

6 0.960 964 294 74 6 0.960 964 294 74
5 0.970 973 220 74 5 0.970 973 220 74

4 0.980 982 146 3 7 4 0.980 982 146 37
3 0.985 986.5 109 3 7 3 0.98 5 986. 5 109 37

2 0.990 991 73 36 2 0.990 991 73 36
1 0.995 995.5 36 36 1 0.99 5 995. 5 36 36

0 1.000 1000 0 0 0 1.000 1000 0 08-9 implementation process published in April 2007 (EPA 2007). The interim EPA modeling guidance for episode selection (EPA 2001; Timin 2002) was consistent with the final EPA regional haze modeling guidance (EPA 2007).

EPA recommends that the selection of a modeling period derive from three principal criteria:

• a variety of meteorological conditions should be covered that include the types of meteorological conditions that produce the worst 20 percent and best 20 percent visibility days at Class I areas in the CENRAP states during the 2000 through 2004 baseline period;

• to the extent possible, the modeling data base should include days for which enhanced databases (i.e., beyond routine aerometric and emissions monitoring) are available; and

• sufficient days should be available such that relative response factors (RRFs) can be based on several (i.e., >15) days.

For regional haze modeling, the guidance goes further by suggesting that the preferred approach is to model a full, representative year (EPA 2001, pg. 188). Moreover, calculations of the required RRF values should be based on model results averaged over the 20 percent worst and 20 percent best visibility days determined for each Class I area based on monitoring data from the 2000 through 2004 baseline period. More recent EPA guidance (Timin 2002) suggests that states should model at least the 10 worst and 10 best visibility days at each Class 1 area. EPA also lists several "other considerations" to bear in mind when choosing potential PM and regional haze episodes including:

• choose periods that have already been modeled;

• choose periods that are drawn from the years upon which the current design values are based;

• include weekend days among those chosen; and

• choose modeling periods that meet as many episode selection criteria as possible in the maximum number of nonattainment or Class I areas as possible.

Due to limited available resources, CENRAP modeled a single calendar year. The Regional Haze Rule uses the five-year baseline period of 2000 through 2004 as the starting point for projecting future-year visibility. Thus, the modeling year sh ould be selected from this five-year baseline period. The CENRAP selected the 2002 calendar year, which lies in the middle of the 2000 through 2004 baseline, for the following reasons.

• Based on available information, 2002 appears to be a fairly typical year in terms of meteorology for the five-year baseline period of 2000 through 2004.

• 2003 and 2004 appeared to be colder and wetter than typical in the eastern United States.

• The enhanced Interagency Monitoring of Protected Visual Environments (IMPROVE) and IMPROVE protocol sites and supersites PM monitoring data were fully operational by 2002. Much less IMPROVE monitoring data was available during 2000 through 2001, especially in the CENRAP region.

• IMPROVE data for 2003 and 2004 were not yet available at the time that the CENRAP modeling was initiated.

• The other RPOs were using 2002.

8.4.11 Initial Concentrations and Boundary Conditions The CMAQ and CAMx models were operated separately for each of four quarters of the 2002 year using an approximate 15-day spin-up period (i.e., the models started approximately 15 days before the first day of interest in each quarter to limit the influence of the assumed initial concentrations, e.g., start June 15 for the third quarter, whose first day of interest is July 1). Sensitivity simulations demonstrated that with fifteen initialization days, the influence of initial8-10 concentrations was minimal using the 36 km Inter-RPO continental United States modeling domain. Consequently, clean initial concentr ations were specified in the CMAQ and CAMx modeling using a 15-day spin-up period.

Boundary conditions (i.e., the assumed concentrations along the later edges of the 36 km modeling domain, see Figure 8- 1 ) used the results from a 2002 simulation by the GEOSCHEM Chem global circulation/chemistry model. GEOS-CHEM Chem is a three-dimensional global chemistry model driven by assimilated meteorological observations from the Goddard Earth Observing System (GEOS) of the NASA Global Modeling and Assimilation Office. Research groups around the world apply it to a wide range of atmospheric composition problems, including future climates and planetary atmospheres using general circulation model meteorology to drive the model. The Atmospheric Chemistry Modeling Group at Harvard University provides central management and support of the model.

VISTAS coordinated a joint RPO study in which Harvard University applied the GEOSCHEM Chem global model for the 2002 calendar year (Jacob, Park, and Logan 2005). The University of Houston was retained to process the 2002 GEOS-CHEM Chem output into boundary conditions for the CMAQ model (Byun 2004).

There were several quality assurance (QA) checks of the boundary conditions generated from the

2002 GEOS-CHEM Chem output. The first QA check was a range check to assure reasonable values. The boundary conditions were compared against the GEOS-CHEM Chem outputs to assure the mapping and interpolation were performed correctly. The University of Houston supplied the code to map the GEOS-CHEM Chem output to the CMAQ boundary conditions format. Environ reviewed the code and duplicated generation of the boundary conditions for several time periods during 2002.

8.4.12 Emission Input Preparation The CENRAP SMOKE emissions modeling used updated 2002 emissions data for the United States (Pechan 2005c,e; Reid et al. 2004a,b), 1999 emissions data for Mexico (ERG 2006), and 2000 emissions data for Canada. These data were used to generate a final 2002 Base G Typical (Typ02G) annual emissions database. Numerous iterations of the emissions modeling were conducted using interim databases before arriving at the final Base G emission inventories (e.g., Morris et al. 2005). The 2018 Base G base case emissions (Base18G) for most source categories in the United States were based on projections of the 2002 inventory assuming growth and control (Pechan 2005d). 2018 EGU emissions were based on the run 2.1.9 of the Integrated Planning Model (IPM) updated by the CENRAP states. Canadian emissions for the Base18G scenario were based on a 2020 inventory. The Mexican 1999 inventory was held constant for

2018.

The Typ02G and Base18G emission inventories represent significant improvements to the preliminary emissions modeling CENRAP performed (Morris et al. 2005). While the preliminary 2002 modeling served to develop the infrastructure for modeling large emissions data sets and producing annual emissions simulations, much of the input data (both as inventories and ancillary data) were placeholders for actual 2002 data being prepared through calendar year 2005. As actual 2002 data sets became available, they were integrated into the SMOKE modeling and QA system that was developed during the preliminary modeling, to produce a high-quality emissions data set for use in the final CMAQ and CAMx modeling. The addition of entirely new inventory categories, like marine shipping, added complexity to the modeling. By the end of the emissions data collection phase, there were 23 separate emissions processing streams covering a variety of source categories necessary to generate model-ready emission inputs for the 2002 calendar year. Details on the emissions modeling are in Chapter 2 and Appendix B of the TSD (Appendix 8-1). Deleted: 28-11 8.4.13 Meteorological Data Input Preparation The IDNR conducted the 2002 36 km MM5 meteorological modeling and also performed a preliminary model performance evaluation (Johnson, 2007). CENRAP performed an additional MM5 evaluation of the CENRAP 2002 36 km MM5 simulation that included a comparative evaluation against the final VISTAS 2002 36 km MM5 and an interim WRAP 2002 36 km simulation (Kemball-Cook et al. 2004). Kemball-Cook and co-workers (2004) found the following in the comparative evaluation of the CENRAP, WRAP, and VISTAS 2002 36 km MM5 simulations (details in Appendix A of the TSD):

Surface Meteorological Performance within the CENRAP Region

• The three MM5 simulations (CENRAP, VI STAS, and WRAP) obtained comparable model performance for winds and humidity that were within model performance
benchmarks.

• The WRAP MM5 simulation obtained better temperature model performance than the other two simulations due to the use of surface temperature data assimilation.

o In the final WRAP MM5 simulation the use of surface temperature assimilation was dropped because it introduced instability in the vertical structure of the atmosphere.

• For all three runs, the northern portion of CENRAP domain (e.g. Minnesota) had a cold
bias in winter and a warm bias in summer.

Surface Meteorological Performance outside the CENRAP Region

• All three runs had similar surface wind model performance in the western United States that was outside the model performance benchmarks.

• For temperature, the WRAP MM5 simulation had the best performance overall due to the surface temperature data assimilation that was dropped in the final WRAP run.

• The three runs had comparable humidity performance, although WRAP exhibited a larger
wet bias in the summer and in the southwestern United States.

Upper-Air Meteorological Performance

• The VISTAS and CENRAP MM5 simulations were better able to reproduce the deep convective summer boundary layers compared to the WRAP MM5 simulations, which
exhibited a smoother decrease in te mperature with increase in altitude.

• CENRAP and VISTAS MM5 simulations be tter simulated the surface temperature
inversions than WRAP.

• WRAP was better able to simulate the surface temperature.

• All three models exhibited si milar vertical wind profiles.

Precipitation Performance

• In winter, all three MM5 simulations exhibited similar, fairly good performance in reproducing the spatial distribution and magnitudes of the monthly average observed precipitation.

• In summer, all runs had a wet bias, particular ly in the desert southwest where the interim WRAP run had the largest wet bias.

In conclusion, the VISTAS simulation appeared to perform best, and the CENRAP MM5 model performance was generally between the VISTAS and WRAP performance, with performance more similar to VISTAS than WRAP. Although the interim WRAP MM5 simulation performed best for surface temperature due to the surface temperature data assimilation, the surface temperature assimilation degraded the MM5 upper-air performance including the ability to assimilate surface inversions and was ultimately dropped from the final WRAP MM5 simulations (Kemball-Cook et al. 2005).8-12 The IDNR 12 km MM5 simulations were also evaluated and compared with the performance of the 36 km MM5 simulation (Johnson et al. 2007). The IDNR 36 km and 12 km MM5 model performance was similar (Johnson 2007), which supported the findings of the CMAQ and CAMx 36 and 12 km sensitivity simulations that there was little benefit of using a 12 km grid for simulating regional haze at rural Class I areas (Morris et al. 2006a). However, as noted by Tonnesen and co-workers (2005; 2006) and EPA modeling guidance (1991; 1999; 2001; 2007) this finding does not necessarily hold for eight-hour ozone and PM 2.5 modeling that is characterized by sharper concentration gradients and frequently occurs in the urban environment as compared to the more rural nature of regional haze.

8.4.14 Photolysis Rate Model Input Several chemical reactions in the atmosphere are initiated by the photodissociation of various trace gases. To accurately represent the complex chemical transformations in the atmosphere, accurate estimates of these photodissociation rates must be made. The Models-3/CMAQ system includes the JPROC processor, which calculates a table of clear-sky photolysis rates (or J-values) for a specific date. JPROC uses default values for total aerosol loading and provides the option to
use default ozone column data or to use measured total ozone column data. These data come from the Total Ozone Mapping Spectrometer (TOMS) sa tellite data. TOMS data that is available at 24-hour averages was obtained from http://toms.gsfc.nasa.gov/eptoms/ep.html . Day-specific TOMS data was used in the CMAQ radiation model (JPROC) to calculate photolysis rates. The TOMS data were missing or erroneous for several periods in 2002: August 2-12, June 10, and November 18-19. Thus, the TOMS data for August 1, 2002, was used for August 2-7 and TOMS data for August 13 was used for August 8-12. Similarly, TOMS data for June 9 was used for June 10 and data for August 17 was used for August 18-19. Note that the total column of ozone in the atmosphere is dominated by stratos pheric ozone, which has very little day-to-day variability, so the use of TOMS data within a week or two of an actual day introduces minimal uncertainties in the modeling analysis.

JPROC produces a "look-up" table that provides photolysis rates as a function of latitude, altitude, and time (in terms of the number of hours of deviation from local noon, or hour angle). In the current CMAQ implementation, the J-values are calculated for six latitudinal bands (10o, 20o, 30o, 40o, 50o, and 60o N), seven altitudes (0 km, 1 km, 2 km, 3 km, 4 km, 5 km, and 10 km), and hourly values up to plus or minus 8 hours of deviation from local noon. During model calculations, photolysis rates for each model grid cell are estimated by first interpolating the clear-sky photolysis rates from the look-up table using the grid cell latitude, altitude, and hour angle, followed by applying a cloud correction (attenuation) factor based on the cloud inputs from

MM5.

The photolysis rates input file was prepared as separate look-up tables for each simulation day. Photolysis files are ASCII files that were visually checked for selected days to verify that photolysis rates are within the expected ranges.

The Tropospheric Ultraviolet and Visible (TUV) Radiation Model ( http://cprm.acd.ucar.edu/Models/TUV/ ) is used to generate the photolysis rates input file for CAMx. TOMS ozone data and land use data were used to develop the CAMx Albedo/Haze/Ozone input file for 2002. As for CMAQ, the missing TOMS data period in the fall of 2002 was filled in using observed TOMS data on either side of the missing period using the same procedures as described above for CMAQ. Default land use specific albedo values were used and a constant haze value used, corresponding to rural conditions over North America.

8.4.15 Air Quality Data Input Preparation Air quality data used with the CMAQ and CA Mx modeling systems include: (1) initial concentrations that are the assumed initial three-dimensional concentrations throughout the modeling domain; (2) the boundary conditions that are the concentrations assumed along the8-13 lateral edges of the RPO national 36 km modeli ng domain; and (3) air quality observations that are used in the model performance evaluation (MPE). The MPE is discussed in Chapter 3 and Appendix C of the TSD.

As previously noted, CMAQ default clean initia l concentrations were used along with an approximately 15-day spin up (initialization) period to eliminate any significant influence of the
initial concentrations on the modeled concentrations for the days of interest. The same initial concentrations were used with CAMx. Both CMAQ and CAMx were run for each quarter of the year. Each quarter’s model run was initialized 15 da ys prior to the first day of interest (e.g., for the third quarter, July-August-September, the model was initialized on June 15, 2002, with the first modeling day of interest July 1, 2002). The CMAQ boundary conditions for the inter-RPO 36 km continental United States grid (Figure 8- 1 ) were based on day-specific three-hour averages from the output of the GEOS-CHEM Chem global simulation model of 2002 (Jacob, Park, and Logan 2005). The 2002 GEOS-CHEM Chem output was mapped to the species and vertical layer structure of CMAQ and interpolated to the lateral boundaries of the 36 km grid shown in Figure

8- 1 (Byun 2004).

Table 8- 3 summarizes the surface air quality monitoring networks and the number of sites available in the CENRAP region that were used in the model performance evaluation. Data from these monitoring networks were also used to evaluate the CMAQ and CAMx models outside of the CENRAP region.

Table 8-3: Ground-level Ambient Data Monitoring Networks and Stations for 2002

Monitoring

Network Chemical Species Measured Sampling Frequency;

Duration Approximate
Number of
Monitors

IMPROVE Speciated PM 2.5 and PM 10 1 in 3 days; 24 hr 11

CASTNET Speciated PM 2.5 and Ozone Hourly, Weekly; 1 hr, 1 Week 3

NADP Wet SO 4 , Wet NO 3 , and Wet NH 4 Weekly 23

EPA-STN Speciated PM 2.5 Varies; Varies 12 AIRS/AQS CO, NO, NO 2 , NO X , and Ozone Hourly; Hourly 25

Note: Available in the CENRAP states for calend ar year 2002 and used in the model performance
evaluation.

8.4.16 2002 Base Case Modeling and Model Performance Evaluation CENRAP’s modeling contractors evaluated the CMAQ and CAMx modeling results against ambient measurements of PM species, gas-phase species, and wet deposition. Table 8-6 summarizes the networks used in the model evaluation, the species measured, and the averaging times and frequency of the measurements. CENRAP carried out numerous iterations of CMAQ and CAMx 2002 base case simulations and model performance evaluations during the course of the CENRAP modeling study. Most of them are posted on the CENRAP modeling website ( http://pah.cert.ucr.edu/aqm/cenrap/cmaq.shtml ), and summaries of the work are in previous reports and presentations for CENRAP (e.g., Morris et al. 2005; 2006a, b). Chapter 3 and Appendix C of the TSD provide details on the final 2002 Base F 36 km CMAQ base case modeling performance evaluation. Because of the similarity between 2002 Base F and 2002 Base G and resource constraints, CENRAP did not repeat the model evaluation for Base G. In general, the model performance of the CMAQ and CAMx models for sulfate (SO 4 ) and elemental carbon (EC) was good. Model performance for nitrate (NO 3 ) was variable, with a summer underestimation and winter overestimation bias. Performance for organic carbon mass (OMC) was also variable, with the inclusion of th e SOA modification enhancement in CMAQ Version 4.5 greatly improving the CMAQ summer OMC model performance (Morris et al., 2006c). Model performance for soil and CM was generally poor. Part of the poor performance for fine soil and coarse mass appear to be due to measurement-model incommensurability. The Deleted: 2

Deleted: 2

Deleted: 68-14 IMPROVE measured values are due, in part, to local blowing dust sources that are not captured in the model’s emission inputs and the 36 km grid resolution is not conducive to modeling localized events. Also, the model usually fails to simulate locally high winds creating dust clouds in one part of the Chihuahuan Desert that later move with lower speed winds to affect Guadalupe Mountains National Park or other Class I areas. Figures 8- 2 and 8- 3 show the observed light extinction compared to the modeled light extin ction at Big Bend National Park and Guadalupe
Mountains National Park.

Worst 20% Obs (left) vs Typ02g (right) at BIBE1

0 20 40 60 80 100 120 140

29 71 89 92 95 101 110 113 116 119 125 128 131 143 167 191 218 221 230 242 245 254 275 329 _ Avg

Julian Day in Worst 20% groupbEXT (1/Mm) bCM

bSOIL

bEC

bOC

bNO3

bSO4

Figure 8- 2 : Observed and Base Case Modeled Concentrations at Big Bend Note: Extinction calculated using the new IMPROVE equation using observed concentrations and base case modeled concentrations at Big Bend National Park. The new IMPROVE equation calculations relied on 2002 IMPROVE data for the worst 20 percent of monitored days and the modeling used the 2002 base Base F emission inventory. Deleted: 4

Deleted: 5

Deleted: 48-15 Worst 20% Obs (left) vs Typ02g (right) at GUMO1

0 10 20 30 40 50 60 70 80 90 100

74 83 92 95 122 131 137 146 161 164 167 170 173 176 191 218 221 245 251 254 260 266 272 329 _ Avg

Julian Day in Worst 20% groupbEXT (1/Mm) bCM

bSOIL

bEC

bOC

bNO3

bSO4

Figure 8- 3 : Observed and Base Case Modeled Concentrations at Guadalupe Mountains Note: Extinction calculated using the new IMPROVE equation using observed concentrations and base case modeled concentrations at Guadalupe Mountains National Park. The new IMPROVE equation calculations relied on 2002 IMPROVE data for the worst 20 percent of monitored days and the modeling used the 2002 base Base F emission inventory.

8.4.17 2018 Modeling and Visibility Projections Emissions for the 2018 base case were generated following the procedures discussed in Chapter 2 of the TSD. Emissions in 2018 for electrical generating units (EGUs) were based on simulations of the Integrated Planning Model (IPM) that took into account the effects of the Clean Air Interstate Rule (CAIR) on emissions from EGUs in CAIR states using an IPM realization of a CAIR cap and trade program. For the purposes of this SIP revision, the TCEQ is assuming that the federal appellate court remand of CAIR to EPA will result in a replacement program providing comparable emissions reductions at EGUs before 2018. Emissions for on-road and non-road mobile sources were based on activity growth and emissions factors from the EPA MOBILE Vehicle Emission Modeling Software Version 6 (MOBILE6) and NONROAD models, respectively. Area sources and non-EGU point sources were grown to 2018 levels using Economic Growth Analysis System (EGAS) (Pechan 2005d). The Canadian year 2000 emissions inventory was replaced by a Canadian 2020 emissions inventory for the 2018 CMAQ/CAMx
simulations.

The following sources were assumed to remain constant between the 2002 and 2018 base case
simulations:

• biogenic VOC and NO X emissions from the Biogenic Emissions Inventory System Version 3 (BEIS3) model;

• wind-blown dust associated with non-agricultural sources (i.e., natural wind-blown fugitive dust); Deleted: 58-16 • off-shore emissions associated with off-shore marine and oil and gas production activities;

• emissions from wildfires;

• emissions from Mexico; and

• global transport (i.e., emissions due to boundary conditions from the 2002 GEOSCHEM Chem global chemistry model).

The results from the 2002 and 2018 CMAQ and CAMx simulations were used to project 2018 PM levels from which 2018 visibility estimates were obtained. The 2002 and 2018 modeling
results were used in a relative sense to scal e the observed PM concentrations from the 2000 through 2004 baseline and the IMPROVE monitoring network to obtain the 2018 PM projections. The modeled scaling factors are called relative response factors (RRFs) and are constructed as the ratio of modeling results for the 2018 model simulation to the 2002 model simulation. Two important regional haze metrics are the average visibility for the worst 20 percent and best 20 percent days from the 2000 through 2004 five-year baseline. For the 2018 visibility projections, EPA guidance recommends developing Class I area and PM species specific RRFs using the average modeling results for the worst 20 percent days during the 2002 modeling period and the 2002 and 2018 emission scenarios. The results of the CENRAP 2018 visibility projections following EPA guidance procedures (EPA 2007a) are provided in Chapter 4 and Appendix D of the TSD in Appendix 8-1 of this SIP revision. CENRAP has also developed alternative procedures for visibility projections that are discussed in Chapter 5 and Appendix D of the TSD. For example, much of the CM impact at Class I area IMPROVE monitors are believed to be natural and primarily from local sources that are subgrid-scale to the modeled 36 km grid so are not represented in the modeling. Thus, one altern ative visibility projection approach is to set the RRF for CM to 1.0. That is, the CM impacts in 2018 are assumed to be the same as in the observed 2000-2004 baseline. Similarly, the soil impacts at IMPROVE monitors are likely mainly due to local dust sources so another alternative approach is to set the RRFs for both CM
and soil to 1.0.

