# BART Resource Guide

Prepared by

NESCAUM

For the Mid-Atlantic/Northeast Visibility Union (MA NE-VU)

Regional Planning Organization



# August 23, 2006

### Members of Northeast States for Coordinated Air Use Management

Arthur Marin, Executive Director Northeast States for Coordinated Air Use Management

Anne Gobin, Bureau Chief Connecticut Department of Environmental Protection, Bureau of Air Management

James P. Brooks, Bureau Director Maine Department of Environmental Protection, Burea u of Air Quality

Barbara Kwetz, Director Massachusetts Department of Environmental Protectio n, Bureau of Waste Prevention

Robert Scott, Director New Hampshire Department of Environmental Services, Air Resources Division

William O’Sullivan, Director New Jersey Department of Environmental Protection, Office of Air Quality Management

David Shaw, Director

N e w Y o r k D e p a r t m e n t o f E n v i r on m e n t a l C on s e r v a t i on
, D i v i s i on o f A i r R e s ou r c e s

Stephen Majkut, Chief Rhode Island Department of Environmental Management , Office of Air Resources

Richard A. Valentinetti, Director Vermont Department of Environmental Conservation, A ir Pollution Control Divisionii



# BART Resource Guide

Prepared by

NESCAUM

for the Mid-Atlantic/Northeast Visibility Union (MA NE-VU)

Regional Planning Organization



## August 23, 2006

Submitted to the United States Environmental Protec tion Agency, Region III in partial fulfillment of requirements for EPA agre ement XA-97318101-0

to the Ozone Transport Commission

Project Director

Gary Kleiman, NESCAUM

Editors Paul Miller, NESCAUM

Principle Contributors

Iyad Kheirback, NESCAUM Gary Kleiman, NESCAUM Lisa Rector, NESCAUM

US EPA Project Officer

Marcia Spink, US EPA Region IIIiii



## Acknowledgments

This report was prepared by NESCAUM staff listed on the opposite page under “Principal Contributors.”

NESCAUM gratefully acknowledges the funding support provided by the U.S. Environmental Protection Agency through their suppo rt of the MANE-VU Regional Planning Organization (Grant # XA-97318101-0).

NESCAUM also thanks the following individuals for p roviding comments on this report:

Anne Arnold, US Environmental Protection Agency – R egion 1 Doug Austin, Ozone Transport Commission Marc Cone, Maine Department of Environmental Protec tion Stephen Dennis, Massachusetts Department of Environ mental Protection Nancy Herb, Pennsylvania Department of Environmenta l Protection Brian Hug, Maryland Department of Environmental Pro tection Wendy Jacobs, Connecticut Department of Environment al Protection Bob Kelly, US Environmental Protection Agency – Reg ion 2 John Kent, New York Department of Environmental Con servation Doug McVay, Rhode Island Department to Environmenta l Management Anne McWilliams, US Environmental Protection Agency – Region 1 Gary Milbury, New Hampshire Department of Environme ntal Services Jack Sipple, Delaware of Natural Resources and Envi ronmental Control Donald Squires, Massachusetts Department of Environ mental Protection David Wackter, Connecticut Department of Environmen tal Conservation

Printed: September 2006iv TABLE OF CONTENTS

Acknowledgments....................................

................................................... .......................iii Executive Summary..................................

................................................... ...................... vi

1. Introduction....................................

................................................... ....................... 1-1 1.1. Overview of Regional Haze Program............. ................................................. 1- 1

1.2. Overview of BART Rule .........................

................................................... ..... 1-1

1.3. Overview of BART Process......................

................................................... .... 1-2 1.3.1. BART eligibility ............................

................................................... ....... 1-2 1.3.2. Cause or contribute to visibility impairment in a Class I area................. 1-3

1.3.3. BART determinations .........................

................................................... .. 1-3 1.4. Overview of Report............................

................................................... ........... 1-4

2. MANE-VU BART PROCESS............................

................................................... .. 2-1 2.1. BART Workgroup ................................

................................................... ........ 2-1

2.2. BART Recommendations ..........................

................................................... ... 2-1 2.2.1. Recommendations regarding BART eligibility: . ..................................... 2-1 2.2.2. Recommendations regarding BART control revie ws.............................. 2-2 2.3. Recommended Presumptive BART Levels of Control .................................... 2-2 2.4. BART Trading ..................................

................................................... ............ 2-3

3. BART DETERMINATIONS.............................

................................................... ... 3-1

3.1. EGUs..........................................

................................................... ................... 3-1

3.1.1. CAIR........................................

................................................... ............. 3-1 3.1.2. Statutory factors...........................

................................................... ......... 3-2 3.1.3. Engineering reviews.........................

................................................... ..... 3-3

3.1.4. MANE-VU staff BART recommendations .......... ................................... 3-3

3.2. Other Industrial Sources ......................

................................................... ......... 3-3

3.2.1. RACT........................................

................................................... ............ 3-4

3.2.2. Permit limitations..........................

................................................... ........ 3-4 3.2.3. Statutory factors...........................

................................................... ......... 3-4

3.2.4. MANE-VU staff BART recommendations .......... ................................... 3-5

4. MODELING ........................................

................................................... ................. 4-1 4.1. Modeling Methods..............................

................................................... .......... 4-1

4.1.1. REMSAD: SO 2 tagging ........................................... ................................ 4-2 4.1.2. CALPUFF approaches: NWS observation-based an d MM5-based meteorology ........................................

................................................... .................. 4-2 4.1.3. Empirical approaches: emissions divided by d istance or Q/d ................. 4-3 4.1.4. Data analysis approach: percent time upwind . ........................................ 4-4 4.2. Anticipated Visibility Improvement as a Result of BART.............................. 4-4

5. BART RESOURCES..................................

................................................... .......... 5-1 5.1. Regulations ...................................

................................................... ................ 5-1 5.2. BART Eligibility Resources ....................

................................................... ..... 5-1 5.3. Control Technology Information ................

................................................... .. 5-1 5.4. Program Implementation Resources.............. .................................................. 5 -2 5.5. Modeling Resources............................

................................................... .......... 5-2

5.6. Stakeholder Submitted Information.............

................................................... . 5-3

6. CONCLUSION......................................

................................................... ............... 6-1v

Appendix A: Regulations............................

................................................... ................. A-1 Appendix B: BART-Eligibility Resources .............

................................................... ..... B-1 Appendix C: Control Technology Options.............

................................................... ..... C-1 Appendix D: Program Implementation Resources ....... .................................................. D -1 Appendix E: Modeling Resources .....................

................................................... ...........E-1 Appendix F: Stakeholder Provided Resources .........

