State of Kansas 

Air Quality 

State Implementation Plan 

Regional Haze 

October 26, 2009 

Our Vision - Healthy Kansans living in safe and sustainable environments. 

Department of Health and Environment 

Division of Environment 

Bureau of Air 

(785) 296-6024
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Table of Contents 

List of Tables................................................................................................................................................................3

List of Figures ..............................................................................................................................................................4

List of Appendices .......................................................................................................................................................5

Submittal Letter...........................................................................................................................................................6

Executive Summary.....................................................................................................................................................7

1. Background and Overview of the Federal Regional Haze Regulation...............................................................9

1.1 General Background / History of Federal Regional Haze Rule ..........................................................................9

1.2 States and Tribes without Class I Areas............................................................................................................10

2. General Planning Provisions................................................................................................................................11

3. Regional Planning.................................................................................................................................................12

4. State and Federal Land Manager Coordination................................................................................................14

5. Assessment of Baseline and Current Conditions and Estimate of Natural Conditions in Class I Areas ......15

6. Monitoring Strategy .............................................................................................................................................17

6.1 Current Monitoring Strategy.............................................................................................................................17

6.1.1 Measuring Visibility Data .........................................................................................................................17

6.1.2 Characterizing Visibility Data...................................................................................................................20

6.1.3 Data Validation and Reporting..................................................................................................................21

6.2 Special Monitoring Studies...............................................................................................................................21

6.3 Future Monitoring Strategy ..............................................................................................................................22

7. Emissions Inventory .............................................................................................................................................23

7.1 Inventory Results ..............................................................................................................................................23

7.2 Point Sources ....................................................................................................................................................24

7.2.1 Natural Gas Compressor Stations..............................................................................................................25

7.2.2 Fuel Ethanol Manufacturing Facilities ......................................................................................................26

7.3 Nonpoint Sources..............................................................................................................................................26

7.4 On-Road Mobile Sources..................................................................................................................................29

7.5 Nonroad Mobile Sources ..................................................................................................................................29

7.6 Nonpoint Fires ..................................................................................................................................................29

7.7 Reporting ..........................................................................................................................................................30

8. Modeling Assessment............................................................................................................................................32

8.1 Model Inputs.....................................................................................................................................................33

8.2 Model Performance Evaluation ........................................................................................................................33

8.2.1 Sulfate (SO4) Model Performance.............................................................................................................34

8.2.2 Nitrate (NO3) Model Performance ............................................................................................................34

8.2.3 Organic Matter Carbon (OMC) Model Performance ................................................................................36

8.2.4 Other PM2.5 (soil) Model Performance......................................................................................................36

8.3 Base G Model Simulations ...............................................................................................................................37

8.4 Information from Modeling Performed by Other RPOs ...................................................................................39

8.4.1 MRPO .......................................................................................................................................................39

8.4.2 VISTAS.....................................................................................................................................................39

8.4.3 WRAP .......................................................................................................................................................39

8.5 Control Strategy Simulations............................................................................................................................40

9. Best Available Retrofit Technology.....................................................................................................................44

9.1 BART Eligible Sources in the State of Kansas.................................................................................................44
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9.2 Determination of Sources Subject to BART.....................................................................................................46

9.3 Determination of BART Requirements for Subject-to-BART Sources............................................................48

9.3.1 Kansas City Power & Light (KCP&L)......................................................................................................49

9.3.2 Westar Energy...........................................................................................................................................50

9.4 Projected Emissions Reductions Resulting from Installation of BART Controls.............................................51

9.5 Enforceability of BART Requirements.............................................................................................................51

9.6 Monitoring, Recordkeeping, & Reporting of BART Requirements .................................................................52

10. Reasonable Progress Goals / Long Term Strategy ..........................................................................................54

10.1 Determining Visibility Impact ........................................................................................................................54

10.1.2 Light Extinction at Wichita Mountains ...................................................................................................57

10.2 Selection of Kansas Sources for Reasonable Progress Evaluation .................................................................60

10.3 Reasonable Progress Conclusions...................................................................................................................72

10.4 Long-Term Strategy........................................................................................................................................74

10.4.1 Share of Emission Reductions.................................................................................................................74

 10.4.1.1 Baseline Inventory.............................................................................................................................74

10.4.2 Anthropogenic Sources of Visibility Impairment ...................................................................................74

10.4.3 Factors the State Must Consider..............................................................................................................75

 10.4.3.1 Emission Reductions Due to Ongoing Air Pollution Programs ........................................................75

 10.4.3.2 Measures to Mitigate the Impacts of Construction Activities ...........................................................81

 10.4.3.3 Emission Limitations and Schedules of Compliance ........................................................................82

 10.4.3.4 Source Retirement and Replacement Schedules ...............................................................................83

 10.4.3.5 Agricultural and Forestry Smoke Management.................................................................................83

 10.4.3.6 Enforceability of Emission Limitations and Control Measures.........................................................83

 10.4.3.7 Anticipated Net Effect on Visibility Resulting from Projected Changes to Emissions.....................83

11. Consultation ........................................................................................................................................................85

11.1 Consultation....................................................................................................................................................85

11.1.1 Arkansas and Missouri ............................................................................................................................85

11.1.2 Texas .......................................................................................................................................................86

11.1.3 Oklahoma ................................................................................................................................................86

12. Plan Revisions and Progress Reports................................................................................................................89

13. Determination of the Adequacy of the Existing Plan.......................................................................................90

14. Reference Information .......................................................................................................................................91

14.1 List of References ...........................................................................................................................................91

14.2 List of Acronyms and Abbreviations ..............................................................................................................91

List of Tables 

Table 3.1 CENRAP Geographical Area ......................................................................................................................12

Table 7.1 2002 Kansas Emissions Summary, by Source Category and Pollutant .......................................................23

Table 7.2 2018 Kansas Projected Emissions Summary, by Source Category and Pollutant .......................................24

Table 7.3 Percent Changes in Kansas Air Emissions, by Source Category and Pollutant, from 2002 to 2018 ...........24

Table 7.4 Total 2018 Reductions in NOx and SO2 from Kansas Emission Sources Subject to BART........................25

