Technical Support Document

for the

Oklahoma Regional Haze State Implementation Plan

and Federal Implementation Plan

Prepared and Reviewed by:

Joe Kordzi

Erik Snyder

Michael Feldman

Ellen Belk

Agustin Carbo-Lugo

March 2011
ii

Table of Contents

I. Relationship of this TSD to our Proposal................................................................................... 4

II. Background to Regional Haze................................................................................................... 6

III. Evaluation of State Submittal .................................................................................................. 9

A. Identification of Areas : 40 CFR 51.308(d).......................................................................... 9

B. Reasonable Progress Goals Development........................................................................... 10

B.1. Establishment of Reasonable Progress Goals: 40 CFR 51.308(d)(1) .......................... 10

B.2. Reasonable Progress Goals Four Factor Analysis: 40 CFR 51.308(d)(1)(i)(A) .......... 10

B.3. Uniform Rate of Progress Determination: 40 CFR 51.308(d)(1)(i)(B) ....................... 11

B.4. Uniform Rate of Progress Determination: 40 CFR 51.308(d)(1)(i)(B) ....................... 12

B.5 Analysis of Reasonable Progress Goal: 40 CFR 51.308(d)(1)(ii)-(iii) ......................... 12

B.6 Reasonable Progress State Consultation: 40 CFR 51.308(d)(1)(iv) ............................. 12

B.7 Reasonable Progress Goal Minimum: 40 CFR 51.308(d)(1)(vi).................................. 13

C. Baseline and Natural Visibility Conditions......................................................................... 13

C.1. Calculation of Baseline Conditions: 40 CFR 51.308(d)(2)(i)...................................... 13

C.2. Calculation of Natural Visibility Conditions: 40 CFR 51.308(d)(2)(iii) ..................... 15

C.3. Natural Visibility Impairment: 40 CFR 51.308(d)(2)(iv)(A)....................................... 16

D. Long Term Strategy: 40 CFR 51.308(d)(3).......................................................17

D.1 Long Term Strategy State Consultation: 40 CFR 51.308(d)(3)(i)................................ 18

D.2 Share of Reductions in Other States’ Progress Goals: 40 CFR 51.308(d)(3)(ii) .......... 19

D.3 Technical Basis for the Long Term Strategy: 40 CFR 51.308(d)(3)(iii) – (iv) ............ 21

D.4 Consideration of Long Term Strategy Factors: 40 CFR 51.308(d)(3)(v)..................... 27

E. Monitoring Strategy/Other SIP Requirements 40 CFR 51.308(d)(4) ................................. 31

F. Best Available Retrofit Technology (BART) Requirements: 40 CFR 51.308(e) ............... 33

F.1. BART Eligible Source Identification: 40 CFR 51.308(e)(1)(i).................................... 34

F.1.1. BART Sources Exempted Due to Permit Modifications....................................... 37

F.2. BART Five Factor Determination: 40 CFR 51.308(e)(1)(ii)(A).................................. 38

F.2.1. OG&E Seminole Units 1, 2, and 3 BART Determinations................................... 40

F.2.2. OG&E Sooner Units 1 and 2 BART Determinations............................................ 41

F.2.3. OG&E Muskogee Units 4 and 5 BART Determinations....................................... 43

F.2.4. AEP/PSO Comanche Units 1 and 2 BART Determinations ................................. 44

F.2.5. AEP/ PSO Northeastern Units 2, 3, and 4 BART Determinations........................ 45

F.2.6. AEP/PSO Southwestern Unit 3 BART Determination.......................................... 47

F.3. BART for Larger Fossil Fuel Power Plants: 40 CFR 51.308(e)(1)(ii)(B).................... 50

F.4. De Minimis BART: 40 CFR 51.308(e)(1)(ii)(C) ......................................................... 51

F.5. Design, Equipment, or Work Practice BART: 40 CFR 51.308(e)(1)(iii)..................... 51

F.6. Installation of BART: 40 CFR 51.308(e)(1)(iv) – (v).................................................. 51

F.7. CAIR for BART: 40 CFR 51.308(e)(4)........................................................................ 52

F.8. Reasonable Progress and BART: 40 CFR 51.308(e)(5)............................................... 52

F.9. BART Exemptions: 40 CFR 51.308(e)(6).................................................................... 53

G. 2018 Regional Haze SIP Revision: 40 CFR 51.308(f) ....................................................... 53

H. Five Year Progress Report 40 CFR 51.308(g).................................................................... 54

I. Existing SIP Adequacy Determination 40 CFR 51.308(h) .................................................. 55

J. Federal Land Manager Coordination 40 CFR 51.308(i)...................................................... 56
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Tables

Table 1. Calculation of Uniform Rate of Progress ......................................................11

Table 2. Summary of 2002 Emissions from Oklahoma Sources (tons per year) .....................23

Table 3. Oklahoma’s 2018 Emissions Inventory ........................................................24

Table 4. Projected Contribution from Oklahoma Emissions on Visibility Degradation for

the 20 Percent Worst Days in 2018 ...............................................................26

Table 5. Facilities with BART-eligible units in Oklahoma.............................................36

Table 6. Sources in Oklahoma required to install BART...............................................39

Table 7. NOx BART Reductions ...........................................................................49

Table 8. NOx BART Visibility Improvements ...........................................................50

Figures

Figure 1. Map of Class I Areas...............................................................................6

Figure 2. Location of the Class I Area in Oklahoma......................................................7

Figure 3. Map of Regional Planning Organization Boundaries.........................................8

Appendices

Appendix A. Review of Modeling and Emission Inventory Development for the Regional Haze

Implementation Plan for the State of Oklahoma

Appendix B. Refined Best Available Retrofit Technology (BART) Modeling Report: OG&E 

Sooner Generating Station, OG&E Muskogee Generating Station, and AEP/PSO 

Northeastern Generating Station

Appendix C. SO2 BART Cost Effectiveness Analysis for the Federal Implementation Plan

Appendix D. EPA Extension of SO2 BART Cost Effectiveness Analysis

Appendix E. Additional Information Provided by ODEQ for the AEP/PSO Southwestern Unit 3

BART Determination
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Oklahoma Regional Haze Technical Support Document (TSD)

I. Relationship of this TSD to our Proposal

We are proposing to partially approve and partially disapprove Oklahoma’s Regional Haze (RH) 

SIP revision submitted on February 19, 2010. Specifically, we are proposing to disapprove the 

Sulfur Dioxide (SO2) Best Available Retrofit Technology (BART) determinations for Units 4 

and 5 of the Oklahoma Gas and Electric (OG&E) Muskogee plant; Units 1 and 2 of the OG&E 

Sooner plant; and Units 3 and 4 of the American Electric Power/Public Service Company of 

Oklahoma (AEP/PSO) Northeastern plant. We are proposing to disapprove these SO2 BART 

determinations because they do not comply with our regulations under 40 CFR 51.308(e).

We are also proposing to disapprove the Long Term Strategy (LTS) under section 51.308(d)(3) 

because Oklahoma has not shown that the strategy is adequate to achieve the reasonable progress 

goals set by Oklahoma and by other nearby States. The visibility modeling used by Oklahoma in 

support of its SIP revision submittal assumed SO2 reductions from the six sources as identified 

above that Oklahoma did not secure when making its BART determinations for these sources. 

As we discuss elsewhere, the Oklahoma Department of Environmental Quality (ODEQ)

participated in the Central Regional Air Planning Association (CENRAP) visibility modeling 

development that assumed certain SO2 reductions from these six BART sources. ODEQ also 

performed its consultations with other states with the understanding that these reductions would 

be secured. We propose a Federal Implementation Plan (FIP) to cure these defects in BART and 

the LTS.

We are also proposing to approve the remaining sections of the RH SIP submission, except as 

discussed below.

We are proposing to find that Units 4 and 5 of the OG&E Muskogee plant, Units 1 and 2 of the 

OG&E Sooner plant, and Units 3 and 4 of the AEP/PSO Northeastern plant are subject to BART 

under 40 CFR 51.308(e). Further, we are proposing a FIP that specifically imposes SO2 BART 

emission limits on these sources. We are proposing that SO2 BART for Units 4 and 5 of the 

OG&E Muskogee plant, Units 1 and 2 of the OG&E Sooner plant, and Units 3 and 4 of the 

AEP/PSO Northeastern plant is an SO2 emission limit of 0.06 lbs/MMBtu that applies singly to 

each of these units on a 30 day rolling average. Additionally, we propose monitoring, recordkeeping, and reporting requirements to ensure compliance with these emission limitations. 

We are proposing that compliance with the emission limits be within three (3) years of the 

effective date of our final rule. In our proposal we solicited comments on alternative timeframes, 

up to five (5) years from the effective date our final rule.

Should OG&E and/or AEP/PSO elect to reconfigure the above units to burn natural gas, as a 

means of satisfying their BART obligations under section 51.308(e), that conversion should be 

completed within the same time frame. In our proposal, we solicited comments as to, 

considering the engineering and/or management challenges of such a fuel switch, whether the 
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full 5 years allowed under section 308(e)(1)(iv) following our final approval would be 

appropriate.

We are proposing to disapprove section VI.E of the Oklahoma RH SIP entitled, ―Greater 

Reasonable Progress Alternative Determination.‖ We are also proposing to disapprove the 

separate executed agreements between ODEQ and OG&E, and ODEQ and AEP/PSO entitled 

―OG&E Regional Haze Agreement, Case No. 10-024, and ―PSO Regional Haze Agreement, 

Case No. 10-025,‖ housed within Appendix 6-5 of the RH SIP. We are proposing that these 

portions of the submittal are severable from the BART determinations and the LTS; therefore, no 

FIP is required.

We are taking no action on whether Oklahoma has satisfied the reasonable progress requirements 

of our regional haze SIP requirements found at section 51.308(d)(1).

This TSD contains five appendices that support our proposal. Appendix A to this TSD contains 

a report describing our review of the emission inventory development, photochemical visibility 

modeling and the BART modeling performed by ODEQ. Appendix B to this TSD contains 

CALPUFF modeling that supports our proposed FIP. Appendix C to this TSD contains a report 

on the SO2 BART cost-effectiveness for Units 4 and 5 of the Oklahoma Gas and Electric 

Muskogee plant, Units 1 and 2 of the Oklahoma Gas and Electric Sooner plant, and Units 3 and 4 

of the American Electric Power/Public Service Company of Oklahoma Northeastern plant. 

Appendix D extends those analyses. Lastly, Appendix E contains additional information we 

received from the Oklahoma Department of Environmental Quality (ODEQ) that informed our 

BART proposal for the AEP/PSO Southwestern Unit 3 BART Determination.

This TSD is not meant to be a complete rationale for our decision. It merely provides additional 

information for some of the technical aspects of the basis for this action when needed. In some 

of the non-technical areas, our Federal Register notice(s) provides more detail than does this 

TSD. Also, this TSD treats the requirements of section 51.308 in the order in which they appear 

in that regulation, whereas our Federal Register notice(s) groups the requirements into related 

areas so the concepts can be understood more easily. In this regard, the TSD can serve as a 

checklist of whether the requirements have been addressed. Lastly, the TSD attempts to refer the 

reader to the specific portions of the Oklahoma’s regional haze SIP that we relied upon for our 

analysis of particular portions of section 51.308.

Throughout this document, we often use language such as, ―we find‖ or other similar phrases 

that on the surface would suggest a final determination has been made. However, all aspects of 

our TSD should be considered to be part of our proposal and are subject to change based on 

comments and other information we may receive during our public comment period.
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II. Background to Regional Haze

In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress set forth a 

program for protecting visibility in Federal Class I areas which calls for the ―prevention of any 

future, and the remedying of any existing, impairment of visibility in mandatory Federal Class I 

areas which impairment results from manmade air pollution.‖ Congress adopted the visibility 

provisions to protect visibility in 156 Federal Class I areas, which include certain national parks, 

memorial parks, and wilderness areas over a certain size, and all international parks. These areas 

are defined at 40 CFR 81.400, are listed by State at 40 CFR 81.401-81.437, and are depicted in 

Figure 1, with the Class I area within Oklahoma, the Wichita Mountains National Wildlife 

Refuge, depicted in Figure 2:

Figure 1. Map of Class I Areas
7

Figure 2. Location of the Class I Area in Oklahoma

On December 2, 1980, we promulgated regulations to address visibility impairment that is 

―reasonably attributable‖ to a single source or small group of sources. (45 FR 80084) These 

regulations represented the first phase in addressing visibility impairment and deferred action on 

regional haze that emanates from a variety of sources until monitoring, modeling and scientific 

knowledge about the relationships between pollutants and visibility impairment improved. 

In the 1990 Amendments to the CAA, Congress added Section 169B and called on us to issue 

Regional Haze rules. The RH rule that we promulgated on July 1, 1999 (64 FR 35713) revised 

the existing visibility regulations to integrate provisions addressing regional haze visibility 

impairment and establish a comprehensive visibility protection program for Federal Class I 

areas. These regulations represented the second phase in addressing visibility impairment. 

States were required to submit state implementation plans (SIPs) to us that set out each state’s 

plan for complying with the RH Rule, including consultation and coordination with other states 

and with Federal Land Managers (FLMs). States were required to submit a Regional Haze SIP 

to us within three years after the date of designation of areas under the National Ambient Air 

Quality Standard (NAAQS) for fine particulate matter (PM2.5). We promulgated PM2.5 

designations on December 17, 2004, and thus, regional haze SIPs were to be submitted to us by 

December 17, 2007, which is also specified at 40 CFR 51.308(b).

The RH rule addressed the combined visibility effects of various pollution sources over a wide 

geographic region. Consequently, all 50 states, including those without Class I areas, 

Washington, D.C., and the Virgin Islands, were required to submit Regional Haze SIPs (40 CFR 

51.300(b)(3)). We designated five Regional Planning Organizations (RPOs) to assist with the 

coordination and cooperation needed to address the visibility issue, as shown by Figure 3.
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Figure 3. Map of Regional Planning Organization Boundaries

Oklahoma, through the ODEQ joined state air agencies from Arkansas, Iowa, Kansas, Louisiana, 

Minnesota, Missouri, Nebraska, and Texas in forming CENRAP, in 1999. CENRAP also 

includes federally recognized Indian tribes located within the geographic boundaries of its 

member states. The State of Oklahoma and it’s agency, the Oklahoma Department of 

Environmental Quality, chose to participate in CENRAP to develop the technical analyses 

needed to fulfill the requirements of the RH Rule.
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III. Evaluation of State Submittal

In evaluating the Oklahoma RH SIP, we reviewed all the parts of the document, including the 

body of the SIP itself, and all appendices. In addition, we drew upon the following additional 

documents that may not have been specifically discussed in our TSD and/or the Federal Register 

publication(s) of our decision:

1. 40 CFR Part 51.

2. Appendix V to 40 CFR Part 51.

3. The ―BART Guidelines‖ in Appendix Y to Part 51—Guidelines for BART

Determinations Under the Regional Haze Rule, 70 FR 39104, July 6, 2005.

4. Guidance for Tracking Progress Under the Regional Haze Rule, EPA-454/B-03-004, 

September, 2003.

5. Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and Regional 

Haze, January 2, 2001.

6. Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, 

EPA-454/B-03-005, September 2003.

7. The ―Baseline Memo,‖ which is entitled, ―2002 Base Year Emission Inventory SIP 

Planning: 8-Hour Ozone, PM2.5 and Regional Haze Programs, dated 11/18/2002, from 

Lydia Wegman to the Regional Air Directors.‖

8. Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, 

dated June 1, 2007.

9. Visibility Monitoring Guidance, EPA-454/R-99-003, June 1999.

10. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter 

National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations, 

EPA-454/R-05-001, dated August, 2005.

11. Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998.

A. Identification of Areas : 40 CFR 51.308(d)

Oklahoma must address regional haze in each mandatory Class I Federal area located within it

and in each mandatory Class I Federal area located outside it which may be affected by 

emissions from within it.

State Submittal

Pages 1, 2, 100-102

The Oklahoma ODEQ is responsible for developing the Regional Haze SIP for Oklahoma and 

submitting it to the Oklahoma Air Pollution Control Board for approval. Oklahoma has one 

Class I area within its borders, the Wichita Mountains National Wildlife Refuge (Wichita 

Mountains), which it has identified in its SIP. ODEQ has also determined that Oklahoma 

emissions have a small potential to impact visibility at Class I areas outside of Oklahoma. 