................................................... ....F-1 Appendix G: BART-Eligible Source Information by Sta te............................................ G-1vi



## Executive Summary

This report was prepared by the Northeast States fo r Coordinated Air Use Management (NESCAUM) as part of an effort to assist states and tribes in implementing the Best Available Retrofit Technology (BART) requi rements of the Regional Haze Rule. The Regional Haze Rule requires states to determine the most stringent technologically feasible system of controls that can reasonably be installed at each facility determined to be BART-eligible. Criteria that determine whether a specific control technology is deemed reasonable include: cost of the controls, ot her control technology in use at the source, energy and other non-air quality environmen tal impacts, remaining useful life of the source, and the degree of visibility improvemen t anticipated to result from installation

of the controls.

This report provides information designed to assist states as they determine what emission limits and controls are necessary for the December 17, 2007 SIP submittal. This SIP submittal requires that states submit a li st of sources eligible for BART, a BART determination for each source, and a complianc e schedule for installing controls. This report seeks to provide states with resources to complete this task. The report provides information on BART requirements, BART det ermination, BART modeling and other resources to assist states in the BART proces s. States will need to conduct an individual analysis for each facility prior to maki ng a BART determination. This information is intended to facilitate that process by collecting available information into a single reference document.

The report finds that the BART program could repre sent a significant emission reduction opportunity for the Northeast and Mid-Atl antic States if implemented strictly. Electrical generation units (EGUs) represent the gr eatest potential single source category

for emission reductions but due to EPA’s determinat ion that CAIR will serve as BART for covered facilities there may be a reduction in BART effectiveness from this category. BART may yield particulate matter emission reductio ns from EGUs however, since CAIR only applies to nitrogen oxides (NO X ) and sulfur dioxide (SO 2 ) emissions. In addition, states that choose to use the flexibility provided in the BART rule may be able

to “harvest” the emissions reductions from several other source sectors in that refinery, cement plant and ICI boiler RACT programs being con sidered for NAAQS compliance to maximize emission reductions under the BART program

.BART Resource Guide - DRAFT document, do copy or di stribute Page 1-1

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## 1. INTRODUCTION

1.1. Overview of Regional Haze Program

In 1977, Congress outlined goals in the federal Cle an Air Act (CAA) to restore pristine visibility conditions in national parks an d wilderness areas. Section 169 of the CAA calls for the prevention of any future, and the remedying of “any” existing, manmade visibility impairment in all Class I areas. 1 Upon adoption of this legislation, EPA took relatively modest steps to remedy visibility i mpairment at Class I areas around the country. Control measures were largely confined to addressing plume blight from specific pollution sources near Class I areas. How ever, these actions did little to address the pervasive, regional nature of haze throughout t he eastern United States. Most of the regional emission reductions occurred through imple mentation of other CAA programs, such as the National Acid Rain Program.

Subsequent to the adoption of the 1977 goals, visib ility in the nation’s Class I areas continued to deteriorate. In eastern areas, average visual range decreased from 90 miles to 15-25 miles. In the West, visual range dec reased from 140 miles to 35-90 miles. 2
Given the lack of improvement in visibility, the US EPA issued a new set of regulations in 1999 (64 Fed. Reg. 35,714, July 1, 1999) aimed a t achieving visibility goals by 2064. These rules, commonly known as the “Regional Haze R ule,” developed a program to restore natural visibility conditions at Class I ar eas across the country. Under the Regional Haze Rule states or tribes are required to develop and submit State Implementation Plans (SIPs) or Tribal Implementatio n Plans (TIPs) to EPA by December 17, 2007. EPA requires these plans to:

• Demonstrate states’ efforts to make reasonable prog ress towards the 2064 national visibility goals.

• Create a long-term strategy for achieving the natio nal regional haze goal with an implementation period to 2018 and reassessm ent every ten years
thereafter.

• Identify sources subject to the Best Available Retr ofit Technology (BART) provisions and determine controls for those units. BART provisions provide a mechanism for achieving visibi lity improvements in

haze SIPs.



### 1.2. Overview of BART Rule

In June 2001, EPA released a proposed rule on BART . This rule outlined the method for determining if a facility is eligible fo r BART, subject to BART provisions, and methods for conducting a BART control review.

In 2002, industry groups challenged the method EPA outlined in the Regional Haze Rule to determine the degree of visibility imp rovement resulting from application

1 The Class I designation applies to national parks exceeding 6,000 acres; wilderness areas and national memorial parks exceeding 5,000 acres; and all international p arks that were in existence prior to 1977.

2 http://epa.gov/oar/visibility/what.htmlBART Resource Guide - DRAFT document, do copy or di stribute Page 1-2

1-2 of BART controls. Under EPA’s interpretation of th e statute, a state would deem sources subject to BART if they emitted emissions into a ge ographic area or region that likely transports pollutants downwind into a protected are a. In May 2002, the D.C. Circuit Court of Appeals agreed with industry petitioners a nd vacated those portions of the Regional Haze Rule dealing with BART.

In June 2005, EPA released the final BART rule. U nder the final rule, the BART program requires states to develop an inventory of sources within each state or tribal jurisdiction that could be subject to control. Spe cifically, the rule:

• Outlined methods to determine if a source is “reaso nably anticipated to cause or contribute to haze;”

• Defined the methodology for conduction of a BART co ntrol analysis;

• Provided presumptive limits for electricity generat ing units (EGUs) larger than 750 Megawatts;

• Provided a justification for the use of the Clean A ir Interstate Rule (CAIR) as

BART for CAIR state EGUs.

Beyond the specific elements listed above, EPA prov ided the states with a large amount of latitude to implement the BART program. The following section provides information on the BART eligibility determination a nd control review process.



### 1.3. Overview of BART Process

The BART program applies to facilities in one of 2 6 source categories that have units installed and operating between 1962 and 1977 with the potential to emit more than 250 tons per year of a visibility impairing polluta nt. Once a source is found to be BARTeligible it must undergo a case-by-case analysis to determine if what emission controls are appropriate. The BART process has three steps. These steps include:

• Determining if a source is BART-eligible;

• Determining if a source reasonably causes or contri butes to visibility impairment in any Class I area;

• Determining if additional controls or emission limi ts are necessary (BART determination).



### 1.3.1. BART eligibility

There are three factors used to determine if a sou rce is BART-eligible under the CAA. Applicability is limited to those sources tha t:

1. Are in one of 26 specific source categories as iden tified in the Clean Air Act (see Table 2.1 for a list of these categories);BART Resource Guide - DRAFT document, do copy or di stribute Page 1-3

1-3 2. Have units that were in existence on August 7, 1977

, 3 but had not been in operation for more than fifteen years as of that da te (prior to August 7, 1962);

3. Have a potential to emit (PTE) 250 tons per year (T PY) or more of any single visibility impairing pollutant from units that sati sfy criterion #2. These pollutants include SO 2 , NO X , VOCs, PM 10 and ammonia. EPA in the final Regional Haze rule, however, allowed states flexibi lity in addressing

ammonia and VOC sources.

Appendix B contains detailed information on MANE-VU ’s BART eligibility process.