The 2018 visibility projections for the worst 20 percent days are compared against a 2018 point on the uniform rate of progress (URP) glide path or the “2018 URP point.” The 2018 URP point is obtained by constructing a linear visibility glide path in deciviews from the observed 2000 through 2004 baseline (EPA 2003a) for the worst 20 percent days to the 2064 natural conditions (EPA 2003b). Where the linear glide path crosses the year 2018 is the 2018 URP point. States may use the modeled 2018 visibility to help define their 2018 RPG in their Regional Haze SIPs. The 2018 URP point is used as a benchmark to help judge the 2018 modeled visibility projections and the state’s RPG. However, as noted in EPA’s RPG guidance, “The glide path is not a presumptive target, and states may establish a RPG that provides for greater, lesser, or equivalent visibility improvement as that described by the glide path” (EPA 2007b). Chapter 4 and Appendix D of the TSD present the 2018 visibility projections for the CENRAP Class I areas and their comparisons with the 2018 URP point using EPA default visibility projection procedures (EPA 2007a) and EPA default URP glide paths (EPA 2003a,b; 2007b).

Various techniques have been developed to display the 2018 visibility modeling results including “DotPlots” that display the 2018 visibility projections as a percentage of meeting the 2018 point on the URP glide path. A value of 100 percent on the DotPlot indicates that the Class I area is predicted to meet the 2018 point on the URP glide path. Over 100 percent means the 2018 visibility projection obtains more visibility improvements (reductions) than required to meet the 2018 point on the URP glide path (i.e., projected value is below the glide path). Less than 100 percent indicates that fewer visibility improvement s are projected than are needed to meet the 2018 point URP on the glide path (i.e., above the glide path). Figure 8-4 displays a DotPlot that compares the 2018 visibility projections from the CENRAP 2018 Base G CMAQ simulation with the 2018 URP point using the EPA default RRFs and alternative RRFs that set the CM and soil RRFs to unity (i.e., assume CM and soil are natural so remain unchanged from the 2000-20048-17 baseline). For these results, the 2018 visibility projections at the Hercules Glades (HEGL1) Class I area meets the 2018 point on the URP glide path (100 percent), whereas the 2018 visibility projections at Caney Creek (CACR), Mingo (MING), and Upper Buffalo (UPBU) achieve more visibility improvements than needed to meet the 2018 URP point so are below the 2018 URP glide path. However, the 2018 visibility projections at Breton come up slightly short (approximately 5 percent) of meeting the 2018 point on the URP glide path and Wichita Mountains (WIMO) comes up approximately 40 percent short of meeting the 2018 point on the URP glide path. Class I areas at the northern (e.g., VOYA, BOWA, and ISLE) and southern (e.g., BIBE and GUMO) boundaries of the United States also fall short of achieving the 2018 URP point.

High contributions of international transport and/or natural sources (e.g., windblown dust) affect the ability of these Class I areas to be on the URP glide path calculated using the default estimates produced by the Natural Conditions II Committee (NC-II). Chapters 4 and 5 of the TSD in Appendix 8-1 discuss these issues in more detail.8-18 CMAQ BaseGa Method 1 predictions for CENRAP+ sites

0% 20% 40% 60% 80% 100% 120% 140% 160% 180% 200%BIBE1GUMO1WIMO1CACR1UPBU1HEGL1MING1BRET1VOYA2BOWA1MACA1SIPS1ISLE1SACR1WHIT1WHPE1GRSA1ROMO1WICA1BADL1THRO1LOST1Percent of target reduction achieved Regular RRF

CM RRF=1

CM&SOIL RRFs=1

CENRAP non-CENRAP

Figure 8- 4 : 2018 Visibility Projections Expressed as Percent of Meeting the 2018 URP Point Note: Using the default NC-II estimates of natural conditions.
BADL Badlands Wilderness Area BOWA Boundary Waters Canoe Area Wilderness CACR Caney Creek Wilderness Area
HEGL Hercules-Glades Wilderness Area ISLE Isle Royale National Park
LOST Lostwood Wilderness Area
MACA Mammoth Cave National Park SIPS Sipsey Wilderness Area
THRO Theodore Roosevelt National Park UPBU Upper Buffalo Wilderness Area VOYA Voyageurs National Park
WICA Wind Cave National Park Deleted: 68-19 8.4.18 Additional Supporting Analysis CENRAP performed numerous supporting analyses of its modeling results including analyzing alternative glide paths and 2018 projection approaches and performing confirmatory analysis of the 2018 visibility projections. Details on the additional supporting analysis are contained in Chapter 5 of the TSD, which include:

• The CENRAP 2018 visibility projections were compared with those generated by VISTAS and MRPO. There was close agreement between the CENRAP and VISTAS 2018 visibility projections at almost all common Class I areas, with the exception of Breton Island where the CENRAP’s projections were slightly more optimistic than VISTAS’. The MRPO 2018 visibility projec tions were less optimistic than CENRAP’s at the four Arkansas-Missouri Class I areas. This difference may have been due to
CENRAP’s BART emission controls in CENRAP states that were not included in the 2018 MRPO inventory.

• Extinction based glide paths were developed and the CENRAP 2018 visibility projections were shown to produce nearly identical estimates of achieving the 2018 URP point when using total extinction glide paths as when the linear deciview glide paths were used. With the extinction based glide paths the analysis of 2018 URP could be made on a PM species-by-species basis where it was shown that 2018 extinctions due to SO 4 and, to a lesser extent, NO 3 and EC, achieve the URP, but the other species do not and, in fact, extinction due to soil and CM is projected to get worse.

• 2018 visibility projections were made using EPA’s Modeled Attainment Test Software (MATS) and the CENRAP Typ02G and Base18G modeling results. The CENRAP 2018 visibility projections agreed with those generated by MATS with three exceptions: Breton, Boundary Waters, and Mingo Class I areas. At these three Class I areas MATS did not produce any 2018 visibility projections due to insufficient observed 2000-2004 data in the raw IMPROVE database to produce a valid baseline. CENRAP used filled
data for these three Class I areas.

• PM PSAT modeling was conducted to estimate the contributions to visibility impairment at Class I areas by source region (e.g., states) and major source category. Source contributions were obtained for a 2002 and 2018 base case and the PSAT modeling results were implemented in a PSAT Visualiz ation Tool that was provided to CENRAP states and others. Major findings from the PSAT source apportionment modeling include the following:

o Sulfate from elevated point sources was the highest source category contribution to visibility impairment at CENRAP Class I areas for the worst 20 percent days.

o International transport contributed significantly to visibility impairment at CENRAP Class I areas on the southern (BIBE and GUMO) and northern (BOWA and VOYA) borders of the United States and to a lesser extent at

WIMO.

• Alternative visibility projections were made, assuming that CM alone, and CM and soil were natural in origin.

• Visibility projections were made using an a lternative model (CAMx) that verified the projections made by CMAQ.

• The effects of international transport were examined several ways indicating that the inability of the 2018 visibility projections to achieve the 2018 URP point at the northern and southern border Class I areas was due to high contributions due to International Transport.

Visibility trends for the worst 20 percent days, be st 20 percent days, and a ll monitored days were analyzed at CENRAP Class I areas using the period of record IMPROVE observations. At most Class I areas there were insufficient years of data to produce a discernable trend. In addition, there was significant year-to-year variability in visibility impairment with episodic events (e.g., wildfires and windblown dust) confounding the analysis.9-1 CHAPTER 9. BEST AVAILABLE RETROFIT TECHNOLOGY

On July 6, 2005, the EPA published final amendments to its 1999 Regional Haze Rule including Appendix Y, the final guidance for Best Available Retrofit Technology (BART) determinations in the Federal Register (70 FR 39104-39172). The BART rule requires the installation of BART on emission sources that fit specific criteria and “may reasonably be anticipated to cause or contribute” to visibility impairment in any Class I area (Appendix 9-1: U.S. EPA BART Rule).

9.1 BART-ELIGIBLE SOURCES IN TEXAS The TCEQ’s Texas Commission on Environmental Quality’s (TCEQ) BART rule adopted on January 10, 2007, identifies potentially affected sources as those:

• belonging to one of 26 industry source categories;

• having the potential to emit (PTE) 250 tons per year (tpy) or more of any visibilityimpairing pollutant; and

• not operating prior to August 7, 1962, and in existence on August 7, 1977 (Appendix 9-2: Texas BART Rule ).

The state is not required to make a determination of BART for SO 2 or NO X if a BART-eligible source has the PTE less than 40 tons per year of such pollutant(s) or less than 15 tons per year for

PM 10

.

A state that opts to participate in the CAIR program need not require affected BART

- eligible EGUs to install, operate , and maintain BART for SO 2 or NO X

. Texas has made the determination that participation in CAIR is participating in equivalent to BART. This exempts EGUs impacted by CAIR from a BART analysis for SO 2 and NO

x . As of the date of this SIP revision, CAIR remains in effect until replaced by EPA rule consis tent with the D.C. Circuit Court of Appeals’ remand of CAIR back to EPA. As a result, EGUs subject to the cap and trade system established by CAIR have not been evaluated for BART for SO 2 and NO

x . The TCEQ will take appropriate action if CAIR is not replaced with a system th at the US EPA considers to be equivalent to

BART

.

The TCEQ has also adopted the model plants, or option 2, developed by the EPA; this is an approach for using model plants to exempt individual sources with common characteristics (70 FR 39162-3). Any BART

- eligible source that has the PTE less than 500 tons per year of
combined SO 2 and NO X and that is located more than 50 kilometers from any Class I area is not subject to BART for SO 2 and NO X . Any BART

- eligible source that has the PTE less than 1,000 tons per year of combined SO 2 and NO X and that is located more th an 100 kilometers from any Class I area is not subject to BART for SO 2 and NO X

. Sources which meet this model plant exemption are considered not to be negatively impacting visibility at Class I areas and are therefore not required to complete a BART analysis.

The TCEQ reviewed its emission inventory The TCEQ manages emissions and emissions-related data and in the State of Texas Air Reporting System (STARS). The STARS was used the EPA’s mod el plants as an initial screening tool for identifying to determine which sources were potentially BART-eligible sources. Surveys were

sent to . This database does not store any permit related information such as build dates or permitted allowable emission levels. As a result of these database limitations the TCEQ surveyed companies regarding their potential to emit and c onstruction dates in order to complete the initial BART determination (Appendix 9-3: Texas Survey for BART-Eligibility ).

Texas Source Survey Each of the 26 BART source categories were addressed for Texas. The Standard Industrial Codes (SIC) as well as the applicable Source Classifications Codes (SCC) were identified by TCEQ Deleted:9-2 staff using the 26 applicable source categories listed in Section III(H) of the 40CFR Part 51, Regional Haze Regulations. This list was compared with other states and regional planning organization lists for completeness. The initial survey population was based on this SIC/SCC list only.

As provided for in the EPA guidance document for BART, the TCEQ chose to adopt a model plant analysis to reasonably eliminate smaller sources of NO X and SO 2 emissions which were distant from a Class I area. The EPA guidance provides exemption of sources from consideration
if their actual emission of NO X or SO 2 (or combination of NO X and SO 2 ) were less than 500 tpy as long as they were located more than 50 kilometers (km) from any Class I area; sources were also exempted if their 2002 emissions of NO X or SO 2 (or combination of NO X and SO 2 ) were less than 1,000 tpy as long as they were located more than 100 km from any Class I area. The TCEQ reduced the emission threshold to 750 tpy for sources greater than 100 km and 375 tpy for sources greater than 50 km to capture sources that might not have met EPA’s threshold based only on their 2002 emissions levels. Given their distance from Class I areas, the relatively low emissions from the screened out sources are unlikely to significantly impact visibility at those

areas.

Based on an estimate by TCEQ staff, the actual emissions are typically 80 percent of the permitted amount. Using this estimate, staff assumed that companies with actual volatile organic compounds (VOC) emissions of 200 tpy would reasonably have a permitted potential to emit of 250 tpy. Companies with the applicable source categories and actual emissions at their sites of 200 tpy or more of VOC or PM 10 were also asked to complete the survey. In 2002, PM 2.5 data were collected but a review of the database indicated that some companies did not fully report fine particulate matter until later inventorie s. As allowed by the BART guidelines, PM 10 was used as a surrogate in order to fully capture sources of particulate matter.

A county level distance screen was employed to avoid removing sources that barely exceeded distance calculations. If any portion of the county was within the applicable distance to the nearest Class I area, then all the sites within that county were considered within the applicable distance. Additionally, all BART category sites w ithin counties within 50 km of a Class I area were surveyed. The Class I areas considered for the Texas screening included the Guadalupe Mountains, Big Bend, Carlsbad Caverns, Wichita Mountains, Caney Creek, Breton Island, and
Salt Creek.

As a result of the screening analysis, 254 sites ( approximately 250 12 percent of the 2,165 sources in the 2002 emissions inventory) were identified as potentially BART-eligible sources. based on distance and actual emissions. A survey was sent to these sites to ask for site representatives tohelp in identifying construction or reconstruction dates and whether the PTE of the BARTeligible equipment exceeded 250 tpy.

The emissions represented by the surveyed sites are summarized in Table 9-1: Emissions from Companies Surveyed as a Percentage of State Total Point Source Emissions . Sources emitting a large percentage of the actual emissions in the state were in the survey population. Emissions covered in the survey ranged from 61.7 percent of the 2002 VOC inventory to 97.7 percent of the

SO 2 inventory.

Table 9-1: Emissions from Companies Surveyed as a Percentage of State Total Point
Source Emissions Emissions (tpy) Source

PM 10 SO 2 NO X VOC BART Survey 49,638 786,274 467,534 95,442

2002 State Total 66,064 805,133 601,447 154,6659-3 Surveys were sent to 254 companies. The survey was a two step process. Companies were first asked to identify if they have any equipment bu ilt or reconstructed during the applicable time period or if the PTE of their site were less than 250 tpy. Companies that did not have BART applicable equipment based on low emissions or construction dates were not asked to supply any further information and were considered not BART-eligible.

If the site did possibly have BART applicable equipment, they were asked to complete a detailed survey of all operating and idle equipment at each site. The detailed survey asked whether each piece of equipment at the site was built or rec onstructed between the applicable dates. The companies were asked if the PTE of their BART-eligible equipment exceeded the 250 tpy threshold for the applicable emissions. Any source with a PTE from equipment built during the applicable period was cons idered BART-eligible.

Based on results from the surveys completed by potentially BART-eligible sources and submitted to the TCEQ in 2005, over 100 sources were identified as BART

- eligible. Table 9- 2 : BARTEligible Sources Based on Results of TCEQ Survey presents the sources that were determined to
be BART

- eligible.

Table 9- 2 : BART-Eligible Sources Based on Results of TCEQ Survey

No. Account Source Regulated Entity SIC

1 AC0017B ABITIBI CONSOLIDATED CORP RN100220110 2621

2 TG0044C AEP TEXAS RN101531226 4911

3 CD0013K AEP TEXAS CENTRAL COMPANY RN102560687 4911

4 NE0024E AEP TEXAS CENTRAL COMPANY RN100642040 4911

5 NE0026A AEP TEXAS CENTRAL COMPANY RN100552181 4911

6 JI0030K AEP TEXAS NORTH COMPANY RN100215557 4911

7 CB0003M ALCOA ALUMINA & CHEMICALS RN100242577 2819

8 MM0001T ALCOA INC RN100221472 3334 9 HT0011Q ALON USA LP RN100250869 2911 10 ED0034O ASH GROVE (formerly NORTH TEXAS CEMENT) RN100225978 3241

11 HG0558G ATOFINA CHEMICALS INC RN100209444 2869

12 BL0021O BASF CORPORATION RN100218049 2869

13 GB0001R BP AMOCO CHEMICAL COMPANY RN102536307 2869

14 GB0004L BP PRODUCTS NORTH AMERICA IN TEXAS RN102535077 2911 15 GH0003Q CABOT CORPORATION RN100221761 2895

16 BG0045E CAPITOL CEMENT DIV CAPITOL RN100211507 3241

17 GH0004O CELANESE CHEMICAL RN101996395 2869

18 MH0009H CELANESE LIMITED RN100258060 2869

19 ED0011D CHAPARRAL STEEL MIDLOTHIAN RN100216472 3312

20 BJ0001T CHEMICAL LIME LTD RN100219856 3274

21 HG0310V CHEVRON PHILLIPS CHEMICAL RN103919817 2869

22 BL0758C CHEVRON PHILLIPS CHEMICAL RN100825249 2869

23 HW0013C CHEVRON PHILLIPS CHEMICAL CO RN102320850 2869

24 NE0027V CITGO REFINING & CHEMICALS RN102555166 2911

25 BG0057U CITY PUBLIC SERVICE RN100217975 4911

26 BG0186I CITY PUBLIC SERVICE RN100217835 4911 27 HW0018P CONOCO PHILLIPS (formerly PHILLIPS 66) RN102495884 2911

28 CR0020C COPANO PROCESSING LP RN101271419 1321 29 AB0012W DCP (formerly DUKE ENERGY FIELD SERVICES) RN100218684 1321

30 HW0008S DEGUSSA ENGINEERED CARBONS RN100209659 2895

31 HGA005E DOW RN104150123 2869 32 HG0126Q DOW RN100227016 2869 Deleted:

Deleted: 1

Deleted:

Deleted:

Deleted: Pa g e Brea k

Deleted: 19-4 33 CI0022A DYNEGY MIDSTREAM SERVICES RN100222900 1321

34 HH0042M EASTMAN CHEMICAL COMPANY RN100219815 2869

35 HG0218K EI DUPONT RN100225085 2869

36 OC0007J EI DUPONT DENEMOURS & CO RN100542711 2869

37 EE0029T EL PASO ELECTRIC CO RN100211309 4911

38 TH0004D ELECTRIC UTILITY DEPT RN100219872 4911

39 CG0012C ENBRIDGE PIPELINES RN102166964 1321 40 MQ0009F ENTERGY GULF STATES INC RN100226877 4911

41 OC0013O ENTERGY GULF STATES INC RN102513041 4911 42 BL0113I EQUISTAR RN100218601 2869 43 BL0268B EQUISTAR CHEMICALS LP RN100237668 2821 44 HG0033B EQUISTAR CHEMICALS LP RN100542281 2869

45 HG0228H EXXON CHEMICAL CO RN102212925 2869

46 JE0065M EXXON MOBIL CHEMICAL CO RN100211903 2821

47 HG0229F EXXONMOBIL CHEMICAL CO RN102574803 2869 48 HG0232Q EXXONMOBIL CORP RN102579307 2911

49 JE0067I EXXONMOBIL OIL CORP RN102450756 2911

50 NE0120H FLINT HILLS RESOURCES RN102534138 2911

51 NE0122D FLINT HILLS RESOURCES LP RN100235266 2911

52 JE0052V HUNTSMAN CORPORATION RN100219252 2869 53 JE0135Q HUNTSMAN PETROCHEMICAL CORP RN100217389 2869

54 EB0057B HUNTSMAN POLYMERS RN101867554 2869

55 BL0002S INEOS OLEFINS & POLYMERS RN100238708 2869

56 CG0010G INTERNATIONAL PAPER CO RN100543115 2621

57 OCA002B INVISTA RN104392626 2869 58 VC0008Q INVISTA (formerly DU PONT DE NEMOURS) RN102663671 2869

59 WE0005G LAREDO POWER RN100213909 4911

60 MB0123F LEHIGH CEMENT COMPANY RN100218254 3241

61 NE0025C LON C HILL POWER RN100215979 4911

62 BC0015L LOWER COLORADO RIVER AUTHORITY RN102038486 4911

63 FC0018G LOWER COLORADO RIVER AUTHORITY RN100226844 4911

64 HG1575W LYONDELL CHEMICAL RN100633650 2869

65 HG0048L LYONDELL CITGO REFINING RN100218130 2911

66 GB0055R MARATHON ASHLAND PETROLEUM RN100210608 2911

67 HH0019H NORIT AMERICAS INC RN102609724 2819 68 GB0037T NRG TEXAS (formerly TEXAS GENCO LP) RN101062826 4911

69 ED0051O OWENS CORNING RN100223585 3296

70 HG1451S OXYVINYLSLP RN102518065 2821

71 HG0175D PASADENA REFINING RN100716661 2911

72 JE0042B PREMCOR REFINING GROUP RN102584026 2911 73 MC0002H REGENCY TILDEN GAS (formerly ENBRIDGE) RN100216621 2819

74 HG0697O RHODIA INC RN100220581 2819

75 HG0632T ROHM & HAAS TEXAS RN100223205 2869

76 HG0659W SHELL OIL CO RN100211879 2911

77 HW0017R SID RICHARDSON CARBON RN100222413 2895

78 HT0027B SID RICHARDSON CARBON CO RN100226026 2895

79 BL0038U SOLUTIA INC RN100238682 2869

80 TF0012D SOUTHWESTERN ELECTRIC POWER RN100213370 4911

81 GJ0043K SOUTHWESTERN ELECTRIC POWER RN102156916 4911

82 ME0006A SOUTHWESTERN ELECTRIC POWER RN100542596 4911

83 PG0040T SOUTHWESTERN PUBLIC SERVICE RN100224641 4911

84 PG0041R SOUTHWESTERN PUBLIC SERVICE RN100224849 4911 Deleted: Pa g e Brea k

Table 9

- 1: BART

- Eligible
Sources Based on Results of TCEQ Survey (cont’d) ¶
No. ... [1]9-5 85 LN0081B SOUTHWESTERN PUBLIC SERVICE RN100224765 4911

