# Technical Support Document

f or 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 2011ii 

### 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 Anal ysis: 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).......................................................1 7 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 Ret rofit 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)

................................ ...................... 56iii 

### Tables

Table 1 . Calculation of Uniform Rate of Progress

....................................... ... ...... ... ... 1 1

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

... ... ...... ... ..... . 2 3

Table 3 . Oklahoma’s 2018 Emissions Inventory

....................................... . ................2 4

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

the 20 Percent Worst D ays in 2018

................................. .. ...... ... .. .......... ....... 2 6

Table 5 . Facilities wi th BART

- eligible units in Oklahoma............................................. 3 6

Table 6 . Sources in Oklahoma required to install B ART

............... ... .............................3 9

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 P lanning 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 Musk ogee Generating Station, and AEP/PSO Northeastern Generating Station Appendix C

. SO 2 BART Cost Effectiveness Analysis for the Federal Implementa tion Plan Appendix D

. EPA Extension of SO 2 BART Cost Effectiveness Analysis Appendix E

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

BART Determination4



### Oklahoma Regional Haze T echnical Support Document (T SD )

I. Relationship of this TSD to our Proposal

We are proposing to partially approve and partially disapprove Oklahoma’s R egional H aze (RH) SIP revision submitted on February 19, 2010. Specifically, we are proposing to disapprove the Sulfur Dioxide ( SO 2 ) 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 prop osing to disapprove these SO 2 BART determinations because they do not comply with our regulations under 40 CFR 51.308(e).

We are al so proposing to disapprove the Long Term S trategy (LTS) under section 51.308(d)(3)

because Oklahoma has not shown that the s trategy 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 SO 2 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

dev elopment that assumed certain SO 2 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 SO 2 BART

emission limits on these sources. We are proposing that SO 2 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 SO 2 emission limit of 0.06 lbs/MMBtu that applies singly to each of these units on a 30 day rolling average. Additionally, we propose monitor ing, record

keeping, 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 solici t ed 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, w e solicited comments as to, considering the engineering and/or management challenges of such a fuel switch, whether the5

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

on the SO 2 BART c ost

- e ffectiveness 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 an alyses. 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 comp lete 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 r egard, 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 p roposal and are subject to change based on comments and other information we may receive during our public comment period.6

I I. 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 area s 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 Areas7 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 o n 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 visib ility 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 wi th 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 spec ified 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, wer e 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 3.8 Figure 3 . Map of Regional Planning Organization Boundaries

Oklahoma, through the O DEQ 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 fu lfill the requirements of the RH Rule.9

II I. 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‖ i n 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 Re gional 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. Emiss ions 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, Apri l 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

Page s 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

. Oklah oma 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 ar eas 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 degradation10

at the Hercules Glades in Missouri, app roximately 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 le vel of reductions of SO 2 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 SO 2 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 o n 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 TS D , 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

Stat e,” 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 a n 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 requirem ent

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 c onsider the costs of compliance, the time necessary for compl iance, the energy and non

- air quality environmental impacts of compliance, and the remaining useful life of11

any potentially affected sources, and include a demonstration showing how these factors were taken into consideration in selecting the goal.

EPA Fi ndings

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 a nalyze 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 mand atory 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

Pag es 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 calculat ed the URP to be 16.28 dv , as depicted by Table 1 , which

is a dapted 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 Findings12

We agree that ODEQ has

, i n establishing its RPG

, analyz ed and determine d the rate of progress needed to attain natural visibility conditions by the year 2064. ODEQ has calculate d this rate of

progress, and compare d baseline visibility conditions to natural visibility conditions for the

Wichita Mountains and determine d the URP need ed 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 cons ider 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

con ditions 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 p rovide 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 Oklah oma ’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 go al 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 fo r visibility improvement provides for reasonable progress towards natural visibility conditions.13

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)(v i )

Oklah oma 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 S IP 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

b aseline 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 day s 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

Page s 8

- 27

.