### 1.3.2. Cause or contribute to visibility impairment in a C lass I area

Once a facility is found to be “eligible” for the BART program, states must determine if that facility causes haze or contribut es to the formation of haze at any Class I area. EPA’s 2005 rule outlines three options to det ermine if a source reasonably causes or contributes to regional haze in any Class I area. These options include:

• Individual source assessment (Exemption Modeling) – This assessment uses CALPUFF or other EPA approved modeling methods. Re sults of modeling would be compared to natural background conditions. EPA defined “cause” as an impact of 1.0 deciview or more and “contribute” as an impact of 0.5 deciview or more. The rule, however, gave states discretion to set lower thresholds for

contribution.

• Cumulative assessment of all BART "eligible sources ” – Under this method, a state can choose to find that all eligible sources are subject to BART. This method could also be used to analyze an area’s cont ribution to visibility impairment and demonstrate that no sources are subject, based on cumulative modeling.

• Assessment based on model plants – This method provides a mechanism to exempt sources with common characteristics that are found not to impair visibility

at Class I areas.



### 1.3.3. BART determinations

Once a facility has been identified as BART-eligib le and found to cause or contribute to haze in a Class I area, it must condu ct an engineering review to determine if the installation of new control requirements is app ropriate. This review takes into

consideration five factors:

• Cost

• Energy and non-air environmental impacts

• Existing controls at source

3 August 7, 1977 is the date that Congress adopted the 1977 Clean Air Act Amendments.BART Resource Guide - DRAFT document, do copy or di stribute Page 1-4

1-4 • Remaining useful life of source

• Visibility improvement reasonably expected from the technology.



### 1.4. Overview of Report

This report is intended to integrate all the infor mation states could use to finalize

their BART information for the December 2007 SIP su bmittal. This report provides an overview of MANE-VU’s BART process, BART determinat ions, BART modeling, and BART resources. A brief review of the findings and their implications can be found in Appendix G, which, at this time, is only available to the individual state agency charged with conducting BART reviews for the specific facil ities.BART Resource Guide - DRAFT document, do copy or di stribute Page 2-1

2-1 

## 2. MANE-VU BART PROCESS

The following sections provide an overview of BART activities undertaken by MANE-VU and guiding actions for the region.



### 2.1. BART Workgroup

MANE-VU formed the BART workgroup as part of an eff ort to assist states and tribes as they prepare to comply with the Best Avai lable Retrofit Technology (BART) requirements of the Regional Haze Rule. Membership in the MANE-VU BART workgroup is open to states and tribes in the MANE- VU region, EPA regional offices and the Federal Land Management agencies. This gro up worked together to refine the BART-eligible identification process. In addition, the group has developed recommendations to the MANE-VU Directors on assumpt ions for identifying BARTeligible sources and in making BART control determi nations. To date, states have made substantial progress in identifying sources that ar e BART-eligible. This, however, is only the first step in the process. Once a source is id entified as “BART-eligible,” an analysis

must be conducted to determine what will constitute BART for each facility.



### 2.2. BART Recommendations

The Regional Haze Rule requires states to determin e the most stringent technologically feasible system of controls that ca n reasonably be installed at each facility eligible for BART. The BART workgroup dev eloped a list of recommendations for the BART control process that have been approve d by the MANE-VU Directors. The recommendations include overall BART policies and s pecific “presumptive” levels and types of control. These recommendations will serve as a regional foundation for conducting BART engineering reviews on a state-by-s tate basis. The recommendations have been grouped by the three steps of the BART pr ocess that they affect.



### 2.2.1. Recommendations regarding BART eligibility:

• Any BART-eligible facility may “cap-out” of BART vi a a permit emission limit, however all permit modifications must be finalized prior to December 16, 2006 in order to eliminate BART eligibility. Caps must limit emissions from BARTeligible units below 250 tons per year of any visib ility impairing pollutant. Caps must be in place prior to December 16, 2006 in orde r to enable states to take action to get permit limitations in place and achie ve emission limits prior to SIP public notice and hearing processes.

• If data do not exist

to accurately determine the installation date for emission unit(s) within a facility, then the unit will be treated as though it is withi n the BART date range unless the facility can provide pro of otherwise (i.e., proof that the unit was in operation prior to 1962) . Many states are having difficulty identifying installation dates for pre-1977 units. All states felt they could easily identify post-1977 units. Therefore, the workgroup supported a policy position that when the state could not accurately determine the "in existence" date, theBART Resource Guide - DRAFT document, do copy or di stribute Page 2-2

2-2 burden of proof lay with the facility in proving th at the unit was installed prior to

1962.



### 2.2.2. Recommendations regarding BART control reviews

• If a source is eligible for BART, it is subject to the BART determination process (i.e., no exemptions will be given; note this does not necessarily mean that controls will be required).

• Regional performance standards or cost thresholds a re appropriate for many individual categories of BART-eligible sources. Th e next section contains an initial round of recommended presumptive levels of control for EGUs, industrial boilers, and cement kilns. The workgroup may devel op additional presumptive

levels in the future.

• Remaining useful life of a source will be considered in the following wa y: Facilities have the option to either control a BART-eligible facility prior to 20 13 or accept a federally enforceable permit limitation or retirement date prior to December 16, 2006.

• Control technology in place will likely have to be dealt with on a source-bysource basis (i.e., no regional recommendation).

• Energy and non-air quality environmental impacts wi ll likely have to be dealt with on a source-by-source basis (i.e., no regional recommendation). The workgroup, however, is still considering regional r ecommendations for non-air quality environmental impacts.



### 2.3. Recommended Presumptive BART Levels of Control

The workgroup reviewed other regional control init iatives and attempted to

harmonize those efforts with BART. This review res ulted in the development of a recommended level of presumptive control for EGUs ( CAIR and non-CAIR units) and industrial boilers. In addition, the group develop ed a list of control technologies that must be reviewed for cement kilns. Specific inform ation on presumptive levels is provided below:

Non-CAIR EGUs:

• SO 2 – Coal - 95% control or 0.15 lb/MMBtu* Oil - 95% control or 0.33 lb/MMBtu (0.3% sulfur c ontent)*

• NO X

o in NO X SIP call area, extend use of controls to year-roun d

o 0.1 – 0.25 lb/MMBtu, depending on boiler and fuel t ype

• PM

– 0.02 – 0.04 lb/MMBtu**

CAIR EGUs:BART Resource Guide - DRAFT document, do copy or di stribute Page 2-3

2-3 • SO 2 – CAIR requirements

• NO X – CAIR requirements

• PM

– 0.02- 0.04 lb/MMBtu**

If an EGU is only enrolled in CAIR for one or two p ollutants, it still must complete an analysis for the remaining visibility impairing pol lutants such as particulate matter.