Table 7.5 2002 Top PM10 Emissions from Kansas Nonpoint (Area) Sources .............................................................27

Table 7.6 2002 Top VOC Emissions from Kansas Nonpoint (Area) Sources.............................................................27

Table 7.7 2002 Top NOx Emissions from Kansas Nonpoint (Area) Sources ..............................................................28

Table 7.8 2002 Top SO2 Emissions from Kansas Nonpoint (Area) Sources...............................................................28

Table 8.1 Kansas NOx Sources Included in the CENRAP Control Strategy Run Using the 2018 Base G Inventory .41

Table 8.2 Kansas SO2 Sources Included in the CENRAP Control Strategy Run Using the 2018 Base G Inventory..41

Table 9.1 Facilities with BART-Eligible Units in the State of Kansas........................................................................45

Table 9.2 Kansas BART-Eligible Emission Units with at Least One > 0.5 dv Visibility Impact Day on Selected 

Class I Areas during 2001–2003 ........................................................................................................................47

Table 9.3 Kansas Facilities with Units Subject to BART under the Regional Haze Rule...........................................48
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Table 9.4 BART Presumptive Limits and Operational Standards for NOx and SO2 at Subject-to-BART Emission 

Units in Kansas ..................................................................................................................................................49

Table 9.5 Projected Emissions Reductions from 2002 Levels after Installation of BART Controls for the Subject-toBART Emission Units in Kansas.......................................................................................................................51

Table 10.1 2018 Percent Total and Absolute Light Extinction Value for Worst 20% Visibility Days at Eleven Class I 

Areas Due to Kansas Air Emission Sources ......................................................................................................56

Table 10.2 2018 Percent Total Light Extinction > 0.5% Due to Kansas Sources for Worst and Best 20% Visibility 

Days for the Wichita Mountains Class I Area....................................................................................................57

Table 10.3 Light Extinction Attributable to Kansas Emission Sources at Wichita Mountains Class I Area, by Source 

Category and Particulate Species .......................................................................................................................59

Table 10.4 Kansas Emission Units Not Subject to BART Emitting at Least 500 Tons/Yr of NOx or SO2 in 2002 ....62

Table 10.5 Refinements to AirControlNET Control Technology Determinations ......................................................63

Table 10.6 Sources with Cost per Ton Reduced Greater than $10,000/ton.................................................................63

Table 10.7 Most Effective Control Technologies with Acceptable Control Costs for Kansas 500-Ton NOx and SO2

Emission Units ...................................................................................................................................................64

Table 10.8 Overall Visibility Improvements Resulting from Application of Most Effective Controls at Selected 

Kansas 500-Ton NOx and SO2 Emission Units..................................................................................................66

Table 10.9 Selected Kansas 500-ton NOx and SO2 Emission Units Showing Significant Visibility Improvement 

Resulting from Application of Most Effective Controls ....................................................................................67

Table 10.10 Ranked List of Kansas Facilities, Emission Units, and Controls after Cost and Visibility Screening.....68

Table 10.11 Summary of Reasonable Progress Non-Cost Statutory Factors for Selected Kansas Point Sources .......69

Table 10.12 Ranked List of Sources under the Reasonable Progress Analysis ...........................................................71

Table 10.13 Kansas Sources Identified in the Control Strategy PSAT Run ................................................................73

Table 10.14 Additional Measures Implemented under the Long-Term Strategy to Meet Reasonable Progress Goals

...........................................................................................................................................................................82

Table 10.15 Net 2002 to 2018 Improvement in Visibility at Selected Class I Areas Due to BART Controls in Kansas

...........................................................................................................................................................................84

Table 11.1 Kansas Sources Identified by Oklahoma as Potentially Impacting Visibility at Wichita Mountains ........87

List of Figures 

Figure 3.1 Geographical Areas of Regional Planning Organizations ..........................................................................12

Figure 6.1 Kansas Improve Protocol Monitoring Network .........................................................................................17

Figure 6.2 Tallgrass Prairie Improve Protocol Monitoring Site ..................................................................................18

Figure 6.3 Cedar Bluff Improve Protocol Monitoring Site..........................................................................................19

Figure 6.4 Sac and Fox Improve Protocol Monitoring Site.........................................................................................20

Figure 7.1 2002 Emissions of Pollutants Contributing to Regional Haze from Kansas Nonpoint Sources.................26

Figure 8.1 Light Extinction for 20% Worst Visibility Days at Wichita Mountains by Particulate Species, Showing 

Observed (Left) versus Modeled (Right) Values ...............................................................................................35

Figure 8.2 Percent Visibility Extinction for the Best and Worst 20% Days at Wichita Mountains.............................36

Figure 8.3 URP Glide Path for Wichita Mountains Class I Area with 2018 Projected Results – 20% Worst Days....38

Figure 8.4 URP Glide Path for Wichita Mountains Class I Area with 2018 Projected Results - 20% Best Days.......38

Figure 8.5 Comparison of 2018 Modeling Results from CENRAP, VISTAS, WRAP, and MRPO ...........................40

Figure 8.6 Comparison of Modeling Results from Base G and Control Strategy Runs ..............................................42

Figure 10.1 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas Sources, by Species, for All 

Source Categories during the Worst 20% Days .................................................................................................55

Figure 10.2 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas Air Emission Sources, by 

Source Category, for All Species during the Worst 20% Visibility Days..........................................................56

Figure 10.3 Glide Path for Wichita Mountains Wilderness Area, Oklahoma, in Terms of Light Extinction..............58

Figure 10.4 Population Growth for the State Of Kansas 1980-2005 and Projected Growth 2010-2020 .....................81
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List of Appendices 

(The appendices are located on the enclosed compact disc.) 