Based on projections of visibility in 2018 for the 20% worst visibility days, ODEQ has projected 

that Oklahoma emissions are responsible for approximately 3.61% of the visibility degradation 
10

at the Hercules Glades in Missouri, approximately 2.53% of the visibility degradation at Salt 

Creek in New Mexico, and approximately 2.0% of the visibility degradation at Guadalupe 

Mountains in Texas. We note that these projections are based on modeling done by CENRAP 

that assumed a certain level of reductions of SO2 emissions from six sources that Oklahoma did 

not actually require in its submitted RH SIP revision. We expect that Oklahoma’s projected 

impacts on visibility at Class I areas outside of Oklahoma would be greater had these controls

and the associated SO2 emission reductions not been included in CENRAP’s visibility modeling. 

Additional detail can be found in Table VIII-9 of the RH SIP.

EPA Findings: We find that ODEQ has satisfied this requirement. 

B. Reasonable Progress Goals Development 

As we explain in our proposal, we are not taking action on Oklahoma’s submitted Reasonable 

Progress Goal (RPG) because, as described more fully therein, we must first evaluate and act 

upon the RH SIP revision submitted by the State of Texas. Therefore, with the exception of 

Oklahoma’s uniform rate of progress determination in section 51.308(d)(1)(i)(B), we do not 

further consider section 51.308(d)(1) in this TSD, other than to list the requirements.

Note: The language under Section 51.308(d)(1)(v), “The reasonable progress goals established 

by the State are not directly enforceable but will be considered by the Administrator in 

evaluating the adequacy of the measures in the SIP to achieve the progress goal adopted by the 

State,” is a statement relating to our review of RH SIPs. Since it does not require a response 

from the state, it is not separately evaluated here.

B.1. Establishment of Reasonable Progress Goals: 40 CFR 51.308(d)(1)

For each mandatory Class I Federal area located within the state, Oklahoma must establish goals 

(expressed in deciviews) that provide for reasonable progress towards achieving natural visibility 

conditions. The reasonable progress goals must provide for an improvement in visibility for the 

most impaired days over the period of the SIP and ensure no degradation in visibility for the least 

impaired days over the same period.

EPA Findings

We are not proposing action on whether Oklahoma has met this requirement

B.2. Reasonable Progress Goals Four Factor Analysis: 40 CFR 51.308(d)(1)(i)(A)

In establishing a reasonable progress goal for any mandatory Class I Federal area within 

Oklahoma, it must consider the costs of compliance, the time necessary for compliance, the 

energy and non-air quality environmental impacts of compliance, and the remaining useful life of 
11

any potentially affected sources, and include a demonstration showing how these factors were 

taken into consideration in selecting the goal.

EPA Findings

We are not proposing action on whether Oklahoma has met this requirement

B.3. Uniform Rate of Progress Determination: 40 CFR 51.308(d)(1)(i)(B)

In establishing a reasonable progress goal for any mandatory Class I Federal area within the 

State, Oklahoma must analyze and determine the rate of progress needed to attain natural 

visibility conditions by the year 2064. To calculate this rate of progress, Oklahoma must 

compare baseline visibility conditions to natural visibility conditions in the mandatory Federal 

Class I area and determine the uniform rate of visibility improvement (measured in deciviews) 

that would need to be maintained during each implementation period in order to attain natural 

visibility conditions by 2064. 

State Submittal

Pages 36, 104-106

See Sections III.C.1 – C.2 of this TSD for a discussion on ODEQ’s calculations of baseline and 

natural visibility conditions. To calculate the rate of progress needed to attain natural visibility 

conditions by the year 2064, also known as the Uniform Rate of Progress (URP), ODEQ 

compared baseline visibility conditions to natural visibility conditions at the Wichita Mountains

Class I area and determined the linear rate of visibility improvement (in deciviews) that would 

have to be maintained during each implementation period in order to attain natural visibility 

conditions by 2064. Using a baseline of 23.81 dv and a natural visibility value of 7.53 dv for the 

20 percent worst days, ODEQ calculated the URP to be 16.28 dv, as depicted by Table 1, which 

is adapted from Table III-9 of the SIP:

Table 1. Calculation of Uniform Rate of Progress

Baseline Conditions 23.81 dv

Natural Visibility 7.53 dv

Total Improvement by 2064 16.28 dv

Improvement for this SIP by 2018 3.80 dv

Uniform Rate of Progress 0.27 dv/year

This information is also depicted graphically in Figure IX-1 of the SIP.

EPA Findings
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We agree that ODEQ has, in establishing its RPG, analyzed and determined the rate of progress 

needed to attain natural visibility conditions by the year 2064. ODEQ has calculated this rate of 

progress, and compared baseline visibility conditions to natural visibility conditions for the 

Wichita Mountains and determined the URP needed to be maintained during each 

implementation period in order to attain natural visibility conditions by 2064.

B.4. Uniform Rate of Progress Determination: 40 CFR 51.308(d)(1)(i)(B)

In establishing the reasonable progress goal, Oklahoma must consider the uniform rate of 

improvement in visibility and the emission reduction measures needed to achieve it for the 

period covered by the SIP.

EPA Findings

We are not proposing action on whether Oklahoma has met this requirement

B.5 Analysis of Reasonable Progress Goal: 40 CFR 51.308(d)(1)(ii)-(iii)

For the period of the SIP, if Oklahoma establishes a reasonable progress goal that provides for a 

slower rate of improvement in visibility than the rate that would be needed to attain natural 

conditions by 2064, it must demonstrate, based on the factors in section 51.308(d)(1)(i)(A), that 

the rate of progress for the SIP to attain natural conditions by 2064 is not reasonable; and that the 

progress goal adopted by it is reasonable. Oklahoma must provide to the public for review as 

part of its SIP an assessment of the number of years it would take to attain natural conditions if 

visibility improvement continues at the rate of progress selected by it as reasonable. 

In determining whether the Oklahoma’s goal for visibility improvement provides for reasonable 

progress towards natural visibility conditions, the Administrator will evaluate the demonstrations 

developed by it pursuant to Section 51.308(d)(1)(i) and (d)(1)(ii).

EPA Findings

We are not proposing action on whether Oklahoma has met this requirement

B.6 Reasonable Progress State Consultation: 40 CFR 51.308(d)(1)(iv)

In developing each reasonable progress goal, Oklahoma must consult with those States which 

may reasonably be anticipated to cause or contribute to visibility impairment in the mandatory 

Class I Federal area. In any situation in which Oklahoma cannot agree with another such State 

or group of States that a goal provides for reasonable progress, Oklahoma must describe in its 

submittal the actions taken to resolve the disagreement. In reviewing Oklahoma’s SIP submittal, 

the Administrator will take this information into account in determining whether its goal for 

visibility improvement provides for reasonable progress towards natural visibility conditions.
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EPA Findings

We are not proposing action on whether Oklahoma has met this requirement

B.7 Reasonable Progress Goal Minimum: 40 CFR 51.308(d)(1)(vi)

Oklahoma may not adopt a reasonable progress goal that represents less visibility improvement 

than is expected to result from implementation of other requirements of the CAA during the 

applicable planning period.

EPA Findings

We are not proposing action on whether Oklahoma has met this requirement

C. Baseline and Natural Visibility Conditions

Note: 40 CFR 51.308(d)(2)(ii) is not applicable since this SIP was submitted after 2003, and 40 

CFR 51.308(d)(2)(iv)(B) is not applicable since this is the first SIP period.

C.1. Calculation of Baseline Conditions: 40 CFR 51.308(d)(2)(i)

For each mandatory Class I Federal area located within Oklahoma, it must determine the 

baseline visibility conditions for the most impaired and least impaired days. The period for 

establishing baseline visibility conditions is 2000 to 2004. Baseline visibility conditions must be 

calculated, using available monitoring data, by establishing the average degree of visibility 

impairment for the most and least impaired days for each calendar year from 2000 to 2004. The 

baseline visibility conditions are the average of these annual values. For mandatory Class I 

Federal areas without onsite monitoring data for 2000–2004, Oklahoma must establish baseline 

values using the most representative available monitoring data for 2000–2004, in consultation 

with the Administrator or his or her designee.

State Submittal

Pages 8 - 27.

Baseline conditions represent visibility for the best and worst days at the time the regional haze 

program is established. Baseline conditions are calculated using multiyear averaging of the 20 

percent of monitored days with the highest (most impaired, or worst days) and the 20 percent of 

monitored days with the lowest (least impaired, or best days) light extinction values, expressed in 

deciviews (dv), for the years 2000 through 2004. The RHR establishes the deciview (dv) as the 

principal metric for measuring visibility. See 70 FR 39104. A deciview is a uniform measure of 

light extinction caused by regional haze. This visibility metric expresses uniform changes in the 
14

degree of haze in terms of common increments across the entire range of visibility conditions, 

from pristine to extremely hazy conditions. The deciview scale approaches zero for no visibility 

degradation and increases as visibility is degraded. The deciview scale was designed similar to 

the decibel scale for sound, so that equal changes in deciview are equally perceptible. The 

deciview is a useful measure for tracking progress in improving visibility, because each deciview 

change is an equal incremental change in visibility perceived by the human eye. Most people 

can detect a change in visibility of one deciview. Common current values in the west are 15 to 

20 dv; common current values in the east are 25 to 30 dv. Visibility is also sometimes expressed 

in terms of the visual range, which is the greatest distance, in kilometers or miles, at which a 

dark object can just be distinguished against the sky.

The baseline is the starting point for this regional haze submittal, against which progress toward 

the national visibility goal is measured. ODEQ calculated its baseline conditions in accordance 

with our 2003 Natural Visibility Guidance1, as required by the RHR. The baseline condition 

calculation begins with the calculation of light extinction, using the IMPROVE equation. The 

IMPROVE equation sums the light extinction resulting from individual pollutants, such as 

sulfates and nitrates.

In 2005 the IMPROVE Steering Committee made recommendations for a refined equation that 

modifies the terms of the original equation to account for the most recent data. The purpose of 

this refinement is to provide more accurate estimates of the various factors that affect the 

calculation of light extinction. 

The new IMPROVE equation estimates additive extinction coefficients for each of several 

chemical constituents of particulate matter: sulfurous, nitrate, organic carbonaceous, elemental 

“light-absorbing” carbonaceous, fine soil, chlorine or chloride, and coarse matter. The 

equation also accounts for Rayleigh scattering of light and for deliquescence on sulfurous, 

nitrate, and chlorine or chloride particulates with an estimate of particle-bound water as a

function of relative humidity. It reflects the most recent review of the science2and it accounts for 

the effect of particle size distribution on light extinction efficiency of sulfate, nitrate, and organic 

carbon. It also adjusts the mass multiplier for organic carbon (particulate organic matter) by 

increasing it from 1.4 to 1.8. New terms are added to the equation to account for light extinction 

by sea salt and light absorption by gaseous nitrogen dioxide. Site-specific values are used for 

Rayleigh scattering (scattering of light due to atmospheric gases) to account for the site-specific 

effects of elevation and temperature. Separate relative humidity enhancement factors are used 

 

1

 Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program, EPA-454/B-03-005, 

September 2003.

2

 The science behind the revised IMPROVE equation is summarized in appendix B.2 of the Oklahoma Regional 

Haze submittal and in numerous published papers. See for example: Hand, J.L., and Malm, W.C.,2006, 

Review of the IMPROVE Equation for Estimating Ambient Light Extinction Coefficients - Final Report. March 

2006. Prepared for Interagency Monitoring of Protected Visual Environments (IMPROVE), Colorado State 

University, Cooperative Institute for Research in the Atmosphere, Fort Collins, Colorado.

http://vista.cira.colostate.edu/improve/publications/GrayLit/016_IMPROVEeqReview/IMPROVEeqReview.htm

; and Pitchford, Marc., 2006, Natural Haze Levels II: Application of the New IMPROVE Algorithm to Natural 

Species Concentrations Estimates. Final Report of the Natural Haze Levels II Committee to the RPO 

Monitoring/Data Analysis Workgroup. September 2006 

http://vista.cira.colostate.edu/improve/Publications/GrayLit/029_NaturalCondII/naturalhazelevelsIIreport.ppt
15

for small and large size distributions of ammonium sulfate and ammonium nitrate and for sea 

salt. The terms for the remaining contributors, elemental carbon (light-absorbing carbon), fine 

soil, and coarse mass terms, do not change between the original and new IMPROVE equations. 

Further details and explanation of the Improve equations can be found in Appendices A and B.

As with the natural visibility conditions calculation, ODEQ chose to use the new IMPROVE 

equation. The choice between use of the old or the new equation for calculating the visibility 

metrics for each Class I area is made by the state in which the Class I area is located. ODEQ 

has chosen to use this new equation, referred to in the SIP as a “revised” approach, for 

calculating both the baseline and natural visibility conditions because it takes into account the 

most recent review of the science and because it is recommended by the IMPROVE Steering 

Committee.

Monitoring began at the Wichita Mountains in March 2001, and ODEQ concluded that no other 

monitor provided reasonable substitute that met our completeness criteria. As a consequence,

the Oklahoma RH SIP employs the incomplete visibility data for 2001, complete data for 2002-

2004, and provisional data for 2005 and 2006. The resulting baseline conditions represent an

average for 2002-2004. ODEQ calculated the baseline by first summing the light extinction 

(where the extinction coefficient is expressed in Mm1) for sulfurous, nitrate, organic 

carbonaceous, elemental “light-absorbing” carbonaceous, fine soil, chlorine or chloride, and 

coarse matter, using the following equation:

βext = βext S + βext NO3 + βext organic+ βext elemental+ βext SOil+ βext coarse+ βext Cl+ βext Rayleigh

ODEQ then converted the total light extinction values to deciviews (dv), using the Haze Index 

(HI) equation:

HI (dv) = 10 ln[βext/(10 Mm -1)]

ODEQ calculated the baseline conditions at the Wichita Mountains as 23.81 dv on the 20 

percent worst days, and 9.78 dv on the 20 percent best days.

EPA Findings

As stated above, ODEQ did not have access to a complete data set from 2000 – 2004. We agree 

with them that no adequate substitute for that monitoring data exists. Nevertheless, we feel that 

ODEQ adequately utilized the data they did have at their disposal and adequately calculated 

baseline conditions.

C.2. Calculation of Natural Visibility Conditions: 40 CFR 51.308(d)(2)(iii)

For each mandatory Class I Federal area located within the State, the State must determine the 

natural visibility conditions for the most impaired and least impaired days. Natural visibility 

conditions must be calculated by estimating the degree of visibility impairment existing under 
16

natural conditions for the most impaired and least impaired days, based on available monitoring 

information and appropriate data analysis techniques.

State Submittal

Pages 28-36

Natural background visibility, as defined in our natural visibility guidance, is based on annual 

average concentrations of fine particle components. Natural background visibility for the 20 

percent worst days is estimated by assuming that fine particle concentrations for natural 

background are normally distributed and the 90th percentile of the annual distribution represents 

natural background visibility on the 20 percent worst days (i.e, Method 1 prediction per our

natural visibility guidance).

In the natural visibility guidance, we provided default estimates for the natural visibility 

condition at almost all Class I areas. For the Wichita Mountains, the default natural visibility 

value for the 20 percent worst days is 11.07 dv and for the 20 percent best days is 3.39 dv. 

The natural visibility guidance also provided that states may use a “refined approach” to 

estimate the values that characterize the natural visibility conditions of the Class I areas. The 

purpose of such a refinement would be to provide more accurate estimates with changes to the 

extinction algorithm that may include the concentration values, factors to calculate extinction 

from a measured particular species and particle size, the extinction coefficients for certain 

compounds, geographical variation (by altitude) of a fixed value, and the addition of visibility 

pollutants.

As with the calculation of baseline conditions, ODEQ chose to use the new IMPROVE equation 

as the basis for its refined estimate because it takes into account the most recent review of the 

science and because it is recommended by the IMPROVE Steering Committee.

ODEQ calculated the natural conditions at the Wichita Mountains as 7.53 dv on the 20 percent 

worst days, and 4.2 dv on the 20 percent best days.

EPA Findings

We find that Oklahoma has satisfied this requirement.

C.3. Natural Visibility Impairment: 40 CFR 51.308(d)(2)(iv)(A)

For the first SIP addressing the requirements of 51.308(d) and (e) of this section, Oklahoma must 

calculate the number of deciviews by which baseline conditions exceed natural visibility 

conditions for the most impaired and least impaired days.