Baseline conditions represent visibility for the best an d 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 t he 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 unif orm measure of light extinction caused by regional haze. This visibility metric expresses uniform changes in the14

degree of haze in terms of common increments across the entire range of visibility conditions, from pristine to extremely hazy conditions. Th e 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 u seful 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 Guidance 1 , as r equired by the RHR

. The baseline condition calculation begins with the calculation of light extinction, using the IMPROVE equation. The IMPROVE equ ation sums the light extinction resulting from individual pollutants, such as sulfates and nitrates

.

In 2 005 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 factor s 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 science 2 and 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 fo r 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 s cattering (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 s ubmittal 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, C olorado. 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/D ata Analysis Workgroup. September 2006 http://vista.cira.colostate.edu/impro ve/Publications/GrayLit/029_NaturalCondII/naturalhazelevelsIIreport.ppt15

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” a pproach

, 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 b egan 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 dat a for 2005 and 2006. The resulting b aseline conditions represent an average for 2002

- 2004. ODEQ calculated the baseline by first summing the light extinction ( where the extinction coefficient is expressed in Mm 1 ) for sulfurous, nitrate, organic

carbonac eous, elemental “light

- absorbing” carbonaceous, fine soil, chlorine or chloride, and

coarse matter

, using the following equation:

β ext = β ext S + β ext NO3 + β ext organic+ β ext elemental+ β ext SO il+ β ext coarse+ β ext Cl+ β ext Rayleigh

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

HI (dv) = 10 ln[ β ext / ( 10 Mm - 1 ) ]

ODEQ calculate d 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)(i ii )

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

n atural visibility conditions for the most impaired and least impaired days

. Natural visibility conditions must be calculated by estimating the degree of visibility impairment existing under16

natural conditions for the most impaired and least impaired days, based on available monitoring information and appropriate data analysis techniques

.

State Submittal

Page s 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 90 th percentile of the annual distribution represen ts 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 area s. 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 visibil ity pollutants.

As with the calculation of b aseline 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 7.5 3 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 Submittal17

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 value s 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

calcul ates the number of deciviews by which baseline conditions exceed natural visibility

conditions at the Wichita Mo untains 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 c onditions 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 e ach 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 o utside 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 mandat ory Class I Federal areas.

State Submittal

Page s 37

- 47, 58

- 67, 86

- 103

The LTS is a compilation of state

- specific control measures relied on by Oklahoma for achieving its RPG s . Oklahoma’s LTS for the first implementation period addresses the

emissions r eductions 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 inventor y, 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 t o 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 l imits 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 UR P.

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 a ddresses 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 t hrough 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 a dequately 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 stra tegies.

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

Page s 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 state19

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. O DE Q 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 fro m 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 corresponden ce, 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 Wil dlife 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 an d 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) re quires 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 consu ltation. ODEQ’s evaluation relied, however, upon SO 2 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 sec tion 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 cause s or contribute s 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 participated20

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

Page s 65, 115

- 117

As discussed in sections III.D.3

- 4, and dep icted 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 vis ibility 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 SO 2 BART levels, when in fact, after the consultation calls with tribes and other states in 2007 ODEQ found

that SO 2 BART was no control on these six units in their 2010 submittal . This original assumption that these six units would be controlled to presumptive SO 2 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 tri bes, 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 t o 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 neede d 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 tec hnical 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 regional21

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 abo ve, 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 fo r 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 consolidate d 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 invent ories 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 Section s 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 applyin g reductions expected from federal and state regulations affecting the emissions of the visibility

- impairing pollutants NO

x , PM, SO 2

, , and VOCs. The BART Guidelines direct states to exercise judgment in deciding whether VOCs and NH 3 impair visibility in t heir22

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 NH 3 do not significantly impair visibility in the CENRAP region. Therefore, Oklahoma did not consider ammonia among visibility

- impairing pollutants and did not further evaluate NH 3 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 th e 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 agricult ural 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 emis sions 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 met hods 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 impr ovement 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 invent ory. 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

Mo del with extensions (CAMx) model. To enhance accuracy of transportable dust estimates, the contractor also applied road and fugitive dust transport factors 3 to appropriate area source emissions. ODEQ and CENRAP developed the on