86 JE0091L SUN MARINE TERMINAL RN100214626 4226

87 WN0042V TARGA RN102552387 1311 88 CY0019H TARGA (formerly DYNEGY MIDSTREAM) RN102551785 1311

89 OC0019C TEMPLE-INLAND RN100214428 2621

90 CI0012D TEXAS GENCO LP RN100825371 4911

91 FG0020V TEXAS GENCO LP RN100888312 4911

92 HK0014M TEXAS LEHIGH CEMENT CO RN102597846 3241

93 HG0562P TEXAS PETROCHEMICALS LP RN100219526 2869

94 BL0082R THE DOW CHEMICAL CO RN100225945 2869

95 JE0039N THE GOODYEAR TIRE AND RUBBER CO RN102561925 2822

96 NE0022I TICONA POLYMERS INC RN101625721 2869

97 JE0005H TOTAL PETROCHEMICALS RN102457520 2911

98 ED0066B TXI OPERATIONS LP RN100217199 3241

99 FI0020W TXU BIG BROWN COMPANY LP RN101198059 4911

100 DB0251U TXU ELECTRIC COMPANY RN101559854 4911

101 FB0025U TXU GENERATION COMPANY LP RN102285855 4911 102 HQ0012T TXU GENERATION COMPANY LP RN100664812 4911

103 MB0116C TXU GENERATION COMPANY LP RN102566494 4911

104 MM0023J TXU GENERATION COMPANY LP RN102147881 4911

105 MO0014L TXU GENERATION COMPANY LP RN102285848 4911

106 RL0020K TXU GENERATION COMPANY LP RN102583093 4911

107 TA0352I TXU GENERATION COMPANY LP RN100693308 4911 108 WC0028Q TXU GENERATION COMPANY LP RN102183969 4911

109 YB0017V TXU GENERATION COMPANY LP RN102563426 4911

110 TF0013B TXU GENERATION COMPANY LP RN102285921 4911

111 GB0076J UNION CARBIDE CORP RN100219351 2869

112 CB0028T UNION CARBIDE CORPORATION RN102181526 2869

113 HR0018T VALENCE MIDSTREAM LTD RN100213685 1321

114 GB0073P VALERO REFINING CO TEXAS RN100238385 2911

115 NE0043A VALERO REFINING COMPANY RN100211663 2911

116 MR0008T VALERO MCKEE RN100210517 2911

117 WH0014S VETROTEX WICHITA FALLS PLANT RN100218601 3229

118 VC0003D VICTORIA POWER RN100214980 4911

119 JB0016M VINTAGE PETROLEUM INC RN100214592 1311

120 JC0003K WESTVACO RN102157609 2631 Deleted: ( formerly XCEL)

Deleted: ¶ Page Break
Table 9

- 1: BART

- Eligible
Sources Based on Results of TCEQ Survey (cont’d) ¶
No.

Deleted: ( formerly ATOFINA)

Deleted: ( formerly DIAMOND) ... [2]9-6 9.2 DETERMINATION OF SOURCES SUBJECT TO BART Under the EPA’s BART guidelines, the state has two options regarding its BART-eligible

sources:

• make BART determinations for all sources; or

• consider exempting some sources from BART because they do not cause or contribute to visibility impairment in a Class I area.

The TCEQ has chosen chose the second option that considers exempting some sources.

When exempting sources from BART because they do not cause or contribute to visibility impairment in a Class I area, the guidelines sugge st three sub-options for determining that certain sources are not subject to BART:

• individual source attribution approach;

• the use of model plants to exempt sources with common characteristics (70 FR 39162-3); and

• a cumulative modeling analysis to show that groups of sources in a state are not subject to

BART ;

• and finally; an individual source attribution approach.

The TCEQ exercised all three sub-options above to determine which sources were subject to BART. These options are explained further below, in the order in which the TCEQ and the sources performed the analyses.

Section 9.2.1 describes the cumulative modeling analyses that the TCEQ performed for the
sources identified as BART

- eligible. Since there were was such a large number of BARTeligible sources in Texas, the TCEQ performed cumulative modeling analyses using CAMx PSAT technology. Once the TCEQ ha d completed the CAMx screening modeling analysis, several BART-eligible sources were determined to be insignificant (screened out) and several remained potentially BART-eligible ( did not screen out ) . Screening out is a process that further examines and evaluates sources for inclusion or exclusion in the BART program. Sources thatdid not screen out through the cumulative modeling analysis were required to perform sourcespecific screening modeling analyses using either the CALPUFF or the CAMx model setup developed by the TCEQ. These source-specific modeling analyses are described in Section 9.2.2. BART-eligible sources that did not screen out in any of the modeling analyses had the option of reducing the emissions from their BART-eligible un its using an enforceable mechanism, such as a permit, or performing an engineering analysis. The BART-eligible sources that chose to reduce potential emissions are discussed in Section 9. 3 . The emission reductions resulting from the engineering analyses and resulting emission controls are presented in Section 9.5.

9.2.1 Cumulative Modeling Using CAMx PSAT The TCEQ conducted screening modeling analyses as described in the CAMx modeling protocol, Screening Analysis of Potentially BART-Eligible Sources in Texas, and the final CAMx modeling
report, Final Report, Screening Analysis of Potential BART-Eligible Sources in Texas, presented in Appendices 9- 4 and 9- 5 , respectively. In addition to the CAMx modeling, the TCEQ developed Texas model plants based on the CAMx modeling results. The model plants are discussed in the addendums to the CAMx modeling report, Addendum I , BART Exemption Screening Analysis, and Addendum II, BART Exemption Screening Analysis. Both addendums are contained in Appendix 9- 6 . Sources that successfully screened out in the CAMx screening modeling analyses or by using the Texas model plants were required to review the modeling analysis and data used and to certify that they agree with the screening modeling analyses and inputs. Copies of these certifications are contained in Appendix 9- 7 . Table 9- 3 shows the BART-eligible sources that successfully screened out in the cumulative modeling analyses. Deleted:

.

Deleted:

Deleted: 4

Deleted: 3

Deleted: 4

Deleted: 5

Deleted: 6

Deleted: 29-7 BART-eligible sources that did not screen out of the cumulative modeling were required to conduct their own screening modeling analysis using either the CALPUFF or the CAMx modeling setup developed by the TCEQ. The single source modeling analyses are outlined in
Section 9.2.2.

Table 9- 3 : BART-Eligible Sources Screened Out Using Cumulative CAMx Modeling

No. Account Source Regulated Entity SIC

1 TG0044C AEP TEXAS RN101531226 4911

2 CD0013K AEP TEXAS CENTRAL COMPANY RN102560687 4911

3 NE0024E AEP TEXAS CENTRAL COMPANY RN100642040 4911

4 NE0026A AEP TEXAS CENTRAL COMPANY RN100552181 4911

5 JI0030K AEP TEXAS NORTH COMPANY RN100215557 4911

6 CB0003M ALCOA ALUMINA & CHEMICALS RN100242577 2819

7 HG0558G ATOFINA CHEMICALS INC RN100209444 2869

8 BL0021O BASF CORPORATION RN100218049 2869

9 GB0001R BP AMOCO CHEMICAL COMPANY RN102536307 2869

10 MH0009H CELANESE LIMITED RN100258060 2869

11 ED0011D CHAPARRAL STEEL MIDLOTHIAN RN100216472 3312

12 BJ0001T CHEMICAL LIME LTD RN100219856 3274

13 BL0758C CHEVRON PHILLIPS CHEMICAL RN100825249 2869

14 HG0310V CHEVRON PHILLIPS CHEMICAL RN103919817 2869

15 HW0013C CHEVRON PHILLIPS CHEMICAL RN102320850 2869

16 BG0057U CITY PUBLIC SERVICE RN100217975 4911

17 BG0186I CITY PUBLIC SERVICE RN100217835 4911

18 CR0020C COPANO PROCESSING LP RN101271419 1321

19 CI0022A DYNEGY MIDSTREAM SERVICES RN100222900 1321

20 HG0218K EI DUPONT RN100225085 2869

21 EE0029T EL PASO ELECTRIC CO RN100211309 4911

22 TH0004D ELECTRIC UTILITY DEPT RN100219872 4911
23 MQ0009F ENTERGY GULF STATES INC RN100226877 4911

24 OC0013O ENTERGY GULF STATES INC RN102513041 4911
25 BL0113I EQUISTAR RN100218601 2869
26 BL0268B EQUISTAR CHEMICALS LP RN100237668 2821

27 HG0228H EXXON CHEMICAL CO RN102212925 2869

28 JE0065M EXXON MOBIL CHEMICAL CO RN100211903 2821

29 HG0229F EXXONMOBIL CHEMICAL CO RN102574803 2869

30 NE0120H Flint Hills Resources RN102534138 2911

31 NE0122D FLINT HILLS RESOURCES LP RN100235266 2911

32 JE0052V HUNTSMAN CORPORATION RN100219252 2869
33 JE0135Q HUNTSMAN PETROCHEMICAL RN100217389 2869
34 BL0002S Ineos Olefins & Polymers RN100238708 2869

35 WE0005G LAREDO POWER RN100213909 4911

36 MB0123F LEHIGH CEMENT COMPANY RN100218254 3241

37 NE0025C LON C HILL POWER RN100215979 4911

38 BC0015L Lower Colorado River Authority RN102038486 4911 Deleted: Pa g e Brea k

Deleted: 29-8 No. Account Source Regulated Entity SIC

39 FC0018G Lower Colorado River Authority RN100226844 4911
40 HG1575W Lyondell Chemical RN100633650 2869

41 HG1451S OXYVINYLSLP RN102518065 2821

42 JE0042B PREMCOR REFINING GROUP RN102584026 2911

43 HG0632T ROHM & HAAS TEXAS RN100223205 2869

44 BL0038U SOLUTIA INC RN100238682 2869

45 GJ0043K SOUTHWESTERN ELECTRIC POWER RN102156916 4911

46 LN0081B SOUTHWESTERN PUBLIC SERVICE (FORMERLY XCEL) RN100224765 4911

47 ME0006A SOUTHWESTERN ELECTRIC POWER RN100542596 4911

48 PG0040T SOUTHWESTERN PUBLIC SERVICE RN100224641 4911

49 PG0041R SOUTHWESTERN PUBLIC SERVICE RN100224849 4911

50 JE0091L SUN MARINE TERMINAL RN100214626 4226

51 WN0042V TARGA RN102552387 1311

52 CI0012D TEXAS GENCO LP RN100825371 4911

53 FG0020V TEXAS GENCO LP RN100888312 4911

54 HG0562P TEXAS PETROCHEMICALS LP RN100219526 2869

55 BL0082R THE DOW CHEMICAL CO RN100225945 2869

56 NE0022I TICONA POLYMERS INC RN101625721 2869

57 FI0020W TXU BIG BROWN COMPANY LP RN101198059 4911

58 DB0251U TXU ELECTRIC COMPANY RN101559854 4911

59 FB0025U TXU GENERATION COMPANY LP RN102285855 4911
60 HQ0012T TXU GENERATION COMPANY LP RN100664812 4911

61 MB0116C TXU GENERATION COMPANY LP RN102566494 4911

62 MM0023J TXU GENERATION COMPANY LP RN102147881 4911

63 MO0014L TXU GENERATION COMPANY LP RN102285848 4911

64 RL0020K TXU GENERATION COMPANY LP RN102583093 4911

65 TA0352I TXU GENERATION COMPANY LP RN100693308 4911
66 WC0028Q TXU GENERATION COMPANY LP RN102183969 4911

67 YB0017V TXU GENERATION COMPANY LP RN102563426 4911

68 GB0076J UNION CARBIDE CORP RN100219351 2869

69 CB0028T UNION CARBIDE CORPORATION RN102181526 2869

70 GB0073P VALERO REFINING CO TEXAS RN100238385 2911

71 VC0003D VICTORIA POWER RN100214980 4911

72 JB0016M VINTAGE PETROLEUM INC RN100214592 1311

Distances from the BART-eligible sources to Class I areas were determined and are shown in
Table 9-4 that follows. Deleted: ¶ Page Break ¶
Table 9

- 2: BART

- Eligible Sources Screened Out Using Cumulative CAMx (cont’d) ¶
No.

Deleted: Pa g e Brea k ... [3]9-9Table 9-4: BART-Eligible SourceDistance to Each Class IDistance to Class I (km)RegulatedEntityCompanyBigBendBretonIsleCaneyCreekCarlsbadCavernsGuada-lupeMtnsSaltCreekUpperBuffaloWheelerPeakWhiteMtnWichitaMtnsRN100220110ABITIBI CONSOLIDATED CORP85158034393796894651411481070533RN102560687AEP TEXAS CENTRAL CO6529579799459531054115213741132962RN100642040AEP TEXAS CENTRAL CO60886281586087495198812551041805RN100552181AEP TEXAS CENTRAL CO59086579783885292697012291018780RN100215557AEP TEXAS NORTH CO4971071556460495455681688579257RN101531226AEP TEXAS NORTH CO3511125684393420442821733549408RN100221472ALCOA INC6097925107317587696791022884490RN100242577ALCOA WORLD ALUMINA LLC65275968085987892785412091030708RN100250869ALON USA LP3731223720295329316837604431372RN100225978ASH GROVE TEXASLP693827342710744700496893827294RN100209444ATTOFINA CHEMICALS INC78060952693295797269812171086647RN100219872AUSTIN ENERGY5538435636907157387311005849505RN100218049BASF CORPORATION76064161394296599678512581105711RN102536307BP AMOCO CHEMICAL CO804590566969993101473612641127697RN102535077BP PRODUCTS NORTH AMERICA805562564970994101473512641127696RN100221761CABOT CORPORATION7211296642497535377686414494225RN100211507CAPITOL CEMENT DIV4669246776526727248431017824579RN101996395CELANESE CHEMICAL7171297645492531373689413489226RN100258060CELANESE LTD70270364289491595581612271061703RN100216472CHAPARRAL STEEL687828348707741699503894825299RN100219856CHEMICAL LIME LTD603858443658689672601901793354RN103919817CHEVRON PHILLIPS CHEMICAL80558451595397999068612311106654RN102320850CHEVRON PHILLIPS CHEMICAL7331332676494531365715379477261RN100825249CHEVRON PHILLIPS CHEMICAL72667361290893096478512291072690RN102555166CITGO REFINING & CHEMICALS55786679883785292697112291018781RN100217975CITY PUBLIC SERVICE4759176936736927488611044847606RN100217835CITY PUBLIC SERVICE4709237016716897488681045845611RN102495884CONOCO PHILLIPS7321333677492530363716378475262RN101271419COPANO PROCESSING LP6407515988138358687711138977619RN100218684DCP MIDSTREAM LP35013558371672041989435193034579-10Distance to Class I (km)RegulatedEntityCompanyBigBendBretonIsleCaneyCreekCarlsbadCavernsGuada-lupeMtnsSaltCreekUpperBuffaloWheelerPeakWhiteMtnWichitaMtnsRN100209659DEGUSSA ENG CARBONS7281337683486524357722373469266RN100227016DOW CHEMICAL CO79160053994797298871012351102665RN104150123DOW CHEMICAL CO79659853695197598771712381113668RN100222900DYNEGY MIDSTREAM SERVICES80758351395498099168412311107653RN100219815EASTMAN CHEMICAL COMPANY88662322492796091539710841042452RN100225085EI DUPONT DE NEMOURS & CO79459653094797298770112321102660RN100542711EI DUPONT DE NEMOURS & CO91847248410531080108064613031199699RN100211309EL PASO ELECTRIC CO428168911781781462601273518175778RN102166964ENBRIDGE PIPELINES LP94064713595298792430810671053428RN100226877ENTERGY GULF STATES INC75364346187890690863411431026565RN102513041ENTERGY GULF STATES INC90748448710431070107165012951190695RN100210574EQUISTAR77761958294897199675312521108694RN100237668EQUISTAR CHEMICALS LP77761858294897299775412521108695RN100542281EQUISTAR CHEMICALS LP78760351793596197368812161088643RN100211903EXXON MOBIL CHEMICALS88950148210241051105364712791171680RN102212925EXXONMOBIL CHEMICAL CO79659452494797298669512291101655RN102574803EXXONMOBIL CHEMICAL CO79559452594797298669612291101656RN102579307EXXONMOBIL CORP79659852694497098269712361112658RN102450756EXXONMOBIL OIL CORP88850248210231050105264712781170679RN102534138FLINT HILLS RESOURCES LP59086579883885292797112301018781RN100235266FLINT HILLS RESOURCES LP58087480082984391897212221009777RN100219252HUNTSMAN CORP89949149210371064106765612931185694RN100217389HUNTSMAN CORP89749350110381065106966612971187700RN101867554HUNTSMAN POLYMERS CORP2931303819212241277936600373467RN100238708INEOS USA LLC779617584951974100075612551111698RN100543115INTERNATIONAL PAPER CO974619128988102396029610991089460RN104392626INVISTA91847248410531080108064613031199700RN102663671INVISTA S.A.R.L.6147976938248428968661182996696RN100213909LAREDO WLE LP411106991870371081810861145890802RN100218254LEHIGH CEMENT COMPANY623820438694725712601942832388RN100215979LON C HILL LP571882802820834911974121610017749-11Distance to Class I (km)RegulatedEntityCompanyBigBendBretonIsleCaneyCreekCarlsbadCavernsGuada-lupeMtnsSaltCreekUpperBuffaloWheelerPeakWhiteMtnWichitaMtnsRN102038486LCRA5838105597277527757291040886529RN100226844LCRA6307605587838078317301094942568RN100633650LYONDELL CHEMICAL CO78760351893696297569012181090645RN100218130LYONDELL CITGO REFINING77561552992895396970312161083648RN100210608MARATHON PETROLEUM806587564971995101573412651128697RN102609724NORIT AMERICAS INC91560320995498894038111041067470RN101062826NRG TEXAS LP799593552960984100372312511117682RN100223585OWENS-CORNING701811336724758717494910843310RN102518065OXY VINYLS LP78960152894196698169912261096654RN100716661PASADENA REFINING SYSTEM77761352893095597170312171085649RN102584026PREMCOR REFINING GROUP89749350510391066107066912991188703RN100216621REGENCY FS (FIELD SERVICES)4689537887117258049571113892705RN100223205RHODIA, INC.79759352494897398769512301102657RN100223205ROHM & HAAS TEXAS78860252894096598069912251095654RN100211879SHELL OIL CO78560453093896497970112241093654RN100222413SID RICHARDSON CARBON7271337683486524357722373468266RN100226026SID RICHARDSON CARBON21814079451421532751063618329590RN100238682SOLUTIA INC77761858294897299775412521108695RN102156916SOUTHWESTERN ELEC POWER88861623193296592140310921048461RN100542596SOUTHWESTERN ELEC POWER91563217894197592135110771049440RN100213370SOUTHWESTERN ELEC POWER90066816591494989033810411019404RN100224641SOUTHWESTERN PUBLIC SERV6791346705435473308754362423281RN100224849SOUTHWESTERN PUBLIC SERV6811347705436474309754361424282RN100224765SOUTHWESTERN PUBLIC SERV4901282712304344248803477377309RN100214626SUN MARINE TERMINAL89649450510381065107067012991188703RN102551785TARGA MIDSTREAM SERVICES2511327859196219288979621370513RN102552387TARGA MIDSTREAM SERVICES684925361647684617488786745182RN100214428TEMPLE-INLAND92147146610501077107462812931194687RN100888312TEXAS GENCO73665656590192594973812051060653RN100825371TEXAS GENCO80458552395598099369412361109660RN102597846TEXAS LEHIGH CEMENT CO52586759967870173476710098415289-12Distance to Class I (km)RegulatedEntityCompanyBigBendBretonIsleCaneyCreekCarlsbadCavernsGuada-lupeMtnsSaltCreekUpperBuffaloWheelerPeakWhiteMtnWichitaMtnsRN100g219526TEXAS PETROCHEMICALS LP77261753492795296870612161083649RN102561925THE GOODYEAR TIRE & RUBBER87451649210131040104465912731161679RN101625721TICONA POLYMERS INC562911839824836920101112301006803RN102457520TOTAL PETROCHEMICALS USA90448549310431070107265712981190698RN100217199TXI OPERATIONS LP688827347708742700503895826299RN101198059TXU BIG BROWN CO LP7417193408028338065111010930409RN101559854TXU GENERATION COMPANY720841312716751695459871823257RN102285855TXU GENERATION COMPANY809822227781818745366887874250RN100664812TXU GENERATION COMPANY630886402645678640550846765277RN102566494TXU GENERATION COMPANY651797413719750733578957854389RN102147881TXU GENERATION COMPANY6107915097327587706791022884490RN102285848TXU GENERATION COMPANY4031178674343376355793627473336RN102583093TXU GENERATION COMPANY88960424293997293041411041057474RN100693308TXU GENERATION COMPANY680865352680715665498852792256RN102285921TXU GENERATION COMPANY88568517089793287234210241001387RN102183969TXU GENERATION COMPANY25513608841621862611001599339528RN102563426TXU GENERATION COMPANY612991441567603541563730669180RN102181526UNION CARBIDE CORP63478370284886792187612081021718RN100219351UNION CARBIDE CORP802591565967991101273512621125695RN100213685VALENCE MIDSTREAM842717204853888831372990959356RN100210517VALERO MCKEE7511387728490527350760326453316RN100238385VALERO REFINING CO TEXAS806588565971995101573512651128697RN100211663VALERO REFINING CO TEXAS55986779883685192597112291017780RN100218601VETROTEX AMERICA671101941958762553952169066899RN100214980VICTORIA WLE LP6077996828138328838551169985682RN100214592VINTAGE PETROLEUM LLC64676166984786791484211951017693RN102157609WESTVACO891503451101610441040617126011606569-13 9.2.2 Individual Source Attribution Approach One of the air quality modeling approaches suggested by the EPA in the BART guidance is anindividual source attribution approach. Specifically, this entails modeling source-specific BARTeligible units and comparing modeled impact s to a particular deciview threshold.