State Submittal
17

Page 36, 104-106.

As discussed in section III.C.1 of this TSD, ODEQ calculated the baseline conditions at the 

Wichita Mountains as 23.81 dv on the 20 percent worst days, and 9.78 dv on the 20 percent best 

days. Also discussed in section III.C.2, ODEQ calculated the natural conditions at the Wichita 

Mountains as 7.53 dv on the 20 percent worst days, and 4.2 dv on the 20 percent best days. 

Subtracting the natural visibility condition values from the baseline values results in the amount 

of visibility impairment. 

As summarized in Table III-9 and IX-1, and displayed in Figure IX-1 of its SIP, ODEQ 

calculates the number of deciviews by which baseline conditions exceed natural visibility 

conditions at the Wichita Mountains for the most impaired (20 percent worst) days to be 16.28 

dv (23.81 – 7.53).

Similarly, using the baseline and natural visibility conditions ODEQ calculated for the least 

impaired (20 percent best) days results in a calculation in which baseline conditions exceed 

natural visibility conditions at the Wichita Mountains for the least impaired (20 percent best) 

days to be 5.6 dv (9.78 – 4.2).

EPA Findings

We find that Oklahoma has satisfied this requirement.

D. Long Term Strategy: 40 CFR 51.308(d)(3).

Oklahoma, as with each State listed in section 51. 300(b)(3), must submit a long-term strategy 

that addresses regional haze visibility impairment for each mandatory Class I Federal area within 

it and for each mandatory Class I Federal area located outside it which may be affected by 

emissions from it. The long-term strategy must include enforceable emissions limitations, 

compliance schedules, and other measures as necessary to achieve the reasonable progress goals 

established by States having mandatory Class I Federal areas.

State Submittal

Pages 37-47, 58-67, 86-103

The LTS is a compilation of state-specific control measures relied on by Oklahoma for 

achieving its RPGs. Oklahoma’s LTS for the first implementation period addresses the 

emissions reductions from federal, state, and local controls that take effect in the state from the 

end of the baseline period starting in 2004 until 2018. The Oklahoma LTS was developed by 

ODEQ, in coordination with the CENRAP RPO, through an evaluation of the following 

components: (1) construction of a CENRAP 2002 baseline emission inventory; (2) construction 

of a CENRAP 2018 emission inventory, including reductions from CENRAP member state 

controls required or expected under federal and state regulations, (including BART); (3) 
18

Photochemical grid modeling that included both 2002 and 2018 analyses of CENRAP region 

and outside the CENRAP region to determine visibility improvement and apportion individual 

state contributions; (4) state consultation; and (5) application of the LTS factors.

EPA Findings

As discussed in section III.B, Oklahoma’s reasonable progress goal provides for a slower rate of

visibility improvement than does the uniform rate of progress. However, we feel it is clear that

sources originating outside of Oklahoma, contribute much more to the visibility degradation at 

the Wichita Mountains than do sources within Oklahoma. This limits Oklahoma’s ability to 

improve the visibility at the Wichita Mountains by controlling sources within its own borders. 

ODEQ has shown that even complete elimination of all anthropogenic emissions in Oklahoma 

would not result in Oklahoma meeting the URP. 

Consequently, we find that with the (1) the controls discussed above, (2) the addition of sources 

controlled through BART, and (3) those additional sources controlled through the FIP, ODEQ 

has demonstrated Oklahoma’s long term strategy sufficiently addresses Oklahoma’s share of 

emission reductions to reduce regional haze visibility impairment at the Wichita Mountains.

With regard to other mandatory Class I Federal areas located outside Oklahoma, Table VIII-9

of the RH SIP, “Projected influence of emissions from Oklahoma on Class I areas (worst quintile 

days, 2018)” shows that emissions from Oklahoma are projected to be responsible for no more 

than 3.61% of the visibility degradation at Class I areas outside of its borders (Hercules Glades

in 2018). We conclude this low level of visibility impairment does not merit additional controls. 

Therefore, we find that with the (1) the controls discussed above, (2) the addition of sources 

controlled through BART, and (3) those additional sources controlled through the FIP, ODEQ 

has demonstrated Oklahoma’s long term strategy sufficiently addresses Oklahoma’s share of 

emission reductions to reduce regional haze visibility impairment at mandatory Class I Federal 

area located its borders. We find that ODEQ has adequately addressed this requirement.

The remaining portions of section III.D expand upon our determination.

D.1 Long Term Strategy State Consultation: 40 CFR 51.308(d)(3)(i)

Where Oklahoma has emissions that are reasonably anticipated to contribute to visibility 

impairment in any mandatory Class I Federal area located in another State or States, it must 

consult with the other State(s) in order to develop coordinated emission management strategies. 

Oklahoma must consult with any other State having emissions that are reasonably anticipated to 

contribute to visibility impairment in any mandatory Class I Federal area within it.

State Submittal

Pages 115 – 117, Appendix 10-1

ODEQ used CENRAP as its main vehicle for facilitating collaboration with FLMs and other 

states in satisfying its LTS consultation requirement. This helped ODEQ and other state 
19

environmental agencies analyze emission apportionments at Class I areas and develop 

coordinated RH SIP strategies. CENRAP modeling concluded that emissions from Oklahoma 

are projected to have little effect on the visibility degradation at Class I areas outside of its

borders. ODEQ used this information to help inform its consultation strategy. ODEQ 

participated in consultations for Mingo and the Hercules Glades in Missouri; the Upper Buffalo,

and Caney Creek in Arkansas; and Big Bend and the Guadalupe Mountains in Texas. As 

described on page 115 of the RH SIP, ODEQ conducted four consultations. ODEQ held its first 

consultation, specifically directed to the tribal leaders in Oklahoma and their environmental 

managers, on 14 August 2007. Only the Delaware Nation of Oklahoma participated. ODEQ 

held the next three consultations as conference calls on 16 August, 30 August, and 25 September 

2007. In these consultations, ODEQ invited CENRAP member clean air agencies, us, and the 

tribes to participate. ODEQ invited personnel from clean-air agencies in Arkansas, Iowa, 

Kansas, Louisiana, Minnesota, Missouri, Nebraska, and Texas to participate in its consultations.

Appendix 10-1 of the RH SIP contains some correspondence related to these consultations. As 

part of that correspondence, the State of Texas agreed to provide ODEQ the opportunity to 

comment on Best Available Control Technology (BACT) determinations for Prevention of 

Significant Deterioration (PSD) sources that have significant impact on the Wichita Mountains 

National Wildlife Refuge (WMNWR). Specifically, ODEQ will be afforded the opportunity to 

review applications for sources if modeling predicts a five percent or higher impact on light 

extinction in a given year and provide comments to Texas during its public review and comment 

period. Texas also agreed to notify ODEQ whenever modeling indicates that a proposed source 

may significantly impact the WMNWR. ODEQ also requested that Class I impact reviews be 

required for all proposed PSD sources within 300 kilometers of a Class I area. However, this 

request was not agreed to by Texas, who cited the need for us to adopt significant impact levels 

for Class I reviews so that there is a consistent approach to requiring Class I reviews.

EPA Findings

Section 51.308(d)(3)(i) requires that Oklahoma consult with other states if its emissions are 

reasonably anticipated to contribute to visibility impairment at that state’s Class I area(s), and 

that Oklahoma consult with other states if their emissions are reasonably anticipated to 

contribute to visibility impairment at the Wichita Mountains. After evaluating whether emissions 

from Oklahoma sources contribute to visibility impairment in other states’ Class I areas, ODEQ 

concluded there was no contribution sufficient to require consultation. ODEQ’s evaluation 

relied, however, upon SO2 BART reductions from the six units of the OG&E and AEP/PSO three 

coal fired power plants. However, ODEQ did not secure these emissions reductions. Because 

this situation is tied to our analysis of section 51.308(d)(3)(ii), we combine our finding on 

section 51.308(d)(3)(i) with that of section 51.308(d)(3)(ii). 

D.2 Share of Reductions in Other States’ Progress Goals: 40 CFR 51.308(d)(3)(ii)

Where Oklahoma causes or contributes to impairment in a mandatory Class I Federal area, it

must demonstrate that it has included in its SIP all measures necessary to obtain its share of the 

emission reductions needed to meet the progress goal for the area. If Oklahoma has participated 
20

in a regional planning process, it must ensure it has included all measures needed to achieve its 

apportionment of emission reduction obligations agreed upon through that process.

State Submittal

Pages 65, 115-117

As discussed in sections III.D.3-4, and depicted in Table 4, below, ODEQ concluded that 

emissions from Oklahoma only minimally affect the visibility at other Class I areas. No states 

requested emission reductions from Oklahoma as part of their long term strategies. However, in 

performing this visibility projection modeling, in which other states relied, ODEQ assumed that 

Units 4 and 5 of the OG&E Muskogee plant, Units 1 and 2 of the OG&E Sooner plant, and Units 

3 and 4 of the AEP/PSO Northeastern plants, would be controlled at presumptive SO2 BART

levels, when in fact, after the consultation calls with tribes and other states in 2007 ODEQ found 

that SO2 BART was no control on these six units in their 2010 submittal. This original 

assumption that these six units would be controlled to presumptive SO2 limits is partially 

responsible for the low projected influence of Oklahoma’s emissions on the visibility of Class I 

areas outside of the state.

EPA Findings

As we discuss above in our analysis of section 51.308(d)(3)(i), ODEQ concluded there was no 

contribution sufficient to require consultation. Regardless of its conclusions regarding the 

impacts of Oklahoma emissions on other states’ Class I areas, however, Oklahoma did consult 

with other states and tribes, largely through the CENRAP process.

Section 51.308(d)(3)(ii) requires that if Oklahoma emissions cause or contribute to impairment 

in another state’s Class I area, Oklahoma must demonstrate that it has included in its RH SIP all 

measures necessary to obtain its share of the emission reductions needed to meet the progress 

goal for that Class I area. Section 51.308(d)(3)(ii) also requires that since Oklahoma 

participated in a regional planning process, it must ensure it has included all measures needed 

to achieve its apportionment of emission reduction obligations agreed upon through that 

process. As we state in the RHR , Oklahoma’s commitments to participate in CENRAP bind it to 

secure emission reductions agreed to as a result of that process, unless it proposes a separate 

process and performs its consultations on the basis of that process:

While States are not bound by the results of a regional planning effort, nor can the content of 

their SIPs be dictated by a regional planning body, we expect that a coordinated regional effort 

will likely produce results the States will find beneficial in developing their regional haze 

implementation plans. Any State choosing not to follow the recommendations of a regional body 

would need to provide a specific technical basis that its strategy nonetheless provides for 

reasonable progress based on the statutory factors. At the same time, we cannot require States 

to participate in regional planning efforts if the State prefers to develop a long-term strategy on 

its own. We note that any State that acts alone in this regard must conduct the necessary 

technical support to justify their apportionment, which generally will require regional 
21

inventories and a regional modeling analysis. Additionally, any such State must consult with 

other States before submitting its long-term strategy to us.

Consequently, because Oklahoma accepted and incorporated the CENRAP-developed visibility 

modeling into its RH SIP, which assumed controls for the six units discussed above that were not 

subsequently secured, we propose to disapprove Oklahoma’s long term strategy. 

However, our proposed FIP does include controls for the six units that at least achieve the level 

of control assumed in the CENRAP modeling. In addition, as described above, Oklahoma has 

required controls on additional sources as part of its BART evaluation. Therefore, we propose 

to find that with the addition of our proposed FIP, the requirements in section 51.308(d)(3)(i) 

and(ii) have been met.

D.3 Technical Basis for the Long Term Strategy: 40 CFR 51.308(d)(3)(iii) – (iv)

Oklahoma must document the technical basis, including modeling, monitoring and emissions 

information, on which the State is relying to determine its apportionment of emission reduction 

obligations necessary for achieving reasonable progress in each mandatory Class I Federal area it 

affects. It may meet this requirement by relying on technical analyses developed by the regional 

planning organization and approved by all State participants. Oklahoma must identify the 

baseline emissions inventory on which its strategies are based. The baseline emissions inventory 

year is presumed to be the most recent year of the consolidated periodic emissions inventory.

Oklahoma must also identify all anthropogenic sources of visibility impairment considered by 

the State in developing its long-term strategy. It should consider major and minor stationary 

sources, mobile sources, and area sources. The following discussion of emission inventories for 

the 2002 base and 2018 future year, 2002 and 2018 photochemical modeling results, and our 

review of the results is a brief summary of the work that was done and our conclusions. For a 

more detailed discussion of the technical analyses including the photochemical modeling and our 

review and conclusions, see Appendix A.

State Submittal

1. Emissions Inventory

Pages 37 – 68

Oklahoma met the requirements of Sections 51.308(d)(3)(iii) – (iv) mainly by relying on 

technical analyses developed by CENRAP and approved by all State participants. The emissions 

inventory used in the regional haze technical analyses was developed by CENRAP with 

assistance from Oklahoma. The 2018 emissions inventory was developed by projecting 2002 

emissions and applying reductions expected from federal and state regulations affecting the 

emissions of the visibility-impairing pollutants NOx, PM, SO2,, and VOCs. The BART Guidelines 

direct states to exercise judgment in deciding whether VOCs and NH3 impair visibility in their 
22

Class I area(s). 70 FR 391160. As discussed further in section V.C.3, CENRAP performed 

modeling sensitivity analyses and/or other analyses, which demonstrated that anthropogenic 

emissions of VOC and NH3 do not significantly impair visibility in the CENRAP region. 

Therefore, Oklahoma did not consider ammonia among visibility-impairing pollutants and did 

not further evaluate NH3 and VOC emissions sources for potential controls under BART or 

reasonable progress.

a. Oklahoma’s 2002 Emission Inventory

ODEQ and CENRAP developed an emission inventory for five inventory source 

classifications: point, area, non-road and on-road mobile sources, and biogenic sources for the 

baseline year of 2002. State, tribal, and local agencies submitted information to the national 

emissions inventory for 2002 which formed the basis of the CENRAP emissions inventory. A 

CENRAP contractor supplemented this inventory with non-point source inventories developed 

for CENRAP. These CENRAP-specific inventories addressed agricultural and prescribed 

burning, on-road and non-road mobile sources, agricultural tilling and livestock dust, and 

agricultural ammonia. For point source emissions, ODEQ rule OAC 252:100-5 requires 

individually permitted point sources to submit an annual emissions inventory, which was 

submitted the data to us as part of the 2002 national emissions inventory. A CENRAP contractor 

provided further refinement. The area-source inventory for 2002 used EPA-provided estimates 

for area-source emissions as a starting point, with refinement from ODEQ and CENRAP. 

ODEQ developed an oil and gas area-source emissions inventory, using county-level oil and gas 

production data from the Oklahoma Corporation Commission and the Oklahoma Tax 

Commission. Emissions calculation methods developed by the Texas Commission on 

Environmental Quality were applied to these data. ODEQ also developed area-source emissions 

estimates for gasoline distribution sources, dry cleaners, and wildfires, using the factors from 

emissions inventory improvement program and county-level activity data for Oklahoma. A 

CENRAP contractor consolidated the area-source inventories from these various inventory 

sources, conducted additional quality assurance, and worked with ODEQ to revise this 

consolidated inventory. Another CENRAP contractor removed selected sources from the 

consolidated area inventories to process them as separate subcategories to allow specialized 

processing to facilitate particulate source apportionment within the Comprehensive Air Quality 

Model with extensions (CAMx) model. To enhance accuracy of transportable dust estimates, the 

contractor also applied road and fugitive dust transport factors3to appropriate area source 

emissions. ODEQ and CENRAP developed the on-road mobile source emissions inventory for 

2002 with contractor support on a county basis. CENRAP contractors used our NONROAD 

model to prepare and develop broad emissions estimates for the non-road mobile source 

inventory generated the non-road emissions inventory. A CENRAP contractor ran our Biogenic 

Emissions Inventory System 3 (BEIS3) model to generate a biogenic emissions inventory. 