Industrial Boilers

• SO 2 – 90% control, MACT acid gas control level, ICI- RACT, or 0.55 lb/MMBtu (0.5% fuel sulfur limit)

• NO X

o 0.1 – 0.4 lb/MMBtu, depending on boiler and fuel ty pe***

• PM

– 0.02 - 0.07 lb/MMBtu

Cement Kilns

No common emission threshold has been identified. T he following lists, however, recommend control technologies to evaluate.

• SO 2

o in process removal

o wet or dry scrubbers

o conversion from wet kiln to dry kiln

• NO X

o Combustion optimization

o Low NO X burners

o Secondary combustion control (SNCR/SCR)

o Mid-Kiln firing

o Flame shape adjustment

• PM

o baghouse

o electrostatic precipitator

o baghouse/ESP upgrades of existing controls

*Consistent with EPA presumptive BART for EGUs and OTC Control Strategy ** PM measures are based on front-half (Method 5) particulate matter measures *** Consistent with OTC Control Strategies and NO X SIP call emission limits



### 2.4. BART Trading

EPA proposed rules regarding BART trading in July 2005. As of the writing of this report, final rules had not been promulgated. The 2005 EPA proposal (see Appendices) requires that a trading program demonst rate results better than those achieved by the source-by-source BART program and t hat all BART sources in a sector participate. The MANE-VU BART workgroup continues t o be interested in and investigate the possibility of developing a BART tr ading program but several significant barriers exist, including limited resources to mana ge a trading program.BART Resource Guide - DRAFT document, do copy or di stribute Page 3-1

3-1 

## 3. BART DETERMINATIONS

In determining what system of controls constitute BART, the category of fossilfuel fired steam-electric plants with greater than 250 MMBtu/hr heat input (hereafter Electrical Generating Units or EGUs) have been cons idered separately. Many options for reducing emissions from this category of sources ex ist and are widely available. While options for reducing emissions from the other 25 BA RT-eligible source categories also exist – and in many cases are the same options used by EGUs – they are often more source-specific with respect to their applicability or capital costs. We begin the

discussion of BART determinations with EGUs.



### 3.1. EGUs

The BART-eligible EGUs in MANE-VU represent the la rgest emissions reduction potential among the various BART-eligible source categories. The population of BART-eligible EGUs within the MANE-VU domain can be broadly divided into three

groups:

• Those in states eligible for participation in the U .S. EPA Clean Air Interstate Rule (CAIR) program on a year-round basis (Delaware , District of Columbia, Maryland, New Jersey, New York and Pennsylvania for SO 2 and NO X ),

• Those in states that participate in the seasonal CA IR program (Connecticut

and Massachusetts for summertime NO X ), and

• Those in states that are not eligible to participat e in the CAIR program (Maine, New Hampshire, Rhode Island, and Vermont).

Given the decision by the US EPA that CAIR will sat isfy the SO 2 and NO X requirements for BART, a discussion of those CAIR facilities is separated from the non-CAIR EGUs.

We then turn in section 3.1.2 to consideration of h ow BART determinations are

conducted for other EGUs.



### 3.1.1. CAIR

The Clean Air Interstate Rule – or CAIR – is a cap and trade program for SO 2 and

NO X emissions intended to address interstate transport of these pollutants. By requiring a large number of eastern states to reduce emissions of these pollutants, the level of transported sulfate and nitrate fine particulate ma tter, as well as ground-level ozone and precursor pollutants, is anticipated to be greatly reduced. Whether this regulation will deal adequately with transported air pollution and its precursors in the context of NAAQS attainment is a larger question, but within the con text of the CAIR regulation, the states’ ability to seek emissions controls from upwind stat es beyond those required under CAIR is limited. There is an opportunity; however, for additional emission reductions through the Regional Haze Rule’s Reasonable Progress Goals and the inter-RPO consultation process where addressing national visibility goals may also help achieve compliance with various other mandated Clean Air Act programs.

EPA has stated that a state’s participation in the CAIR program will satisfy the BART control requirements for BART-eligible EGUs th at are also subject to the CAIRBART Resource Guide - DRAFT document, do copy or di stribute Page 3-2

3-2 provisions. Those facilities, however, will still n eed to conduct an analysis for PM. This includes all BART-eligible EGUs in Delaware, Distri ct of Columbia, Maryland, New Jersey, New York, and Pennsylvania. EGUs located in Connecticut and Massachusetts are also included in the CAIR program, but only for ozone season NO X

.

While BART determinations still must be conducted f or all BART-eligible sources, it is anticipated that in CAIR states, ado ption of the CAIR program will satisfy BART for the BART-eligible EGUs participating in th e CAIR program for the specific pollutants covered under the rule. This means that all States must still consider whether

PM and VOC controls are warranted at facilities whe re SO 2 or NO X controls may be covered under CAIR. In addition, CAIR-participati ng EGUs in Delaware, New Jersey,

Connecticut and Massachusetts will still have to id entify appropriate SO 2 controls to serve as BART, as well as controls for NO X in the non-ozone season (October through April). Identification of controls for these pollutants, ho wever, must be done with proper consideration of the statutory factors contained in the BART regulations as for any other pollutant. Discussion of issues related to this de termination for potential PM, VOC, or

non-ozone season NO X controls is in the following section and is german e for all controls – including SO 2 and ozone season NO X – being considered by the non-CAIR states of Rhode Island, New Hampshire and Maine. 4



### 3.1.2. Statutory factors

The BART determination process includes an enginee ring review, which requires the identification of the most stringent technologi cally feasible system of controls that can be installed at a facility. An engineering rev iew for each facility in the MANE-VU region will be time-consuming and labor intensive. For states like New York or Pennsylvania, which have a large number of BART-eli gible sources, it may be more efficient to conduct the mandatory review of statut ory factors – and here we are primarily thinking of energy and non-air quality environmenta l factors, other controls already in place, and degree of visibility improvement that co uld result from installation of controls – prior to conducting a detailed engineering review for some facilities. The degree of visibility improvement must be considered in conjun ction with the other statutory factors, but this analysis can be done before the engineerin g review. For many facilities, these statutory considerations could eliminate the reason able installation of controls and obviate the need for an engineering review.

Regardless of which system of controls or control strategy is identified as meeting the objectives of the BART program, states are requ ired to consider (1) the cost of compliance, (2) any energy or non-air quality impac ts of compliance, (3) any existing pollution control technology in use at the source, (4) the remaining useful life of the source, and (5) the degree of visibility improvemen t that may reasonably be anticipated

from the use of BART. Given that EPA has establish ed a presumptive level of SO 2 control for previously uncontrolled EGUs greater th an 750 MW that is consistent with the MANE-VU recommendation for all EGUs, if a state fee ls that the MANE-VU

4 Note that Vermont has no known BART-Eligible sources.BART Resource Guide - DRAFT document, do copy or di stribute Page 3-3

3-3 presumptive levels of control are appropriate at an individual EGU facility, states will not necessarily have to justify the imposition of SO 2 controls, but may have to justify why

NO X and PM controls are reasonable at the levels speci fied through a statutory factor analysis as described in EPA guidance. If, after r eview of the statutory factors, a state still believes that controls on the BART-eligible f acilities are reasonable, then a full engineering review should be conducted in order to establish the most stringent technologically feasible system of controls that is appropriate for that facility. Resources to assist in this process are discussed in the foll owing section.