CALPUFF The CALPUFF modeling protocol, Best Available Retrofit Technology (BART) Modeling Protocol to Determine Sources Subject to BART in the State of Texas , developed by the TCEQ for determining which sources are subject to BART is included in Appendix 9- 8 : CALPUFF Modeling Guidelines (online) . Appendix 9- 8 also contains a summary report for each modeling
demonstration. Table 9- 5: BART-Eligible Sources Exempt Based on CALPUFF Modeling
Results lists the BART-eligible sources that are exempt from BART based on CALPUFF modeling results. Deleted: 7

Deleted: 7

Deleted: 3:

Deleted: ¶ Page Break9-14 Table 9- 5 : BART-Eligible Sources Exempt Based on CALPUFF Modeling Results Regulated

Entity Account Source SIC

RN100221472 MM0001T ALCOA INC 3334

RN100250869 HT0011Q ALON USA LP 2911

RN100225978 ED0034O ASH GROVE (formerly NORTH TEXAS CEMENT) 3241

RN100221761 GH0003Q CABOT CORPORATION 2895

RN101996395 GH0004O CELANESE CHEMICAL 2869

RN102495884 HW0018P CONOCO PHILLIPS (formerly PHILLIPS 66 CO) 2911

RN100218684 AB0012W DCP (formerly DUKE ENERGY FIELD SERVICES) 1321

RN100209659 HW0008S DEGUSSA ENGINEERED CARBONS 2869

RN100219815 HH0042M EASTMAN CHEMICAL COMPANY 2869

RN100542281 HG0033B EQUISTAR CHEMICALS LP 2869

RN102579307 HG0232Q EXXONMOBIL CORP 2911

RN102450756 JE0067I EXXONMOBIL OIL CORP 2911

RN101867554 EB0057B HUNTSMAN POLYMERS 2869

RN100543115 CG0010G INTERNATIONAL PAPER CO 2621

RN104392626 OCA002B INVISTA 2869

RN102663671 VC0008Q INVISTA (formerly DU PONT DE NEMOURS) 2869

RN101062826 GB0037T NRG TEXAS (formerly TEXAS GENCO LP) 4911

RN100223585 ED0051O OWENS CORNING 3296

RN100220581 HG0697O RHODIA INC 2819

RN100211879 HG0659W SHELL OIL CO 2911

RN100222413 HW0017R SID RICHARDSON CARBON 2895

RN100226026 HT0027B SID RICHARDSON CARBON CO 2895

RN100213370 TF0012D SOUTHWESTERN ELECTRIC POWER 4911

RN100214428 OC0019C TEMPLE-INLAND 2621

RN102597846 HK0014M TEXAS LEHIGH CEMENT CO 3241

RN102457520 JE0005H TOTAL PETROCHEMICALS INC (formerly ATOFINA PETROCHEMICALS INC) 2911

RN100217199 ED0066B TXI OPERATIONS LP 3241

RN102285921 TF0013B TXU GENERATION COMPANY LP 4911

RN102157609 JC0003K WESTVACO 2631 Deleted: 3

Deleted: No. ... [4]9-15 CAMx The CAMx modeling guideline, Guidance for the Application of the CAMx Hybrid Photochemical Grid Model to Assess Visibility Im pacts of Texas BART Sources at Class I Areas

, developed by the TCEQ is in Appendix 9- 9 . This appendix also contains the modeling summary reports for each modeling demonstration. Table 9- 6 presents the BART-eligible sources that screened out on an individual basis using CAMx.

Table 9- 6 : BART-Eligible Sources Exempted Screened Out on Individual Basis Using Single
Source CAMx Modelin g

No. Account Source Regulated Entity SIC

1 GB0004L BP PRODUCTS NORTH AM ERICA RN102535077 2911

2 NE0027V CITGO REFINING & CHE M ICALS RN102555166 2911

3 HGA005E DOW RN104150123 2869

4 HG0048L LYONDELL CITGO REFIN ING RN100218130 2911

5 HG0175D PASADENA REFINING RN100716661 2911

6 NE0043A VALERO REFINING COMP ANY RN100211663 2911

Reference

Number Reference Number Nearest
Class I
Area Distance

to Nearest
Class I area (km) Emission Rate
Data Source Highest Impact (dv) Class I
Area
with Highest Impact

RN102535077 BP Products North
American BRET 562 Permit Allowables 0.28 CACR

RN102555166 CITGO Corpus Christi Refinery BIBE 557 Permit Allowables 0.16 BIBE

RN104150123 Dow Chemical Company CACR 536 Permit Allowables 0.21 BRET

RN100218130 Houston Refining LP CACR 529 PTE, Permit
Allowables 0.10 UPBU/

CACR

RN100716661 Pasadena Refining System Inc. CACR 528 Permit Allowables 0.42 CACR

RN100211663 Valero Corpus Christi
East Plant BIBE 554 Facility Wide Emission Cap 0.11 BIBE/

CACR

9.3 SITES REMOVED FROM FURTHER BART CONSIDERATION The TCEQ BART rule was published January 10, 2007. Companies requested removal from further BART consideration per the exemptions in the rule or based on updated information on the site. To be removed from the list, a site had to be exempted for all potential haze causing pollutants, NO X , SO 2 , and fine particulate matter. A site may be exempted if the combined NO X and SO 2 potential to emit are less than 1,000 tpy, and the site is greater than 100 km from a Class I area. Some sites may be exempted if the combined NO X and SO 2 potential to emit are less than 500 tpy, and the site is greater than 50 km from a Class I area. Several sites requested exemption
for combined SO X and NO X limits and certified that the TCEQ-sponsored modeling adequately represented particulate emissions. One site requested PM 2.5 exemption due to de minimis levels
of emissions.

Updated site information included construction dates and potential emission rates of equipment. Two sites requested removal because the operating equipment did not meet a BART category. The results of granted exclusions are also shown in Table 9.7: Summary of BART-Eligible Source

Determinations

. Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough Deleted: 8

Deleted: 4

Deleted: 4

Deleted: 9.3 ¶9-16 Table 9-7: Sites Removed From BART Due to Exemption Requests

No. Regulated Entity Company Reason Account SIC

1 RN100220110 ABITIBI CONSOLIDATED
CORP PTE*<1,000,
de minimis PM AC0017B 2621

2 RN102559291 BMC HOLDINGS INC PTE<1,000,
PM certification JE0343H 2869

3 RN100211507 CAPITOL CEMENT Shut down kiln BG0045E 3241

4 RN100227016 CELANESE PTE<250 HG0126Q 2869

5 RN100825249 CHEVRON PHILLIPS
CHEMICAL met TCEQ model plant BL0758C 2869

6 RN100542711 EI DUPONT DENEMOURS &
CO PTE<1,000,
PM certification OC0007J 2869

7 RN102166964 ENBRIDGE PIPELINES PTE<250 CG0012C 1321

8 RN104579487 INEOS USA PTE<250 GBA007G 2869

9 RN100212018 J.L. DAVIS GAS PROCESSING No BART sources CA0011B 1321

10 RN100213719 JOHNS MANVILLE
INTERNATIONAL PTE<250 JH0025O 3296

11 RN100633650 LYONDELL PETROCHEMICAL PTE<1,000,
PM certification HG1575W 2869

12 RN100210608 MARATHON ASHLAND
PETROLEUM PTE<250 GB0055R 2911

13 RN102609724 NORIT AMERICAS INC PTE<1,000,
PM certification HH0019H 2819

14 RN102643327 PUEBLO MIDSTREAM GAS
CORP recheck dates,

not BART AG0024G 1321

15 RN100211408 REGENCY GAS SERVICES No BART equip PE0024Q 1321

16 RN100216621 REGENCY TILDEN GAS PTE<1,000,
PM certification MC0002H 2819

17 RN102551785 TARGA Shut down CY0019H 1311

18 RN102561925 THE GOODYEAR TIRE AND
RUBBER CO PTE<250 JE0039N 2822

19 RN100213685 VALENCE MIDSTREAM LTD plant shut down HR0018T 1321

20 RN100210517 VALERO MCKEE REFINERY PTE<1,000,
PM certification MR0008T 2911

21 RN100219310 VALERO REFINING TEXAS LP PTE<1,000,
PM certification HG0130C 2911

22 RN100218601 VETROTEX AMERICA ST.
GOBAIN PTE<500,
PM certification WH0014S 3229 Note: *PTE is potential to emit9-17 9.4 DETERMINATION OF BART FOR SOURCES SUBJECT TO BART Upon conclusion of all BART screening analyses and review of exclusion requests , no Texas sources remained subject to BART. The Some EGUs may become subject to BART pending resolution of CAIR at the federal level. Table 9-8: Summary of BART-Eligible Source
Determination summarizes where a determination was made for all sources in the BART determination process. Several sources were added to the process after the BART survey, either at the site’s request or as a result of recent activity at the site. Their status is reflected in this table. Site activity included transfer of equi pment or corporate reorganization resulting in site splits. Although not used thus far for any sources, the TCEQ’s Engineering Analysis Guidance and forms are in Appendix 9- 10

.

Table 9-8: Summary of BART-Eligible Source Determinations

Reason for Removal

Account Company BARTeligible 1 Cum.

Model
CAMx CALPUFF Single
Source
CAMx Exemption Request

TG0044C AEP TEXAS y y CD0013K AEP TEXAS CENTRAL COMPANY y y NE0024E AEP TEXAS CENTRAL COMPANY y y NE0026A AEP TEXAS CENTRAL COMPANY y y JI0030K AEP TEXAS NORTH COMPANY y y CB0003M ALCOA ALUMINA & CHEMICALS y y BL0002S INEOS OLEFINS & POLYMERS y y HG0558G ATOFINA CHEMICALS INC y y BL0021O BASF CORPORATION y y GB0001R BP AMOCO CHEMICAL COMPANY y y MH0009H CELANESE LIMITED y y ED0011D CHAPARRAL STEEL MIDLOTHIAN y y BJ0001T CHEMICAL LIME LTD y y HG0310V CHEVRON PHILLIPS CHEMICAL y y HW0013C CHEVRON PHILLIPS CHEMICAL CO y y BG0057U CITY PUBLIC SERVICE y y BG0186I CITY PUBLIC SERVICE y y CR0020C COPANO PROCESSING LP y y CI0022A DYNEGY MIDSTREAM SERVICES y y WN0042V TARGA y y HG0218K EI DUPONT y y EE0029T EL PASO ELECTRIC CO y y TH0004D ELECTRIC UTILITY DEPT y y MQ0009F ENTERGY GULF STATES INC y y OC0013O ENTERGY GULF STATES INC y y BL0113I EQUISTAR y y BL0268B EQUISTAR CHEMICALS LP y y HG0033B EQUISTAR CHEMICALS LP y y HG0228H EXXON CHEMICAL CO y y JE0065M EXXON MOBIL CHEMICAL CO y y HG0229F EXXONMOBIL CHEMICAL CO y y NE0122D FLINT HILLS RESOURCES LP y y JE0052V HUNTSMAN CORPORATION y y JE0135Q HUNTSMAN PETROCHEMICAL y y Deleted: 99-18 Reason for Removal

Account Company BARTeligible 1 Cum.

Model
CAMx CALPUFF Single
Source
CAMx Exemption Request

CORP

EB0057B HUNTSMAN POLYMERS y y GBA007G INEOS y NE0120H FLINT HILLS RESOURCES LP y y WE0005G LAREDO POWER y y MB0123F LEHIGH CEMENT COMPANY y y NE0025C LON C HILL POWER y y

BC0015L LOWER COLORADO RIVER
AUTHORITY y y

FC0018G LOWER COLORADO RIVER
AUTHORITY y y

HG1575W LYONDELL CITGO REFINING y y y HG1451S OXYVINYLSLP y y JE0042B PREMCOR REFINING GROUP y y HG0632T ROHM & HAAS TEXAS y y BL0038U SOLUTIA INC y y GJ0043K SOUTHWESTERN ELECTRIC POWER y y ME0006A SOUTHWESTERN ELECTRIC POWER y y PG0040T SOUTHWESTERN PUBLIC SERVICE y y PG0041R SOUTHWESTERN PUBLIC SERVICE y y JE0091L SUN MARINE TERMINAL y y CI0012D TEXAS GENCO LP y y FG0020V TEXAS GENCO LP y y GB0037T NRG Texas y y HG0562P TEXAS PETROCHEMICALS LP y y BL0082R THE DOW CHEMICAL CO y y NE0022I TICONA POLYMERS INC y y ED0066B TXI OPERATIONS, L.P. y y FI0020W TXU BIG BROWN COMPANY LP y y DB0251U TXU ELECTRIC COMPANY y y FB0025U TXU GENERATION COMPANY LP y y HQ0012T TXU GENERATION COMPANY LP y y MB0116C TXU GENERATION COMPANY LP y y MM0023J TXU GENERATION COMPANY LP y y MO0014L TXU GENERATION COMPANY LP y y RL0020K TXU GENERATION COMPANY LP y y TA0352I TXU GENERATION COMPANY LP y y WC0028Q TXU GENERATION COMPANY LP y y YB0017V TXU GENERATION COMPANY LP y y GB0076J UNION CARBIDE CORP y y CB0028T UNION CARBIDE CORPORATION y y GB0073P VALERO REFINING CO TEXAS y y VC0003D VICTORIA POWER y y JB0016M VINTAGE PETROLEUM, INC. y y LN0081B SOUTHWESTERN PUBLIC SERVICE y y AC0017B ABITIBI CONSOLIDATED CORP y y9-19 Reason for Removal

Account Company BARTeligible 1 Cum.

Model
CAMx CALPUFF Single
Source
CAMx Exemption Request

TF0012D SOUTHWESTERN ELECTRIC POWER y y MM0001T ALCOA INC y y HT0011Q ALON USA LP y y ED0034O ASH GROVE y y JE0343H BMC HOLDINGS INC y

GB0004L BP PRODUCTS NORTH AMERICA IN
TEXAS y y GH0003Q CABOT CORPORATION y y BG0045E CAPITOL CEMENT DIV CAPITOL y y GH0004O CELANESE CHEMICAL y y BL0758C CHEVRON PHILLIPS CHEMICAL y y NE0027V CITGO REFINING & CHEMICALS y y HW0018P CONOCOPHILLIPS y y AB0012W DCP y y HW0008S DEGUSSA ENGINEERED CARBONS y y MR0008T DIAMOND SHAMROCK REFINING y y HGA005E DOW y y HG0126Q DOW y y HH0042M EASTMAN CHEMICAL COMPANY y y OC0007J EI DUPONT DENEMOURS & CO y y MC0002H ENBRIDGE PIPELINE y CG0012C ENBRIDGE PIPELINES y y HG0033B EQUISTAR CHEMICALS LP y HG0232Q EXXONMOBIL CORP - Baytown y y JE0067I EXXONMOBIL OIL CORP - Beaumont y y EB0057B HUNTSMAN POLYMERS y CG0010G INTERNATIONAL PAPER CO y y OCA002B INVISTA y y VC0008Q INVISTA y y JH0025O JOHNS MANVILLE INTERNATIONAL y HG0048L LYONDELL CITGO REFINING y y

GB0055R MARATHON ASHLAND
PETROLEUM y y HH0019H NORIT AMERICAS INC y y GB0037T NRG Texas y ED0051O OWENS CORNING y y HG0175D PASADENA REFINING y y AG0024G PUEBLO MIDSTREAM GAS CORP y PE0024Q REGENCY GAS SERVICES y HG0697O RHODIA, INC. y y HG0659W SHELL OIL CO y y HW0017R SID RICHARDSON CARBON y y HT0027B SID RICHARDSON CARBON y y CY0019H TARGA y y OC0019C TEMPLE-INLAND y y HK0014M TEXAS LEHIGH CEMENT CO y y9-20 Reason for Removal

Account Company BARTeligible 1 Cum.

Model
CAMx CALPUFF Single
Source
CAMx Exemption Request

JE0039N THE GOODYEAR TIRE AND RUBBER
CO y y JE0005H TOTAL PETROCHEMICALS y y ED0066B TXI OPERATIONS, L.P. y TF0013B TXU GENERATION COMPANY LP y y HR0018T VALENCE MIDSTREAM LTD y y NE0043A VALERO REFINING COMPANY y y HG0130C VALERO REFINING TEXAS LP y WH0014S VETROTEX WICHITA FALLS PLANT y y JC0003K WESTVACO y y
Note:
1. Some sources were added to the determination process after the BART survey , either by their request or as a result of equipment transfers. These are indicated with a blank.9-21 9. 5 POST-BART EMISSIONS REDUCTIONS Subsequent to the 2002 base year inventory, some BART-eligible sources reduced their permitted emissions. Documentation of the emission reductions is in Appendix 9- 11 : Documentation of
Emission Reductions . The sources and the estimated reductions are presented in Table 9- 9

. Reduction estimates are conservative because they are from the 2002 actual emissions level to apotential to emit level. Capitol Cement shut down their BART units. The final list of all BARTeligible sources is in Appendix 9- 13 : BART-Eligible List

.

Table 9- 9 : Post-BART Emissions Reductions at Texas Sources

No. Regulated Entity Source Account* NO X Reduced

from
Baseline

2002 (tpy) SO 2 Reduced

from
Baseline

2002 (tpy) PM
Reduced

from
Baseline

2002 (tpy)

1 RN100211507 CAPITOL CEMENT DIV BG0045E 1,328 1,193 100

2 RN100227016 DOW HG0126Q 694 0 0

3 RN102450756 EXXONMOBIL OIL*** JE0067I 2.7 290 0

4 RN102609724 NORIT AMERICAS INC HH0019H** 16.6 +5.4 0

5 RN100216621 REGENCY TILDEN GAS (FORMERLY ENBRIDGE PIPELINE) MC0002H 2 2,276 0.2

6 RN102551785 TARGA (FORMERLY

DYNEGY MIDSTREAM SERVICES) CY0019H 336 0.3 0.5

7 RN102561925 THE GOODYEAR TIRE
AND RUBBER CO JE0039N 89.1 +11.3 2.9

8 RN100213685 VALENCE MIDSTREAM

LTD HR0018T 247.1 2,743.5 5.6

9 RN100218601 VETROTEX AMERICA
ST. GOBAIN WH0014S 62.6 16.4 59.0

Total estimated reductions in haze emissions = 9,485.2 tpy 2,778.1 6,535.9 168.2

*The first two letters in account number are the ab breviation for the source’s county location. See Appendix 9- 12 for the list of county abbreviations. **Company has permit limiting combined SO 2 and NOx to 841 tpy on previously grandfathered BART

sources but 2002 . This limit is lower than actual emissions from th ese units were 8 tpy less than this in previous years. For example, th e facility emitted 1,266 tpy of NO X and SO 2 in 1990

. ***ExxonMobil numbers are preliminar y and subject to change. These estimates are based on reductions

from the 2002 EI and proposed a lterations to permit 1 913 6 pre- and an EPA consent decree. Deleted: 4

Deleted: 10

Deleted: 6

Deleted: 12

Deleted: 6

Deleted: No.