Oklahoma’s 2002 emissions inventory is summarized in Table 2:

 

3

 Using Methodology to Estimate the Transportable Fraction of Fugitive Dust Emissions for Regional and Urban 

Scale Air Quality Analyses, Thompson G. Pace, US EPA (8/3/2005 Revision), available at 

http://www.epa.gov/ttn/chief/emch/dustfractions/transportable_fraction_080305_rev.pdf
23

Table 2. Oklahoma’s 2002 Emissions Inventory

SO2 NH3 NOx VOCs PM10-

PM2.5 PM2.5

Point 148,761 24,102 158,818 37,794 8,026 8,636

Area 11,779 114,363 115,407 201,758 304,560 109,279

Non-road 

mobile

4,773 280 49,396 47,863 433 4,580

On-road 

mobile

4,708 4,434 142,592 99,924 879 2,459

Biogenic 0 0 35,909 988,314 0 0

Total 170,021 143,179 502,122 1,375,653 313,898 124,954

b. Oklahoma’s 2018 Emission Inventory

In general. ODEQ used a combination of our Economic Growth Analysis System (EGAS 

5), our mobile emissions model (MOBILE 6), our off-road emissions factor model (NONROAD), 

and the Integrated Planning Model (IPM) for electric generating units. ODEQ modified the 

projected emissions from the IPM modeling for OG&E Sooner and Muskogee electric power 

plants and the PSO Northeast electric power plants to reflect the application of presumptive 

BART controls.4 

More specifically, CENRAP developed emissions for five inventory source 

classifications: point, area, non-road and on-road mobile sources, and biogenic sources. 

CENRAP used its 2002 emission inventory, described above, to estimate emissions in 2018. 

CENRAP contractors, with input from us, compiled the growth and control assumptions and 

factors used to estimate point-source emissions in 2018 from the inventory for 2002. This 

included EGUs, internal combustion engines and other non-EGU point sources. CENRAP states 

provided data for the area source and non-road mobile emissions inventory for 2018, to which a 

CENRAP contractor applied area source growth and control factors. Similarly, CENRAP states 

provided data for the emissions inventory for 2018, to which a CENRAP contractor applied 

source growth and control factors for locomotives, aircraft, and commercial marine vessels. 

These control factors accounted for federal standards for commercial marine vessels and 

locomotives. For the remaining non-road mobile categories, the contractor ran our

NONROAD2004 model for 2018. This accounted for estimated growth in equipment populations 

and incorporated anticipated effects of most final federal standards, including the Tier 4 

compression-ignition engine standards and the exhaust emissions standards for large sparkignition engines, compression-ignition marine engines, and land-based recreational engines. 

ODEQ and CENRAP also developed the on-road mobile source emissions inventory for 2018 

with contractor support. Biogenic emissions were held constant from the 2002 emission 

 

4

 Note, our proposed FIP, discussed in section V.E, would require a stricter level of SO2 for six units in these 

facilities.
24

inventory. Oklahoma’s 20018 emissions inventory is summarized in Table 3:

Table 3. Oklahoma’s 2018 Emissions Inventory

SO2 NH3 NOx VOCs PM10-

PM2.5 PM2.5

Point 106,701 35,215 140,298 125,648 8,935 13,989

Area 12,374 141,532 128,257 400,056 275,844 127,018

Non-road 

mobile 156 40 25,387 28,489 2,914 292

On-road 

mobile 545 5,818 39,397 39,281 0 953

Biogenic 0 0 35,909 988,314 0 0

Total 119,776 182,605 369,248 1,581,788 287,693 142,252

CENRAP and ODEQ used this and other state’s 2018 emission inventories to construct 

visibility projection modeling for 2018. We find ODEQ’s 2018 emission inventory to be 

acceptable. 

2. Visibility Projection Modeling

Pages 48-68

Sections A through E of Chapter V of the ODEQ Regional Haze SIP discuss the modeling 

methods and protocol used by CENRAP and ODEQ in developing the assessment. Chapter IV 

describes the baseline emission inventory used in the Oklahoma analysis and submitted as 

Appendix 4-1 of the ODEQ RH SIP. A detailed description and discussion of the model 

selection, modeling protocol, quality assurance, performance evaluation, emission inventory 

development and data used in the regional haze analysis can be found in Appendix A and 

references therein. A short summary is provided below:

CENRAP performed modeling for the regional haze LTS for its member states, including 

Oklahoma. The modeling analysis is a complex technical evaluation that began with selection of 

the modeling system. CENRAP used the following modeling system:

Meteorological Model: The Pennsylvania State University/National Center for 

Atmospheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5) is a 

nonhydrostatic, prognostic meteorological model routinely used for urban- and regionalscale photochemical, PM2.5, and regional haze regulatory modeling studies.

Emissions Model: 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 mobile, area, point, fire and biogenic emission sources for 

photochemical grid models.
25

Air Quality Model: EPA’s Models-3/ Community Multiscale Air Quality (CMAQ) 

modeling system is a photochemical grid model capable of addressing ozone, PM, 

visibility and acid deposition at a regional scale. The photochemical model selected for 

this study was CMAQ version 4.5. It was modified through CENRAP with a module for 

Secondary Organics Aerosols (SOA) in an open and transparent manner that was also 

subjected to outside peer review. The Comprehensive Air Quality Model with extensions 

(CAMx) Version 4.40 model, applied using similar options as used by CMAQ, was used 

as a secondary corroborative model. CAMx was also utilized with its Particulate Source 

Apportionment Technology (PSAT) tool to provide source apportionment of predicted 

nitrate and sulfate aerosol concentrations. 

CMAQ and CAMx modeling of regional haze in the CENRAP region for 2002 and 2018 was 

carried out on a grid of 36x36 kilometer (km) cells that covers the continental United States, 

portions of Canada and Mexico, and portions of the Atlantic and Pacific Oceans along the east 

and west coasts. Selection of a representative period of meteorology is crucial for evaluating 

baseline air quality conditions and projecting future changes in air quality due to changes in 

emissions of visibility-impairing pollutants. CENRAP conducted an in-depth analysis which 

resulted in the selection of the entire year of 2002 (January 1-December 31) as the best period of 

meteorology available for conducting the modeling. The CENRAP modeling was developed 

consistent with our guidance.5

CENRAP examined the model performance of the regional modeling for the areas of interest 

before determining whether the CMAQ model results were suitable for use in the regional haze 

assessment of the LTS and for use in the modeling assessment. The modeling assessment 

predicts future levels of emissions and visibility impairment used to support the LTS and to 

compare predicted, modeled visibility levels with those on the URP. In keeping with the 

objective of the CMAQ modeling platform, the air quality model performance was evaluated 

using graphical and statistical assessments based on ambient measurements of PM species,

gas-phase species and wet deposition from various monitoring networks and databases for the 

2002 base year. CENRAP used a diverse set of statistical parameters from our Modeling 

Guidance to stress and examine the model and modeling inputs. Once CENRAP determined the 

model performance to be acceptable, CENRAP used the model to assess the 2018 RPGs using 

the current and future year air quality modeling predictions, and compared the RPGs to the 

URP. Table 4 summarizes the projected contribution from Oklahoma emissions on visibility 

degradation at Class I areas for the 20 percent worst days in 2018. Note, this table only 

includes contributions of 0.15 deciviews or greater.

 

5

 Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for 

Ozone, PM2.5, and Regional Haze, (EPA-454/B-07-002), April 2007, located at 

http://www.epa.gov/scram001/guidance/guide/final-03-pm-rh-guidance.pdf

 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air 

Quality Standards (NAAQS) and Regional Haze Regulations, August 2005, updated November 2005 (―our

Modeling Guidance‖), located at http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html, EPA-454/R-05-001
26

Table 4. Projected Contribution from Oklahoma Emissions on Visibility Degradation for 

the 20 Percent Worst Days in 2018

Class I area State

Contribution

to light

Extinction

(Mm-1)

Total light

Extinction

(Mm-1)

Oklahoma

contribution

(Percent)

Deciview

contribution

Wichita

Mountains Oklahoma 12.28 86.56 14.19% 1.53

HerculesGlades Missouri 3.74 103.49 3.61% 0.37

Salt Creek New

Mexico 1.46 57.67 2.53% 0.26

Caney Creek Arkansas 2.23 96.84 2.30% 0.23

Upper 

Buffalo Arkansas 1.97 97.16 2.03% 0.21

Guadalupe

Mountains Texas 1.11 55.43 2.00% 0.20

Seney Michigan 1.74 95.27 1.83% 0.18

White

Mountain

New

Mexico 0.69 40.8 1.70% 0.17

Isle Royale Michigan 1.08 73.71 1.46% 0.15

This modeling indicates that emissions from Oklahoma contribute a small amount to visibility 

degradation at Class I areas in other states. In fact, this modeling indicates that Oklahoma’s 

emissions are responsible for 3.61% or less to the visibility degradation at all other Class I 

areas other than the Wichita Mountains. This informed ODEQ’s LTS and its state consultations. 

EPA Findings

We find ODEQ’s 2002 and 2018 emission inventory and the visibility projection modeling to be 

acceptable. We find that Oklahoma has adequately documented the technical basis, including 

modeling, monitoring, and emissions information, on which it relied upon to determine its 

apportionment of emission reduction obligations necessary for achieving reasonable progress in 

each mandatory Class I Federal area it affects. We also find that Oklahoma has adequately 

identified all anthropogenic sources of visibility impairment considered by it in developing its 

LTS. We therefore find that ODEQ has satisfied this requirement.
27

D.4 Consideration of Long Term Strategy Factors: 40 CFR 51.308(d)(3)(v)

Oklahoma must consider, at a minimum, the following factors in developing its long-term 

strategy:

(A) Emission reductions due to ongoing air pollution control programs, including 

measures to address reasonably attributable visibility impairment; 

(B) Measures to mitigate the impacts of construction activities; 

(C) Emissions limitations and schedules for compliance to achieve the reasonable 

progress goal; 

(D) Source retirement and replacement schedules;

(E) Smoke management techniques for agricultural and forestry management 

purposes including plans as currently exist within the State for these purposes;

(F) Enforceability of emissions limitations and control measures; and 

(G) The anticipated net effect on visibility due to projected changes in point, area, and 

mobile source emissions over the period addressed by the long-term strategy.

State Submittal

Pages 86-91, 114. Appendices 1-1, 6-1

In addition to its BART determinations and by extension our proposed FIP, Oklahoma’s LTS 

incorporates emission reductions due to a number of ongoing air pollution control programs. 

This includes enforceable emissions limitations, compliance schedules, administrative orders, 

the issuance and enforcement of permits limiting emissions from all known major sources in 

Oklahoma, state rules which specifically limit targeted emissions sources and categories, and 

several other ongoing air pollution control programs. ODEQ has promulgated rules in order to 

administer these programs. These rules govern ODEQ’s permitting process, including PSD, 

BACT and BART requirements, and implementation of federal requirements. ODEQ also has 

promulgated rules that limit emissions in order to comply with the National Ambient Air Quality 

Standards, which have ancillary visibility improving benefits. Other air pollution control 

programs, including federal mobile emissions programs, the Clean Air Interstate Rule, 

Maximum Achievable Control Technology, and Refinery Consent Decrees are implemented by 

ODEQ, which similarly have ancillary visibility improving benefits. 

ODEQ addresses the long term strategy factors in 40 CFR 51.308(d)(3)(v)(A)-(G) as follows:

(A) Emission reductions due to ongoing air pollution control programs, including measures 

to address reasonably attributable visibility impairment
28

ODEQ points out that since Oklahoma attains all national ambient air quality standards, 

it has not implemented many ongoing pollution-control programs beyond those required 

under federal regulations. These rules include motor vehicle emissions control 

programs, CAIR, and EPA requirements for cleaner non-road diesel and gasolinepowered engines. ODEQ’s rules under the Oklahoma Administrative Code (OAC) that 

limit opacity and particulate matter, sulfate, nitrate, and carbon emissions from point 

and area sources include:

OAC 252:100-7, Permits for Minor Facilities, applies to permitted and 

unpermitted minor sources.

OAC 252:100-8, Permits for Part 70 Sources, which contains provisions for PSD 

and BART requirements.

OAC 252:100-8, Parts 7 and 9, which are ODEQ’s PSD NSR rules, require the 

application of BACT or Lowest Achievable Emission Rate (LAER) to major new 

and modified point sources of SO2, NOx, VOCs, and particulate matter. 

OAC 252:100-13, Open Burning, prohibits most open burning of refuse and other 

combustible materials.

OAC 252:100-17, 19, 23, 24, and 25 limits particulate matter and/or opacity of 

emissions from incinerators; fuel-burning units and industrial processes; cotton 

gins; fugitive dust from grain, feed, and seed operations; smoke, visible 

emissions, and particulates.

OAC 252:100-29, Control of Fugitive Dust, provides control over fugitive dust, 

including the minimization of blowing dust from construction activities.

OAC 252:100-31, Control of Emission of Sulfur Compounds, limits sulfur dioxide, 

hydrogen sulfide, total reduced sulfur compounds, and sulfuric acid from various 

sources, including: petroleum and natural gas related operation processes, pulp 

mills, electric generating units, limekilns, sulfuric acid plants, smelters, and sulfur 

recovery units at petroleum refineries and all other sources.

OAC 252:100-33, Control of Emission of Nitrogen Oxides, controls emissions of 

nitrogen oxides from fuel-burning equipment.

ODEQ administers applicable federal rules, including (1) motor vehicle emissions 

control programs under 40 C.F.R. Parts 80, 81, 86, 89, 90, 92, 94, 1039, and 1048; (2) 

reciprocating internal combustion engines regulation under 40 C.F.R. section 63.6580 et 

seq.; (3) turbine MACT regulations in 40 C.F.R. section 63.6080 et seq.; and (4) the new 

source performance standard for residential wood combustion under 40 C.F.R. Part 60, 

Subpart AAA. Oklahoma has also joined us in refinery consent decrees that result in 

significant SO2 and NOx reductions.

We approved ODEQ’s SIP to address Reasonably Attributable Visibility Impairment 

(RAVI) at the Wichita Mountains on November 8, 1999 (64 FR 60683), The FLMs did 

not identify any integral vistas in Oklahoma. In addition, the Wichita Mountains is not 

experiencing RAVI, nor are any Oklahoma sources affected by the RAVI provisions. 

Therefore, the Oklahoma RH SIP does not incorporate any measures to specifically 

address RAVI. .
29

(B) Measures to mitigate the impacts of construction activities

We note that fine and coarse particulate, of which construction-related activities are 

thought to be a small contributor, are themselves minor contributors to visibility 

impairment at the Wichita Mountains. ODEQ relies on fugitive dust control rules in 

OAC 252:100-29 to control and minimize dust from construction activities.

(C) Emissions limitations and schedules for compliance to achieve the reasonable progress 

goal

ODEQ implements an air permitting program that includes the issuance of permits to all 

known major point sources in Oklahoma. Each permit contains enforceable limitations 

on emissions of various pollutants, some of which may cause or contribute to regional 

haze at the Wichita Mountains. Unless permits specify a different schedule for 

compliance, ODEQ requires permitted sources to comply with their permits immediately 

upon issuance. ODEQ also enforces compliance schedules of relevant administrative and 

judicial orders, including consent decrees. ODEQ also enforces compliance schedules of 

relevant administrative and judicial orders, including consent decrees.

We and ODEQ have entered into refinery consent decrees with Sinclair Oil, Valero 

Refining, Sunoco Refinery, and Conoco, Inc. that include SO2 and NOx reductions. 

CENRAP modeling in support of this SIP included these reductions. These enforceable 

consent decrees include compliance schedules.

(D) Source retirement and replacement schedules

ODEQ considered source retirement and replacement schedules in developing its longterm strategy of emissions reductions. ODEQ took the position that it could not reliably 

predict the retirement or replacement of sources and did not rely on source retirement to 

achieve any reasonable progress goal. 

(E) Smoke management techniques for agricultural and forestry management purposes 

including plans as currently exist within the State for these purposes;

Fires are responsible for much of the directly emitted fine particulate matter in the 

Oklahoma emissions inventory. ODEQ considered smoke management techniques for 

the purposes of agricultural and forestry management in its LTS. OAC 252:100-13 

includes provisions regulating the burning of forestland, cropland, and rangeland. As 

Tables IV-1 and IV-2 in the Oklahoma RH SIP revision submittal indicate, all types of 

fire sources (wildfire, agricultural burning, rangeland burning, etc.) are responsible for 

approximately 4.2% of the total SO2, 4.1% of the total NH3, 3.9% of the total NOx, 2.1 % 

of the total VOCs, and 3.6% of the total PM10 emissions. In contrast, fire is responsible 

for about 33.4% of the total PM2.5 emissions. However, Table VIII-3 of the Oklahoma 

RH SIP indicates that all Oklahoma area sources combined, of which fire is only a part, 

account for less than 1% of the total visibility impact at the Wichita Mountains. 