### 3.1.3. Engineering reviews

The engineering reviews should consider control te chnologies that have been

discussed in the MANE-VU document: Assessment of Control Technology Options for BART-Eligible Sources (Appendix C1). Chapter 2 of that document provide s a detailed listing of pre-combustion, combustion and post-comb ustion options for a variety of EGU types that are prevalent in the MANE-VU region. In formation regarding the typical

installation costs for these facilities has also be en included. States, however, are responsible for reviewing these data to ensure they represent facility-specific installation costs. Other sources of control technology informa tion can be found in US EPA guidance documents (especially its RACT/BACT/LAER c learinghouse). In addition, other RPOs have developed information beyond what i s included in the MANE-VU Assessment. Finally, STAPPA/ALAPCO has also develo ped a control technology assessment for particulate matter that reviews EGUs and many other categories of point, area, and mobile source emissions (see Chapter 5 fo r additional resources).



### 3.1.4. MANE-VU staff BART recommendations

MANE-VU staff developed preliminary BART control r ecommendations, where possible, based upon review of facility data, inclu ding their emission characteristics and controls already in place. Complete data for many facilities are still not available and thus MANE-VU staff was limited in its ability to de velop recommendations for many facilities in some states. For each state, a separ ate spreadsheet has been created with all of the relevant information compiled along with tec hnology or program recommendations for states to consider as a starting point. These are based on consideration of control technologies in place and the presumptive levels es tablished by the MANE-VU BART workgroup. These spreadsheets are available to the state agencies and are not public at

this time. These data will continue to evolve as s tates and MANE-VU staff continues the process of conducting BART determinations over the next several months.



### 3.2. Other Industrial Sources

In addition to EGUs, there are 25 BART-eligible ca tegories including cement plants, paper and pulp facilities, and industrial b oilers. These three categories are prevalent in the MANE-VU region and represent the g reatest emission reductionBART Resource Guide - DRAFT document, do copy or di stribute Page 3-4

3-4 possibilities for the BART program outside the EGU sector. Because the CAIR rule is limited to EGUs, there are no special consideration s with respect to CAIR that must be considered when conducting BART determinations. Th ere are, however, other programs with may interact with BART and these are discussed below.



### 3.2.1. RACT

The MANE-VU member states are also members of the Ozone Transport Commission. At present time, the Ozone Transport C ommission is coordinating the development of an integrated set of control strateg ies that will meet state needs for emission reductions under 8-hour ozone and fine par ticulate national ambient air quality standards (NAAQS) as well as regional haze regulati ons. Among the strategies being discussed is the application of Reasonably Achievab le Control Technologies (RACT) at industrial, commercial, and institutional (ICI) boi lers, refineries, and cement plants. In instances where a BART-eligible boiler or other fac ility is being considered for RACT, it is anticipated that RACT controls will already be i n place by 2009, and that no additional control will be needed under BART for the pollutant s covered by the RACT analysis. Thus for those sources brought into an OTC RACT pro gram, the BART determination would consist of documenting the controls that will be installed and then justifying that no further controls for the relevant pollutants are reasonable in light of the statutory

factors.



### 3.2.2. Permit limitations

Many BART-eligible facilities in the MANE-VU regio n are relatively small emission sources with potential emissions that exce ed the statutory threshold of 250 tons per year or more, but with actual emissions below 2 50 tons in any year. These facilities may wish to accept a permit limitation that restric ts their emissions by law to less than 250 tons per year. The MANE-VU BART workgroup has recommended that if a facility accepts such a permit limitation prior to December 16, 2006, that facility will no longer be BART-eligible and may be eliminated from the BAR T list for that state. The 2006 date was selected in order to give state agencies o ne full year to submit their regulatory package to a full public hearing and adoption proce ss prior to submitting their SIP to the

US EPA.



### 3.2.3. Statutory factors

In the event that a non-EGU source is not brought into an OTC control program being contemplated for 8-hour ozone or fine particu late NAAQS compliance, and is not able to accept a permit limitation rendering a faci lity ineligible for BART, then full BART determinations must be conducted. A starting point would be to consider any controls in place and the degree of visibility impa irment that could be achieved by the installation of controls, followed by engineering r eviews to identify the most stringent technologically feasible system of controls to sati sfy BART.BART Resource Guide - DRAFT document, do copy or di stribute Page 3-5

3-5 This process is very similar to that described abo ve for EGUs, but many of the technology options and resources identified for EGU S may not be applicable for several of the specific source categories within the MANE-V U states (e.g., FGD/scrubbers may be appropriate for EGU or large ICI boilers, but ma y not be appropriate for a chemical plant with many small emission units). MANE-VU has explored technology options for EGUs, ICI boilers, paper and pulp facilities, and c ement plants in the 2005 technology assessment (Appendix C1). Beyond that assessment, the American Forest & Paper Association (AFPA) and the Council of Industrial Bo iler Owners (CIBO) have submitted their own documentation for technology options and other considerations to take into account when conducting BART determinations. MANE- VU has provided this

information as submitted for the states’ considerat ion in Appendix F.

As with EGUs, other sources of control technology information are available as listed in the US EPA guidance document (note especi ally its RACT/BACT/LAER clearinghouse) and other RPOs may have additional i nformation beyond what is included

in the MANE-VU Assessment. STAPPA/ALAPCO has also undertaken a control technology assessment for particulate matter and a draft report is now available. This report reviews EGUs and many other categories of po int, area and mobile source emissions (See Chapter 5 for additional resources).

For many facilities that are not within the EGU, i ndustrial boiler, cement, or paper industrial sectors, states will need to develop fac ility-specific technology assessments of

which controls are feasible and cost estimates for such controls. EPA guidance suggests methods for determining which control option (among several possibilities) will serve as BART for a given source.



### 3.2.4. MANE-VU staff BART recommendations

As in the case of EGUs, MANE-VU has developed prel iminary BART

recommendations based on a review of actual facilit y characteristics, emission characteristics, and controls already in place. Com plete data for many facilities – particularly in the non-EGU source categories – are still not available at this time and thus MANE-VU staff was limited in its ability to de velop recommendations for many facilities in some states. Detailed spreadsheets f or each state have been developed and are available to the state agencies (they are not p ublic at this time) and will continue to evolve as MANE-VU states and staff continue the pro cess of conducting BART

determinations over the next several months.BART Resource Guide - DRAFT document, do copy or di stribute Page 4-1

4-1 

## 4. MODELING

US EPA guidance suggests several detailed modeling approaches for exemption modeling. Given that MANE-VU states have opted to consider all BART-eligible sources as subject to BART, no exemption modeling n eeds to be conducted for MANEVU BART-eligible sources. The US EPA is less speci fic about modeling methods that must be employed in order to determine the degree o f visibility improvement that will

result from installation of controls or how to cons ider that improvement, but they do discuss modeling approaches for performing this “vi sibility improvement determination” and it is worth repeating the following excerpt fro m the US EPA’s guidance here:

“When making this determination, we believe you hav e flexibility in setting absolute thresholds, target levels of improvement, or de minimis levels since the deciview improvement must be weighed among the five factors, and you are free to determine the weight and significance to be assi gned to each factor.”