1.1 Guide to Locating 40 CFR § 51.308 Requirements

1.2 EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

2.1 Summary of Legal Authority, Public Participation Process, and Public Comments and Responses on SIP Drafts

4.1 Summary of Federal Land Manager Comments and Responses

4.2 US Department of the Interior Comments on the Kansas Regional Haze SIP

4.3 US Department of Agriculture Comments on the Kansas Regional Haze SIP

7.1 2002 Emissions Inventory

7.2 2018 Emissions Inventory

7.3 Emissions Inventory Technical Documentation

7.4 Natural Gas Production Trends

8.1 Emissions Modeling (TSD Chapter 2)

8.2 Model Performance Evaluation (TSD Chapter 3)

8.3 Additional Supporting Analysis (TSD Chapter 5)

9.1 Identification of BART-Eligible Sources in the State of Kansas

9.2 Modeling Protocol Used to Determine Subject-to-BART Sources

9.3 Results of Modeling to Screen for Sources Subject to BART

9.4 Guidance for Facilities Conducting a BART Analysis

9.5 BART Analysis for KCP&L - La Cygne Units 1 and 2

9.6 BART Analysis for Westar Energy - Gordon Evans Unit 2 and Jeffrey Units 1 and 2 (including May 2009 

addendum for GEEC)

9.7 BART Agreements

9.8 BART Exemption modeling –

Monarch Cement

Kansas City BPU – Quindaro

Kansas City BPU – Nearman

Westar Energy – Hutchinson

Westar Energy – Lawrence

10.1 PSAT Tool-Generated Tables

10.2 2018 Visibility Projections for CENRAP Class I Areas (TSD Appendix D)

10.3 Calculations for Emissions Reductions for Kansas Reasonable Progress Goals

10.4 Kansas Prescribed Fire Emissions

11.1 Sunflower Visibility Analysis Performed by KDHE

11.2 Holcomb Class I Visibility Modeling Report
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Executive Summary 

In amendments to the Clean Air Act (CAA) in 1977, Congress set a national goal to restore 

national parks and wilderness areas to pristine conditions by preventing any future, and 

remedying any existing man-made visibility impairment. In 1999, the U.S. Environmental 

Protection Agency (EPA) finalized the federal Regional Haze Rule, which aims to fulfill the 

goals set forth in the CAA by the year 2064. The Regional Haze Rule addresses the combined 

effects of several pollution sources over large geographic areas. It was therefore necessary to use 

a regional planning approach. 

EPA designated five regional planning organizations (RPOs); the Central Regional Air Planning 

Association (CENRAP) was designated as the RPO representing the central portion of the United 

States. Since its inception, the State of Kansas has been actively involved in CENRAP. The 

Kansas Regional Haze Plan incorporates data analyses, modeling results, and technical support 

documents prepared for CENRAP members by various contractors. In addition, CENRAP has 

served as a platform for consultation between states, tribes, federal land managers (FLMs), and 

stakeholders. 

The federal Regional Haze Rule requires states to submit revisions to their State Implementation 

Plans by December 17, 2007. The Regional Haze Rule applies to all states that contribute to 

visibility impairment, even those states that do not have Class I areas. Technical analyses has 

shown that, while Kansas sources only moderately impact most Class I areas in the CENRAP 

region, Kansas sources have been identified by Oklahoma as potential contributors to visibility 

impairment at the Wichita Mountains Class I area. 

States are required by 40 CFR 51.308 to set reasonable progress goals for achieving natural 

visibility conditions, to develop a long-term emissions reduction strategy, and to maintain a 

monitoring network and emissions inventory to support regional haze programs. In addition, 

Section 51.308(e) outlines the requirements for applying Best Available Retrofit Technology 

(BART) to certain older emission sources that were not previously regulated by the CAA. 

In July of 2005, EPA published a revised final rule, including Appendix Y to 40 CFR part 51, 

entitled “Guidelines for BART Determinations under the Regional Haze Rule.” Kansas followed 

these guidelines in its selection of sources that are subject to BART requirements. Kansas has 

five subject-to-BART emission units at three facilities. The BART requirements are outlined in 

Chapter 9 of this document. 

In addition to requiring BART controls at subject facilities, the state also evaluated other sources 

to address reasonable progress goals. Kansas completed a multi-step analysis for large, nonBART sources which considered the cost of compliance, the time necessary for compliance, the 

energy and non-air quality environmental impacts, and the remaining useful life of the source. 

This analysis is referred to as the statutory factor analysis, or four-factor analysis. Several 

additional sources that were not subject to BART have agreed to implement controls as part of 

the long-term strategy as outlined in Chapter 12 of this document. 

At the onset of the regional haze consultation process, states relied heavily on the Clean Air 

Interstate Rule (CAIR), a rule that addresses the interstate transport of air pollution to downwind 

states. CAIR covered 28 eastern states plus the District of Columbia, and would have reduced 

SO2 emissions by an estimated 5.4 million tons and NOx emissions by an estimated 2 million 

tons by 2015. Affected states had the choice of either meeting the state’s emission budget by 
8

requiring power plants to participate in a cap and trade system, or by means of a measure of the 

state’s choosing. 

Although Kansas was not included in the final CAIR rulemaking, the rule was a major 

component in the underlying assumptions used to determine source apportionment because of the 

reductions expected in neighboring states with Class I areas. 

In July 2008, the D.C. District Court of Appeals vacated the CAIR rule in its entirety. On 

September 24, 2008 EPA filed a petition for rehearing or for a remand of the case without 

vacatur. On December 23, 2008, the D.C. Court of Appeals remanded the case to EPA without 

vacatur so that EPA could remedy CAIR’s flaws as were discussed in their July ruling. At this 

time, it is unclear what the ramifications of this decision may be to the regional haze program. 

Kansas will continue to coordinate in regional efforts to reduce visibility impairment at Class I 

areas by maintaining a visibility monitoring network and emissions inventory, and providing 

periodic progress reports and SIP revisions as required by the Regional Haze Rule. 
9

1. Background and Overview of the Federal Regional Haze Regulation 

1.1 General Background / History of Federal Regional Haze Rule 

In amendments to the Clean Air Act (CAA) in 1977, Congress added Section 169 (42 U.S.C. 

7491) setting forth the following national visibility goal of restoring pristine conditions in certain

national parks and wilderness areas, which it named Class I areas: 

Congress hereby declares as a national goal the prevention of any future, 

and the remedying of any existing, impairment of visibility in mandatory 

Class I Federal areas which impairment results from man-made air 

pollution. 