Nevertheless, ODEQ states that it and the Oklahoma Department of Agriculture, Food, 
30

and Forestry intend to create a basic, voluntary smoke management program based on 

our Interim Air Quality Policy on Wildland and Prescribed Fires.

(F) Enforceability of emissions limitations and control measures

ODEQ has adopted rules to ensure the enforceability of these emission limitations. This 

includes rules that govern ODEQ’s permitting process for major and minor sources, 

Prevention of Significant Deterioration (PSD) provisions, Best Available Control 

Technology (BACT), and BART requirements. ODEQ issues permits to all major and 

minor point sources in Oklahoma, and each permit contains enforceable limitations on 

emissions of various pollutants, including those which cause or contribute to RH at the 

Wichita Mountains. Unless those permits specify a different schedule for compliance, 

ODEQ requires permitted sources to comply with their permits immediately upon 

issuance. ODEQ also enforces compliance schedules of relevant administrative and 

judicial orders, including consent decrees that result in significant SO2 and NOx 

reductions. ODEQ has committed to issuing enforceable Part 70 air quality permits 

requiring BART-eligible sources subject to BART to install BART and achieve the 

associated BART emission limits. Subject sources must achieve the BART emission limits 

referenced above within five years of our approval the SIP. Section 51.308(e)(1)(iv). 

Furthermore, the emission limitations we propose to require under our FIP are 

“applicable federal requirement[s]” under the CAA, and thus must be incorporated in 

those facilities’ Title V operating permits.

ODEQ has the statutory authority to carry out all “duties, requirements, and 

responsibilities necessary and proper for the implementation of the Oklahoma Clean Air 

Act and fulfilling the requirements of the Federal Clean Air Act.” 27A O.S. § 2-5-

105(22). This authority includes “sole environmental jurisdiction to regulate air 

emissions from all facilities and sources subject to operating permit requirements under 

Title V of the Federal Clean Air Act as amended.” 27A O.S. § 1-3-101(E)(8). The ODEQ 

also has authority to issue and renew air quality permits, see 27A O.S. §§ 2-5-112(B), 2-

5-105(22), and 2-14-202, as well as to reopen and revise existing air quality permits, see 

27A O.S. § 2-5-112(B)(3). It is unlawful for any entity to “operate any new or existing 

source of air contaminants except in compliance with a permit issued by the [ODEQ].” 

27A O.S. § 2-5-112(A); see also OAC 252:100-8-1.3.

(G) The anticipated net effect on visibility due to projected changes in point, area, and mobile 

source emissions over the period addressed by the long-term strategy.

As described above, CENRAP used its 2002 emissions inventory as the starting point for 

its 2018 emissions inventory. The 2018 emissions inventory was designed to capture the 

anticipated changes in point, area, and mobile sources emissions over the period 

addressed by the long term strategy. ODEQ assumed in the visibility projection 

modeling summarized above that Units 4 and 5 of the OG&E Muskogee plant, Units 1 

and 2 of the OG&E Sooner plant, and Units 3 and 4 of the AEP/PSO Northeastern 

plants, would be controlled at presumptive SO2 BART levels, when in fact, ODEQ found 

that SO2 BART was no control. This assumption of these units being controlled is 
31

partially responsible for the low projected influence of Oklahoma’s emissions on the 

visibility of Class I areas outside of the state. As we are remedying that flaw through our 

proposed FIP, we find ODEQ’s visibility projection modeling to be acceptable, and that 

ODEQ properly considered the anticipated net effect on visibility due to projected 

changes in point, area, and mobile source emissions over the period addressed by the 

long-term strategy, required by section 51.308(d)(3)(v)(G).

EPA Findings

We find that with the addition of the controls included under our proposed FIP, the ODEQ has 

adequately addressed factors A - G of 51.308(d)(3)(v) in developing its long-term strategy.

E. Monitoring Strategy/Other SIP Requirements 40 CFR 51.308(d)(4)

Oklahoma must submit with the SIP a monitoring strategy for measuring, characterizing, and 

reporting of regional haze visibility impairment that is representative of all mandatory Class I 

Federal areas within it. This monitoring strategy must be coordinated with the monitoring 

strategy required in section 51.305 for reasonably attributable visibility impairment. Compliance 

with this requirement may be met through participation in the Interagency Monitoring of 

Protected Visual Environments network. The SIP must also provide for the following: 

(i) The establishment of any additional monitoring sites or equipment needed to 

assess whether reasonable progress goals to address regional haze for all 

mandatory Class I Federal areas within Oklahoma are being achieved.

(ii) Procedures by which monitoring data and other information are used in 

determining the contribution of emissions from within Oklahoma to regional haze 

visibility impairment at mandatory Class I Federal areas both within and outside 

the State.

(iii) For a State with no mandatory Class I Federal areas, procedures by which 

monitoring data and other information are used in determining the contribution of 

emissions from within the State to regional haze visibility impairment at 

mandatory Class I Federal areas in other States.

(iv) The SIP must provide for the reporting of all visibility monitoring data to the 

Administrator at least annually for each mandatory Class I Federal area in the 

State. To the extent possible, Oklahoma should report visibility monitoring data 

electronically.

(v) A statewide inventory of emissions of pollutants that are reasonably anticipated to 

cause or contribute to visibility impairment in any mandatory Class I Federal area. 

The inventory must include emissions for a baseline year, emissions for the most 

recent year for which data are available, and estimates of future projected 
32

emissions. The State must also include a commitment to update the inventory 

periodically.

(vi) Other elements, including reporting, recordkeeping, and other measures, 

necessary to assess and report on visibility.

State Submittal

Pages 8-10, 119

Section 51.308(d)(4) requires the SIP contain a monitoring strategy for measuring, 

characterizing, and reporting of regional haze visibility impairment that is representative of all 

mandatory Class I Federal areas within the State. This monitoring strategy must be coordinated 

with the monitoring strategy required in Section 51.305 for reasonably attributable visibility 

impairment. As Section 51.308(d)(4) notes, compliance with this requirement may be met 

through participation in the IMPROVE network, which applies to the monitor at the Wichita

Mountains. ODEQ stated its intention to rely on the IMPROVE network for complying with the 

regional haze monitoring requirement in our RHR for the current and future regional haze 

implementation periods. The primary monitoring network for regional haze in CENRAP is the 

Interagency Monitoring of Protected Visual Environments (IMPROVE) network. FLMs 

responsible for Class I areas joined us in 1985 in response to the 1977 CAA Amendments to form 

the IMPROVE Program. The IMPROVE Steering Committee consists of representatives from 

the FLMs, us, and regional-state agencies At the direction of the National Park Service, the 

Cooperative Institute for Research in the Atmosphere, at Colorado State University’s Foothills 

Campus in Fort Collins, Colorado, maintains the network plan on the IMPROVE Internet Web 

site.6 The primary objectives of the IMPROVE Web site are to provide federal, state, and air 

quality regulatory agencies as well as the general public access to IMPROVE data, data 

products, and metadata fully describing the IMPROVE database, including characteristics and 

history of all network sites. The Web site allows users to query data, review reports, and 

communicate with different members of the IMPROVE Program.

Section 51.308(d)(4)(i) requires the establishment of any additional monitoring sites or 

equipment needed to assess whether reasonable progress goals to address regional haze for all 

mandatory Class I Federal areas within the State are being achieved. Shortly after the creation 

of CENRAP, its monitoring workgroup noted the lack of a representative monitor for the Wichita 

Mountains. At that time, an IMPROVE site for Upper Buffalo, Arkansas, in a wetter climate 

several hundred miles to the east-northeast, provided the closest available visibility monitoring 

data. Because this monitoring data was deemed unrepresentative, a particle sampler monitor 

was established at the Wichita Mountains and began operating in March, 2001. As described in 

section III.C.1, above, baseline visibility conditions were calculated using data representative of 

2002-2004 due to lack of data from previous years.

Section 51.308(d)(4)(ii) requires that ODEQ establish procedures by which monitoring data and 

other information are used in determining the contribution of emissions from within Oklahoma 

to regional haze visibility impairment at mandatory Class I Federal areas both within and 

 

6

 http://vista.cira.colostate.edu/improve/
33

outside the State. The monitor at the Wichita Mountains is operated by Wichita Mountains

personnel. Under IMPROVE protocol, the Wichita Mountains personnel send filter modules for 

analysis to the Crocker Nuclear Laboratory at the University of California in Davis every 

Tuesday. The modules collect 24-hour samples every third calendar day. The IMPROVE 

program makes data available on the Internet via the site noted above and submits them to our

air quality system. This information is used to characterize the visibility at the Wichita 

Mountains and assess Oklahoma’s progress toward its RPG. The IMPROVE monitoring 

program is national in scope, and other states have similar monitoring and data reporting 

procedures, ensuring a consistent and robust monitoring data collection system. 

Section 51.308(d)(4)(iv) requires that the SIP must provide for the reporting of all visibility 

monitoring data to the Administrator at least annually for each mandatory Class I Federal area 

in the State. To the extent possible, Oklahoma should report visibility monitoring data 

electronically. Section 51.308(d)(4)(vi) also requires that ODEQ provide for other elements, 

including reporting, recordkeeping, and other measures, necessary to assess and report on 

visibility. Again, Oklahoma’s participation in the IMPROVE network ensure the monitoring 

data is reported at least annually and is available for download from the site referenced above.

Section 51.308(d)(4)(iv) requires that ODEQ maintain a statewide inventory of emissions of 

pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any 

mandatory Class I Federal area. The inventory must include emissions for a baseline year, 

emissions for the most recent year for which data are available, and estimates of future projected 

emissions. The State must also include a commitment to update the inventory periodically. 

Please refer to section III.D, above, where we discuss how ODEQ has constructed its emission 

inventory. ODEQ has stated on page 119 of its RH SIP that it intends to update the Oklahoma 

statewide emissions inventories periodically and review periodic emissions information from 

other states and future emissions projections.

EPA Findings

We find that ODEQ has satisfied the requirements of section 51.308(d)(4).

F. Best Available Retrofit Technology (BART) Requirements: 40 CFR 51.308(e)

Best Available Retrofit Technology (BART) requirements for regional haze visibility 

impairment. Oklahoma must submit a SIP containing emission limitations representing BART 

and schedules for compliance with BART for each BART eligible source that may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I 

Federal area, unless it demonstrates that an emissions trading program or other alternative will 

achieve greater reasonable progress toward natural visibility conditions.

Notes: The evaluation of whether the RH SIP contains ―adequate emission limitations 

representing BART and schedules for compliance with BART for each BART eligible 

source that may reasonably be anticipated to cause or contribute to any impairment of 
34

visibility in any mandatory Class I Federal area‖ is conducted within each BART 

evaluation in Sections III.F.2.1 to III.F.2.7.

40 CFR 51.308(e)(2) – (3) concerning the use of a trading program or other alternative to 

BART are not applicable to this SIP.

F.1. BART Eligible Source Identification: 40 CFR 51.308(e)(1)(i)

Oklahoma must submit a SIP containing a list of all BART-eligible sources within the State.

Note: This section is intended to cover the general question of whether the state identified which 

sources were subject to BART. Subsequent sections treat this determination in more detail.

State Submittal

Pages, 69-71

Oklahoma’s BART rule, OAC 252:100-8, Part 11, and companion definitions related to the 

BART rule added as OAC 252:100-8.1.1, implement the BART requirements of ODEQ’s regional 

haze rule. The Oklahoma BART rule sets out the criteria for identifying BART-eligible sources 

and incorporates by reference the guidelines contained in Appendix Y to 40 C.F.R. Part 51.

These rules can be found in Appendix 6-1. ODEQ identified sources that were BART eligible if 

they:

1. Belonged to one of the twenty-six BART categories listed below;

2. Did not operate before 7 August 1962 but were in existence on 7 August 1977; and 

3. Had the potential to emit 250 tons per year or more of any visibility-impairing pollutant.

ODEQ determined that the visibility-impairing pollutants in Oklahoma include sulfur dioxide 

(SO2), nitrogen oxides (NOx), and particulate matter (PM10 and PM2.5). ODEQ determined 

using CENRAP modeling including source apportionment techniques and an evaluation of 

monitoring data that anthropogenic VOCs do not significantly impair visibility at the Wichita 

Mountains. Because of the uncertainties in assessing the effect of ammonia emissions reductions 

on visibility and review of modeling an monitoring data, Oklahoma decided to not consider 

ammonia among visibility-impairing pollutants. 

ODEQ initially determined which sources were BART eligible by screening its emissions 

inventory and permitting database to identify major facilities with emission units in one or more 

of the 26 BART categories:

1. Fossil-fuel fired steam electric plants of more than 250 million British thermal 

units (BTU) per hour heat input,

2. Coal cleaning plants (thermal dryers),

3. Kraft pulp mills,

4. Portland cement plants,

5. Primary zinc smelters,
35

6. Iron and steel mill plants,

7. Primary aluminum ore reduction plants,

8. Primary copper smelters,

9. Municipal incinerators capable of charging more than 250 tons of refuse per day,

10. Hydrofluoric, sulfuric, and nitric acid plants,

11. Petroleum refineries,

12. Lime plants,

13. Phosphate rock processing plants,

14. Coke oven batteries,

15. Sulfur recovery plants,

16. Carbon black plants (furnace process),

17. Primary lead smelters,

18. Fuel conversion plants,

19. Sintering plants,

20. Secondary metal production facilities,

21. Chemical process plants,

22. Fossil-fuel boilers of more than 250 million BTUs per hour heat input,

23. Petroleum storage and transfer facilities with a capacity exceeding 300,000 

barrels,

24. Taconite ore processing facilities,

25. Glass fiber processing plants, and

26. Charcoal production facilities.

ODEQ then used its databases and records to identify facilities within these source categories 

with potential emissions of 250 tons per year or more for any visibility-impairing pollutant from 

any unit that was in existence on August 7, 1977 and began operation after August 7, 1962. As 

necessary, ODEQ contacted the sources to obtain or confirm pertinent data and information. 

These emissions units comprise the “BART-eligible sources” listed in Table 5, taken from Table 

VI-1 of the RH SIP:
36

Table 5. Facilities with BART-eligible units in Oklahoma

BART source category Facility name County Number 

of units

Fossil fuel-fired boilers 

of more than 250 

MMBTU/hr heat input

Georgia Pacific Consumer Products 

(formerly Fort James Operating) 

Muskogee Mill

Muskogee 2

Kraft pulp mill International Paper (formerly 

Weyerhaeuser) Valliant Paper Mill McCurtain 4

Hydrofluoric, sulfuric, 

and nitric acid plants 

Koch Nitrogen Enid Plant Garfield 7

Terra International Oklahoma 

Woodward Complex Woodward 11

Terra Nitrogen Partnership 

Verdigris Plant Rogers 12

Petroleum refineries 

Sinclair Oil Tulsa Refinery Tulsa 7

Holly Refining and Marketing 

(formerly Sunoco) Tulsa Refinery Tulsa 25

Wynnewood Refining Garvin 14

Valero Refinery (formerly TPI 

Petroleum Inc) Ardmore Refinery Carter 24

Portland cement plants Lafarge Building Materials Tulsa 

Rogers City Line Rogers 10

Fossil fuel-fired steam 

electric plants of more 

than 250 MMBTU/hr 

heat input 

OG&E Horseshoe Lake Generating 

Station Oklahoma 2

OG&E Muskogee Generating 

Station Muskogee 2

OG&E Seminole Generating Station Seminole 3

OG&E Sooner Generating Station Noble 2

PSO Comanche Power Station Comanche 2

PSO Northeastern Power Station Rogers 3

PSO Riverside Jenks Power Station Tulsa 2

PSO Southwestern Power Station Caddo 1

Western Farmers Electric Coop 

Anadarko Plant Caddo 3

Western Farmers Electric Coop 

Mooreland Station Woodward 3
37

EPA Findings

We find that ODEQ has adequately identified all BART-eligible sources within the State.