Deleted: 11 ... [5]9-22 9.5 SITES REMOVED F ROM FURTHER POST- BART CONSIDERATION
The TCEQ BART rule was published January 10, 2007. Companies requested removal from further BART consideration per the exemptions in the r ule or based on updated information on the site. To be removed from the list, a site had to be exempted for all potential haze causing pollutants, NO X , SO 2 , and fine particulate matter. A site may be exempted if the combined NO X and SO 2 potential to emit are less than 1,000 tpy, and the site is greater than 100 km from a Class I area. Some sites may be exempted if the combined NO X and SO 2 potential to emit are less than 500 tpy, and the site is greater than 50 km from a Class I area. Several sites reque sted exemption
for combined SO X and NO X limits and certified that the TCEQ

- sponsored modeling adequately represented particulate hourly emissions One site requested PM 2.5 exemption due to de minimis
levels of emissions.

Updated site information include d construction dates and potential emission rates submitted. (Emission reductions as a result of equipment. Two sites requested removal because the operating equipment did not meet a BART category. Table 9

- 7 lists the sites removed from
further BART con sideration. Table 9

- 7: Sites Removed From BART Due to Exemption Requests per TCEQ BART Rule and Updated Site Information the completion of permit 49138 (FCCU) will be updated when they become available.) Deleted:

.

Deleted: Pa g e Brea k

Deleted: No. ... [6]10-1 CHAPTER 10. REASONABLE PROGRESS GOALS

10.1 INTRODUCTION The national goal for regional haze is to achieve natural visibility levels at Class I areas by 2064.
The Texas Commission on Environmental Quality ( TCEQ ) must show reasonable progress toward the national goal by 2018. The uniform rate of progress (URP) named in the United States Environmental Protection Agency ( EPA ) guidance (described as uniform rate of improvement in 40 Code of Federal Regulations ( CFR ) §51.308(d)(1)(i)(B)) is a straight line between base period conditions on the worst 20 percent days and estimated natural visibility in

2064 conditions . Chapter 5: Assessment of Baseline and Current Conditions and Estimate of
Natural Conditions in Class I Areas details the calculation of base period conditions and estimations of 2064 natural conditions. The URP is a tool for comparing the reasonable progress goals (RPGs) set by the state with the visibilit y improvement that would be needed to reach natural conditions by 2064. Table 10-1 : Uniform Rate of Progress for Class I Areas in Texas (Worst 20 Percent Days) shows the URP goals for Texas’ 2018 deciview values for the two
Texas Class I areas.

Table 10-1 shows Texas’ calculation of natural conditions using the approximation that 100 percent of the dust (coarse mass and fine soil) at both Big Bend and Guadalupe Mountains National Parks is natural. As Chapter 5 discusse s in more detail, analysis indicated that the approximation that all the dust is natural is a better approximation than an estimate using any substantively lower percentage.

The TCEQ plans to work with the EPA, Federal Land Managers (FLMs), and other experts and
researchers as Texas continues to refine natura l condition estimates for future five-year reports and ten-year Regional Haze SIP revisions.

Table 10-1: Uniform Rate of Progress for Class I Areas in Texas (Worst 20 Percent Days)

Class I Area Improvement Needed by 2018 assuming Assumi

ng URP (dv) Annual Progress Annually Needed

to 2018 assuming Meet URP (dv) Improvement Needed by 2064 (dv)

Big Bend 1.7 0.12 7.2

Guadalupe Mountains 1.2 0.08 4.9

10.2 REASONABLE PROGRESS GOALS FOR TEXAS CLASS I AREAS The TCEQ has determined that the rate of visibility improvement by 2018, shown in Table 10-2 : Reasonable Progress Goals for Class I Areas (Worst 20 Percent Days) , is reasonable and will be implemented as the RPGs for the listed Class I areas.

Table 10-2: Reasonable Progress Goals for Class I Areas (Worst 20 Percent Days)

Class I Area Improvement Projected by

2018 using RPG (dv) Improvement by 2018 at
URP (dv) Projected Improvement by 2064

(dv) Date Natural Visibility
Attained at RPG

Rate

Big Bend 0.7 1.7 2.9 2155

Guadalupe Mountains 0.9 1.2 3.8 2081 Deleted:

,

Deleted:

Deleted:10-2 These RPGs are derived from the CENRAP modeling and reflect emissions reductio n reductions programs already in place , including CAIR and additional refinery SO 2 reductions from refineries as a result of the EPA refinery consent decrees. These RPGs assume that either CAIR will remain in place or will be replaced by a comparable program to reduce visibility impairing pollution from EGUs in Texas and in the eastern United States. As Chapter 11: Long-Term Strategy to Reach Reasonable Progress Goals details, the TCEQ’s emissions reduction requirements have often gone beyond the Federal Clean Air Act ( FCAA ) requirements for the past 35 years and continue to go beyond many federal requirements today. Texas programs that often go beyond federal requirements include:

• opacity limits on gra ndfathered facilities ;

• Best Available Control Technology (BACT) requirements that typically go beyond EPA’s New Source Performance Standards (NSPS) for new and modified sources;

• extensive NO X emission limits on existing and new sources including major, minor, and area sources including some on a statewide basis;

• the Texas Emissions Reduction Program (TERP ), which provides financial incentives to accelerate the implementation of new, cleaner diesel engine technologies in on-road and non-road applications; and

• the Air Check Texas Repair and Replacement Assistance Program , which provides financial incentives for scrappage of older gasoline-powered on-road vehicles.

The reasonable progress goals were developed after considering the statutory factors: cost and time of compliance, the energy and non-air quality impacts of compliance, and the remaining useful life of existing sources. Appendix 10-1: Analysis of Control Strategies and Determination of Reasonable Progress Goals provides an analysis showing that these goals are reasonable.

The TCEQ focused its control strategy analysis on point source emissions of SO 2 and NO X

. Chapter 11: Long-Term Strategy to Reach Reasonable Progress Goals demonstrates that these are the main anthropogenic pollutants that affect visibility at Class I areas in Texas and in neighboring states. For SO 2 , point sources make up over 95 90 percent of the projected 2018 statewide emissions. Point sources are clearly the issue for this pollutant. For NO X , point sources comprise over 45 percent of the projected statewide emissions. This is the largest single component. The next largest is area source s . Of that, the greatest component also has the greatest uncertainty: emissions from upstream oil and gas production. The Working with CENRAP, the TCEQ will continue plans to refine its understanding of those emissions and options for controls over the next few years. Nevertheless, Texas is moving aggressively to reduce those emissions through the $4 million grant program to pay for retrofits on rich burn compressor engines. Texas is going beyond federal requirements in an effort to reduce NO X emissions of NO X from on-road and non-road mobile sources through the Texas Emissions Reduction Program (TERP) . As a result, the TCEQ elected to focus the control strategy analysis on point sources.

Figures 10-1 : Glide Path for Big Bend Worst 20 Percent Days and 10-2 : Glide Path for Guadalupe Mountains Worst 20 Percent Days graphically illustrate how these RPGs compare to the URP or the glide path for the Texas Class I areas. Deleted:

,

Deleted: ’

Deleted:

,

Deleted: )

Deleted:

,10-3 17.3 16.8 15.6 14.4 13.2 12.0 10.8 10.1 16.6

0 5 10 15 20 25 30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearHaziness Index (Deciviews)

Uniform Rate of Progress (TX) Observation 2018 Projection

Figure 10-1: Glide Path for Big Bend Worst 20 Percent Days

17.2 16.9 16.0 15.2 14.4 13.6 12.8 12.3 16.3

0 5 10 15 20 25 30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

YearHaziness Index (Deciviews)

Uniform Rate of Progress (TX) Observation 2018 Projection

Figure 10-2: Glide Path for Guadalupe Mountains Worst 20 Percent Days

The figures and tables above address the TCEQ’s RPGs for the worst 20 percent days at Big Bend and Guadalupe Mountains. These figures use the TCEQ’s refined estimate for natural conditions, rather than the EPA default values. Appendix 10-3 : Uniform Rate of Progress Curves Using Default Natural Conditions Estimates shows the glide paths using the EPA default
values. The natural condition estimate was no t a factor in setting the RPG. Table 10-3 :10-4 Reasonable Progress Goals for Class I Areas (Best 20 Percent Days) provides the state’s RPGs for the 20 percent days with the best visibility at the Texas Class I areas.

Table 10-3: Reasonable Progress Goals for Class I Areas (Best 20 Percent Days)

Class I Area Baseline Visibility (dv) Projected 2018 Visibility (RPG) (dv) Improvement by 2018 at RPG (dv)

Big Bend 5.8 5.6 0.2

Guadalupe Mountains 5.9 5.7 0.2

These RPGs reflect visibility improvements from emissions reductions associated with the FCAA, the Texas Clean Air Act, Texas’ ozone SIP revisions and rules, and agreements between
EPA and oil refineries for SO 2 emissions reductions. These RPGs do not include additional emissions reductions from implementing the Texas BART rule and new rules adopted in the recent May 23, 2007, Dallas-Fort Worth eight-hour ozone attainment demonstration SIP revision. The TCEQ considered additional controls beyond those already adopted. Given the cost and insignificant imperceptible effect of additional controls, uncerta inty of Clean Air Interstate Rule (CAIR) impacts, and significant international sources of visibility impairment (all discussed in the following section), it is not reasonable to require additional controls at this time to reduce the impact of Texas’ emissions on the two Class I areas in Texas.

10.3 CONSIDERATION OF ADDITIONAL POLLUTION CONTROL

Development of Area of Influence (AOI) Based Cost Data The TCEQ participated in its regional air planning organization, CENRAP, to develop emission inventories for 2002 and 2018, model the results of the emission reductions for each state, and
draw areas of influence for each Class I area in the CENRAP domain. To draw the areas of influence CENRAP combined results from three techniques: 1) residence time difference plots for each pollutant that has a substantial effect on visibility impairment at each Class I area, 2) a combination of backward trajectory analysis, emissions information, and monitored concentrations, and 3) tagged species source apportionment within reactive photochemical grid modeling. Appendix 10-1: Analysis of Control Strategies RPG provides more detailed
information about CENRAP’s work to define areas of influence.

For the Class I areas that emissions from Texas affect, the main visibility impairing pollutants resulting from human activity are sulfate and nitrate. The emissions that react to form these pollutants are, respectively, sulfur dioxide and nitrogen oxides. Because of the differences between conditions that lead to high sulfate and high nitrate conditions, the areas of influence for sulfur dioxide and nitrogen oxides are substantially different for several Class I areas that Texas
emissions affect

.

The TCEQ used the control strategy analysis completed by the CENRAP as the starting point for the analysis of additional controls. The CENRAP’s CENRAP analysis used the EPA’s Air
Control Net EPA AirControlNET tool to develop cost per ton estimates for the relevant pollutants. The TCEQ reviewed this information and made changes based on knowledge of the particular facilities and agency experience with implemen ting ozone control strategies. The analysis focused on moderate cost controls for sources that were likely to contribute to visibility impairment at Class I areas. This work resulted in an estimate of the10-5 Texas assessed the costs and possible benefits of additional of potential controls, as shown in the following Tables 10

- 4 and 10

- 5. and reductions for Texas sources at ten Class I areas. These are Big Bend, Breton Island, Caney Creek, Carlsbad Caverns, Guadalupe Mountains, Salt Creek, Upper Buffalo, Wheeler Peak, White Mountain, and Wichita Mountains. Texas used the second
level area of influence for each Class I area to determine sources that met the emissions over distance threshold and were within that Class I area’s AOI. The cost associated with potential
controls for each Class I area are listed in Table 10-4: Cost of Controls for Class I Areas

. The TCEQ’s significant point sources within each AOI are in Appendix 4-3: Additional Consultation Letters to Adjacent States . A master list of potential additional control costs associated with these units for each Class I area were determined and are in Appendix 10-1.

Table 10-4: Cost of Controls for Class I Areas

Class 1 Big Bend Breton Isle Caney Creek Carlsbad
Caverns Guadalupe
Mountains

NOx $ 24,100,000 $ 27,000,000 $ 28,600,000 $ 24,100,000 $ 33,800,000

SO 2 $215,900,000 $231,000,000 $245,900,000 $255,500,000 $254,900,000

Class 1 Salt Creek Upper Buffalo Wheeler Peak White
Mountain Wichita
Mountains

NOx $ 27,000,000 $ 24,100,000 $ 22,700,000 $ 23,000,000 $ 28,100,000

SO 2 $251,900,000 $233,800,000 $229,500,000 $244,500,000 $269,500,000

Many of these controls are in more than one area of influence. The total cost of all state-wide point source controls are summarized in Table 5: TCEQ Point Source Control Strategy Summary

.

Table 10-5: TCEQ Point Source Control Strategy Summary

The TCEQ used the CENRAP modeling to estimate the impact that the control strategy would have on the Class I areas impacted by Texas’ emissions. The CENRAP conducted a modeling analysis presuming an aggressive set of additional controls above and beyond CAIR and BART Texas used the results of this modeling analys is to determine an effectiveness ratio for NO

x and

SO 2 reductions. The effectiveness ratio provides an estimate of improvement in visibility for every ton of NO X and SO 2 reduced. Using these ratios, the TCEQ was able to develop an orderof-magnitude estimate of the likely visibility improvements resulting from the point source control strategy (see Table 10-6: Estimated Haze Index Improvements for Affected Class I

Areas ) . This full analysis can be found in Appendix 10-2: Estimating Visibility Impacts from
Additional Point Source Controls and in Appendix 10-4: Detailed Calculations for Estimating Visibility Impacts . Table 10-5 shows the results. Pollutant Tons Per Year (tpy) Reduced Estimated Cost

Sulfur Dioxide (SO 2 ) 155,873 $270,800,000

Nitrogen Oxides (NO X ) 27,132 $53,500,000

Total Costs $324,300,000

Deleted:

.10-6 Table 10

- 5: Estimated Visibility Improvement

Table 10-6: Estimated Haze Index Improvements for Affected Class I Areas

Class 1 Big Bend Breton Isle Caney Creek Carlsbad
Caverns Guadalupe
Mountains

Haze Index Improvement (dv) 0.16 0.05 0.33 0.22 0.22

Class 1 Salt Creek Upper
Buffalo Wheeler Peak White
Mountain Wichita
Mountains

Haze Index Improvement (dv) 0.18 0.16 0.04 0.24 0.36

As Tables 10- 5 and 10- 6: Estimated Haze Index Improvements for Affected Class I Areas show, the analysis identified controls costing well over $300 million, yet the projected benefit of those
controls on each Class I is negligible not perceptible . A single (1.0) deciview is the smallest perceptible improvement in visibility. In th e TCEQ’s Best Available Retrofit Technology (BART) rule, the state considered 0.5 deciview deciviews as the threshold under which a facility was not considered to meaningfully contribute to visibility impairment. An A difference improvement of 0.05 deciview deciviews is well within the uncertainty of the modeling techniques and is much lower than perceptible. This improvement did not justify the substantial

expense.

10. 4 FOUR FACTOR ANALYSIS The Federal Regional Haze Rule requires states to set reasonable progress goals (RPGs) toward meeting a national goal of natural visibility conditions in Class I areas by the year 2064. The first RPG is to be established for the planning period 2008 to 2018. The State of Texas worked with CENRAP to develop RPGs for Texas Class I areas.

The Federal Regional Haze Rule (§51.308(d)(1)(i)(A)) requires states to consider the factors listed in section 169A(g)(1) of the FCAA when setting reasonable progress goals. These factors are the cost of compliance, the time for compliance, the energy and non-air quality impacts of compliance, and the remaining useful life of any potentially affected sources (EPA 1999).

• Cost of Compliance The cost of compliance is a factor used to determine whether compliance costs for sources are reasonable compared to the emission reduction and visibility improvement they will achieve.

• Time Necessary for Compliance The time necessary for compliance factor may be used to adjust the reasonable progress goals to reflect the degree of improvement achievable within the first planning period, as opposed to the improvement expected at full implementation of a control measure.

• Energy and Non-Air Quality Environmental Impacts of Compliance The energy and non-air quality environmental impacts of compliance factor is meant to consider whether the energy requirements of the control technology result in energy Class I Area Improvement (dv)

Big Bend 0.05

Guadalupe Mountains 0.05

Deleted: 4

Deleted: 5

Deleted: Page Break

Deleted: 310-7 penalties or benefits, or whether there are non-air quality impacts such as water quality and solid waste impacts resulting from the technology.

• Remaining Useful Life of the Source The remaining useful life of the source factor is applicable only to those measures which would require retrofitting of control devi ces (or possibly production changes) at existing sources. Shutdowns of sources were only counted if the shutdowns were enforceable.10-8 10.4.1 Applying the Statutory Factors Because the pollutants of primary co ncern were determined to be SO 2 and NO X from point sources, the 2018 emissions inventory was assessed to determine the sources that would have the most impact on Class I areas from these pollutants. All units in the inventory were assessed. An emissions over distance to any Class I area analysis ratio with a threshold of five or greater (Q/d ≥ 5 in tpy/kilometers) was applied to the projected 2018 emissions for both SO 2 and NO X to eliminate sources so far away from a Class I area that any reduction in emissions would be unlikely to have a perceptible impact on visibility. Also, any source with predicted 2018 emissions less than 100 tpy was excluded, since the regulatory and logistical overhead associated with controlling these small sources would not be justified by the likely benefit.

The TCEQ also excluded additional NO X controls on cement kilns from consideration since Texas has already required all the measures determined to be reasonable to control NO X emission from these sources in the latest Dallas-Fort Worth ozone SIP revision. See Appendix 10-1: Analysis of Control Strategies and Determination of Reasonable Progress Goals for further
discussion of Texas cement kilns.

Determination of Proposed Controls The 2018 inventory included the on-the-books controls for each of the states in the CENRAP region. The list of proposed controls is for controls beyond those already included in the baseline level used in the modeling. This is necessary to provide a frame of reference to estimate the
amount of emissions available for additional control and estimate the effect of control measures. Additionally, the progress toward the RPG with only on-the-books controls can also be assessed.

CENRAP used the latest revised version of the EPA AirControlNET model (Alpine 2007) to analyze potential add-on control device strategies. AirControlNET is a control technology analysis tool developed to support the EPA in analyses of air pollution policies and regulations. The tool provides data on emission sources, potential pollution control measures and emission reductions, and the costs of implementing those controls. Every available SO 2 and NO X control strategy in AirControlNET was run against the electric generating units (EGUs) and non-EGU point source inventories to develop a master list of available incremental control strategies for the
entire CENRAP 36 kilometer domain.

Texas reviewed the resulting data curves and so me additional individual sources were selected from source-types that were not part of the CENRAP AirControlNET dataset. The analyses of these facilities were designed to ensure that opportunities for cost-effective visibility improvements were not overlooked. The first step in the technical evaluation of control measures for a source category was to establish the future emissions baseline with on-the-books regulations. This baseline was used to asse ss the potential emissions reductions with the proposed control. The TCEQ added flue gas desulfurization at nine carbon black units based on this analysis.

10.4.2 Four Factor Analysis Process

Cost of Compliance At a total estimated cost exceeding $300 million and no perceptible visibility benefit, Texas has determined that it is not reasonable to implement additional controls at this time. All units in Texas that met the emissions over distance threshold were assessed. The cost per ton of controls from EPA CAIR and existing TCEQ control programs were used as a threshold value for determining a proposed set of controls. The EPA estimated the cost of implementing CAIR was up to $2,700 per ton. This limiting threshold was used to limit the proposed controls group to cost effective measures. The annualized cost values, additional emissions reductions based on proposed efficiency, as listed in the AirControlNET files, were used. Modifications for Texas included the consideration of flue gas desulfurization for carbon black units.10-9 Time Necessary for Compliance The time necessary for compliance was not a critical factor for the determination of applicable additional controls for Texas sources. The focus of the time necessary for compliance analysis for on-the-books controls will be to quantify the magnitude of emissions reductions that will occur prior to 2018. The EPA in its CAIR regulatory impact statement estimated that approximately 30 months is required to design, build, and install SO 2 scrubbing technology for a single EGU boiler. The total time for a si ngle facility to comply with one of the NO X caps would be about five years. Shortage of skilled labor as a result of increased design and construction of pollution control units required to meet deadlines in CAIR or its eventual replacement could increase times for some construction but completion by 2018 would still be anticipated.

For mobile sources, MOBILE and NONROAD model runs were completed for the 2018 emissions inventory. These model runs incorporate the degree of fleet and expected engine replacement prior to 2018. The completion of other proposed controls are anticipated by 2018.

Energy and Non-Air Quality Environmental Impacts of Compliance To the extent energy impacts are quantifiable for a particular control, they have been included in the cost estimates. Including impacts on a source-by-source basis would have added further weight against finding that the potential additional controls were reasonable to apply.

Scrubbers, Selective Catalytic Reduction (SCR) systems, and Selective Non-Catalytic Reduction (SNCR) systems installed under the EGU control strategies would require electricity to operate fans and other ancillary equipment. In addition, steam would be required for some scrubbers and SCR systems. Additional fuel will be consumed at the utilities to produce this electricity and steam, resulting in the lowering of the energy effi ciency of the plant. Estimates have given the electricity and steam required by controls installed to meet SO 2 and NO X emission caps would be less than 1 percent of the total electricity and steam production of EGUs (EPA 1999).

Source-by-source review of the non-air quality impacts of the potential controls would possibly have lead to a different determination about the unreasonableness of the set of potential additional controls. Scrubbers, coal washing, and spray dryers will require additional safeguards for fuel handling and waste handling systems to avoid additional non-air environmental impacts such as increased effluents in waste water discharges and storm water runoff. Solid waste disposal and wastewater treatment costs are expected to be less than five percent of the total operating costs of pollution control equipment. These factors will need to be considered specific to individual

sources.