- road mobile source emissio ns 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 cont ractor 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.pdf23 Table 2 . Oklahoma’s 2002 Emissions Inventory

SO 2 NH 3 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 electri c 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 20 02 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

inclu ded 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. Similarl y, 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 f ederal standards, including the Tier 4 compression

- ignition engine standards and the exhaust emissions standards for large spark

ignition 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 SO 2 for six units in these

facilities.24

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

Table 3 . Oklahoma’s 2018 Emissions Inven tory

SO 2 NH 3 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 o

f 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 t he 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 reference s 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 use d for urban

- and regional

scale photochemical, PM 2.5 , 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 speci ated 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 capab le 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 transp arent 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 (Janu ary 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 L TS 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 measure ments 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 inp uts. 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 contr ibution 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

E missions Inventory Gui dance 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

- 00126

Table 4

. Projected Contribution from Oklahoma Emissions on Visibility Degradation for

the 20 Percent Worst D ays 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

Hercules

Glades 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 a l l other Class I

areas other than the Wichita Mountains . This info rmed 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 documen ted 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 sche dules;

(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 n et 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 , 11 4

. 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, adm inistrative 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 program s. O DEQ 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 impairment28

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

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 gasoline

powered 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 a nd 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 R ate (LAER) to major new and modified point sources of SO 2 , 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 co ntrol 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 vari ous 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, Contro l 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 SO 2 and NOx reductions.

We approved ODEQ’s SIP to address R easonably A ttributable V isibility I mpairment (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 no t incorporate any measures to specifically

address RAVI.

.29

(B) Measures to mitigate the impa cts of construction activities

We note that fine and coarse particulate, of which construction

- related activities are thought to be a small contributor , are them selves minor contributor s 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 achiev e 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 w hich may cause or contribute to regional
haze at the Wichita Mountains

. Unless permits specify a different schedule for compliance, O DEQ requires permitted sources to comply with their permits immediately upon issuance. O DEQ 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 SO 2 and NOx reductions

. CENRAP modeling in support of this SIP included these reductions. These enforceable consent decrees include compliance schedules.

(D) Source retir ement and replacement schedules

ODEQ considered source retirement and replacement schedules in developing its long

term strategy of emissions reductions. ODEQ took the position that it could not reliably predict the retirement or replacement of sources a nd 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 fo r 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 SO 2 , 4.1% of the total NH 3 , 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 PM 2.5 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 inten d to create a basic, voluntary smoke management program based on our Interim Air Quality Policy on Wildland and Prescribed Fires

.

(F) Enforceability of emissions limita tions 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

Tech nology (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 SO 2 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 lim its. 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 requiremen t[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 Cl ean 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 qual ity 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 anti cipated 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 emis sions 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 SO 2 BART levels, when in fact, ODEQ found

that SO 2 BART was no control. T his assumption of these units being controlled is31

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

P rotected 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 t o 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 projected32 emissions. The State must also inc lude 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 monitor ing s trategy 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 i n 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 t he 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 de scribing 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 establ ishment 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 moni toring 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 mo nitoring 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 c alculated using data representative of

2002

- 2004 due to lack of data from previous years.

Section 51.308(d)(4)(ii) requires that ODEQ establish p rocedures 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 Mounta ins 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 Interne t 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, an d 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 t he 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 f rom 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. Th e 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 re fer 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 inventori es periodically and review periodic emissions info rmation 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) R equirements : 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 reas onably 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 visibi lity conditions.

Note s : 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 of34

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)

O klahoma 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 de termination in more detail.

State Submittal

Pages, 69

- 71

Oklahoma’s BART rule, OAC 252:100

- 8, Part 11, and companion d efinitions 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. B elong ed to one of the twenty

- six BART categories listed below ; 2. D id not operate before 7 August 1962 but were in existence on 7 August 1977; and

3. H ad the potential to emit 250 tons per year or more of any visibility

- impairing pollutant.

O DEQ determined that the visibility

- impairing pollutants in Oklahoma include sulfur dioxide ( SO 2 ), nitrogen oxides (NOx), and particulate matter (PM10 and PM2.5). ODEQ determined using CENRAP modeling including source apportionment techniques and an ev aluation 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 d ata , Oklahoma decided to not consider ammonia among visibility

- impairing pollutants.