F.1.1. BART Sources Exempted Due to Modeling Waivers and Modeling Waivers with

Permit Modifications

State Submittal

Following the identification of those sources which were determined to be BART eligible, 

ODEQ required each sources to perform visibility modeling to determine whether it caused or 

contributed to visibility impairment at any Class I area. Pursuant to federal regulations, states 

have the option of exempting a BART-eligible source from the BART requirements based on 

dispersion modeling demonstrating that the source cannot reasonably be anticipated to cause or 

contribute to visibility impairment in a Class I area. Please see Appendix A for more details of 

how sources were granted waivers by the state and our analysis of this modeling.

Based on the approved BART modeling protocol between CENRAP, EPA, FLM representatives, 

and states participating in CENRAP, Oklahoma granted BART applicability waivers to a number 

of facilities. For sources that utilized BART modeling that did not include the inclusion of 

meteorological observations using the 1st High or maximum value from CALPUFF modeling 

was required to be below 0.5 deciviews to obtain a waiver. For modeling that did include the 

meteorological observations, the 8th High value from CALPUFF modeling was required to be 

below 0.5 deciviews to obtain a waiver. Based on these modeling considerations the state issued

waivers to 11 facilities that are listed in Table 6-2 of Appendix A.

With this initial BART screening modeling, ODEQ also identified three sources with a 

contribution of greater than 0.5 deciviews in visibility impairment that desired to limit their 

emissions in order to avoid a BART determination. These sources were (1) the Georgia Pacific 

Consumer Products LP, Muskogee Mill; (2) the International Paper, Valliant Paper Mill; and (3) 

the Western Farmers Electric Coop (WFEC), Anadarko Plant. As described below, each of these 

facilities then identified reductions in emissions that were subsequently secured through Title V 

permit modifications. Following this, an updated BART modeling analysis, assuming those 

controls were in place, demonstrated a contribution of less than 0.5 deciview of visibility 

impairment under all conditions. 

a. Georgia Pacific Consumer Products LP, Muskogee Mill

The Georgia Pacific, Muskogee Mill has two BART eligible boilers, Boiler B-1 and 

Boiler B-2. Georgia Pacific requested of ODEQ that an enforceable emission limit be imposed 

on Boiler B-1 to maintain emissions below the BART contribution threshold of 0.5 deciviews. 

Where previously Boiler B-1 was permitted to burn either No. 2 fuel oil or natural gas, Boiler B1 is now restricted to burning natural gas, which will reduce its NOx emissions. ODEQ has 

determined that under the Title V operating permit modification, this facility will have a 

visibility impairment contribution of less than 0.5 deciviews at any Class I area, which is below 

the contribution threshold used by ODEQ in their BART analyses. This emission reduction is 

housed in a modification to the facility’s Oklahoma Department of Environmental Quality, Air 
38

Quality Division operating Permit, No. 99-113-TV (M-5), issued January 5, 2011. This permit 

requires that this fuel switch be operational no more than five years following our final action on 

the Oklahoma RH SIP.

b. International Paper, Valliant Paper Mill

The International Paper, Valliant Paper Mill has three BART eligible boilers: EUG D1, 

Bark Boiler ; EUG D2, Power Boiler; and EUG D3, Package Boiler. It also has a BART eligible 

Lime Kiln, EUG E7a. The Valiant Paper Mill has accepted limits on the sulfur content of fuel to 

the Bark and Power boilers in order to reduce its visibility impact. ODEQ has determined that 

following this modification, this facility will have a visibility impairment contribution of less 

than 0.5 deciviews at any Class I area, which is below the contribution threshold used by ODEQ 

in their BART analyses. This emission reduction is housed in a modification to the facility’s 

Oklahoma Department of Environmental Quality, Air Quality Division operating Permit No. 97-

057-TV (M-10), issued March 24, 2010. This permit requires these controls be operational no 

more than five years following our final action on the Oklahoma RH SIP.

c. Western Farmers Electric Coop, Anadarko Plant

The Western Farmers Electric Coop (WFEC), Anadarko facility has three BART eligible 

combine cycle gas turbines, AN-Unit 4, AN-Unit 5, and AN-Unit 6. It also has a BART eligible 

internal combustion engine, AN ENG-1. WFEC has agreed to NOx, SO2, and PM-10 emission 

limits on the combined cycle gas turbines in order to reduce their visibility impact. ODEQ has 

determined that following this modification, this facility will have a visibility impairment 

contribution of less than 0.5 deciviews at any Class I area, which is below the contribution 

threshold used by ODEQ in their BART analyses. This emission reduction is housed in a 

modification to the facility’s Oklahoma Department of Environmental Quality, Air Quality 

Division operating Permit, No. 2005-037-TVR (M-1), issued July 9, 2010. This permit will 

require these controls be operational no more than five years following our final action on the 

Oklahoma RH SIP.

EPA Findings

We find that ODEQ has demonstrated that the modifications proposed in the three plants 

discussed above will result in emission reductions that are adequate to exempt these sources from 

being subject to BART using the 0.5 dv threshold for significant contribution to visibility 

impairment.

F.2. BART Five Factor Determination: 40 CFR 51.308(e)(1)(ii)(A)

For the sources that were not granted waivers ODEQ must make a determination of BART for 

each BART-eligible source in Oklahoma that emits any air pollutant which may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I 

Federal area. All such sources are subject to BART. The determination of BART must be based 

on an analysis of the best system of continuous emission control technology available and 
39

associated emission reductions achievable for each BART-eligible source that is subject to 

BART within the State. In this analysis, Oklahoma must take into consideration the technology 

available, the costs of compliance, the energy and non-air quality environmental impacts of 

compliance, any pollution control equipment in use at the source, the remaining useful life of the 

source, and the degree of improvement in visibility which may reasonably be anticipated to 

result from the use of such technology.

State Submittal

Table 7, adapted from Table VI-4 of the RH SIP, lists all of the sources determined by ODEQ to 

be subject to BART. Of these, the SO2 BART determinations for the Oklahoma Gas and Electric 

(OG&E) Sooner Generating Station Units 1 and 2, the OG&E Muskogee Generating Station

Units 4 and 5, and the American Electric Power/Public Service Company of Oklahoma 

(AEP/PSO) Northeastern Power Station Units 3 and 4 are the subject of our proposed FIP. The 

NOX and PM10 BART determinations for these facilities and the NOx BART determinations 

performed by ODEQ for the remaining facilities listed in Table 6 are evaluated in Sections 

III.F.2.1 – 2.6, below.

Table 6. Sources in Oklahoma required to install BART

Facility Name BART 

Emission 

Units 

Source Category Pollutants 

Evaluated 

OG&E Seminole 

Generating Station 

Units 1, 2, 

and 3 

fossil fuel-fired steam 

electric plants 

NOx 

OG&E Sooner 

Generating Station 

Units 1 

and 2 

fossil fuel-fired steam 

electric plants 

SO2

NOx 

PM10

OG&E Muskogee 

Generating Station 

Units 4 

and 5 

fossil fuel-fired steam 

electric plants 

SO2

NOx 

PM10

AEP/PSO Comanche 

Power Station 

Units 1 

and 2 

fossil fuel-fired steam 

electric plants 

NOx 

AEP/PSO Northeastern 

Power Station 

Unit 2 fossil fuel-fired steam 

electric plants 

NOx 

AEP/PSO Northeastern 

Power Station 

Units 3 

and 4 

fossil fuel-fired steam 

electric plants 

SO2

NOx 

PM10

AEP/PSO Southwestern 

Power Station 

Unit 3 fossil fuel-fired steam 

electric plants 

NOx 
40

EPA Findings

We find that ODEQ has adequately identified all sources subject to BART within the State. For 

each BART determination, except as we note below, we feel ODEQ adequately considered the 

requirements under section 51.308(e)(1)(ii)(A), to consider “the technology available, the costs 

of compliance, the energy and non-air quality environmental impacts of compliance, any 

pollution control equipment in use at the source, the remaining useful life of the source, and the 

degree of improvement in visibility which may reasonably be anticipated to result from the use of 

such technology. We disagree with ODEQ’s SO2 BART determinations for Units 4 and 5 of the 

OG&E Muskogee plant, Units 1 and 2 of the OG&E Sooner plant, and Units 3 and 4 of the 

AEP/PSO Northeastern plants. The SO2 BART determinations for these six units are the subject 

of our proposed FIP.

F.2.1. OG&E Seminole Units 1, 2, and 3 BART Determinations

State Submittal

Pages, 69 - 84, Appendix 6-4.

The OG&E Seminole Units 1, 2 and 3 are BART-eligible sources. These units are gas 

fired boiler with gross outputs of 567 MW each. ODEQ determined that Low NOx Burners 

(LNB) and Over Fire Air (OFA) are technically feasible for all three units. As Seminole Unit 3 

is currently fitted with Flue Gas Recirculation (FGR), ODEQ deemed it technically feasible for 

retrofit to the remaining units. ODEQ also determined that Selective Catalytic Reduction (SCR)

was technically feasible and that Selective Non-Catalytic Reduction (SNCR) was not technically 

feasible. ODEQ evaluated the control effectiveness of these technologies. ODEQ then evaluated 

the impacts, including the costs of compliance, the energy impacts, the non-air quality 

environmental impacts, and the remaining useful life. Lastly, ODEQ performed modeling to 

investigate the visibility impacts. ODEQ found that NOx BART was the installation of LNB with 

OFA and FGR for Units 1, 2, and 3 based on the following conclusions:

The cost of installing SCR on each unit is significantly higher than the cost for 

LNB with OFA and FGR. Additional capital costs for SCR on Units 1-3 are on 

average $89,957,200 per unit. Based on projected actual emissions, SCR could 

reduce overall NOx emissions from Seminole Units 1, 2 and 3 by approximately 

5,513 tpy (compared to combustion controls and flue gas recirculation); however, 

the incremental cost associated with this reduction is approximately $44,534,600 

per year, or $8,078/ton.

The cumulative visibility improvement for SCR, as compared to LNB/OFA and 

FGR across Wichita Mountains and Caney Creek (based on the 98th percentile 

modeled results) was 0.56-0.60 Δdv for all three units.

Installation of new LNB with OFA and FGR was cost effective, with a capital cost 

of $16,977,200 per unit for units 1 and 2 and $9,468,600 for unit 3 and an 
41

average cost effectiveness of $1,554-$2,120 per ton of NOx removed for each unit 

over a twenty year operational life.

Combustion control using the LNB/OFA and FGR do not require non-air quality 

environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) 

and there is minimal energy impact.

NOx control levels on 30-day rolling averages of 0.203 lb/mmBtu for Unit 1, 

0.212 lb/mmBtu for Unit 2 and 0.164 lb/mmBtu for Unit 3 are justified.

Annual NOx emission reductions from new LNB with OFA and FGR on Units 1, 

2, and 3 are 662-1,704 tons for a total annual reduction of 3,998 tons.

As Units 1, 2, and 3 are gas fired, ODEQ determined that SO2 and PM BART for them 

are no additional control. Oklahoma’s BART rule requires each source subject to BART to 

install and operate BART no later than 5 years after we approve this implementation plan 

revision. OAC 252-100-8-75(e). 

EPA Findings

We find that ODEQ adequately determined BART for the Seminole Units 1, 2, and 3.

F.2.2. OG&E Sooner Units 1 and 2 BART Determinations

State Submittal

Pages, 69 - 84, Appendix 6-4.

The OG&E Sooner Units 1 and 2 are BART-eligible sources. Both units are coal fired 

with a gross output of 570 MW. The SO2 BART determinations for Units 1 and 2 are covered 

under our proposed FIP. Therefore, we reviewed ODEQ’s NOx and PM BART determination 

for these units.

ODEQ determined that LNB and OFA are technically feasible for both units. ODEQ 

also determined that SCR was technically feasible and that SNCR was not technically feasible. 

ODEQ evaluated the control effectiveness of these technologies. ODEQ then evaluated the 

impacts, including the costs of compliance, the energy impacts, the non-air quality 

environmental impacts, and the remaining useful life. Lastly, ODEQ performed modeling to 

investigate the visibility impacts. ODEQ found that NOx BART was the installation of LNB with 

OFA for Units 1 and 2, based on the following conclusions:

The cost of installing SCR on each unit is significantly higher than the cost for 

LNB with OFA. Additional capital costs for SCR on Units 1 and 2 are on average 

$192,018,500 per unit. Based on projected emissions, SCR could reduce overall 

NOX emissions from Sooner Units 1 and 2 by approximately 3,226 TPY beyond 
42

combustion controls; however, the incremental cost associated with this reduction 

is approximately $17,795/ton. 

The cumulative visibility improvement for SCR, as compared to LNB/OFA across 

Wichita Mountains and Caney Creek (based on the 98th percentile modeled 

results) was 0.15 Δdv for both units. 

Installation of new LNB with OFA was cost effective, with a capital cost of 

$14,055,900 per unit for units 1 and 2 and an average cost effectiveness of $493-

785 per ton of NOX removed for each unit over a twenty-five year operational 

life.

Combustion control using the LNB/OFA does not require non-air quality 

environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) 

and there is minimal energy impact.

NOx control levels on 30-day rolling averages of 0.15 lb/mmBtu for Unit 1 and 2 

are justified and meet the presumptive limits.

Annual NOx emission reductions from new LNB with OFA on Units 1 and 2 are 

2,664-4,241 tons for a total annual reduction of 6,905 tons based on actual 

emissions from 2004-2006 and projected emissions at maximum heat input and 

90% capacity.

ODEQ considered the addition of fabric filters (baghouses) for PM control on Units 1 

and 2, which are currently equipped with Electrostatic Precipitators (ESPs). ODEQ considered 

fabric filters to be technically feasible. ODEQ then evaluated the additional cost versus the 

increased PM control. ODEQ estimated the cost for fabric filters was $9,324/ton over the 

existing ESP controls. Based on the high cost and the incrementally small improvement in PM 

control, ODEQ determined that PM BART for Units 1 and 2 was the existing ESPs. ODEQ 

specified additional BART emission limitations in lbs/hour and tons/year. Oklahoma’s BART 

rule requires each source subject to BART to install and operate BART no later than 5 years 

after we approve this implementation plan revision. OAC 252-100-8-75(e). 

EPA Findings

EPA reviewed the modeling associated with the NOx and PM BART determinations 

ODEQ made for Units 1 and 2 of the OG&E Sooner plant. ODEQ determined that the 

installation of LNB with OFA to achieve an emission limit of 0.15 lb/mmBTU is NOx BART for 

these units. The BART determination also identified the existing electrostatic precipitators 

(ESP) as PM BART for these units. EPA reviewed ODEQ’s basis for these BART 

determinations, including the costs of compliance, the energy impacts, the non-air quality 

environmental impacts, the remaining useful life and visibility modeling. EPA performed 

additional visibility modeling with CALPUFF that included our proposed SO2 limits in 

combination with ODEQ proposed limits for NOx and PM. This modeling suggests small 

visibility improvements can be expected from also requiring the installation of SCR on these 
43

units. The small visibility improvements achieved are not justified due to the additional cost of 

SCR. See Appendix B for additional information on EPA visibility modeling for these units. 

With the inclusion of the SO2 BART determinations covered in our proposed FIP, we find that 

ODEQ’s BART determinations for NOx and PM for Sooner Units 1 and 2 are adequate.

F.2.3. OG&E Muskogee Units 4 and 5 BART Determinations

State Submittal

Pages, 69 - 84, Appendix 6-4.

The OG&E Muskogee Units 4 and 5 are BART-eligible sources. Both units are coal fired 

with a gross output of 572 MW. The SO2 BART determinations for Units 4 and 5 are covered 

under our proposed FIP. Therefore, we reviewed ODEQ’s NOx and PM BART determination 

for these units.

ODEQ determined that LNB and OFA are technically feasible for both units. ODEQ 

also determined that SCR was technically feasible and that SNCR was not technically feasible. 

ODEQ evaluated the control effectiveness of these technologies. ODEQ then evaluated the 

impacts, including the costs of compliance, the energy impacts, the non-air quality 

environmental impacts, and the remaining useful life. Lastly,ODEQ performed modeling to 

investigate the visibility impacts. ODEQ found that NOx BART was the installation of LNB with 

OFA for Units 4 and 5, based on the following conclusions:

The cost of installing SCR on each unit is significantly higher than the cost for 

LNB with OFA. Additional capital costs for SCR on Units 4 and 5 are on average 

$193,077,000 per unit. Based on projected emissions, SCR could reduce overall 

NOX emissions from Muskogee Units 4 and 5 by approximately 3,456 TPY 

beyond combustion controls; however, the incremental cost associated with this 

reduction is approximately $16,611/ton. 