Pilot testing of SNCR on wet and dry kilns in 2006 demonstrated that 30 to 40 percent reductions were achievable without hazardous by-product formation. In July 2006, ERG submitted a report to TCEQ entitled Assessment of NO X Emissions Reduction Strategies for Cement Kilns - Ellis County: Final Report (ERG 2006).

Some low-NO X combustion technologies require electricity for turbo charging, or steam for steam injection. Systems that require only modifications to alter fuel-air mixing and combustion temperatures are not expected to produce any additional electricity or steam demands, or generate
wastewater or solid waste.

Remaining Useful life CENRAP considered remaining useful life in modeling for mobile sources that assumes reduced emissions per vehicle mile traveled due to the turnover of the on-road mobile source fleet. For sources with a relatively short remaining useful life, this consideration would have weighed more heavily against a determination that controlling those sources would have been reasonable. In general, this factor is not critical for sector analyses for the 2018 timeline. For the purposes of10-10 initial analyses, no limited useful equipment life was assumed. A site-specific analysis would be needed to determine any units with limited usef ul life. Only units that were scheduled for shutdown under enforceable decrees were eliminated from the 2018 inventory and further analysis.

10.5 UNCERTAINTY IN THE REASONABLE PROGRESS GOALS The majority of the emissions reductions underlying the predicted visibility improvements are from the CAIR program or its eventual replacement . The TCEQ presumes that any eventual replacement for CAIR will include interstate trading of emissions allowances. Although CAIR or its replacement program requires should result in substantial reductions in SO 2 and NO X emissions from electric generating units ( EGUs). There , there is uncertainty regarding how CAIR will improve visibility will be improved at individual Class I areas because the CAIR program allows of trading of emissions allowances. T he program will reduce visibility

- impairing emissions across the entire eastern half of the United States, including Texas and Minnesota

. Because emission allowances can be purchased by EGUs relatively close to the Texas Class I areas from EGUs far from the Texas Class I areas, the visibility improvement may not be as great as predicted by the CENRAP’s modeling. Conversely, nearby EGUs may elect to control beyond their emission caps and sell emission allowances out of state, resulting in reduced emissions
closer to the Texas Class I areas.

The CENRAP used the Integrated Planning Model (IPM) that the EPA employed to predict the emissions reductions expected from CAIR in 2018. This SIP revision presumes that those results would be comparable under any program to replace CAIR. The IPM model predicts the effect of emission trading programs considering economic s, logistics, and the specific regulatory
environment for each EGU. Table 10- 7: Comparison of Sulfur Dioxide Emissions compares current emissions of SO 2 to the CAIR caps and the IPM results for the 2018 planning year.

Table 10- 7 : Comparison of Sulfur Dioxide Emissions

Sources: EPA, CENRAP
*Rounded to the nearest thousand

The CAIR cap is the total allowable emissions of SO 2 from EGUs in Texas under CAIR. The IPM model analysis used by CENRAP predicts that by 2018 EGUs in Texas will purchase approximately 125,000 tons per year tpy of emissions allowances from out of state. The TCEQ requested that key EGUs in Texas review and comment on the predictions of the IPM model. However, no EGU was able to make made an enforceable commitment to any particular pollution control strategy and preferred to retain the flexibility offered by the CAIR program.

The potential overprediction of EGU emissions on Class I areas by the IPM model analysis. This uncertainty in the impact of t he CAIR program is one reason why the agency has elected not to pursue additional controls at this time. In the five-year periodic progress report required by 40 CFR §51.308(g), the TCEQ will plans to review emissions inventory and permit information to evaluate the accuracy of the predicted emissions used in the CENRAP modeling. SO 2 Emissions Texas SO 2 Emissions (tpy)*

Current (2002 base case) 550,000

EPA’s CAIR budget for Texas EGUs for 2015 225,000

IPM projection CENRAP modeled for 2018 350,000 Deleted: 6

Deleted: 6

Deleted:

.10-11 10. 6 INTERNATIONAL SOURCES OF VISIBILITY IMPAIRMENT The Texas Class I areas are close to Mexico, and international transport of emissions from Mexico and Central America significantly influence regional haze at these areas. The CENRAP conducted a particulate source apportionment Particulate Matter Source Apportionment Technology (PSAT) analysis on the modeling conducted for the 2018 projections. The PSAT modeling apportioned all the particulate pollutant contributions to extinction except for secondary organic aerosol. The pollutants apportioned by geographic areas are sulfate, nitrate, primary organic carbon, elemental carbon, fine soil, and coarse mass. Table 10- 8: Contributions to Visibility in the Texas Class I Areas on Worst 20 Percent Day summarizes the contribution from these areas to visibility impairment at the Texas Class I areas.

Table 10- 8 : Contributions to Visibility in the Texas Class I Areas on Worst 20 Percent Days

Boundary conditions are the conditions at the model’s geographic boundaries. These are visibility-impairing emissions from Central Mexico and further south into Central America. The analysis indicates that 52 percent of the impairment at Big Bend and 25 percent of the impairment at Guadalupe Mountains is from Mexico and further south. The national goal of natural visibility
at these Class I areas cannot be met without substantial reductions in emissions from outside of
the United States.

10. 7 REDUCTIONS REQUIRED TO MEET THE UNIFORM RATE OF PROGRESS The TCEQ’s analysis of point source reductions can be extrapolated to estimate the amount of reductions that would be required for the RPG to meet the URP for the Texas Class I areas.

Table 10- 9 : Emissions Reductions Required to Meet Uniform Rate of Progress

Class I Area Additional Improvement
Needed to Meet URP (dv) Approximate
Additional Pollutant
Reductions
SO 2 and NO X (tpy) Estimated Cost of
Additional
Reductions

Big Bend 1.0 3,700,000 $6,500,000,000

Guadalupe Mountains 0.3 1,100,000 $1,900,000,000 Contribution by Area Big Bend (%) Guadalupe
Mountains (%)

Texas 24.8 34.8

Mexico 26.7 16.5

Boundary Conditions 25.7 8.7

Other US 11.9 18.9

Miscellaneous 5.8 9.6

Neighboring States 5.1 11.5 Deleted: 4

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Deleted:10-12 Table 10- 9: Emissions Reductions Required to Meet Uniform Rate of Progress assumes that all
of the reductions needed to meet the URP would come from Texas. These additional reductions would require significant over

- control in order to compensate for the impacts of international pollution. The preamble to the July 1, 1999, issuance of the Regional Haze Rule clearly says that states are not required to carry out compensatory over

- control to make up for the lack of progress in reducing the impacts of international transport.

Table 10- 9 illustrates that to meet the goal of natural visibility at Big Bend a better understanding of how pollutants are brought into the area is needed so that the correct sources can be addressed. This also reinforces the point that progress at the Texas Class I areas, especially at Big Bend, is dependent upon reducing emissions from Mexico and Central America. In Chapter 11: LongTerm Strategy to Reach Reasonable Progress Goals , the TCEQ specifically asks the EPA for
federal efforts to reduce the international tran sport impacts on regional haze coming into the
United States across Texas’ southern border.

Given the significant impact from international emissions, the uncertainty in the impact of CAIR and the poor cost-effectiveness of additional, reasonable point source controls, the TCEQ has determined that additional controls for Regional Haze regional haze are not appropriate at this
time.

10. 8 CONSULTATION In determining a reasonable progress rate for each Class I area discussed previously, the TCEQ
has consulted with the other states and tribes that are reasonably anticipated to cause or contribute to visibility impairment in each of the Texas Class I areas. Similarly, the TC EQ has consulted with other states whose Class I areas are impacted by pollution sources in Texas. The TCEQ invited tribes in the CENRAP states to the consultation calls, but no tribes participated in the consultation on Big Bend and Guadalupe Mountains. A full description of the consultation process is in Chapter 4: State, Tribe, and Federal Land Manager Consultation

.

10. 9 REPORTING The TCEQ will report progress to the EPA Administ rator every five years in accordance with 40 CFR §51.308(g). Chapter 12: Comprehensive Periodic Implementation Plan Revisions and Adequacy of the Existing Plan , provides more detail on five-year reporting and ten-year SIP submittal requirements. Deleted: 8

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Deleted: ¶11-1 CHAPTER 11. LONG-TERM STRATEGY TO REACH

RE ASONABLE PROGRESS GOALS

11.1 INTRODUCTION The long-term strategy for the Regional Haze SIP revision incorporates planning for the next ten years, from 2008 through 2018. Title 40 CFR §51.308.308(d)(3) specifies the requirements for the long-term strategy for regional haze (Appendix 1-1).

The main anthropogenic emissions that affect visi bility in Class I areas in Texas and neighboring

states are SO 2 and NO X . There is a much smaller anthropogenic PM impact in Texas from stack, engine exhaust, and fine soil emissions compared to SO 2 and NO X . Although the contribution of anthropogenic VOC to the formation of secondary organic carbon PM is small, there is a contribution. The impact of coarse mass and fine soil at the two Texas Class I areas comes primarily from natural dust storms and dust blowing from the Chihuahuan Desert, which the modeling does not represent well. Chapter 5: Assessment of Baseline and Current Conditions and Estimate of Natural Conditions in Class I Areas discusses and documents the predominance of these natural impacts. The modeled impact of wild fire and prescribed burning emissions on primary organic carbon is uncertain because of questions about the accuracy of fire emission inventories. However, the modeled projections show that fires are the main source of the impacts.

The bar Bar charts in C hapter 11 this chapter show the modeled apportioned impact of different areas and pollutants to visibility impairment at Big Bend and other Guadalupe Mountains
National Parks and at the Class I areas Texas emissions impact in other states (Figures 11- 2 through 11-3 1 ). There are separate graphs to show the impacts of different source areas on the worst 20 percent of monitored days and on the best 20 percent of monitored days in 2002. The projected impact apportioned impacts shown in the figures use the modeling results scaled to measured pollutant concentrations according to the EPA’s modeling guidelines as detailed in Chapter 8: Modeling Assessment

. As Chapter 5 explains, the projections for 2018 set the relative response factors (RRFs) for coarse mass (dust) and fine soil equal to one based on analysis showing that dust storms and wind blown desert dust are the dominant cause of the coarse mass and fine soil pollution at Big Bend and Guadalupe Mountains National Parks. Since the dominant source of these pollutants is natural, the TCEQ does not expect that to change between the base period and 2018.

The primary organic carbon and elemental carbon (i.e., black carbon) captured in the modeling is

are largely from fire. The term “primary” refers to a pollutant emitted directly to the atmosphere. The term “secondary” refers to a pollutant formed in the atmosphere by reaction, condensation, or both. The modeling indicates that primary organic carbon and black carbon at Big Bend comes on the worst 20 percent days come overwhelmingly from boundary conditions, which include the
areas of southern Mexico, the Yucatan

, and Central America with extensive agricultural burning and sometimes wildfire emissions each April and May.

The haze pollutants listed shown in the figures bar graphs and tables include: sulfate (SO 4 ), nitrate (NO 3 ), primary organic aerosols (POA), elemental carbon (EC), other inorganic fine particulate (Soil soil ), coarse mass (CM), anthropogenic secondary organic aerosols anthropogenic (SOAA)
that are , which result from human- made activity , and biogenic secondary organic aerosols biogenic (SOAB) that come from plants ), which form from hydrocarbon emissions from vegetation . Initial conditions (IC) and boundary conditions (BC) are areas related to the domain

map; initial conditions are the assumed initial three-dimensional concentrations throughout the modeling domain, and boundary . Except on the first few days of the model runs, the contribution
of initial conditions is vanishingly small. Boundary conditions (BC) are the concentrations
assumed imported into the modeling domain along the lateral edges and the top of the CENRAP Deleted: s

Deleted: ’s11-2 modeling domain. These boundary conditions come from a year-long run of the global model
GEOS-Chem.

Figures 11-2 through 11- 31 also make reference refer to extinction (abbreviated as B ext ) and Rayleigh. In the case of visibility, extinction or B ext refers to the loss of image-forming light as it passes from an object to the observer. Rayleigh scattering is the scattering of light by air molecules (Malm 1999). Figure 11-1 compares extinction to deciviews (dv) and visual range (in kilometers).

Source: William Malm, Introduction to Visibility , 1999, National Park Service Figure 11-1: Comparison of Extinction, Deciviews and Visual Range

Figure 11-2: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE)
Note: On the worst on Worst 20 percent of days Percent Days in 2002 Deleted: 1011-3 Figure 11-3: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) on Best 20 Percent Days in 2002 Note the change in scale on the y-axis.11-4 Table 11-1: Pollutant Contributions to Extinction at Big Bend from Texas and from All Areas on Worst 20 Percent Days in 2002 and 2018

Texas Total Total, All
Source Areas Texas Total Total, All
Source Areas

Sulfate 5.50 26.10 3.95 23.00

Nitrate 0.59 2.05 0.56 1.99

Primary Organic Aerosol 0.55 5.81 0.41 5.61

Elemental Carbon 0.42 2.12 0.20 1.81

Fine Soil 0.99 2.54 0.98 2.54

Coarse Mass 3.82 7.03 3.87 7.03 Secondary Organic Aerosol, Anthropogenic not available1 0.64 not available1 0.59

Secondary Organic Aerosol, Biogenic not available1 1.52 not available1 1.49

Total 11.87 47.79 9.97 44.06 2002 Impacts at Big Bend

( inverse me g ameters ) 2018 Impacts at Big Bend ( inverse me g ameters ) Particulate Matter
Constituent

1 The CENRAP PSAT modeling did not apportion either the anthropogenic or the biogenic secondary organic aerosol (SOA). The reasons are (1) that su lfate and nitrate are generally the main causes of visibility impairment resulting from human activit y and (2) that tracking the multiple volatile organic compound constituents and reaction products nece ssary to apportion SOA would have extended the modeling run times far beyond the time that was available for the modeling.11-5 Figure 11-4: Areas and Pollutants Causing Regional Haze at Guadalupe Mountains (GUMO) on the Worst 20 Percent Days in 2002

Figure 11-5: Areas and Pollutants Causing Regional Haze at Guadalupe Mountains (GUMO) on Best 20 Percent Days in 2002

Note : On the worst 20 percent of days 2002 the change on the y-axis.11-6 Table 11-2: Pollutant Contributions to Extinction at Guadalupe Mountains from Texas and from All Areas on Worst 20 Percent Days in 2002 and 2018

Texas Total Total, All

Source Areas Texas Total Total, All

Source Areas

Sulfate 4.28 15.94 3.65 13.65

Nitrate 0.78 3.67 0.68 3.32

Primary Organic Aerosol 1.16 2.75 0.87 2.38

Elemental Carbon 0.53 1.19 0.28 0.86

Fine Soil 1.71 4.37 1.66 4.37

Coarse Mass 8.16 16.04 8.19 16.02 Secondary Organic Aerosol, Anthropogenic not available1 1.23 not available1 1.16

Secondary Organic Aerosol, Biogenic not available1 2.61 not available1 2.56

Total 16.62 47.80 15.33 44.32 2002 Impacts at Guadalupe Mountains (inverse megameters) 2018 Impacts at Guadalupe Mountains (inverse megameters) Particulate Matter

Constituent

11.1.1 Reasonably Attributable Visibility Impairment Reasonably attributable visibility impairment (RAV I) is a specifically defined term from EPA’s early efforts to protect visibility at Class I areas. Limitations in RAVI requirements for improving visibility at many Class I areas led to provisions in the 1990 Clean Air Act Amendments that added the broader requirements for to reduce regional haze impacts at Class I areas. The EPA implemented these provisions in the Regional Haze Regulations first issued July 1, 1999.

The FLMs for Big Bend and Guadalupe Mountains National Parks have not identified any reasonably attributable visibility impairment from Texas or other United States sources. The
FLMs for the Class I areas that Texas’ emissions impact in other states have not identified any reasonably attributable visibility impairment caused by Texas sources. For these reasons, the TCEQ does not have any measures in place or plans a requirement to address reasonably attributable visibility impairment.

11.2 CONSULTATION The TCEQ has participated in the CENRAP since its inception in 1999 and has provided emission inventory information for all source categories . The TCEQ has cooperated with all CENRAP states and tribes through participation in the process of developing information on base period emission inventories and visibility impairment, estimates of 2064 natural conditions, and projections of 2018 emissions and visibility impairment considering all emission reduction requirements in Texas, including state and federal rules. These rules include the Clean Air Interstate Rule (CAIR), BART requirements , emission reductions from the Federal Motor Vehicle Emission Control Program ( FMVCP), EPA refinery consent decrees, and EPA requirements for cleaner non-road diesel and gasoline-powered engines. Detailed information on consultation is in Chapter 3: Regional Planning and Chapter 4: State, Tribe, and Federal Land11-7 Manager Consultation . Information on base period emissions inventory development is in Chapter 7: Emissions Inventory , and information on modeling is in Chapter 8: Modeling

Assessment

.

11.2.1 Consultation on Class I Areas in Texas The TCEQ used CENRAP Particulate Matter Source Apportionment Technology (PSAT) modeling to determine that Kansas, Louisiana, New Mexico, and Oklahoma contribute to the states contributing to visibility impairment at Texas’ Class I areas. Since each state is considering
which additional are Kansas, Louisiana, New Mexico, and Oklahoma. Each of these states has adopted or is in the process of adopting emissions reductions are it has determined to be reasonable under the factors listed in 40 CFR §51.308(d)(1), Reasonable Progress Goals . Based on their plans and commitments elicited through the consultation process

, the commission has made a preliminary determination determined that the emissions reductions that these states are projecting are reasonable for contributing to reasonable progress in reducing their contributions to visibility impairment at Texas’ the two Class I areas. Arkansas and Missouri have completed their consultation with Texas regarding the impact of Texas’ emission and regional haze impact reductions on Arkansas’ and Missouri’s Class I areas. They have accepted the TCEQ’s pl anned emission reductions as adequate for their Class I areas. in Texas has consulted with Oklahoma regarding Oklahoma’s Class I area, the Wichita Mountains National Wildlife Refuge. Oklahoma consultation conference calls were held August 16, 30, and Se ptember 25, 2007. The TCEQ has communicated with New Mexico, Louisiana, and Colorado about consultation on the impact of Texas’ emissions on each states Class I areas. However, at this time, these three states have not
invited Texas to a formal consultat ion regarding any of their respective Class I areas . Chapter 4
discusses consultations with these states in detail

.

11.2.2 Consultation on Class I Areas Impacted by Emissions from Texas Arkansas, Missouri, and Oklahoma have each included Texas in consultations concerning regional haze impacts on the Class I areas in these states. The TCEQ reviewed CENRAP PSAT modeling to assess how Texas’ emissions might affect other states states’ Class I areas . Pursuant to this review, Texas has written to Arkansas, Missouri, and Oklahoma have included Texas in consultations concerning emissions. In the future, New Mexico, Oklahoma, New Mexico, Louisiana, and Colorado to ask whether emission reductions projected in Texas by 2018 are sufficient to meet Texas’ apportionment of the impact reduction needed to meet the reasonable progress goal for each Class I area in each state. Texas has completed its consultation with Louisiana, Arkansas, Missouri, Oklahoma, and Colorado are expected to consult with TCEQ on

, and none of these states has asked Texas for further emission reductions to help the state meet its reasonable progress goals for its Class I area(s). Chapter 4 discusses these consultations in more detail. Appendix 4-3 contains the official communications from these states to Texas.

11.2.3 Texas’ Impacts and 2018 Impact Reduction for Class I Areas Outside Texas The TCEQ’s review of the CENRAP PSAT modeling results to assess how Texas’ emissions might affect other states’ Class I areas in 2002 indicated that Texas’ emissions affect one or more Class I areas in New Mexico, Oklahoma, Colorado, Arkansas, Missouri, and Louisiana. This subsection presents the results of this review.

11.2.3.1 New Mexico Emissions from the western portion of Texas account for most of Texas’ impact on the Class I areas in New Mexico. The following graph shows the impacts of the western portion of Texas on their Class I areas in New Mexico that are included in the CENRAP PSAT modeling. The graph provides the basis for choosing the New Mexico Class I areas for more detailed examination of Texas’ impacts. Carlsbad Caverns National Park is not included in this graph since it has no regional haze monitor; instead, it uses data measured at Guadalupe Mountains National Park to assess the impact of regional haze on the park. Deleted:

.