Over the following years, modest steps were taken to address the visibility problems in Class I 

areas. The control measures taken mainly addressed plume blight from specific pollution 

sources, and did little to address regional haze issues in the Eastern United States. Plume blight 

is the visual impairment of air quality that manifests itself as a coherent plume. This results from 

specific sources, such as a power plant smoke stack, emitting pollutants into a stable atmosphere. 

The pollutants are then transported in some direction with little or no vertical mixing. 

When the CAA was amended in 1990, Congress added Section 169B (42 U.S.C. 7492) 

authorizing further research and regular assessments of progress. In 1993, the National 

Academy of Sciences concluded: “current scientific knowledge is adequate and control 

technologies are available for taking regulatory action to improve and protect visibility” (1). 

In addition to authorizing creation of visibility transport commissions and setting forth their 

duties, Section 169B(f) of the CAA specifically mandated creation of the Grand Canyon 

Visibility Transport Commission (Commission) to make recommendations to the U.S. 

Environmental Protection Agency (EPA) for the region affecting the visibility of the Grand 

Canyon National Park. Following four years of research and policy development the 

Commission submitted its report to EPA in June of 1996. This report, as well as the many 

research reports prepared by the Commission, contributed invaluable information to EPA in its 

development of the federal Regional Haze Rule. 

EPA’s Regional Haze Rule was adopted July 1, 1999, and went into effect on August 30, 1999. 

The Regional Haze Rule aims at achieving national visibility goals by 2064. This rulemaking 

addressed the combined visibility effects of various pollution sources over a wide geographic 

region. This wide-reaching pollution net meant that many states, even those without Class I 

Areas, would be required to participate in haze reduction efforts. EPA designated five regional 

planning organizations (RPOs) to assist with the coordination and cooperation needed to address 

the visibility issue. The Central Regional Air Planning Association (CENRAP) was designated 

as the RPO to represent those states that make up the midsection of the contiguous United States. 

On May 24, 2002, the U.S. Court of Appeals D.C. District Court ruled on the challenge brought 

by the American Corn Growers Association against EPA’s Regional Haze Rule of 1999. The 

Court denied industry’s challenge to the haze rule goals of natural visibility and no degradation 

requirements and remanded to EPA the Best Available Retrofit Technology (BART) provisions 

of the rule. 
10

EPA revised the Regional Haze Rule pursuant to the remand. Amendments to the rule and 

guidelines for BART were finalized on June 15, 2005. To facilitate the review of this State 

Implementation Plan (SIP) by the EPA, federal land managers (FLMs), stakeholders, and the 

public, a guide is provided for locating 40 CFR Section 308 Requirements in this document (see 

Appendix 1.1). The EPA Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308 can 

be found in Appendix 1.2.

1.2 States and Tribes without Class I Areas 

In accordance with 40 CFR 51.308(d), the State of Kansas must address regional haze in each 

mandatory Class I area located outside the State which may be affected by emissions from within 

the State. Kansas consulted with states and tribes in the CENRAP region as outlined in Chapter 

3 and Chapter 11. The State of Oklahoma has determined that Kansas emission sources 

contribute to visibility impairment at the Wichita Mountains Class I area. Other states in the 

region did not find Kansas sources to be significant contributors to visibility impairment in Class 

I areas, at the present. New determinations could be made in the future by other states. 

List of Chapter 1 Appendices

1.1 Guide to Locating 40 CFR Section 308 Requirements 

1.2 EPA Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308 
11

2. General Planning Provisions 

Pursuant to 40 CFR 51.308(a) and (b), the State of Kansas submits this SIP revision to meet the 

requirements of EPA’s Regional Haze Rule which was adopted to comply with the Clean Air 

Act. Elements of this plan address the requirements pursuant to 40 CFR 51.308(d) which 

include regional planning, state and federal land manager (FLM) coordination, setting reasonable 

progress goals, consulting with states that contain Class I areas, and developing a long-term 

strategy. This plan also addresses the Best Available Retrofit Technology (BART) components 

of 40 CFR 50.308(e). In addition, this SIP contains a commitment to provide plan revisions, 

periodic progress reports, and adequacy determinations. 

The State of Kansas has adopted this SIP in accordance with Kansas Air Quality Statutes 65-

3005 et. seq. 

The State of Kansas provided public notice in the Kansas Register on July 17, 2008, of the 

opportunity to comment on the SIP. In addition, Kansas also provided a copy of the SIP to the 

Iowa Tribe in Kansas and Nebraska, the Kickapoo Tribe, the Prairie Band Potawatomi Nation, 

and the Sac and Fox Nation. The State of Kansas held a public hearing regarding the SIP on 

August 20, 2008, in Topeka. Public comments were addressed and are summarized in Appendix 

2.1. 

The State of Kansas provided a second public notice in the Kansas Register on July 16, 2009, of 

the opportunity to comment on the revised SIP. In addition, Kansas also provided a copy of the 

revised SIP to the Iowa Tribe in Kansas and Nebraska, the Kickapoo Tribe, the Prairie Band 

Potawatomi Nation, and the Sac and Fox Nation. The State of Kansas held a public hearing 

regarding the revised SIP on August 27, 2009, in Topeka. Public comments were addressed and 

are summarized in Appendix 2.1. 

List of Chapter 2 Appendices

 

2.1 Summary of Legal Authority, Public Participation Process, and Public Comments and 

Responses on SIP Drafts 
12

3. Regional Planning 

In 1999, EPA and affected states/tribes agreed to create five RPOs to facilitate interstate 

coordination on Regional Haze SIPs. The State of Kansas is a member of the Central Regional 

Air Planning Association (CENRAP) RPO. Member states of CENRAP are listed in Table 3.1. 

Figure 3.1 is a map of all five regional planning organizations. 

Table 3.1 CENRAP Geographical Area 

Arkansas Iowa 

Kansas Louisiana 

Minnesota Missouri 

Nebraska Oklahoma 

Texas 

*Includes both state and tribal areas 

Figure 3.1 Geographical Areas of Regional Planning Organizations 
13

The governing body of CENRAP is the Policy Oversight Group (POG). The POG is made up of 

18 voting members representing the states and tribes within the CENRAP region and non-voting 

members representing local agencies, EPA, Fish and Wildlife Service, Forest Service, and 

National Park Service. The POG facilitates communication with federal land managers, 

stakeholders, and CENRAP staff. 