The cumulative visibility improvement for SCR, as compared to LNB/OFA across 

Wichita Mountains and Caney Creek (based on the 98th percentile modeled 

results) was 0.10 and 0.18 Δdv respectively. 

Installation of new LNB with OFA was cost effective, with a capital cost of 

$14,113,700 per unit for units 4 and 5 and an average cost effectiveness of $260-

$281 per ton of NOx removed for each unit over a twenty-five year operational 

life.

Combustion control using the LNB/OFA does not require non-air quality 

environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) 

and there is minimal energy impact.

NOx control levels on 30-day rolling averages of 0.15 lb/mmBtu for Unit 4 and 5 
44

are justified meet the presumptive limits prescribed by us.

Annual NOx emission reductions from new LNB with OFA on Units 4 and 5 are 

projected to be 2,018-2,469 tons for a total annual reduction of 4,487 tons based 

on actual emissions from 2004-2006 and projected emissions at maximum heat 

input and 90% capacity.

ODEQ considered the addition of fabric filters (baghouses) for PM control on Units 4 

and 5, which are currently equipped with Electrostatic Precipitators (ESPs). ODEQ considered 

fabric filters to be technically feasible. ODEQ then evaluated the additional cost versus the 

increased PM control. ODEQ estimated the cost for fabric filters was $9,324/ton over the 

existing ESP controls. Based on the high cost and the incrementally small improvement in PM 

control, ODEQ determined that PM BART for Units 4 and 5 was the existing ESPs. ODEQ 

specified additional BART emission limitations in lbs/hour and tons/year. Oklahoma’s BART 

rule requires each source subject to BART to install and operate BART no later than 5 years 

after we approve this implementation plan revision. OAC 252-100-8-75(e). 

EPA Findings

EPA reviewed the modeling associated with the NOx and PM BART determinations 

ODEQ made for Units 4 and 5 of the OG&E Muskogee plant. ODEQ determined that the 

installation of LNB with OFA to achieve an emission limit of 0.15 lb/mmBTU is NOx BART for 

these units. The BART determination also identified the existing electrostatic precipitators 

(ESP) as PM BART for these units. EPA reviewed ODEQ’s basis for these BART 

determinations, including the costs of compliance, the energy impacts, the non-air quality 

environmental impacts, the remaining useful life and visibility modeling. EPA performed 

additional CALPUFF visibility modeling that included our proposed SO2 limits in combination 

with ODEQ proposed limits for NOx and PM. This modeling suggests small visibility 

improvements can be expected from also requiring the installation of SCR on these units. The 

small visibility improvements achieved are not justified due to the additional cost of SCR. See 

Appendix B for additional information on EPA visibility modeling for these units. 

 

With the inclusion of the SO2 BART determinations covered in our proposed FIP, we find that 

ODEQ’s BART determinations for NOx and PM for Muskogee Units 4 and 5 are adequate.

.

F.2.4. AEP/PSO Comanche Units 1 and 2 BART Determinations

State Submittal

Pages, 69 - 84, Appendix 6-4.

The AEP/PSO Comanche Units 1 and 2 are BART-eligible sources. These units are gas 

fired turbines with duct burners and heat recovery steam generators with a gross output of 94 

MW each. ODEQ determined that dry LNBs are technically feasible for both units. ODEQ also 
45

accepted AEP/PSO’s explanation that AEP-PSO contends that it is technically infeasible to 

retrofit post combustion SCR NOx control without rebuilding the generating units. ODEQ 

evaluated the control effectiveness of dry LNBs. ODEQ then evaluated the impacts, including 

the costs of compliance, the energy impacts, the non-air quality environmental impacts, and the 

remaining useful life. Lastly, ODEQ performed modeling to investigate the visibility impacts. 

ODEQ found that NOx BART was the installation of LNB for Units 1 and 2, based on the 

following conclusions:

Installation of new DLNB was cost effective, with a capital cost of $34,660,000 

for units 1 and 2 and an average cost effectiveness of $2,600 per ton of NOx 

removed for each unit over a twenty year operational life.

Combustion control using the LNB does not require non-air quality 

environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) 

and there is minimal energy impact.

NOx control levels on 30-day rolling averages of 0.15 lb/mmBtu for Unit 1 and 2 

are justified.

Annual NOx emission reductions from new LNB on Units 1, and 2 are a total of 

1,891 tons.

As Units 1 and 2 are gas fired, ODEQ determined that SO2 and PM BART for them are 

no additional control. Oklahoma’s BART rule requires each source subject to BART to install 

and operate BART no later than 5 years after we approve this implementation plan revision. 

OAC 252-100-8-75(e).

EPA Findings

We find that ODEQ adequately determined BART for the Comanche Units 1 and 2.

F.2.5. AEP/ PSO Northeastern Units 2, 3, and 4 BART Determinations

State Submittal

Pages, 69 - 84, Appendix 6-4.

The AEP/PSO Northeastern Units 2, 3, and 4 are BART-eligible sources. Unit 2 is gas 

fired boiler with a gross output of 495 MW. Units 3 and 4 are coal fired with gross outputs of 

490 MW. The SO2 BART determinations for Units 3 and 4 are covered under our proposed FIP. 

Therefore, we reviewed ODEQ’s NOx and PM BART determination for these units. 

Units 2, 3, and 4 all have first generation Low NOx Burners (LNB) and Over Fire Air 

(OFA). ODEQ considered both combustion and post combustion types of NOx controls. ODEQ 

determined that new LNB and OFA are technically feasible for all three units. ODEQ also 
46

determined that SCR was technically feasible for Units 2, 3 and 4 and that SNCR was technically 

feasible for Units 3 and 4. ODEQ did not make a determination that SNCR was not technically 

feasible for Unit 2, but did not further evaluate it. ODEQ evaluated the control effectiveness of 

these technologies. ODEQ then evaluated the impacts, including the costs of compliance, the 

energy impacts, the non-air quality environmental impacts, and the remaining useful life. Lastly, 

ODEQ performed modeling to investigate the visibility impacts. ODEQ found that NOx BART 

was the installation of LNB with OFA for Units 2, 3, and 4, based on the following conclusions:

The cost of installing SCR on each unit is significantly higher than the cost for 

LNB with OFA. Additional capital costs for SCR on Units 3 and 4 are on average 

$290,000,000. Based on projected emissions, SCR could reduce overall NOx

emissions from Northeast Units 3 and 4 by approximately 4,120 TPY beyond 

combustion controls; however, the incremental cost associated with this reduction 

is approximately $11,013/ton. SCR controls on Unit 2 would result in an 

incremental cost of $13,989. 

The cumulative visibility improvement for SCR, as compared to LNB/OFA across 

Wichita Mountains and Caney Creek (based on the 98th percentile modeled 

results) was 0.10 and 0.18 Δdv respectively. 

Installation of new LNB with OFA was cost effective at an average cost 

effectiveness of $303-313.

Combustion control using the LNB/OFA does not require non-air quality 

environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) 

and there is minimal energy impact.

NOx control levels on 30-day rolling averages of 0.15 lb/mmBtu for Units 3 and 4 

and 0.28 lb/mmBtu on Unit 2 are justified meet the presumptive limits.

For Unit 2, ODEQ determined NOx BART is the retrofitting of new LNB and OFA with 

an emission rate of 0.28 lbs/MMBtu on a 30 day average. The BART Guidelines do not specify a 

presumptive NOx BART limit for gas fired power plants. As Unit 2 is gas fired, ODEQ 

determined that SO2 and PM BART for it is no additional control. 

For Units 3 and 4, ODEQ determined NOx BART is the retrofitting of new LNB and OFA 

with an emission rate of 0.15 lbs/MMBtu on a 30 day average, which meets the BART 

presumptive limit. ODEQ determined PM BART is the existing ESPs with an emission rate of 

0.1 lbs/MMBtu on a 3-hour average. ODEQ considered the addition of fabric filters 

(baghouses) for PM control on Units 3 and 4, which are currently equipped with Electrostatic 

Precipitators (ESPs). ODEQ considered fabric filters to be technically feasible. ODEQ then 

evaluated the additional cost versus the increased PM control. ODEQ estimated the cost for 

fabric filters was $12,565/ton over the existing ESP controls. Based on the high cost and the 

incrementally small improvement in PM control, ODEQ determined that PM BART for Units 3 

and 4 was the existing ESPs.
47

ODEQ specified additional BART emission limitations in lbs/hour and tons/year. 

Oklahoma’s BART rule requires each source subject to BART to install and operate BART no 

later than 5 years after we approve this implementation plan revision. OAC 252-100-8-75(e). 

EPA Findings

EPA reviewed the modeling associated with the NOx and PM BART determinations 

ODEQ made for Units 3 and 4 of the AEP/PSO Northeastern plant. ODEQ determined that the 

installation of LNB with OFA to achieve an emission limit of 0.15 lb/mmBTU is NOx BART for 

these units. The BART determination also identified the existing electrostatic precipitators 

(ESP) as PM BART for these units. EPA reviewed ODEQ’s basis for these BART 

determinations, including the costs of compliance, the energy impacts, the non-air quality 

environmental impacts, the remaining useful life and visibility modeling. EPA performed 

additional CALPUFF visibility modeling that included our proposed SO2 limits in combination 

with ODEQ proposed limits for NOx and PM This modeling suggests small visibility 

improvements can be expected from also requiring the installation of SCR on these units. The 

small visibility improvements achieved are not justified due to the additional cost of SCR. See 

Appendix B for additional information on EPA visibility modeling for these units.

 

With the inclusion of the SO2 BART determinations covered in our proposed FIP, we find that 

ODEQ’s BART determinations for NOx and PM for Northeastern Units 3 and 4 are adequate.

We also find that ODEQ adequately determined BART for Northeastern Unit 2.

F.2.6. AEP/PSO Southwestern Unit 3 BART Determination

State Submittal

Pages, 69 - 84, Appendix 6-4.

The AEP/PSO Southwestern Unit 3 is a BART-eligible source. This unit is a gas fired 

boiler with a gross output of 332 MW. ODEQ determined that LNB and OFA are technically

feasible. ODEQ also determined that SCR was technically feasible. ODEQ did not address the 

feasibility of SNCR. ODEQ evaluated the control effectiveness of the remaining technologies. 

ODEQ then evaluated the impacts, including the costs of compliance, the energy impacts, the 

non-air quality environmental impacts, the remaining useful life, and visibility impacts. ODEQ 

found that NOx BART was the installation of LNB with OFA for Unit 3, based on the following 

conclusions:

The cost of installing SCR on each unit is significantly higher than the cost for 

LNB with OFA. Additional capital costs for SCR on Unit 3 are $65,968,400. 

Based on projected actual emissions, SCR could reduce overall NOx emissions 

from Southwestern Unit 3 by approximately 1,441 tpy (compared to combustion 

controls); however, the incremental cost associated with this reduction is 

approximately $10,281,677 per year, or $6,859/ton. 
48

ODEQ concluded that SCR control may not be as effective on boilers that operate 

as peaking units, as NOx reduction in an SCR is a function of flue gas 

temperature. 

Installation of new LNB with OFA was cost effective, with a capital cost of 

$3,000,000 and an average cost effectiveness of $947 per ton of NOx removed 

over a twenty year operational life.

Combustion control using the LNB/OFA does not require non-air quality 

environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) 

and there is minimal energy impact.

NOx control levels on 30-day rolling averages of 0.45 lb/mmBtu for Unit 3 are 

justified.

Annual actual NOx emission reductions from new LNB with OFA on Unit 3 are 

450 tons.

Due to the relatively high NOx emission rate that ODEQ determined was BART, and the 

fact that it appeared the annual average emissions rates recorded with the Clean Air Markets 

Division indicate that the boiler can currently comply with the standard on an annual average 

basis, we asked for additional information justifying that rate. ODEQ responded with data 

detailing 9 years of emissions versus load data, that indicate that the boiler operates through a 

range where emissions can reach as much as 1.4 lb/MMBtu at full load. ODEQ stated, 

“The vendor guarantee of an expected emissions rate is in reference to the 

highest NOx emissions and the percent reduction “predicted” by the vendor for 

the site specific application. Once in operation, a similar graph of emissions 

versus load would indicate that the boiler would have maximum emissions near 

the 0.45 lbs/MMBtu level rather than annual averages. These new daily and 

annual averages would be expected to be much lower. We are not restricting 

load on the unit and therefore will permit AEP at the maximum emission rate for 

the proposed control technology on this specific boiler.”

After having examined the data, attached to Appendix E, we accept ODEQ’s explanation.

As Unit 3 is gas fired, ODEQ determined that SO2 and PM BART for it are no additional 

control. Oklahoma’s BART rule requires each source subject to BART to install and operate 

BART no later than 5 years after we approve this implementation plan revision. OAC 252-100-

8-75(e). 

EPA Findings

We find that ODEQ adequately determined BART for the AEP/PSO Southwestern Unit 3.
49

ODEQ BART Results and Summary

Table 7, modified from Table VI-12 of the RH SIP, summarizes the NOx reductions 

ODEQ calculated from baseline that result from the NOx BART determinations discussed above. 

Table 8, modified from Table VI-13 of the RH SIP summarizes the NOx BART visibility benefits 

ODEQ calculated as the 3-year average of the modeled visibility improvement at the 98th 

percentile.

Table 7. NOx BART Reductions

Facility Unit

Baseline

Emissions

(lb/MMBTU)

Emissions

Reduction

(tpy)

OG&E Muskogee 4 (coal-fired) 0.495

4,487

OG&E Muskogee 5 (coal-fired) 0.522

OG&E Seminole 1 (gas-fired) 0.339

OG&E Seminole 2 (gas-fired) 0.354 3,998

OG&E Seminole 3 (gas-fired) 0.219

OG&E Sooner 1 (coal-fired) 0.601

6,905

OG&E Sooner 2 (coal-fired) 0.584

PSO Northeastern 2 (gas-fired) 0.71 1,615

PSO Northeastern 3 (coal-fired) 0.536

7,697

PSO Northeastern 4 (coal-fired) 0.491

PSO Southwestern 3 (gas-fired) 0.57 450

PSO Comanche 1 (gas-fired) 0.696

1,891

PSO Comanche 1 (gas-fired) 0.613

Total NOx Reduction 27,043
50

Table 8. NOx BART Visibility Improvements

Facility

Wichita 

Mountains 

(Δ-dv)

Caney 

Creek 

(Δ-dv)

Upper 

Buffalo 

(Δ-dv)

Hercules 

Glades 

(Δ-dv)

Total 

(Δ-dv)

OG&E Muskogee

(coal fired) 0.44 0.77 0.55 0.33 2.09

OG&E Seminole

(gas fired) 0.37 0.25 0.14 0.12 0.88

OG&E Sooner

(coal fired) 0.83 0.38 0.31 0.28 1.80

PSO Northeastern

(gas fired) 0.22 0.40 0.21 0.21 1.04

PSO Northeastern

(coal fired) 0.39 0.64 0.41 0.30 1.74

PSO Southwestern

(gas fired) 1.93 0.14 0.11 0.08 2.26

PSO Comanche

(gas fired) 1.28 0.07 0.06 0.05 1.46

Totals 5.46 2.65 1.79 1.37 11.27

F.3. BART for Larger Fossil Fuel Power Plants: 40 CFR 51.308(e)(1)(ii)(B)

A determination of BART is required for each BART-eligible source in Oklahoma that emits any 

air pollutant which may reasonably be anticipated to cause or contribute to any impairment of 

visibility in any mandatory Class I Federal area. All such sources are subject to BART. The 

determination of BART for fossil-fuel fired power plants having a total generating capacity 

greater than 750 megawatts must be made pursuant to the guidelines in appendix Y of this part 

(Guidelines for BART Determinations under the Regional Haze Rule).

State Submittal

Pages 69 - 85

All the facilities required to install BART that are identified above in Table 6, are fossil-fuel fired 

steam electric generating plants with heat inputs greater than 250-mmBtu/hr, and with a total 

generating capacity in excess of 750 MW. ODEQ has stated it followed the requirements in 

Section 51.308(e)(1)(ii)(B) in preparing the BART determinations for these facilities.

