UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street
 

San Francisco, CA 94105
 

NOV 1 7 2011 

Mr. Jeff Yockey 

Tucson Electric Power 

88 East Broadway Boulevard 

Mail Stop - HQW602 

Tucson,Aurizona 85701 

Dear Mr. Yockey: 

I am writing to inform you that EPA Region 9 is developing a partial Regional Haze Federal 

Implementation Plan (pIP) for the state of Aurizona. The purpose ofthe Regional Haze FIP is to 

improve visibility in national parks and wilderness areas in Aurizona and surrounding states as 

required by Section 169A ofthe Clean Air Act (Act). During the process of developing the 

Aurizona Regional Haze State Implementation Plan (SIP), submitted to EPA on March 2,2011, 

the Aurizona Department of Environmental Quality (ADEQ) determined that the Irvington 

Generating Station was exempt from Best Available Retrofit Technology (BART) requirements. 

As part of the FIP development process, we will revisit that determination, performing an 

analysis to determine whether this facility is subject to BART requirements under section 

169A(b)(2)(A) of the Act, and EPA's implementing regulations and BART guidelines at 40 CFR 

Part 51, Subpart P and Appendix Y. 

As we begin our FIP analysis, we have requested that ADEQ provide us with all background 

materials, including subject-to-BART analyses, that were performed by them or the affected 

facilities. We may also request that you provide us with additional information on the Irvington 

Generating Station as our analysis proceeds. In the meantime, we welcome the submission of any 

additional, relevant information that you would like to provide to our office. If we determine that 

this facility is subject to BART requirements, we will perform a five-factor BART analysis to 

determine whether any additional emissions controls are warranted. 

EPA has entered into a consent decree that requires the Agency to propose approval of Arizona's 

Regional Haze SIP and/or propose a Regional Haze FIP that meets the requirements of the Act 

and EPA's regional haze regulations by May 15,2012. The consent decree also requires the 

Agency to take final action on the Aurizona Regional Haze SIP and/or FIP by November 15,2012. 

EPA Region 9 will hold public hearings in Aurizona and solicit public comments on a proposed 

Aurizona Regional Haze FIP in the months preceding the November 15 deadline. 

If you would like to submit any additional information or analysis, we request that you send it by 

January 31,2012. Any modeling of the facility should use the regulatory versions of CALPUFF 

(version 5.8, level 070623), CALMET (version 5.8, level 070623), and CALPOST (version 
6.221 ). You may wish to prepare a modeling protocol and consult with EPA Region 9 about the 

preparation of modeling inputs in accord with EPA guidance. Submit any information to: 

Thomas Webb 

US EPA (AIR-2) 

75 Hawthorne Street 

San Francisco, CA 94105 

You can also reach Thomas at webb.thomas@epa.gov or by phone at 415-947-4139. 

Thank you for your attention to this matter. If you have any questions, please contact Thomas 

Webb or myself(mckaughan.colleen@epa.gov, 520-498-0118). 

Sincerely, 

~~~ Colleen McKaughan 

Associate Director, Air Division 

cc:	 Henry R. Darwin, ADEQ 

Eric Massey, ADEQ