Deleted:

. ¶

Deleted: ¶

Figure 11

- 4: Calculated11-8 On February 13, 2008, the TCEQ approved the renewal of Air Quality Permit Number 20345 for the American Smelting and Refining Company (ASARCO) El Paso copper smelter. On February 6, 2009, the TCEQ received confirmation from ASARCO LLC that it intends to close the smelter and requests that TCEQ void all air permits and pending applications for the plant. The TCEQ voided these permits and applications on February 9, 2009 (See Appendix 11-4: ASARCO El

Paso ). The TCEQ will con tinue to consult with affected st ates and Federal Land Managers on surrounding Class I areas of concern. On February 13, 2008, the TCEQ approved the renewal of Air Quality Permit Number 20345 for the American Smelting and Refining Company (ASARCO) El Paso smelter. As of the date this SIP revision was finalized, the TCEQ has not yet made a final determination regarding the BART
status of ASARCO’s facilities. Due to this and other permitting and operational readiness i ssues raised by ASARCO in their status report required by TCEQ order, there is uncertainty about the amount of allowable emissions the ASARCO El Paso facility would have should it begin operation. Because of this uncertainty in addition to time limitation s, it is not possible for the TCEQ to account for possible future ASARCO El Paso emissions in this Regional Haze SIP revision. When the TCEQ has determined the allowable emissions from the ASARCO El Paso facility, the TCEQ will mo del the visibility impact s of these emissions at affected Class I areas. The TCEQ plans to consult with affected states and Federal Land Managers and include ASARCO’s emissions and impacts in its next Regional Haze SIP revision.

Figure 11-6: Calculated Regional Haze Impacts of West Texas Emissions from Western
Areas of Texas at Each Class I Area in New Mexico
Note: On the worst on Worst 20 percent of days 2002 Percent Days in 2002
BAND BAND1 - Bandelier Wilderness Area National Monument
BOAP BOAP1 - Bosque del Apache Wilderness Area
G I CL GICL1 - Gila Wilderness Area
SACR SACR1 - Salt Creek Wilderness Area
SAPE SAPE1 - San Pedro Parks Wilderness Area
WHIT WHIT1 - White Mountain Wilderness Area
WHPE WHPE1 - Wheeler Peak Wilderness Area11-9 Figure 11- 7: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns National Park on Worst 20 Percent Days in 2002 Note: The impacts at Carlsbad Caverns National Pa rk are calculated using the CENRAP PSAT tool for Guadalupe Mountains but using the EPA guidance for a pplying relative response factors (RRFs) since New Mexico is using modeled apportionment of coarse mass (CM) and fine soil (FS). These calculations do not use the Texas assumptions for Guadalupe Mountains an d Big Bend National Park s that the RRFs for CM and FS both equal one. Deleted: 511-10 Figure 11-8: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns National Park on Best 20 Percent Days in 2002 Note the change on the y-axis.

Table 11-3: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Carlsbad Caverns National Park on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 4.28 15.94 3.65 13.65

Nitrate 0.78 3.67 0.68 3.32

Primary Organic Aerosol 1.16 2.75 0.87 2.38

Elemental Carbon 0.53 1.19 0.28 0.86

Fine Soil 1.71 4.37 1.66 4.37

Coarse Mass 8.16 16.04 8.24 16.13 Secondary Organic Aerosol, Anthropo g enic not available 1 1.23 not available 1 1.16 Secondary Organic Aerosol, Biogenic not available 1 2.61 not available 1 2.56

Total 16.62 47.80 15.39 44.43 Particulate Matter
Constituent 2002 Impacts at Carlsbad Caverns 2
( inverse me g ameters ) 2018 Impacts at Carlsbad Caverns 2
( inverse me g ameters )

1 The CENRAP PSAT modeling did not apportion either the anthropogenic or the biogenic secondary organic aerosol (SOA). The reasons are (1) that su lfate and nitrate are generally the main causes of visibility impairment resulting from human activit y and (2) that tracking the multiple volatile organic compound constituents and reaction products nece ssary to apportion SOA would have extended the modeling run times far beyond the time that was available for the modeling.11-11 Figure 11-9: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) in New Mexico on Worst 20 Percent Days in 2002

Figure 11-10 : Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) in New
Mexico on Best 20 Percent Days in 2002

Note : On the worst 20 percent of days change in scale on the y-axis.11-12 Table 11-4: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Salt Creek Wilderness Area on Worst 20 Percent Days

Texas Total Total, All

Source Areas Texas Total Total, All

Source Areas

Sulfate 4.79 16.75 3.50 13.75

Nitrate 3.05 11.15 2.43 9.81

Primary Organic Aerosol 1.17 4.31 0.69 2.99

Elemental Carbon 0.76 2.31 0.30 1.23

Fine Soil 1.06 3.34 0.96 3.41

Coarse Mass 2.58 11.47 2.36 12.52 Secondary Organic Aerosol, Anthropogenic not available 1 1.12 not available 1 1.00

Secondary Organic Aerosol, Biogenic not available 1 2.06 not available 1 1.95

Total 13.41 52.50 10.24 46.67 Particulate Matter

Constituent 2002 Impacts at Salt Creek (inverse megameters) 2018 Impacts at Salt Creek (inverse megameters)

Figure 11- 11: Areas and Pollutants Causing Regional Haze at White Mountain (WHIT) in New Mexico on Worst 20 Percent Days in 2002 D e l eted :11-13 Figure 11-12: Areas and Pollutants Causing Regional Haze at White Mountain (WHIT) in New Mexico on Best 20 Percent Days in 2002 Note the change in scale on the y-axis.

Table 11-5: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at White Mountain Wilderness Area on Worst 20 Percent Days

Texas Total Total, All

Source Areas Texas Total Total, All

Source Areas

Sulfate 2.78 10.51 2.37 8.92

Nitrate 0.53 3.05 0.47 2.68

Primary Organic Aerosol 1.14 3.87 0.78 3.13

Elemental Carbon 0.59 1.82 0.27 1.08

Fine Soil 0.55 1.89 0.53 1.95

Coarse Mass 1.81 6.68 1.80 7.29 Secondary Organic Aerosol, Anthropogenic not available 1 1.83 not available 1 1.64

Secondary Organic Aerosol, Biogenic not available 1 3.27 not available 1 3.11

Total 7.40 32.91 6.22 29.80 Particulate Matter

Constituent 2002 Impacts at White Mountain (inverse megameters) 2018 Impacts at White Mountain (inverse megameters)11-14 Figure 11-13: Areas and Pollutants Causing Regional Haze at Wheeler Peak Wilderness Area on Worst 20 Percent Days in 2002

Figure 11-14: Areas and Pollutants Causing Regional Haze at Wheeler Peak Wilderness Area on Best 20 Percent Days in 2002 Note the change in scale on the y-axis.11-15 Table 11- 6: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Wheeler Peak Wilderness Area on Worst 20 Percent Days

Texas Total Total, All

Source Areas Texas Total Total, All

Source Areas

Sulfate 0.76 5.27 0.79 5.00

Nitrate 0.22 1.64 0.19 1.48

Primary Organic Aerosol 0.28 3.93 0.18 3.64

Elemental Carbon 0.21 2.18 0.08 1.48

Fine Soil 0.25 1.75 0.23 1.88

Coarse Mass 0.12 2.77 0.12 3.09 Secondary Organic Aerosol, Anthropogenic not available 1 1.41 not available 1 1.28

Secondary Organic Aerosol, Biogenic not available 1 3.03 not available 1 2.96

Total 1.85 21.96 1.59 20.80 Particulate Matter

Constituent 2002 Impacts at Wheeler Peak (inverse megameters) 2018 Impacts at Wheeler Peak (inverse megameters)

11.2.3.2 Oklahoma

Figure 11-15: Areas and Pollutants Causing Regional Haze at Wichita Mountains (WIMO) in Oklahoma on Worst 20 Percent Days in 200211-16 Figure 11-16: Areas and Pollutants Causing Regional Haze at Wichita Mountains (WIMO)
in Oklahoma on Best 20 Percent Days in 2002

Note : On the worst 20 percent of days change in scale on the y-axis.

Table 11-7: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Wichita Mountains Wilderness Area on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 13.98 49.12 9.68 33.33

Nitrate 7.89 23.72 6.08 18.10

Primary Organic Aerosol 3.05 11.81 2.57 10.92

Elemental Carbon 1.42 4.47 0.68 3.00

Fine Soil 0.29 0.79 0.30 0.79

Coarse Mass 1.51 4.64 1.49 4.35 Secondary Organic Aerosol, Anthropogenic not available 1 2.57 not available 1 2.22

Secondary Organic Aerosol, Biogenic not available 1 2.91 not available 1 2.84

Total 28.15 100.03 20.79 75.56 Particulate Matter

Constituent 2002 Impacts at Wichita Mountains (inverse megameters) 2018 Impacts at Wichita Mountains (inverse megameters)11-17 11.2.3.3 Colorado Emissions from the western portion of Texas account for most of Texas’ impact on the Class I areas in Colorado. The following graph shows the impacts of the western portion of Texas on the Class I areas in Colorado that are included in the CENRAP PSAT modeling. The graph is to show the basis for choosing Great Sand Dunes as the Colorado Class I area for more detailed examination of Texas’ impacts.

Figure 11- 1 7: Calculated Regional Haze Impacts of West Texas Emissions at Each Class I Area in Colorado Note: On the worst 20 percent of days Included in CENRAP PSAT Modeling on Worst 20 Percent Days in 2002

GRSA - Great Sand Dunes Wilderness Area National Park
MEVE - Mesa Verde National Park
MOZI - Mount Zirkel Wilderness Area ROMO - Rocky Mountain National Park
WEMI - Weminuche Wilderness Area
WHRI - White River National Forest11-18 Figure 11- 1 8: Areas and Pollutants Causing Regional Haze at Great Sand Dunes (GRSA)
in Colorado Note: On the worst on Worst 20 percent of days Percent Days in 2002

Figure 11- 1 9: Areas and Pollutants Causing Regional Haze at Great Sand Dunes (GRSA) in Colorado on Best 20 Percent Days in 2002 Note the change in scale on the y-axis. Deleted: Pa g e Brea k11-19 Table 11-8: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Great Sand Dunes Wilderness Area on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 0.66 5.84 0.65 5.32

Nitrate 0.02 1.94 0.02 1.83

Primary Organic Aerosol 0.18 3.34 0.12 3.07

Elemental Carbon 0.10 1.57 0.04 1.08

Fine Soil 0.23 2.84 0.21 2.95

Coarse Mass 0.07 7.36 0.07 7.69 Secondary Organic Aerosol, Anthropogenic not available 1 1.38 not available 1 1.28

Secondary Organic Aerosol, Biogenic not available 1 3.61 not available 1 3.56

Total 1.25 27.88 1.11 26.77 Particulate Matter

Constituent 2002 Impacts at Great Sand Dunes (inverse megameters) 2018 Impacts at Great Sand Dunes (inverse megameters)

Figure 11-20: Areas and Pollutants Causing Regional Haze at Rocky Mountains National Park (ROMO) in Colorado on Worst 20 Percent Days in 200211-20 Figure 11-21: Areas and Pollutants Causing Regional Haze at Rocky Mountains National Park (ROMO) in Colorado on Best 20 Percent Days in 2002 Note the change in scale on the y-axis.

Table 11-9: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Rocky Mountain National Park on Worst 20 Percent Days

Texas Total Total, All

Source Areas Texas Total Total, All

Source Areas

Sulfate 0.30 7.69 0.30 6.52

Nitrate 0.08 5.17 0.06 4.28

Primary Organic Aerosol 0.07 5.65 0.05 5.37

Elemental Carbon 0.03 2.33 0.02 1.54

Fine Soil 0.06 1.39 0.05 1.52

Coarse Mass 0.03 5.17 0.03 5.66 Secondary Organic Aerosol, Anthropogenic not available 1 1.73 not available 1 1.60

Secondary Organic Aerosol, Biogenic not available 1 3.00 not available 1 2.91

Total 0.58 32.13 0.51 29.41 Particulate Matter

Constituent 2002 Impacts at Rocky Mountain National Park (inverse megameters) 2018 Impacts at Rocky Mountain National Park (inverse megameters)11-21 11.2.3.4 Arkansas

Figure 11-22: Areas and Pollutants Causing Regional Haze at Caney Creek (CACR) in
Arkansas on Worst 20 Percent Days in 2002
Note: On the worst 20 percent of days

2002

Deleted: Figure 11

-11-22 Figure 11-23: Areas and Pollutants Causing Regional Haze at Caney Creek (CACR) in Arkansas on Best 20 Percent of Days in 2002 Note the change in scale on the y-axis.11-23 Table 11- 10: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Caney Creek Wilderness Area on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 11.55 87.05 7.24 48.95

Nitrate 1.49 13.78 0.83 7.57

Primary Organic Aerosol 0.83 10.50 0.83 9.93

Elemental Carbon 0.36 4.80 0.20 3.17

Fine Soil 0.15 1.12 0.17 1.29

Coarse Mass 0.50 3.73 0.47 3.58 Secondary Organic Aerosol, Anthropogenic not available 1 3.94 not available 1 3.21

Secondary Organic Aerosol, Biogenic not available 1 9.00 not available 1 8.14

Total 14.89 133.93 9.74 85.84 2002 Impacts at Caney Creek (inverse megameters) 2018 Impacts at Caney Creek (inverse megameters) Particulate Matter
Constituent

Figure 11-24: Areas and Pollutants Causing Regional Haze at Upper Buffalo (UPBU) in Arkansas on Worst 20 Percent Days in 200211-24 Figure 11-25: Areas and Pollutants Causing Regional Haze at Upper Buffalo (UPBU) in Arkansas on Best 20 Percent Days in 2002 Note the change in scale on the y-axis.

Table 11-11: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Upper Buffalo Wilderness Area on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 4.41 83.18 2.74 45.38

Nitrate 0.27 13.30 0.18 9.22

Primary Organic Aerosol 0.24 10.85 0.24 10.17

Elemental Carbon 0.10 4.72 0.05 3.07

Fine Soil 0.04 1.21 0.05 1.40

Coarse Mass 0.12 6.85 0.11 6.53 Secondary Organic Aerosol, Anthropogenic not available 1 4.14 not available 1 3.36

Secondary Organic Aerosol, Biogenic not available 1 7.55 not available 1 7.02

Total 5.19 131.79 3.38 86.16 Particulate Matter
Constituent 2002 Impacts at Upper Buffalo (inverse megameters) 2018 Impacts at Upper Buffalo (inverse megameters)11-25 11.2.3.5 Missouri

Figure 11-26: Areas and Pollutants Causing Regional Haze at Hercules-Glades (HEGL) in Missouri on Worst 20 Percent Days in 2002

Figure 11-27: Areas and Pollutants Causing Regional Haze at Hercules-Glades (HEGL) in Missouri on the Best 20 Percent of Days 2002 Note the change in scale on the y-axis.11-26 Table 11-12: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Hercules-Glades Wilderness Area on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 3.48 87.94 2.51 50.63

Nitrate 2.56 17.91 1.51 12.35

Primary Organic Aerosol 0.33 14.55 0.28 12.95

Elemental Carbon 0.12 5.22 0.06 3.51

Fine Soil 0.03 0.92 0.03 1.00

Coarse Mass 0.06 2.78 0.06 2.48 Secondary Organic Aerosol, Anthropogenic not available 1 4.50 not available 1 3.76 Secondary Organic Aerosol,

Bio g enic not available 1 6.22 not available 1 5.83

Total 6.59 140.05 4.45 92.49 Particulate Matter
Constituent 2002 Impacts at Hercules-Glades (inverse megameters) 2018 Impacts at Hercules-Glades (inverse megameters)

Figure 11-28: Areas and Pollutants Causing Regional Haze at Mingo (MING) in Missouri on Worst 20 Percent Days in 200211-27 Figure 11-29: Areas and Pollutants Causing Regional Haze at Mingo (MING) in Missouri on Best 20 Percent Days in 2002 Note the change in scale on the y-axis.

Table 11-13: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Mingo Wilderness Area on Worst 20 Percent Days

Texas Total Total, All Source

Areas Texas Total Total, All Source

Areas

Sulfate 0.69 102.52 0.53 54.45

Nitrate 1.18 27.24 0.64 19.14

Primary Organic Aerosol 0.07 10.21 0.06 9.09

Elemental Carbon 0.03 5.49 0.02 3.53

Fine Soil 0.01 1.26 0.01 1.44

Coarse Mass 0.02 5.95 0.02 5.31 Secondary Organic Aerosol, Anthropogenic not available 1 3.66 not available 1 3.04 Secondary Organic Aerosol, Biogenic not available 1 3.50 not available 1 3.25

Total 2.01 159.83 1.28 99.24 Particulate Matter
Constituent 2002 Impacts at Mingo (inverse megameters) 2018 Impacts at Mingo (inverse megameters)11-28 11.2.3.6 Louisiana

Figure 11-30: Areas and Pollutants Causing Regional Haze at Breton Wilderness Area (BRET) in Louisiana on Worst 20 Percent Days in 2002 Note: On the worst 20 percent of days 2002

Figure 11-31: Areas and Pollutants Causing Regional Haze at Breton Wilderness Area (BRET) in Louisiana on Best 20 Percent Days in 200211-29 Note the change in scale on the y-axis. Table 11-14: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 Total Visibility Extinction at Breton Wilderness Area on Worst 20 Percent Days

Texas Total Total, All

Source Areas Texas Total Total, All

Source Areas

Sulfate 3.55 96.83 2.66 68.63

Nitrate 0.15 8.29 0.16 8.20

Primary Organic Aerosol 0.12 4.71 0.11 4.37

Elemental Carbon 0.14 5.40 0.06 3.92

Fine Soil 0.05 0.95 0.05 1.16

Coarse Mass 0.19 3.70 0.18 3.95 Secondary Organic Aerosol, Anthropogenic not available 1 1.63 not available 1 1.38

Secondary Organic Aerosol, Biogenic not available 1 2.48 not available 1 2.46

Total 4.20 123.99 3.23 94.06 Particulate Matter

Constituent 2002 Impacts at Breton

Wilderness Area (inverse megameters) 2018 Impacts at Breton

Wilderness Area (inverse megameters)

11.3 REQUEST FOR FEDERAL EFFORTS TO REDUCE INTERNATIONAL
TRANSPORT Figures 11-2 and 11- 4 show the CENRAP PSAT results apportioning the causes of 2000-2004 regional haze on the worst 20 percent visibility days at Big Bend and Guadalupe Mountains, based on the 2002 base period modeling. The figures show large contributions from anthropogenic sources categorized as from Mexico and from the boundary conditions outside the CENRAP modeling domain. The boundary conditions domain includes some of central Mexico, all of southern Mexico, most of the Mexican Yucatan, and all of Central America. Chapter 8: Modeling Assessment describes the modeling in more detail. These results are directionally consistent with federal studies that have previously found substantial international pollutant transport impacts on regional haze at Big Bend. These studies include the Big Bend Regional Aerosol and Visibility Observational (BRAVO) study of regional haze impacts at Big Bend and a number of National Park Service (NPS) studies in the 1990s that relied on back trajectory analysis to determine where air accumulated regional haze on its way to Big Bend (NPS et al. 2004). Figure 11- 4 shows that the CENRAP PSAT mode ling calculates that international transport contributes over 25 percent of the regional haze on the worst 20 percent of days during the base period at Guadalupe Mountains. Figures 11- 9 and 11- 15 show that international transport contributes over ten percent of the regional haze on the worst 20 percent of days at Salt Creek and Wichita Mountains. At Caney Creek, the international transport contribution to regional haze on the worst 20 percent of days is over five percent of the total (after discounting coarse mass, which the model does not represent reliably) (ENVIRON 2007).

CENRAP modeling estimates of the base period visibility impairment at Big Bend from the United States and foreign contributions indicate 52 percent of the light extinction at Big Bend on the worst 20 percent of regional haze days comes from international transport. The concentrations are adjusted to match the visibility extinction measured for the 2000 through 2005 base period. Deleted: 3

Deleted: 3

Deleted: 5

Deleted: 6

Deleted:

,11-30 Due to the large impact of international transport on anthropogenic regional haze in Texas, it will be impossible to reach natural conditions at the two Class I areas in Texas without reductions in
international this transport impacts to parallel the reductions in United States anthropogenic regional haze impacts on Texas’ two Class I areas. Although the impact of international transport on Class I areas in the states bordering Texas is approximately ten percent or less of the total impairment, reductions in international transport of anthropogenic regional haze are necessary will
also be needed for the Class I areas in these states to approach reach the natural conditions goal

.

The TCEQ requests that the EPA initiate and pursue federal efforts to reduce international transport of visibility impairing pollutants into Texas.

11.4 MINIMIZING VISIBILITY IMPAIRMENT FROM TEXAS EMISSIONS The TCEQ has implemented rules that limit and minimize emissions causing both local and regional visibility impairment. The Texas SIP includes numerous rules that minimize emissions that cause or contribute to local and regional vi sibility impairment. The TCEQ plans to continue to implement all these rules that protect visib ility at Class I areas in Texas and other states (Appendices 11-2 and 11-3).

11.4.1 Opacity Limitations Title 30 TAC Chapter 111, Control of Air Pollution from Visible Emissions and Particulate Matter, limits visible emissions and mass emissions from industrial and power plant stacks, motor vehicles, and incinerators. Together with opacity limits in many preconstruction permits, these rules limit the emissions of PM from a wide variety of sources. The TCEQ continues to enforce both the rule and permit limits on opacity and PM emissions from electric generating units (EGUs) and other sources.