O DEQ initially determined which sources were BART eligible by screening its emissions inventory and permitting database to identify major facilities with emission units i n 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. Lim e 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 faciliti es.

O DEQ then used its databases and records to identify facilities with in 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, O DEQ 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 337

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 fede ral 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, Ok lahoma granted BART applicability waivers to a number of facilities. For sources that utilized BART modeling that did not include the inclusion of

meteor o logical observations using the 1 st High or maximum value from CALPUFF modeling was required to be bel ow 0.5 deciviews to obtain a waiver. For modeling that did include the meteorological observations, the 8 th High value from CALPUFF modeling was required to be below 0.5 deciviews to obtain a waiver. Based on these modeling considerations the state issue d

waivers to 11 facilities that are listed in Table 6

- 2 of Appendix A.

W ith 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

emi ssions 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 describe d below, each of these facilities then identified reductions in emissions that were subsequently secured through Title V permit modifications. Following this, a n updated BART modeling analysis, assuming those controls were in place, demonstrated a contrib ution 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 ha s 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 B

1 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 decivie ws 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, Air38

Quality Division operating Permi t, 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

, V alliant Paper Mill has three BART eligible boilers: EUG D1, Bark Boiler ; EUG D2, Power Boiler ; and EUG D3, P ackage 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 B ark 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 We stern Farmers Electric Coop (WFEC), Anadarko facility has three BART eligible combine cycle gas turbines, AN

- Unit 4

, AN

- U nit 5, and AN

- Unit 6. It also has a BART eligible internal combustion engine, AN ENG

- 1. WFEC has agreed to NOx, SO 2 , and PM

- 10 emissi on 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, whi ch 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

di scussed 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 and39

associated emission reductions achi evable 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, a ny 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 fro m Table VI

- 4 of the RH SIP, lists all of the sources determined by ODEQ to be subject to BART. Of these, the SO 2 BART determination s 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

NO X and PM10 BART determinations for these facilities and the NOx BART determina tions 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 SO 2

NOx

PM 10

OG&E Muskogee Generating Station Units 4

and 5 fossil fuel

- fired steam

electric plants SO 2

NOx

PM 10

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 SO 2

NOx

PM 10

AEP/ PSO Southwestern

Power Station Unit 3 fossil fuel

- fired steam electric plants NOx40

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 conside r “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 visibi lity which may reasonably be anticipated to result from the use of such technology. We disagree with ODEQ’s SO 2 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 Nor theastern plants. The SO 2 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 Determination s

State Submittal

Page s, 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 output s of 567 MW each. ODEQ determined that Low NOx Burners ( LNB ) and Over F ire 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. Lastl y, 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 hig her 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 NO x emissions from Seminole Units 1, 2 and 3 by approximately
5,5 13 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 a nd 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 an41 average cost effectiveness of $1,554

- $2,120 per ton of NO x removed for each unit over a twenty year operational life.

Combustion contro l 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.

NO x 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 NO

x 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 SO 2 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 S ooner Units 1 and 2 BART Determinations

State Submittal

Page s, 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 SO 2 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 complian ce, 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, base d 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 cou ld reduce overall NOX emissions from Sooner Units 1 and 2 by approximately 3,226 TPY beyond42 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

environmenta l 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 pres umptive limits

.

Annual NOx emission r eductions 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 additiona l 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 r evision. 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 SO 2 limits in

combination with ODEQ proposed limits for NOx and PM. This modeling s uggests small visibility improvements can be expected from also requiring the installation of SCR on these43

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, w e find that ODEQ ’s BART determin ations 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

Page s, 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 SO 2 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 S CR 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

environmen tal 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 f

rom 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

Wich ita 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 effect iveness 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 544 are justified meet the presumptive limits prescribed by us

.