While the US EPA goes on to describe a basic visibi lity improvement determination modeling approach involving the same basic CALPUFF platform described for exemption modeling, it is less specific about how t he results are used in concert with

other factors to determine what level of control sh ould be considered BART. 5

Given this flexibility, MANE-VU feels comfortable in its approach of developing multiple modeling and data analysis platforms for t he analysis of single source impacts and providing these (along with a protocol explaini ng the development of each platform and results) to each state for their own considerat ion of how to weight the results relative

to the other factors that must be considered in mak ing BART determinations.



### 4.1. Modeling Methods

A separate requirement of the Regional Haze Regul ation requires the development of a contribution assessment, or a poll ution apportionment for visibility impairment. As a part of the technical effort supp orting the development of the MANEVU contribution assessment, several modeling platfo rms and data analysis methods were developed that are capable of distinguishing single source impacts and are now available to support BART modeling in the context of the visi bility improvement determination. In addition, a number of additional modeling and data analysis platforms have been developed that are appropriate only for more aggreg ated (generally state-by-state)

contributions and thus are not included here. All methods and how they are used to develop a weight-of-evidence approach to geographic and regional contribution

5 US EPA suggests a default approach of relying on the CAL PUFF modeling platform with parameter settings taken from the Interagency Workgroup on Air Qualit y Modeling (IWAQM) Phase II recommendations (US EPA, 1998). Any deviations or departu res from these recommendations should be identified and explained in the modeling protocol.BART Resource Guide - DRAFT document, do copy or di stribute Page 4-2

4-2 determinations are described in the MANE-VU contrib ution assessment. 6 Each of the methods for single source contribution assessment i s described briefly below and references are provided to more detailed descriptio ns of each platform. This is followed by discussion of the results from this set of model ing exercises.



### 4.1.1. REMSAD: SO 2 

### tagging

A principal method for assessing the contributions of individual sources to

observed sulfate at Federal Class I areas is based on the REMSAD model. REMSAD is a computationally efficient grid model that has simpl ified photochemistry (this represents a limitation for calculating ozone concentrations wit h accuracy) but has good performance for many components of PM 2.5 , including sulfate. Newer versions of REMSAD incorporate an emission tagging feature that allows for the apportionment of simulated sulfate, nitrate, or mercury among different tagged emission components. MANE-VU has used this platform to tag SO 2 emissions from each state in the eastern U.S. as p art of the pollution apportionment. This tagging feature can also be used to assess the contribution of individual BART-eligible facilities to the measured sulfate at Class I sites before and after controls for a visibility improvem ent determination. Full details on the REMSAD platform, including emissions inventory deve lopment and processing, meteorological data, meteorological model performan ce, and overall model performance

are included in the MANE-VU contribution assessment (Appendix C in footnote 6) and are not repeated here.

Given the time required to process emissions for a n annual run and the time required for an annual REMSAD simulation itself, we do not anticipate running each and every BART-eligible source as an independent tag th rough REMSAD, but will work with the BART workgroup to identify the priority sources and attempt to model as many of these sources as possible.



### 4.1.2. CALPUFF approaches: NWS observation-based and MM5-b ased meteorology

In addition to the REMSAD modeling platform, MANE- VU has also developed two different CALPUFF modeling systems. The Vermon t Department of Environmental Conservation and the Maryland Department of the Env ironment (through their contractor ERM) have jointly developed a set of emissions inpu t files for CALPUFF based on the MANE-VU emission inventory version 2 (MARAMA, 2006) , and supplemented these data with Continuous Emission Monitoring System (CE MS) data for 869 large power plants that reported SO 2 emissions to that system for the full year in 2002

.

6 NESCAUM, Contributions to Regional Haze in the Northeast and Mid-Atlantic United States: the Mid-Atlantic/Northeast Visibility Union (MANE-VU) Contribution

Assessment , ,August, 2006.BART Resource Guide - DRAFT document, do copy or di stribute Page 4-3

4-3 The primary difference between the two CALPUFF pla tforms involves different meteorological datasets developed by each team. E RM developed CALMET-processed meteorology on a large domain (extending from Oklah oma City, OK up to Prince Edward Island, Canada). The CALMET meteorology was proce ssed directly from the MM5 model output developed on a 12-km horizontal grid b y the University of Maryland for the OTC modeling committee and MANE-VU. The Vermont t eam developed CALMET meteorology (for the identical domain) driven by th e National Weather Service’s surface observation network, rawinsonde network, and supple mented by the Airport Surface Observation System (ASOS) network. This observatio n-based dataset provides an alternative to the gridded wind fields generated by the diagnostic model MM5.

Both data sets have been used to estimate contribu tions of individual states and large facilities within states to the sulfate burde n observed at MANE-VU Class I areas for the purposes of the MANE-VU pollution apportionment

. 7 The platforms are now ready to be used for estimating source contributions of i ndividual BART-eligible facilities as states provide modeling parameters for those facili ties. Details on the platform are available in the MANE-VU contribution assessment (A ppendix D in footnote 6).



### 4.1.3. Empirical approaches: emissions divided by distance or Q/d

As one of the screening approaches suggested by th e US EPA in its guidance for exemption modeling, it describes a very simple appr oach involving a review of the ratio of a source’s emissions divided by the distance to a receptor of interest. Based on a review of a memorandum from the North Carolina Depa rtment of Natural Resources, the US EPA suggests that a ratio of 20 may be an approp riate level of significance to use as a threshold level of impact (when emissions are expre ssed in tons per year of the sum of

NO X and SO X and distance is expressed in kilometers).

MANE-VU has modified and included this basic appro ach as one method for inclusion in visibility improvement determinations. The basic approach is extremely simplistic, ignoring meteorological and chemical dy namics of the real atmosphere. Nonetheless, it can be a fairly reliable predictor of relative impact. By comparing the emissions divided by distance, or Q/d, ratio to CAL PUFF-calculated source impacts, a strong linear relationship can be established for a given wind sector. Thus by scaling our Q/d results within a given wind sector to CALPUFF-m odeled impacts for sources within that wind sector, we develop a metric that represen ts the functional empirical approach of the emissions divided by distance method, but takes into account the relative importance of some sources given prevailing winds. The metric is also scaled according to CALPUFF calculated chemical loss rates (see footnot e 6 for details). While this method is dependent on the CALPUFF platform for establishi ng the absolute magnitude of estimated impacts, it is a completely independent e mpirical method for establishing the relative importance of individual sources within a given wind-sector. As such, it can provide evidence of relative improvement with respect to visibility in Class I sites.