Since its inception, CENRAP has established an active committee structure to address both 

technical and non-technical issues related to regional haze. The work of CENRAP is 

accomplished through five standing workgroups: Monitoring, Emissions Inventory, Modeling, 

Communications, and Implementation and Control Strategies. Participation in workgroups is 

open to all interested parties. Ad hoc workgroups are formed by the POG to address specific 

issues. Ultimately, policy decisions are made by the CENRAP POG. 

CENRAP has adopted the approach that the Regional Haze Rule requires the states to “establish 

goals and emission reduction strategies for improving visibility in all 156 mandatory Class I 

parks and wilderness areas.” The Regional Haze Rule also encourages states and tribes to work 

together in regional partnerships. 

This SIP utilizes data analyses, modeling results, and other technical support documents prepared 

for CENRAP members by contractors and provided through the CENRAP website or FTP site. 

By coordinating with CENRAP and other RPOs, the State of Kansas has worked to ensure that 

its long-term strategy, reasonable progress goals, and BART determinations provide sufficient 

reductions to mitigate impacts of sources from the State of Kansas on Class I areas. 
14

 4. State and Federal Land Manager Coordination 

Coordination between states and federal land managers (FLMs) is required by 40 CFR 51.308(i). 

FLMs are part of CENRAP’s POG and the membership on standing committees. FLMs have 

contributed to the development of technical and non-technical work as a result of that 

participation. In addition, opportunities have been provided by CENRAP for FLMs to review 

and comment on each of the technical documents developed by CENRAP and included in this 

SIP. The State of Kansas has provided agency contacts to the FLMs as required. In 

development of this plan, the FLMs were consulted in accordance with the provisions of 40 CFR 

51.308(i)(2). 

The State of Kansas sent copies of modeling protocols for BART screening, modeling results, 

and BART analyses to the FLMs. In addition, Kansas provided FLMs an opportunity for 

consultation, in person and at least 60 days prior to holding any public hearing on an 

implementation plan or plan revision. 

During the consultation process, the FLMs were given the opportunity to address their: 

• Assessment of the impairment of visibility in any Class I areas 

• Recommendations on the development of reasonable progress goals 

• Recommendations on the development and implementation of strategies to address 

visibility impairment. 

The State of Kansas sent the draft SIP to the FLMs on November 1, 2007. The State of Kansas 

notified the FLMs of a public hearing to be held on August 20, 2008. A summary of FLM 

comments and responses are included in Appendix 4.1 to this plan. The letters received from the 

FLMs can be found in Appendix 4.2 and 4.3. 

The State of Kansas sent the draft revised SIP to the FLMs on July 16, 2009. The State of 

Kansas notified the FLMs of a public hearing held on August 27, 2009. A summary of FLM 

comments and responses are included in Appendix 4.1 to this plan. 

The State of Kansas will continue to coordinate and consult with the FLMs during the 

development of future progress reports and plan revisions, as well as during the implementation 

of programs having the potential to contribute to visibility impairment in the mandatory Class I 

areas. 

List of Chapter 4 Appendices

4.1 Summary of Federal Land Manager Comments and Responses 

4.2 US Department of the Interior Comments on the Kansas Regional Haze SIP 

4.3 US Department of Agriculture Comments on the Kansas Regional Haze SIP 
15

5. Assessment of Baseline and Current Conditions and Estimate of Natural Conditions in 

Class I Areas 

The goal of the Regional Haze Rule is to restore natural visibility conditions to the 156 Class I 

areas identified in the 1977 Clean Air Act Amendments. Section 51.301(q) defines natural 

conditions: “Natural conditions include naturally occurring phenomena that reduce visibility as 

measured in terms of light extinction, visual range, contrast, or coloration.” Regional Haze SIPs 

must contain measures that make “reasonable progress” toward this goal by reducing 

anthropogenic emissions that cause haze. Although Kansas does not have any Class I areas, this 

chapter is provided as background information to support the technical analyses presented 

throughout this document. 

For each Class I area, there are three metrics of visibility that are part of the determination of 

reasonable progress: 

1) baseline conditions, 

2) natural conditions, and 

3) current conditions. 

Each of the three metrics includes the concentration data of the visibility pollutants as different 

terms in the light extinction algorithm, with respective extinction coefficients and relative 

humidity factors. Total light extinction when converted to deciviews (dv) is calculated for the 

average of the 20 percent best and 20 percent worst visibility days. 

“Baseline” visibility is the starting point for the improvement of visibility conditions. It is the 

average of the IMPROVE monitoring data for 2000 through 2004 and can be thought of as 

“current” visibility conditions for this initial planning period. The comparison of initial baseline 

conditions to natural visibility conditions indicates the amount of improvement necessary to 

attain natural visibility by 2064. 

Each state must estimate natural visibility levels for Class I areas within its borders in 

consultation with federal land managers and other states [40 CFR 51.308(d)(2)]. “Current 

conditions” are assessed every five years as part of the SIP review where actual progress in 

reducing visibility impairment is compared to the reductions committed to in the SIP. 

EPA’s Guidance for Estimating Natural Visibility Conditions under the Regional Haze Program

(2) provides states a “default” estimate of natural visibility. The default values of concentrations

of visibility pollutants are based on a 1990 National Acid Precipitation Assessment Program 

report(3). In the guidance, the United States is divided into “East” and “West” along the western 

boundary of the states one tier west of the Mississippi River. This division divides the CENRAP 

states into “East” (MN, IA, MO, AR, LA) with seven Class I areas, and “West” (NE, KS, OK, 

TX) with three Class I areas. In the two equations, only sulfate and organic carbon have 

different values, but the calculated deciview difference is significant. 

In the guidance, EPA also provides 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 
16

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 particulate species and particle size, the extinction coefficients for certain compounds, 

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

States can choose between the default and refined equations. One equation is used to calculate 

baseline and current conditions of visibility due to haze-causing pollutants and, with natural 

concentrations of the same pollutants; the same equation is used to calculate natural visibility. 