Annual NOx emission reductions from new LNB with OFA on Units 4 and 5 are project ed 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 Unit s 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 filte rs 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 l bs/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

e nvironmental impacts, the remaining useful life and visibility modeling. EPA performed

additional CALPUFF visibility modeling that included our proposed SO 2 limits in combination with ODEQ proposed limits for NOx and PM. This modeling s uggests small visi bility 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 mo deling 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 Determination s

State Submittal

Page s, 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 also45

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

e valuated 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 investiga te 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 e ffectiveness 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 SO 2 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 Unit s 2 , 3, and 4 BART Determination s

State Submittal

Page s, 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 SO 2 BART determinations for Units 3 and 4 are covered under our pr oposed FIP. Therefore, we review ed 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 also46

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 e valuated 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 NO x 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 NO x 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 a n 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 da y 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 SO 2 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 exis ting 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 lim it 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 SO 2 limits in combination with ODEQ proposed limits for NOx and PM This modeling s uggests 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 add itional 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

Page s, 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 th e 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 NO x 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 OD EQ concluded that SCR control may not be as effective on boilers that operate as peaking units, as NO x 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 a n average cost effectiveness of $947 per ton of NO x 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 th ere 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 info rmation 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 e mission 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 SO 2 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 A EP/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

3,998 OG&E Seminole 2 (gas

- fired) 0.354

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) 0.6 13

Total NOx Reduction 27,04350 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

visibili ty 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 u nder the Regional Haze Rule).

State Submittal

Page s 69

- 85

All the facilities required to install BART that are identified above in Table 6, are fossil

- fuel fired steam electric generating plant s 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

T hese BART determinations are covered in Sections III.F.2.1 to III.F.2. 6

, above. We find that except for the SO 2 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 Nort heaster n 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 SO 2 BART determinations for these facilities are the subject of our proposed F IP

.

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 Fe deral area. All such sources are subject to BART.

Oklahoma is not required to make a determination of BART for SO 2 or for NOx if a BART

eligible source has the potential to emit less than 40 tons per year of such pollutant(s), or for

PM10 if a BART

- eligi ble 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 BAR T: 40 CFR 51.308(e)(1)(iv )

– (v )

E ach 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

Page s 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 t he Oklahoma Regional Haze SIP.” O DEQ 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 BAR T and achieve the associated BART emission within five years of our approval the SIP. Furthermore, O DEQ 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 e ach source subject to BART will (1) install and operate BART as expeditiously as practicable, but in no event later than 5 years af ter 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 SO 2 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 i n part 96 of this chapter, and is approved, in accordance with section 51.123(o)(1) or (2) (for the NO x annual program) and (aa)(1) or (2) (for the NO x ozone season program) and section 51.124(o)(1) or (2) (for the SO 2 program) or by remaining subject to th e 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, con sistent 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 prog ram 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 Subm ittal53

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 subje ct 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

t echniques, 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 tow ards 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 visibil ity 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 pa ragraph (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

O DEQ acknowledged this requirement on page 119 of the ir RH SIP.

H. Five Y ear 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 b y 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 requiremen ts 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 mand atory 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 Fede ral 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 mos t 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

im paired 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 a ny 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 the ir RH SIP. O DEQ stated it intends to submit the first fiv e

- year report by February 2015.

I. E xisting SIP A dequacy 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 vis ibility 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 rea sonable 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

S tates. 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 inadequa te to ensure reasonable progress due to emissions from sources in another country, it shall provide notification, along with available information, to the Administrator.

(4) W here Oklahoma determines that the SIP is or may be inadequate to ensure

reaso nable 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. O DEQ stated it intends to

s ubmit the first five

- year report required by Section 51.308(g) by February 2015. Using the56

findings of that report

, O DEQ 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 Fed eral 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 affec ted 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 conti nuing 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

Page s 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 For est 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 practice57

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 d raft 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 implementat ion 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 coordi nate 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 FL Ms 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 sat isfied 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 p rovided 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, SO 2 BART for the six OG&E and AEP/PSO coal fired units that are the subject of ou r FIP was determined by ODEQ to be dry SO 2 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 final58

RH SIP to us, those SO 2 BART determinations were changed to replac e the SO 2 scrubber requirements with an SO 2 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

whet her 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

.