11.4.2 Sulfur Emission Limitations Title 30 TAC Chapter 112 Control of Air Pollution from Sulfur Compounds limits sulfur dioxide, hydrogen sulfide, total reduced sulfur compounds, and sulfuric acid from a variety of sources including EGUs, sulfuric acid plants, smelters, and sulfur recovery units. These rules, together with many lower limitations in permits for new and modified sources, limit the impacts of
ammonium sulfate from Texas on the Class I areas in Texas and at the Class I areas in other states that Texas impacts Texas’ emissions impact

.

11.4.3 Best Available Control Technology (BACT) Requirements BACT requirements have been in effect since 1972 for new and modified sources of air pollution
for SO 2 , NO X , PM, and VOC. While federal new source review (NSR) rules requiring BACT apply only to major new sources or modifications, Texas law requires BACT for all emissions increases at new or modified units. The basic requirement is that each new and modified source of air pollution built in Texas use BACT to minimize or eliminate emissions of all pollutants subject to the national ambient air quality standa rds (NAAQS). This includes all the emissions from human activity that contribute to regional haze, such as including NO X , SO 2 , PM, and VOC. Title 30 TAC Chapter 116: Control of Air Pollution by Permits for New Construction or Modification contains these requirements.

Each applicable source must obtain a construction permit before beginning construction. Issuance of a construction permit can occur only after an engineering determination that the facility will use BACT. In some cases, the BA CT requirements apply th rough permits by rule or standard permits rather than through case-by-case review of each new or modified source of air pollution.11-31 11.4.4 Programs to Manage Smoke Impacts on Class I Areas The Texas Forest Service (TFS) coordinates fire and smoke management issues in Texas. The 34th Texas Legislature created the TFS in 1915. The legal mandate of the TFS includes the responsibility to "assume direction of all forest interests and all matters pertaining to forestry within the jurisdiction of the state." The TFS has developed a voluntary approach called the Texas Forest Service Smoke Management System, under which all land managers in Texas, including the NPS, inform the TFS before performing prescribed burns. The TFS dispatch office maintains communications with the TCEQ.

Examination of the data for the worst 20 percent visibility days at both Big Bend and Guadalupe Mountains indicates that smoke from agricultural burning and wildfires in Texas are is not a large contributor to visibility impairment in Texas. There is no indication that agricultural burning and wildfires in Texas are significant contributors to regional haze on the worst 20 percent days at Class I areas that Texas impacts outside the state. For these reasons, the current rules, policies and plans listed below, along with the NPS smoke management plans, and the smoke management plans of other federal agencies responsible for Class I areas that Texas impacts, are adequate to meet the long-term strategy requirements. Appendix 11-1 contains documents in the following list. The TCEQ provides the documents as examples of the fire management plans that the responsible agencies maintain. This SIP revision does not incorporate the non-TCEQ documents. The outdoor burning rules are currently approved in to the Texas SIP.

• Texas Wildfire Protection Plan (TFS 2007)

• Texas Forest Service Smoke Management System (TFS 1995)

• 30 TAC Chapter 111, Subchapter B: Outdoor Burning (TCEQ 2006)

• Big Bend National Park Fire Management Plan (NPS 2005a)

• Guadalupe Mountains National Park Fire Management Plan (NPS 2005b)

• Big Thicket National Preserve Fire Management Plan (NPS 2004a)

• Lyndon B. Johnson National Historical Park Fire Management Plan (NPS 2005c)

• Padre Island National Seashore Fire Management Plan (NPS 2004b)

• San Antonio Missions National Historical Park Fire Management Plan (NPS 2004c).

A significant component of preventing wildfires is the authority that Texas counties have to prohibit open burning in times of drought. The counties get their authority from §352.081 and §352.082 of the Texas Local Government Code, relating to outdoor burning. Another component in reducing wildfire hazards is the red flag warn ings that the National Weather Service issues in times of drought, low humidity, and windy conditions. The broadcast media routinely publicize these warnings, especially during times of drought and outdoor burning bans.

Because of the relatively low contribution of smoke from Texas to worst 20 percent day visibility impairment at Texas’ Class I areas and the Class I areas Texas’ emissions affect in other states, the TCEQ is not certifying a smoke management plan as part of this SIP revision.

11.4.5 Program to Lower the Impact of Construction Activity on Air and Water Quality The main regulatory requirements that the TCEQ uses to minimize the air and water quality impacts of dust and soil from construction activity in Texas are under water pollution control requirements to prevent pollution from storm water runoff and mud and dirt tracked from construction sites. The reduction in silt-bearing runoff on paved roads and in mud and dirt tracked onto paved roads around construction sites reduces the amount of fine soil material suspended in the air from traffic in these areas.

The TCEQ’s Texas Pollutant Discharge Emission System (TPDES) General Permit TXR150000 regulates activities at c onstruction sites one acre or larger. The size threshold applies to single Deleted: ¶ Page Break

Deleted: s

Deleted: :11-32 projects or multiple projects as part of a larger development plan. The TCEQ issued this permit March 5, 2003, pursuant to §26.040 of the Texas Water Code and §402 of the Clean Water Act.

State rule 30 TAC §111.145, Construction and Demolition, provides additional authority and

states: “For the purpose of this section, the following restrictions apply if the area of land affected by the listed activities is more than one acre in size, except for the City of El Paso, where restrictions shall apply regardless of the size of the area of land affected. No person may cause, suffer, allow, or permit a structure, road, street, alley, or parking area to be constructed, altered, repaired, or demolished, or land to be cleared without taking at least the following precautions to
achieve control of dust emissions: (1) Use of water or of suitable oil or chemicals for control of dust in the demolition of structures, in construction operations, in work performed on a road, street, alley, or parking area, or in the clearing of land.”

11.5 FEDERAL PROGRAMS THAT REDUCE EMISSIONS The Federal Motor Vehicle Control Program (FMVCP) has produced and is continuing to produce large reductions in motor vehicle emissions of NO X , PM, and VOCs. The increasingly lower federal limits on sulfur content for gasoline and diesel fuel are continuing to reduce the sulfur input to total sulfur emissions from internal combustion engines. They are enabling lower

NO X , PM, and VOC emission limits for on-road motor vehicles, both diesel and gasoline, as well as for non-road engines. The lower sulfur fuel content is also enabling implementation of lower emission limits on new on-road and non-road engines.

The following lists several significant programs:

Federal On-Road Measures

• Federal Phase II reformulated gasoline (RFG) Dallas-Fort Worth (DFW) and HoustonGalveston-Brazoria (HGB)

• Tier 2 vehicle emission standards and federal low-sulfur gasoline

• National low emissions vehicle standards (NLEV)

• Heavy-duty diesel standards

Federal Non-Road Measures

• Lawn and garden equipment

• Tier 2 heavy-duty diesel equipment

• Locomotive engine standards

• Compression ignition standards for vehicles and equipment

• Recreational marine engine standards

Appendix 11-2: Federal and Texas Programs Related to On-Road and Non-Road Mobile

Sources lists the federal and state rules and programs in considerable detail.

11.5.1 Texas Vehicle Inspection and Maintenance Programs Motor vehicle inspection and maintenance programs are in place to maintain the effectiveness of the FMVCP in the HGB, DFW, Austin, and El Paso areas. The Department of Public Safety administers the programs and TCEQ maintains oversight of the programs including collecting and analyzing data directly from the equipment at the inspection stations.

11.5.2 Air Check Texas Repair and Replacement Assistance Program In 2002, the TCEQ established a financial assistance program for qualified owners of vehicles that fail the emissions test. The Low Income Vehicle Repair Assistance, Retrofit, and11-33 Accelerated Vehicle Retirement Program (LIRAP) provisions of House Bill 2134, 77th Texas Legislature 2001, created the program. House Bill 1611 passed in the 79th Legislature 2005, modified the program. The LIRAP applies only to counties that implement a vehicle inspection and maintenance program and have elected to implement LIRAP provisions.

By enacting Senate Bill 12, the 80th Texas Legislature expanded the LIRAP program and appropriated $45 million for LIRAP for fiscal year 2008 and an additional $45 million for fiscal year 2009. The purpose of this voluntary program is to remove older, more polluting vehicles from Texas roadways in certain counties with hi gh ozone. Under Senate Bill 12, residents of certain Texas counties who meet income criteria and whose vehicles meet certain registration criteria may be eligible to receive vouchers for up to $3,500 toward the purchase of a new or no more than three-year-old qualifying vehicle from participating auto dealers. A motor vehicle scrappage facility must certify that the engine fr om a retired vehicle has been destroyed for the vehicle owner to be eligible for the voucher. Accelerated retirement of older, higher polluting
vehicles will reduce NO X , fine PM, and VOC emissions.

11.6 EMISSION REDUCTIONS SINCE ISSUANCE OF THE REGIONAL HAZE RULE Since July 1, 1999, the TCEQ has implemented substantial programs that reduce Texas’ regional haze impact at Class I areas in Texas and in surrounding states. Appendix 11-3: Major Point
Source NO X Rules and Reductions Promulgated in Texas Since 2000 provides a detailed list of the TCEQ rule provisions that regulate NO X and PM emissions.

11.6.1 NO X Emission Reduction Requirements in Texas Ozone SIP Revisions Texas’ SIP revisions from 2000 forward include required NO X emission reductions for the following regions: HGB, DFW, Beaumont-Port Ar thur, Austin, and Northeast Texas as well as one for East Texas. In addition, the SIP includes the Texas low emission diesel requirements for East and Central Texas in 30 TAC Chapter 114. The rules for control of NO X emissions from stationary sources for the Texas ozone SIP are included in Chapter 117. Recent NO X control measures adopted in Chapter 117 address a wide range of point and area sources at major and
minor sources of NO X . Some of these rules implemented the NO X reduction requirements of Senate Bill 7, for grandfathered EGUs, as discu ssed in more detail in Section 11.6.2 The TCEQ has submitted all of the Chapter 117 NO X limitations and requirements as well as the Chapter 114 low emission diesel fuel requirements to EPA as revisions to the Texas SIP.

11.6.2 SO 2 and NO X Reduction Requirements under Senate Bill 7 Senate Bill 7 required the fo llowing emission reductions from grandfathered EGUs: for NO X, a 50 percent reduction of the 1997 emission level by May 1, 2003, and for SO 2 , a 25 percent reduction of the 1997 emission level by May 1, 2003, accompanied by an in-state emissions cap and trade program. Grandfathered EGUs are the EGUs built before Texas’ BACT emission control requirements for new and modified sources of air pollution went into effect in 1972. These requirements produced reductions approximately a decade before the BART emissions
reductions will be effective in states withou t CAIR requirements. They were effective approximately six and seven years before the Phas e I CAIR requirements will be effective in states that implement CAIR NO X and SO 2 emission reductions. Phase I of CAIR becomes
effective in 2009 for NO X and in 2010 for SO 2 . Phase II of CAIR will become effective in 2015,
at which time it will become the limiting requirement for SO 2 and NO X for most EGUs in Texas. This SIP revision presumes that either CAIR will be finally upheld by the courts or will be replaced with a federal program that achieves comparable reductions in emissions. On December 23, 2008, the U.S. Circuit Court of Appeals for the District of Columbia Circuit issued a decision remanding CAIR to EPA to initiate ru lemaking consistent with its opinion, but the
court did not vacate CAIR.11-34 11.6.3 CAIR Reductions for NO X and SO 2 On March 10, 2005, the EPA issued the CAIR, requiring reductions in SO 2 and NO X emissions from EGUs in 28 states and the District of Columbia (70 FR 25162-25405). These include states in the Northeast, the South, and along the Mississippi River plus Texas, the only largely western state subject to the CAIR emissions reductions requirements. Figure 11- 32 shows that the CAIR emissions reductions requirements in Texas apply more than 480 miles west of the areas where CAIR requirements apply in other states. The map also shows that Texas is the only state where CAIR applies in the next tier of states west of the states that border the Mississippi River.

Figure 11-32: CAIR Emission Reduction States Note: States shown in green have CAIR emission reductions requirements Source: TCEQ 2007 Figure 11

- 11: CAIR Emission Reduction States

CAIR applies to SO 2 in all CAIR areas except in Arkansas, Delaware, New Jersey, and New England. In states where CAIR applies to SO 2 , CAIR will reduce SO 2 emission allowances by over 60 percent from 2003 federal acid rain cap levels. In all CAIR states, the program will
reduce NO X emission allowances by over 60 percent from 2003 federal acid rain cap levels. CAIR establishes an EPA-administered cap-and-trade program for EGUs in which states may participate as a means of meeting these requirements. The Texas Legislature directed the TCEQ to participate in this interstate cap-and-trade system. SO 2 and NO X reductions will occur in two phases under a cap-and-trade system established by the EPA. SO 2 emission caps will be lowered in 2010 and again in 2015. NO X emission allowables will decrease in 2009 and again in 2015.
Table 11- 15 shows the emission allowances for EGUs in Texas under the CAIR program.

Table 11-1 5 : EGU Emission Allowances in Texas under the CAIR Program

Annual NO X Cap (tons)

State 2003 Acid Rain Emissions Inventory 2009 CAIR Phase I Budget 2015 CAIR Phase II Budget Texas 211,000 181,014 150,845

Annual SO 2 Cap (tons) Deleted:

Deleted: 11

Deleted: 111-35 State 2003 Acid Rain Emissions Inventory 2010 CAIR Phase I Budget 2015 CAIR Phase II Budget Texas 578,000 320,946 224,662

Source: EPA11-36 The TCEQ has submitted to the EPA as a revision to the Texas SIP its rules that implement the CAIR requirements. The following links provide further information on the CAIR SIP revisions and CAIR requirements for Texas.

The Texas CAIR SIP -<http://www.tceq.state.tx.us/assets/public/implementation/air/sip/caircamr/05048CAIRSIP_adoption_final.pdf>
The Texas CAIR Rule -<http://www.tceq.state.tx.us/assets/public/implementation/air/sip/caircamr/05046101_ado_clean.pdf>
The Texas CAIR/CAMR Web Page - <http://www.tceq.state.tx.us/implementation/air/sip/caircamr.html>

11.6.4 Best Available Retrofit Technology (BART) Requirements The commission adopted the final BART Rule (30 TAC Chapter 116, Subchapter M) January 10,
2007. It is available at: <http://info.sos.state.tx.us/pls/pub/readtac $ext.Vie wTAC?tac_view =5&ti=30&pt=1&ch=116&sc
h=M&rl=Y> . Because most sources reviewed under the BART rule are a long distance from the nearest Class I federal area, a large percentage fell below the de minimis level for impacting all Class I areas, so they did not have to proceed to a BART engineering analysis. Chapter 9: Best Available Retrofit Technolog y details the implementation of the BART program in Texas in
Table 9-7.11-37 11.6.5 Comparison of the NO X Emission Limits for EGUs with CAIR Limits The following table shows the relationship among the requirements.

Table 11- 16 : Texas Electric Generating Utility NO X Control Strategies Compared to
CAIR Facility Type State Emission Rate Requirements CAIR 2009 CAIR 2015

Utility Electric Generation in Ozone Nonatta inment Areas Emission Specifications for
Attainment Demonstrations

Houston-GalvestonBrazoria Pounds of

NO X /MMBtu Pounds of

NO X /MMBtu Pounds of

NO X /MMBtu Gas-Fired Utility
Boilers 0.030 lb 0.15 lb 0.125 lb

Coal-Fired Utility
Boilers 0.050 lb (wall-fired)
0.045 lb (tangential-fired) 0.15 lb 0.125 lb

Oil-Fired Utility
Boilers 0.050 lb (wall-fired)
0.045 lb (tangential-fired) 0.15 lb 0.125 lb

Auxiliary Steam Utility Boilers 0.030 lb 0.15 lb 0.125 lb

Stationary Gas
Turbines 0.032 lb 0.15 lb 0.125 lb

Dallas-Fort Worth Large Utility Boilers 0.033 lb 0.15 lb 0.125 lb
Small Utility Boilers 0.06 lb 0.15 lb 0.125 lb

Beaumont-Port Arthu r All Utility Boilers 0.10 lb 0.15 lb 0.125 lb
Utility Electric Generation in East and Central Texas Gas-Fired Utility
Boilers 0.14 lb 0.15 lb 0.125 lb

Coal-Fired Utility
Boilers 0.165 lb 0.15 lb 0.125 lb

Senate Bill 7 East Texas Region
Grandfathered
Facilities 0.14 lb 0.15 lb 0.125 lb

West Texas and El Paso Region
Grandfathered
Facilities 0.195 lb 0.15 lb 0.125 lb

Source: TCEQ, current as of February 23, 2007 Deleted: 211-38 11.6.6 Sulfur Dioxide Reductions under the EPA Refinery Consent Decrees The EPA refinery consent decrees cover both SO 2 and NO X . The NO X reductions are generally company-wide reduction requirements, but and the details of which emission points will have reductions and the amount of the reductions are not yet available.

The EPA has provided specifics of the SO 2 reductions by emission point for refineries. In addition, information is available regarding SO 2 emission reductions at a large sulfuric acid plant at the western end of the Houston Ship Channel. The following table combines these SO 2 emission reduction data. The growth projected growth from 2002 to 2018 are estimates from CENRAP’s emission inventory contractor (Pechan 2005). Since the TCEQ’s new and modified source permitting requirements prohibit an increase in allowable emissions without a construction permit, which requires use of BACT, the projected emission increases between 2002 and 2018 may be substantially over estimated.

Table 11- 17 : Annual SO 2 Emissions at Consent Decree Impacted Sources

SO 2 Emissions 2002 (tpy) 2018 (tpy)
Pre-decree levels 48,868 62,229
Reduction estimate* 45,453 56,433 Difference (remaining emissions) 3,415 5,796 *Reductions estimate applied to 2002 actual emissions to show theoretical impact. Controls will be in place before 2018.

Source: EPA 1999

11.6.7 Texas Low Emissions Diesel (TxLED) Program The goal of the TxLED program is to lower emissions of NO X and other pollutants from dieselpowered motor vehicles and non-road equipment. It applies to diesel fuel producers, importers, common carriers, distributors, transporters, bulk terminal operators, and retailers. The rules cover 110 counties in eastern Texas, including the ozone nonattainment areas of Beaumont-Port Arthur, DFW, and HGB. The rules require that diesel fuel as defined under 30 TAC §114.6 produced for delivery and ultimate sale to the consumer for both on- and non-road use must contain less than 10 percent by volume of aromatic hydrocarbons and have a cetane number of 48 or greater. The rules, which took effect October 1, 2005, allow some compliance options (30 TAC 114, Subchapter A, §114.6 and Subchapter H, Division 2, §§114.312 - 114.319).

11.6.8 The Texas Emission Reduction Plan (TERP) TERP is a comprehensive set of incentive programs aimed at improving air quality in Texas. The TCEQ administers TERP grants and other TERP financial incentives. The Texas Legislature established the TERP in 2001 through enactment of Senate Bill 5. The TERP includes a number of voluntary financial incentive programs, as well as other assistance programs, to help improve the air quality in Texas. The goals of the TERP are to:

• assure that the air in this state is safe to breathe and meets minimum federal standards established under the FCAA (42 USC §7407);

• develop multi-pollutant approaches to solving the state’s environmental problems; and

• adequately fund research and development that will make the state a leader in new technologies that can solve its environmental problems while creating new business and industry in the state.

The primary objective of the TERP has been to reduce NO X emissions to aid in attaining the NAAQS for ozone. By encouraging replacement of older on-road and non-road engines with newer engines, the TERP has also decreased fine PM emissions from the motor vehicles and equipment using these engines. As of January 2007, the TCEQ had approved over $406 million in grants under the TERP since the program started in 2001. Deleted: 311-39 The Texas Legislature approved over $143 million for fiscal year 2008 and $146 million for fiscal year 2009 to increase TERP grants aimed at NO X emission reductions in Texas. The program also reduces fine PM emissions by accelerating the replacement of older diesel engines with newer engines that have much lower PM emission rates.11-112-1 CHAPTER 12. COMPREHENSIVE PERIODIC IMPLEMENTATION PLAN REVISIONS AND ADEQUACY OF THE EXISTING PLAN

Title 40 CFR §51.308(f) requires states to revise and submit to the EPA a comprehensive regional haze implementation plan revision every 10 years until 2064. In addition, 40 CFR §51.308(g) requires periodic reports in the form of a SIP revision that evaluates progress towards the reasonable progress goals established for each Class I area. In accordance with the requirements, the TCEQ plans to submit a report to the EPA on reasonable progress every five years following the initial submittal of the Regional Haze SIP. The report will be in the form of a SIP revision and will evaluate the progress made towards the reasonable progress goal for each Class I area located within Texas, and in each Class I area located outside of Texas that may be affected by
emissions from within Texas. The TCEQ will consult with the Federal Land Managers during the SIP revision development process. All requirements listed in 40 CFR §51.308(g) will be addressed in the SIP revision for demonstrating reasonable progress.

Depending on the findings of its five-year progr ess report, the TCEQ will examine the actions listed in 40 CFR §51.308(h). The findings of the five-year progress report may determine which action the state may choose as appropriate.REFERENCES

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. ( http://www.tceq.state.tx.us/implementa tion/air/sip/ba rt/haze_appendices.html ). If you have problems accessing, please contact:

Margaret Earnest Texas Commission on Environmental Quality
12100 Park 35 Circle Austin, TX 78752

512-239-4581 mearnest@tceq.state.tx.us