The old (default) algorithm: 

bext = 3 × f (RH) × [Sulfate] 

 + 3 × f (RH) × [Nitrate] 

 + 4 × [Organic Carbon] 

 + 10 × [Elemental Carbon]

 + 1 × [Fine Soil]

 + 0.6 × [Coarse Mass] 

 + 10 

The new (refined) algorithm: 

(Differences from the default are in bold) 

bext = 2.2 × fS (RH) × [Small Sulfate] + 4.8 × fL(RH) × [Large Sulfate] 

 + 2.4 × fS (RH) × [Small Nitrate] + 5.1 × fL(RH) × [Large Nitrate] 

 + 2.8 × fS (RH) × [Small Organic Carbon] + 6.1 × fL(RH) × [Large Organic Carbon] 

 + 10 × [Elemental Carbon]

 + 1 × [Fine Soil]

 + 1.7 × fSS(RH) × [Sea Salt] 

 + 0.6 × [Coarse Mass]

 + Rayleigh Scattering (Site Specific) 

 + 0.33 × [NO2 (ppb)] 

 

The choice between use of the default or the refined equation for calculating the visibility 

metrics for each Class I area is made by the state in which the Class I area is located [40 CFR 

51.308(d)(2)]. Kansas consulted with other CENRAP states as those states assessed baseline and 

natural visibility conditions in their respective Class I areas. 
17

6. Monitoring Strategy 

Section 51.308(d)(4) of the federal Regional Haze Rule requires a monitoring strategy for 

measuring, characterizing, and reporting regional haze visibility impairment that is representative 

of all mandatory Class I areas. The monitoring strategy relies, in large part, upon participation in 

the Interagency Monitoring of Protected Visual Environments (IMPROVE) network. The 

IMPROVE website is located at http://vista.cira.colostate.edu/improve/.

6.1 Current Monitoring Strategy 

 6.1.1 Measuring Visibility Data 

Shortly after creation of the Central Regional Air Planning Association (CENRAP), the 

organization’s Monitoring Workgroup identified large visibility data voids in southern Arkansas, 

Iowa, Kansas, southern Minnesota, Nebraska, and Oklahoma. Only five IMPROVE sites were 

located in the CENRAP region. Between 2000 and 2003, five more IMPROVE sites and 15 

IMPROVE Protocol sites (i.e., sites not managed by IMPROVE directly but by individual 

government or tribal organizations) were established in the CENRAP region. 

In conjunction with CENRAP and EPA Region 7, Kansas installed one IMPROVE protocol 

sampler at Cedar Bluff State Park in Trego County in the western part of the State, and another at 

the Tallgrass Prairie National Preserve in the Flint Hills region of eastern Kansas. A third 

IMPROVE Protocol sampler in Kansas is operated independently at Reserve, Kansas, by the Sac 

and Fox Nation of Missouri in Kansas and Nebraska. 

Figure 6.1 Kansas IMPROVE Protocol Monitoring Network 
18

 6.1.1.1 Tallgrass Prairie 

The IMPROVE Protocol site at Tallgrass Prairie National Preserve is located in the heart of the 

Flint Hills of eastern Kansas. The 10,894 acre preserve was established in 1996, with most of 

the land held in trust, but managed by the National Park Service. This area is within the largest 

remaining expanse of tall grass prairie in North America. 

Management of this prairie region requires seasonal burning of grass in the early spring to inhibit 

the invasion of woody and non-native plants and to maximize the rate of weight gain in beef 

cattle early in the grazing season. Kansas considers monitoring in the Flint Hills to be a priority, 

and future addition of monitors at the Tallgrass Prairie site is a possibility. 

Tallgrass IMPROVE 

Protocol 

Lat: 38.43411 

Long: -96.56038 

Chase 

County 

Start: 

9/2/2002 

Figure 6.2 Tallgrass Prairie IMPROVE Protocol Monitoring Site 

 6.1.1.2 Cedar Bluff 

The site at Cedar Bluff Reservoir in western Kansas serves as the State's background site for 

evaluating baseline levels of regional ambient air pollutants (i.e., PM2.5 and ozone) in Kansas. 

The Cedar Bluff site is approximately 175 miles from the Tallgrass Prairie site, 200 miles from 

the Newkirk, Oklahoma site, and 240 miles from the Sac and Fox (Reserve, Kansas) site. 

Because of its remote location, this site was selected for installation of an IMPROVE Protocol 

sampler to fill a very large spatial data gap in the CENRAP region. The site also hosts a 

CENRAP nephelometer. Preliminary analysis of data has indicated that the Cedar Bluff site is 

influenced by air masses originating in different regions at different times of the year, due to its 

location in the center of North America and associated meteorology. The State of Kansas 

considers the IMPROVE Protocol sampler at this site to be a priority. 
19

Cedar Bluff IMPROVE 

Protocol 

Lat: 38.77027 

Long: -99.76361 

Trego 

County 

Start: 

6/1/2002 

Figure 6.3 Cedar Bluff IMPROVE Protocol Monitoring Site 

 6.1.1.3 Sac and Fox Nation of Missouri in Kansas and Nebraska 

The Sac and Fox Nation of Missouri in Kansas and Nebraska also operates an IMPROVE 

Protocol sampler at Reserve, in northeast Kansas. This location hosted a satellite supersite 

during the last five months of 2002. Data from this site are used for modeling and to determine 

the transition zone between the eastern U.S. and the central plains. 

Sac and 

Fox Nation 

IMPROVE

Protocol 

Lat: 39.97915 

Long: -95.56816 

Sac and Fox 

Reservation 

Start: 

6/19/2002 
20

Figure 6.4 Sac and Fox IMPROVE Protocol Monitoring Site 

For information about the Sac and Fox IMPROVE protocol site, contact: 

 Sac and Fox Nation of Missouri 

Rick Campbell (785) 742-4705

rick.campbell@sacfoxenviro.org

 6.1.2 Characterizing Visibility Data 

The State of Kansas does not have any mandatory Class I Federal areas. In accordance with 40 

CFR 51.308(d)(4)(iii), states without Class I areas must establish 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 affected mandatory Class I Federal 

areas in other states. The procedures were established through the work completed by 

contractors retained by CENRAP, and are only briefly described here. 