EPA Findings

These BART determinations are covered in Sections III.F.2.1 to III.F.2.6, above. We find that 

except for the SO2 BART determinations for Units 4 and 5 of the OG&E Muskogee plant, Units 1 

and 2 of the OG&E Sooner plant, and Units 3 and 4 of the AEP/PSO Northeastern plants,
51

ODEQ has followed the requirements of Section 51.308(e)(1)(ii)(B) in preparing the BART 

determinations of all of its subject to BART sources. The SO2 BART determinations for these 

facilities are the subject of our proposed FIP.

F.4. De Minimis BART: 40 CFR 51.308(e)(1)(ii)(C)

A determination of BART for each BART-eligible source in Oklahoma that emits any air 

pollutant which may reasonably be anticipated to cause or contribute to any impairment of 

visibility in any mandatory Class I Federal area. All such sources are subject to BART. 

Oklahoma is not required to make a determination of BART for SO2 or for NOx if a BARTeligible source has the potential to emit less than 40 tons per year of such pollutant(s), or for 

PM10 if a BART-eligible source has the potential to emit less than 15 tons per year of such 

pollutant.

State Submittal

ODEQ did not specifically exclude any BART eligible sources under this provision.

F.5. Design, Equipment, or Work Practice BART: 40 CFR 51.308(e)(1)(iii)

If Oklahoma determines in establishing BART that technological or economic limitations on the 

applicability of measurement methodology to a particular source would make the imposition of 

an emission standard infeasible, it may instead prescribe a design, equipment, work practice, or 

other operational standard, or combination thereof, to require the application of BART. Such 

standard, to the degree possible, is to set forth the emission reduction to be achieved by 

implementation of such design, equipment, work practice or operation, and must provide for 

compliance by means which achieve equivalent results.

ODEQ did not prescribe a design, equipment, work practice, or other operational standard, or 

combination thereof, as BART.

F.6. Installation of BART: 40 CFR 51.308(e)(1)(iv) – (v)

Each source subject to BART must (1) install and operate BART as expeditiously as practicable, 

but in no event later than 5 years after approval of the SIP revision, and (2) maintain the control 

equipment required by this subpart and establish procedures to ensure such equipment is 

properly operated and maintained.

State Submittal

Pages 75-76, Appendix 6-1.
52

Oklahoma’s BART Rule, OAC 252:100-8-75(e), requires that “each BART-eligible source 

subject to BART shall install and operate BART no later than five years after EPA approves the 

Oklahoma Regional Haze SIP.” ODEQ has stated on page 87 of the RH SIP that it will issue 

enforceable Part 70 air quality permits requiring BART-eligible sources subject to BART to 

install BART and achieve the associated BART emission within five years of our approval the 

SIP. Furthermore, ODEQ has the authority to administratively and judicially enforce any 

provision of its issued air quality permits. See 27A O.S. §§ 2-5-110, 2-3-502, and 2-3-504.

EPA Findings

We find that ODEQ has demonstrated it has the authority and enforceable mechanisms in place 

to ensure each source subject to BART will (1) install and operate BART as expeditiously as 

practicable, but in no event later than 5 years after approval of the SIP revision, and (2) 

maintain the control equipment required by this subpart and establish procedures to ensure such 

equipment is properly operated and maintained.

F.7. CAIR for BART: 40 CFR 51.308(e)(4)

If Oklahoma chooses to meet the emission reduction requirements of the Clean Air Interstate 

Rule (CAIR) by participating in one or more of the EPA-administered CAIR trading programs 

for SO2 and NOx, it need not require BART-eligible EGUs subject to such trading programs in 

Oklahoma to install, operate, and maintain BART for the pollutants covered by such trading 

programs in it. Oklahoma may choose to participate in the EPA-administered CAIR trading 

programs either by submitting a SIP that incorporates the CAIR model trading rules in part 96 of 

this chapter, and is approved, in accordance with section51.123(o)(1) or (2) (for the NOx annual 

program) and (aa)(1) or (2) (for the NOx ozone season program) and section 51.124(o)(1) or (2) 

(for the SO2 program) or by remaining subject to the Federal implementation plan in part 97 of 

this chapter (which may be modified by a SIP approved in accordance with sections 51.123(p) 

and (ee) and 51.124(r)). If Oklahoma chooses to participate in such trading programs, it may 

also adopt provisions, consistent with such trading programs, for a geographic enhancement to 

the program to address the requirement under section 51.302(c) related to BART for reasonably 

attributable impairment from the pollutants covered by the CAIR cap-and-trade programs.

Note: This provision of the regional haze rule does not apply to Oklahoma since it did not 

participate in the CAIR.

F.8. Reasonable Progress and BART: 40 CFR 51.308(e)(5)

After a State has met the requirements for BART or implemented emissions trading program or 

other alternative measure that achieves more reasonable progress than the installation and 

operation of BART, BART-eligible sources will be subject to the requirements of paragraph (d) 

of this section in the same manner as other sources.

State Submittal
53

Note: There are no BART sources that ODEQ revisited for the purposes of obtaining additional 

reductions under Section 51.308(d).

F.9. BART Exemptions: 40 CFR 51.308(e)(6)

Any BART-eligible facility subject to the requirement under paragraph (e) of this section to 

install, operate, and maintain BART may apply to the Administrator for an exemption from that 

requirement. An application for an exemption will be subject to the requirements of section

51.303(a)(2)–(h).

Note: This provision of the regional haze rule was not used by ODEQ in the preparation of its 

RH SIP.

G. 2018 Regional Haze SIP Revision: 40 CFR 51.308(f)

Each State identified in section 51. 300(b)(3),which includes Oklahoma, must revise and submit 

its regional haze SIP revision to EPA by July 31, 2018 and every ten years thereafter. In each 

SIP revision, Oklahoma must evaluate and reassess all of the elements required in paragraph (d) 

of this section, taking into account improvements in monitoring data collection and analysis 

techniques, control technologies, and other relevant factors. In evaluating and reassessing these 

elements, Oklahoma must address the following: 

(1) Current visibility conditions for the most impaired and least impaired days, and 

actual progress made towards natural conditions during the previous 

implementation period. The period for calculating current visibility conditions is 

the most recent five year period preceding the required date of the SIP submittal 

for which data are available. Current visibility conditions must be calculated 

based on the annual average level of visibility impairment for the most and least 

impaired days for each of these five years. Current visibility conditions are the 

average of these annual values.

(2) The effectiveness of the long-term strategy for achieving reasonable progress 

goals over the prior implementation period(s); and 

(3) Affirmation of, or revision to, the reasonable progress goal in accordance with the 

procedures set forth in paragraph (d)(1) of this section. If Oklahoma established a 

reasonable progress goal for the prior period which provided a slower rate of 

progress than that needed to attain natural conditions by the year 2064, it must 

evaluate and determine the reasonableness, based on the factors in paragraph 

(d)(1)(i)(A) of this section, of additional measures that could be adopted to 

achieve the degree of visibility improvement projected by the analysis contained 

in the first SIP described in paragraph (d)(1)(i)(B) of this section.
54

State Submittal

ODEQ acknowledged this requirement on page 119 of their RH SIP.

H. Five Year Progress Report 40 CFR 51.308(g)

Each State identified in section 51. 300(b)(3), which includes Oklahoma, must submit a report to 

the Administrator every 5 years evaluating progress towards the reasonable progress goal for 

each mandatory Class I Federal area located within it and in each mandatory Class I Federal area 

located outside it which may be affected by emissions from within it. The first progress report is 

due 5 years from submittal of the initial SIP addressing paragraphs (d) and (e) of this section. 

The progress reports must be in the form of SIP revisions that comply with the procedural 

requirements of section 51. 102 and section 51. 103. Periodic progress reports must contain at a 

minimum the following elements: 

(1) A description of the status of implementation of all measures included in the SIP

for achieving reasonable progress goals for mandatory Class I Federal areas both 

within and outside Oklahoma.

(2) A summary of the emissions reductions achieved throughout Oklahoma through 

implementation of the measures described in paragraph (g)(1) of this section.

(3) For each mandatory Class I Federal area within Oklahoma, it must assess the 

following visibility conditions and changes, with values for most impaired and 

least impaired days expressed in terms of 5-year averages of these annual values.

(i) The current visibility conditions for the most impaired and least impaired 

days; 

(ii) The difference between current visibility conditions for the most impaired 

and least impaired days and baseline visibility conditions; 

(iii) The change in visibility impairment for the most impaired and least 

impaired days over the past 5 years; 

(4) An analysis tracking the change over the past 5 years in emissions of pollutants 

contributing to visibility impairment from all sources and activities within 

Oklahoma. Emissions changes should be identified by type of source or activity. 

The analysis must be based on the most recent updated emissions inventory, with 

estimates projected forward as necessary and appropriate, to account for 

emissions changes during the applicable 5-year period.

(5) An assessment of any significant changes in anthropogenic emissions within or 

outside Oklahoma that have occurred over the past 5 years that have limited or 

impeded progress in reducing pollutant emissions and improving visibility.
55

(6) An assessment of whether the current SIP elements and strategies are sufficient to 

enable Oklahoma, or other States with mandatory Federal Class I areas affected 

by emissions from it, to meet all established reasonable progress goals.

(7) A review of Oklahoma’s visibility monitoring strategy and any modifications to 

the strategy as necessary.

State Submittal

ODEQ acknowledged this requirement on page 119 of their RH SIP. ODEQ stated it intends to 

submit the first five-year report by February 2015.

I. Existing SIP Adequacy Determination 40 CFR 51.308(h)

At the same time Oklahoma is required to submit any 5-year progress report to us in accordance 

with paragraph (g) of this section, it must also take one of the following actions based upon the 

information presented in the progress report: 

(1) If Oklahoma determines that the existing SIP requires no further substantive 

revision at this time in order to achieve established goals for visibility 

improvement and emissions reductions, it must provide to the Administrator a 

negative declaration that further revision of the existing SIP is not needed at this 

time. 

(2) If Oklahoma determines that the SIP is or may be inadequate to ensure reasonable 

progress due to emissions from sources in another State(s) which participated in a 

regional planning process, it must provide notification to the Administrator and to 

the other State(s) which participated in the regional planning process with the 

States. Oklahoma must also collaborate with the other State(s) through the 

regional planning process for the purpose of developing additional strategies to 

address the plan’s deficiencies. 

(3) Where Oklahoma determines that the SIP is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another country, it shall 

provide notification, along with available information, to the Administrator. 

(4) Where Oklahoma determines that the SIP is or may be inadequate to ensure 

reasonable progress due to emissions from sources within the State, the State shall 

revise its SIP to address the plan’s deficiencies within one year. 

State Submittal

ODEQ acknowledged this requirement on page 119 of the RH SIP. ODEQ stated it intends to 

submit the first five-year report required by Section 51.308(g) by February 2015. Using the 
56

findings of that report, ODEQ will make a determination regarding the adequacy of this RH SIP

and take an appropriate action based upon the requirements of Section 51.308(h).

J. Federal Land Manager Coordination 40 CFR 51.308(i)

(1) By November 29, 1999, Oklahoma must identify in writing to the Federal Land 

Managers the title of the official to which the Federal Land Manager of any mandatory 

Class I Federal area can submit any recommendations on the implementation of this 

subpart including, but not limited to: 

(i) Identification of impairment of visibility in any mandatory Class I Federal area(s); 

and

(ii) Identification of elements for inclusion in the visibility monitoring strategy 

required by section 51.305 and this section.

(2) Oklahoma must provide the Federal Land Manager with an opportunity for consultation, 

in person and at least 60 days prior to holding any public hearing on a SIP (or plan 

revision) for regional haze required by this subpart. This consultation must include the 

opportunity for the affected Federal Land Managers to discuss their: 

(i) Assessment of impairment of visibility in any mandatory Class I Federal area; and 

(ii) Recommendations on the development of the reasonable progress goal and on the 

development and implementation of strategies to address visibility impairment.

(3) In developing any SIP (or plan revision), Oklahoma must include a description of how it 

addressed any comments provided by the Federal Land Managers. 

(4) The SIP (or SIP revision) must provide procedures for continuing consultation between 

Oklahoma and Federal Land Manager(s) on the implementation of the visibility 

protection program required by this subpart, including development and review of SIP

revisions and 5-year progress reports, and on the implementation of other programs 

having the potential to contribute to impairment of visibility in mandatory Class I Federal 

areas.

State Submittal

Pages 117-119, Appendix 10-2.

Under Section 51.308(i)(2), the Oklahoma was obligated to provide the Fish and Wildlife 

Service with an opportunity for consultation, in person and at least 60 days prior to holding a 

public hearing on it RH SIP. In practice, state environmental agencies have usually provided all 

FLMs – the Forest Service, the Park Service, and the Fish and Wildlife Service, copies of their 

RH SIP, as the FLMs collectively have reviewed these RH SIPs. ODEQ followed this practice 
57

and sent its draft of this implementation plan revision to the federal land manager staff on 

October 1, 2009 and notified the federal land manager staff of the public hearing held on 

December 16, 2009. In its letter dated December 4, 2009, transmitting its comments, the Fish 

and Wildlife Service acknowledged having received Oklahoma’s draft RH SIP on October 5, 

2009.

Section 51.308(i)(3) requires that ODEQ provide in its RH SIP a description of how it addressed 

any comments provided by the FLMs. ODEQ has provided that information in Appendix 10-2 of 

its RH SIP.

Lastly, Section 51.308(i)(4) specifies the RH SIP must provide procedures for continuing 

consultation between the State and Federal Land Manager on the implementation of the visibility 

protection program required by section 51.308, including development and review of 

implementation plan revisions and 5-year progress reports, and on the implementation of other 

programs having the potential to contribute to impairment of visibility in the mandatory Class I 

Federal areas. ODEQ has stipulated in its RH SIP it will continue to coordinate and consult 

with the FLMs as required by section 51.308(i)(4). ODEQ states it intends to consult the FLMs 

in the development and review of implementation plan revisions; review of progress reports; and 

development and implementation of other programs that may contribute to impairment of 

visibility at the Wichita Mountains and other Class I areas. We find that ODEQ has satisfied 

section 51.308(i).

EPA Findings

The Wichita Mountains is one of more than 546 refuges throughout the United States managed

by the Fish and Wildlife Service, which is the Federal Land Manager (FLM) for this Class I 

area. Although the FLMs are very active in participating in the RPOs, the RH Rule grants the 

FLMs a special role in the review of the RH SIPs. We view both the FLMs and the state 

environmental agencies as our partners in the RH process.

We acknowledge that Section 51.308(i)(1) has been satisfied by all states via communication 

prior to this SIP. We find that ODEQ has satisfied the requirements of Section 51.308(i)(2)-(3) 

by providing the FLMs with a with an opportunity for consultation, in person and at least 60 

days prior to holding any public hearing on its RH SIP, and ODEQ has adequately addressed 

the FLM comments in its SIP. Further, we find that ODEQ has satisfied Section 51.308(i)(4) by 

committing to continuing consultation between the it and the FLMs on the implementation of the 

visibility protection program required by Section 51.308(i), including development and review of 

SIP revisions and 5-year progress reports, and on the implementation of other programs having 

the potential to contribute to impairment of visibility in mandatory Class I Federal areas.

The FLMs have communicated to us their dissatisfaction with the fact that the draft RH SIP they 

were provided by ODEQ was markedly different that the version ODEQ submitted to us as their 

final RH SIP. Specifically, the FLMs note that in the version of the SIP they reviewed, SO2

BART for the six OG&E and AEP/PSO coal fired units that are the subject of our FIP was 

determined by ODEQ to be dry SO2 scrubbers with an emission limit of 0.10 lbs/MMBtu for the 

OG&E units, and 0.153 lbs/MMBtu for the AEP-PSO units. When ODEQ submitted their final 
58

RH SIP to us, those SO2 BART determinations were changed to replace the SO2 scrubber 

requirements with an SO2 limit of 0.65 lbs/MMBtu on a 30 day rolling average that corresponds 

to uncontrolled low sulfur coal. We note the Fish and Wildlife Service has not requested that 

ODEQ re-open their 60 day comment period. We would like to address any question as to 

whether section 51.308(i)(2) has been satisfied. We believe, however, that our proposed FIP, as 

described in section V.F., above, may alleviate these concerns. We invite the FLMs to provide 

comment on this or other aspects of our proposal.