7 A pollution apportionment is a required element of the l ong term emissions management strategy required by EPA for compliance with the Regional Haze Rule.BART Resource Guide - DRAFT document, do copy or di stribute Page 4-4

4-4 

### 4.1.4. Data analysis approach: percent time upwind

MANE-VU has developed one additional data analysis approach that can also be used in a relative sense (i.e., to identify potenti al improvement relative to current impacts on Class I areas) on an individual facility basis. By using back trajectories to identify the “upwind residence time” or the fraction of time tha t a selected location spent upwind of a Class I area, and multiplying that time by the tota l emissions from a facility at that location, we can develop a crude metric for relativ e source impact. Again, by comparing this measure of impact before and after an emission s reduction, we can estimate the degree of visibility improvement.



### 4.2. Anticipated Visibility Improvement as a Result of B ART

The preceding section lays out several potential m odeling and data analysis approaches for assessing the degree of visibility i mprovement anticipated to result from installation of BART controls. MANE-VU will apply these techniques to an individual state’s BART-eligible sources and provide results i n the spreadsheets that have been developed for state reference as the states conduct their final BART determinations. While these analyses are being provided to states a s a resource, they are not necessarily the final word on modeling or data analysis for BAR T determinations. Rather, these methods are provided as a regionally consistent fou ndation for assessing the degree of visibility improvement that could result from insta llation of controls at each BART source. Each state will then have the opportunity t o supplement these data with its own modeling or require individual sources within a sta te to conduct modeling of their own, thus enabling each state to tailor its BART determi nation process to individual state

needs.BART Resource Guide Page 5-1



## 5. BART RESOURCES

This resource book provides links and references t o materials useful to states as they conduct BART determinations, in addition to cl arifying the requirements for BART determinations, identifying what progress toward BA RT determinations has been accomplished by MANE-VU to date, and providing an o utline for next steps in the BART determination process. A wide-variety of reso urces have been collected, including relevant regulations, technical memos and reports identifying potentially BART-eligible sources, information on and assessmen ts of potential control technologies, modeling and data analysis protocols, the US EPA and industry provided guidance for states’ consideration, as well as stat e workgroup recommendations representing regional consensus on specific issues. A brief description of the documents

that are cited and their relevance is included here

.



### 5.1. Regulations

The US EPA issued the Regional Haze Rule, which in cluded BART provisions, in 1999. This regulation was subsequently litigated a nd the BART provisions of the rule were remanded to EPA. A revised “BART Rule” was pr oposed and finalized in April 2005. Both the initial Regional Haze Rule and the final BART Rule are attached here as Appendices A1 and A2. Appendix A3 includes a subse quent regulation that addresses how states can implement a trading program in lieu of BART. This is termed the “BART Trading Rule.”



### 5.2. BART Eligibility Resources

In 2001, NESCAUM produced a report that contained a preliminary list of BART-eligible EGUs in the MANE-VU region. This was followed in 2003 with a preliminary list of BART-eligible sources from the other 25 categories of stationary sources. Both of these documents provided lists th at included potential BART-eligible sources. State have subsequently reviewed the NESC AUM lists and further developed them. This has been provided to MANE-VU staff and serves as the basis for the current list of BART-eligible sources. The NESCAUM documen ts, which describe the methodology for developing the preliminary lists fo r both EGUs and non-EGUs, are attached as Appendices B1 and B2.



### 5.3. Control Technology Information

In 2005, NESCAUM published a report entitled Assessment of Control Technology Options for BART-Eligible Sources that reviews potential technology choices for EGUs, industrial boilers, cement kilns, and pap er and pulp facilities. While there are clearly other types of BART-eligible sources in the region that may need controls under the BART program, the majority of potential emissio ns that might be reduced under BART come from these four categories. These catego ries also share the characteristic ofBART Resource Guide Page 5-2

having fairly generic control options. It is like ly that other facilities, like petroleum refineries or chemical plants, will require very un ique control combinations given the diversity of equipment and usage at each facility. While paper and pulp facilities and industrial boilers don’t necessarily have a “one-si ze-fits-all” control method, they do tend to have some more common control approaches that ha ve been utilized previously, and in sufficient numbers to allow the development of a re port with cost estimates for typical installations. This report has been attached as Ap pendix C1.

Additional control technology assessments have bee n developed or are under development by other groups and RPOs and are provid ed here for state consideration. The US EPA maintains a RACT/BACT/LAER clearinghouse with control technology options by source category available at: http://cfpub.epa.gov/rblc/htm/bl02.cfm

. STAPPA/ALAPCO has a contract with M.J. Bradley and Associates to identify potential controls for a wide-variety of source categories, i ncluding many of the BART categories. 8
This work should be completed in the very near futu re, which the states may want to consider. The Midwest RPO hired MACTEC Engineerin g and Consulting, Inc. to conduct a survey of control technology options for BART and its final report is available

at: http://www.ladco.org/reports/rpo/MWRPOprojects/Stra tegies/Final%20Control%20Meas ures.pdf . The VISTAS RPO has developed an Excel spreadshe et with control technology information that may serve as a useful r eference. These links and resources are attached as Appendices C2, C3 and C4, respectiv ely.



### 5.4. Program Implementation Resources

MANE-VU has formed a state working group to formul ate regional positions on BART program implementation to the extent that cons ensus exists. This workgroup has developed a list of recommendations for the air dir ectors’ consideration as BART

determinations are made. These recommendations cov er several aspects of program implementation and include presumptive levels of co ntrols for some source categories. They are contained in Appendix D.



### 5.5. Modeling Resources

In 2005, NESCAUM published an interim contribution assessment report that

contains detailed results from seven different mode ling platforms or data analysis methods used to attribute sulfate pollution in MANE -VU Class I areas. The modeling platforms and analysis techniques are described in great detail in the technical appendices of that document. Each of these analysis platforms has been refined and updated with new results based on current meteorological and emi ssion inventory inputs. A final contribution assessment is being published concurre ntly with this BART resource book that contains the results of that refined analysis. 6 Insofar as four of the seven methods have been discussed here (see Chapter 4) as potenti al methods for visibility improvement

8 STAPPA/ALAPCO, Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options, draft , March, 2006.BART Resource Guide Page 5-3

determinations for BART, the full technical descrip tions of these analysis platforms are resources to be provided for state consideration. The final MANE-VU contribution assessment is attached as Appendix E.