IMPROVE monitoring data for the 2000-2004 period was used to define baseline, natural, and 

2018 conditions for each of the Class I areas. PM10 was speciated into six components (sulfate, 

particulate nitrate, organic carbon, elemental carbon, soil, and coarse mass) which were used to 

develop relative response factors (RRFs) between current and predicted concentrations for each 

component. The RRFs were multiplied by current baseline values to estimate future 

concentrations. The visibility improvements for 2018 were then calculated using the original or 

new IMPROVE equation. Additional information about these analyses can be found in Chapter 

4 of the Technical Support Document (TSD) prepared by ENVIRON and the Causes of Haze 

Assessment work performed by Sonoma Technology, Inc. (4). These documents can be found at 

http://www.kdheks.gov/bar/index.html

Kansas also relied upon source apportionment modeling (CAMx PSAT) in determining the 

State’s contribution to other Class I areas. This type of modeling provides the best available 

estimate of the potential visibility impacts Kansas may have on various surrounding Class I areas 
21

in 2018. Source apportionment modeling for the CENRAP region is outlined in Chapter 10 of 

this document. 

6.1.3 Data Validation and Reporting 

The filter samples from all IMPROVE modules from the three IMPROVE-protocol sites in 

Kansas are sent for analysis to the Crocker Nuclear Laboratory at the University of California in 

Davis, and the resultant data are subjected to preliminary review and quality assurance/quality 

control (QA/QC) procedures. Nephelometer data from the Cedar Bluff site are validated by the 

CENRAP contractor. Other visibility-related data collected by the State of Kansas (PM2.5, SO2, 

NO2, and NH3) are subjected to review and QA/QC procedures prior to reporting. 

After validation, data from the three IMPROVE-protocol sites in Kansas are sent by the Crocker 

Nuclear Laboratory at the University of California in Davis for posting to the IMPROVE website 

and the Visibility Information Exchange Web System (VIEWS) website 

[http://vista.cira.colostate.edu/views/]. Nephelometer data from the Cedar Bluff site are reported 

to the VIEWS database by the CENRAP contractor. Other visibility-related data collected by the 

State of Kansas (PM2.5, SO2, NO2, and NH3) are reported to EPA's Air Quality System (AQS) 

database on a quarterly basis. For the State of Kansas, this fulfills the reporting requirement of 

visibility data under 40 CFR 51.308(d)(4)(iv). 

6.2 Special Monitoring Studies 

CENRAP, in cooperation with member states and tribes, studied the impacts of ammonia on 

visibility impairment in the CENRAP region. Preliminary monitoring studies and monitoring 

data analysis suggest that ammonia contributes to visibility impairment in the CENRAP 

geographical area. 

During two measurement periods in 2002 (August 24 – October 23 and November 18 –

December 31), an intensive study was conducted to characterize ambient fine particulate matter 

(PM2.5) at the Sac and Fox Nation IMPROVE Protocol site in Reserve. The sampling station 

was configured in the same manner as the St. Louis, Missouri Supersite. Selected semicontinuous monitors remained in operation during the six-week interim period. This special 

study was funded by CENRAP and EPA Region 7. Daily 24-hour mass reconstructions 

demonstrated the episodic nature and seasonal variations of sulfate (summer/fall) and nitrate 

(fall/winter). Ion balances for 24-hour sampling periods were consistent with conditions 

favorable for formation of ammonium nitrate. A sulfate transport episode was captured as well 

as elevated local ammonia levels possibly associated with seasonal application of anhydrous 

ammonia to corn and soybean fields. 

From November 1, 2003 through June 28, 2006, the Sac and Fox Nation also operated a passive 

ammonia monitoring station for a CENRAP ammonia monitoring project. Denuder-based gasphase ammonia, nitric acid, and sulfur dioxide were monitored at the Reserve, Kansas site and 

six other sites within the CENRAP region. Twenty-four hour samples were collected on a onein-six day schedule. The denuder-based samples were analyzed by the Illinois State Water 

Survey Laboratory. IMPROVE Protocol samplers were in operation at all but one of the 
22

CENRAP ammonia study sites. This special ammonia study was conducted to collect data for 

evaluation of the role of ammonia in regional haze formation in the CENRAP region. 

6.3 Future Monitoring Strategy 

In order to assess progress in reducing visibility impairment in Class I areas, the existing 

IMPROVE and IMPROVE Protocol sites will be maintained contingent upon continued national 

funding. Data from the IMPROVE Protocol sites in Kansas will be used to characterize and 

model conditions within the State of Kansas. Data from IMPROVE monitors will be used to 

compare visibility conditions in Kansas to regional haze visibility impairment at Class I areas 

affected by emissions from Kansas to satisfy requirements of 40 CFR 51.308(d)(4)(i). The State 

of Kansas will evaluate the monitoring network periodically, including an evaluation of changes 

in technology and the need for new monitors. With continuation of adequate funding, the 

network will be reconfigured as necessary to enable assessment of reasonable progress toward 

goals for each of mandatory Class I area potentially affected by emissions from within the State 

of Kansas. 
23

7. Emissions Inventory 

Kansas is required by 40 CFR 51.308(d)(4)(v) to provide a statewide emissions inventory of 

pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any 

mandatory Class I area(s). 

7.1 Inventory Results 

As specified in the applicable EPA guidance, the pollutants inventoried by Kansas include 

volatile organic compounds (VOCs), nitrogen oxides (NOx), fine particulates (PM2.5), coarse 

particulates (PM10), ammonia (NH3), and sulfur dioxide (SO2). An inventory was developed for 

the baseline year 2002; a summary of those inventory results is presented in Table 7.1. The 

complete 2002 emission inventory can be found in Appendix 7.1. Included in this appendix are 

two other categories, fugitive dust and road dust, which are not included in the summaries below. 

Table 7.1 2002 Kansas Emissions Summary, by Source Category and Pollutant 

VOC NOx PM2.5 PM10 NH3 SO2

Source category 

tons/yr 

Point 40,278 165,224 16,321 38,366 59,750 143,367

Nonpoint (except fires) 87,327 13,851 10,024 10,533 796 3,100

On-road mobile 74,519 100,152 1,607 2,179 2,816 3,097

Nonroad mobile 28,138 82,697 5,993 6,549 115 8,101

Nonpoint fire 35,046 29,322 117,597 129,187 19 11,051

Biogenic 575,073 49,616 N/A N/A N/A N/A

Totals 840,381 440,862 151,542 186,814 63,496 168,716

Methodologies for the 2002 emissions inventory are documented in Appendix 7.3. 