### 5.6. Stakeholder Submitted Information

In addition to technical information generated by MANE-VU, the US EPA, other RPOs, and a number of interested stakeholders have provided MANE-VU with their own assessments of control technology and program imple mentation options. These materials are presented here as submitted by the various grou ps so that states can take this information into consideration when conducting thei r BART determinations. MANE-VU, however, provides no guarantees as to their accurac y. It has not developed these materials nor been involved with their development. MANE-VU does feel it is important for states to be aware of the perspectives of the i ndustry associations that they are regulating.

First, a white paper from the Council of Industria l Boiler Owners (CIBO) (Appendix F1) reconciles the differences between co st estimates for control programs when developed by different groups as opposed to th e regulated industry itself. The white paper is supported by a presentation from Bla ck and Veatch that reviews cost differences between the US EPA and industry cost es timates for NO X and SO 2 controls.

From the American Forest and Paper Association (AF &PA), MANE-VU received a number of control cost estimates, reports and sta tistics. The National Council for Air and Stream Improvement (NCASI) has published a pape r – provided in Appendix F2 – that reviews currently available control technologi es for NO X , SO 2 , and PM for the major emission sources at paper and pulp mills.

AF&PA also provided Appendices F3, F4, F5, and F6 that contain a summary of points to consider when retrofitting boilers at pap er and pulp facilities, AF&PA’s own analysis of control costs for paper and pulp boiler s relative to EPA’s assessments, and two reports developed by consulting firms for the i ndustry to support its cost information.

AF&PA has also submitted a discussion of emissions trading programs and what might be accomplished through the application of su ch a program – as opposed to a source-by-source application of BART—in the CENRAP states. The discussion and the CENRAP white paper are presented as Appendices F7 a nd F8.

Finally, AF&PA provided an Excel file showing the diversity of emission rates

from various boilers. These data are intended to d emonstrate that fixed percentage reduction targets may be difficult to achieve in ma ny cases given the starting baselines, controls, fuels, etc. This spreadsheet is containe d in Appendix F9.BART Resource Guide Page 6-1



## 6. CONCLUSION

The BART program represents a significant emission reduction opportunity for the Northeast and Mid-Atlantic States as they seek to attain 8-hour ozone and PM 2.5 standards and demonstrate reasonable progress towar d national visibility goals under the Regional Haze Rule. While the BART program is desc ribed clearly in guidance documents and regulations, there are a number of pr ovisions that require significant analytical effort. This document is intended to as sist states in navigating the requirements and completing BART determinations for each BART-eligible source in the region.

Many of the BART-eligible emissions reductions are necessarily included in the CAIR caps within states that participate in either the seasonal or annual CAIR program and the US EPA has been fairly prescriptive in how emissions reductions will be achieved from these sources. States may have flexi bility with respect to how they choose

to “harvest” the emissions reductions from several other source sectors. This may allow states to require controls under either the BART pr ogram or under RACT programs with fewer regulatory “hoops.” Finally, many small faci lities that emit less than 250 tons per year of any visibility impairing pollutant may be c apped out of the BART program if permit changes occur prior to the end of 2006.

MANE-VU has provided program recommendations, mode ling resources, and preliminary control recommendations for those sourc es that could be, after consideration of the many interactions between BART and other reg ulatory programs, controlled under the BART program. This information is provided for the states’ consideration. MANEVU is now prepared to work with individual states t o provide further state-by-state assistance as they conduct detailed engineering rev iews and prepare BART SIP

submissions.BART Resource Guide Page A-1



# Appendix A: Regulations

Appendix A: Regulations

A.1. 1999 Regional Haze Rule & Preamble

A.2. 2005 Regional Haze Rule (Final BART Provisions)

A.3. 2005 Regional Haze Rule Preamble (Final BART Provi sions)

A.4. 2005 Proposed BART Trading Rule

A.5. 2005 BART Trading Rule PreambleBART Resource Guide Page B-1



# Appendix B: BART-Eligibility Resources

Appendix B: BART-Eligibility Resources

B.1. A Basis for Control of BART-Eligible Sources, 2001 (EGUs Only)

B.2. Technical Memorandum #6

– Development of a List of BARTEligible Sources in the MANE-VU Region: Interim Rep ort, 2003 (nonEGUs)BART Resource Guide Page C-1



# Appendix C: Control Technology Options

Appendix C: Control Technology Options

C.1. Assessment of Control Technology Options for BART-E ligible Sources, 2005 (EGUs, Industrial Boilers, Cement Pla nts, and Paper and Pulp)

C.2. US EPA RACT/BACT/LAER Clearinghouse (web link) (L01 : http://cfpub.epa.gov/rblc/htm/bl02.cfm )

C.3. Midwest RPO Control Technology Assessment (web link ) (L02: http://www.ladco.org/reports/rpo/MWRPOprojects/Stra tegies/Fin al%20Control%20Measures.pdf )

C.4. VISTAS BART Control SpreadsheetBART Resource Guide Page D-1



# Appendix D: Program Implementation Resources

Appendix D: Program Implementation Resources

D.1. MANE-VU BART Workgroup – Program RecommendationsBART Resource Guide Page E-1



# Appendix E: Modeling Resources

Appendix E: MANE-VU Final Contribution AssessmentBART Resource Guide Page F-1



# Appendix F: Stakeholder Provided Resources

Appendix F: Stakeholder Provided Resources

F.1. CIBO: Industrial Air Pollution Control Project Costs with Control Equipment Cost Representations.

F.2. National Council on Air and Stream Improvement (NCA SI): Retrofit Control Technology Assessment for NO X 

### , SO 2 

### , and PM Emissions from Kraft Pulp and Paper Mill Unit Opera tions, by Arun V.

Someshwar.

F.3. American Forest & Paper Association (AF&PA): Speci al Considerations for Boiler Controls at Paper and Pul p Mills.

F.4. American Forest & Paper Association (AF&PA): EPA C ost
Estimates for NO X 

### Controls on Pulp and Paper Boilers are too Low by

100->300%.

F.5. - American Forest & Paper Association (AF&PA): Stone & Webster report on Control Technology Costs for Pape r and Pulp Industry.

F.6. American Forest & Paper Association (AF&PA): BE & K report on Control Technology Costs for Paper and Pulp Indu stry.

F.7. American Forest & Paper Association (AF&PA): Why Emissions Trading is Important.

F.8. American Forest & Paper Association (AF&PA): CEN RAP Regional Haze Emissions Trading Straw Proposal.

F.9. American Forest & Paper Association (AF&PA): Boi ler Emissions - Control Distribution Figures.BART Resource Guide Page G-1



# Appendix G: BART-Eligible Source Information

by State

Appendix G: BART-Eligible Source Information by State (including: Facility IDs, controls already in place , current emissions, recommended BART, estimated post-BART emissions, and modeling parameters)

G.1. Connecticut

G.2. Delaware

G.3. District of Columbia

G.4. Maine

G.5. Maryland

G.6. Massachusetts

G.7. New Hampshire

G.8. New Jersey

G.9. New York

G.10. Pennsylvania

G.11. Rhode Island