These 2002 emissions were grown to year 2018, primarily using the Economic Growth Analysis 

System (EGAS6), MOBILE 6.2 vehicle emission modeling software, and the Integrated Planning 

Model (IPM) version 2.93 for electric generating units (EGUs). Table 7.2, a summary of those 

inventory results follows; the complete 2018 emissions inventory is submitted as Appendix 7.2. 

Methodologies for the 2018 emissions inventory are documented in Appendix 7.3.

Table 7.3 presents percent changes in the inventory based on values in Tables 7.1 and 7.2, in 

relation to base year 2002. Discussions of the projected changes for different source categories 

follow. 
24

Table 7.2 2018 Kansas Projected Emissions Summary, by Source Category and Pollutant 

VOC NOx PM2.5 PM10 NH3 SO2

Source category 

tons/yr 

Point 54,007 145,647 23,669 50,165 71,623 81,664 

Nonpoint (except fires) 104,983 15,822 9,143 9,534 1,247 3,860 

On-road mobile 32,724 28,779 655 655 3,892 369 

Nonroad mobile 15,156 38,044 2,696 2,954 52 126 

Nonpoint fire 35,046 29,322 117,597 129,187 19 11,051 

Biogenic 575,073 49,616 N/A N/A N/A N/A 

Totals 816,989 307,230 153,760 192,495 76,833 97,070 

Table 7.3 Percent Changes in Kansas Air Emissions, by Source Category and Pollutant, from 

2002 to 2018 

Source category VOC NOx PM2.5 PM10 NH3 SO2

Point 34.1% -11.8% 45.0% 30.8% 19.9% -43.0% 

Nonpoint (except fires) 20.2% 14.2% -8.8% -9.5% 56.7% 24.5% 

On-road mobile -56.1% -71.3% -59.2% -69.9% 38.2% -88.1% 

Nonroad mobile -46.1% -54.0% -55.0% -54.9% -54.8% -98.4% 

Nonpoint fire 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

Biogenic 0.0% 0.0% N/A N/A N/A N/A 

Totals -2.9% -30.3% 1.5% 3.0% 21.0% -42.5%

7.2 Point Sources 

The majority of visibility-impairing point source emissions in Kansas currently come from the 

electric utility sector. This sector represented 93% of the reported SO2 emissions and 57% of the 

NOx emissions for the 2002 inventory year. The other large NOx emissions category in Kansas 

is the natural gas compression industry, which represented 28% of total NOx emissions for the 

2002 inventory year. Unlike the larger non-municipal electric generating units (EGUs), which 

are generally located in the eastern third of Kansas, several large natural gas compressor stations 

are located along pipelines crisscrossing the State, with numerous other stations clustered around 

the Hugoton and Panoma gas fields in the southwest. In 2002, 19 EGUs reported NOx emissions 

over 100 tons, whereas in the same period 95 natural gas compressor stations reported NOx

emissions over 100 tons. 
25

For the point source sector, Kansas projects significant reductions in NOx and SO2 by 2018, 

primarily at the five EGU units in the State found to be subject to BART controls. Table 7.4 

details the reductions predicted from these emission units. 

Table 7.4 Total 2018 Reductions in NOx and SO2 from Kansas Emission Sources Subject to 

BART 

2002 

NOx

1

2002 

SO2

1

2018 

NOx

2

2018 

SO2

2

NOx

reduction 

SO2

Subject-to-BART unit reduction 

tons/yr 

KCP&L - La Cygne 1 30,058 6,648 2,576 3,948 27,482 2,700

KCP&L - La Cygne 2 8,362 19,355 6,229 3,993 2,133 15,362

Westar - Gordon Evans 2 2,023 3,211 138 0.0 1,886 3,211

Westar - Jeffrey 1 9,602 20,459 4,268 3,532 5,334 16,927

Westar - Jeffrey 2 10,892 23,715 4,040 3,465 6,852 20,251

Total BART reductions 43,687 58,451

1

 Data from EPA Clean Air Markets 

2

 Data from IPM 3.0 

The remaining 2002 to 2018 emissions differences reflect the projected growth in emissions due 

to construction of new sources. The projections were estimated by using EGAS 5.0 for the nonEGU sources and the Integrated Planning Model (IPM), version 2.93 for the EGU sector. At the 

time this document was being prepared, a 1,400 MW coal-fired power plant was in the 

permitting process in Kansas. This power plant, located in Holcomb in the southwest portion of 

the State, was analyzed for visibility impacts on the Wichita Mountains Class I area. It was 

determined, using CAMx PSAT modeling, that visibility impairment in the Wichita Mountains 

attributed to this new source would be below 0.5 delta deciview. The permit for the 1,400 MW 

power plant was denied by the Secretary of KDHE. However, on May 4, 2009, a settlement 

agreement was reached that allows for an 895 MW coal-fired power plant to be constructed in 

Holcomb. 

7.2.1 Natural Gas Compressor Stations 

From 1995 to 2005, production from the Hugoton gas field, the State’s largest natural gas 

production area, has decreased from approximately 460,000 billion cubic feet (Bcf) to 200,000 

Bcf. Over the same period, actual NOx emissions reported from the compressor stations have 

steadily decreased from 75,000 tons/yr to 50,000 tons/yr. Kansas expects emissions from this 

sector to continue to decline as production declines and equipment is replaced with new, more 

efficient designs. Additional information on this sector can be found in Appendix 7.4. 
26

7.2.2 Fuel Ethanol Manufacturing Facilities 

In 2002, there were four ethanol plants in operation in Kansas, with a total production capacity of 

164 million gallons per year (Mgal/yr). That number grew to 14 facilities in 2007 with a total 

capacity of 814 Mgal/yr. Currently, there are 12 active ethanol facilities, 3 facilities under 

construction, 1 facility that has been permitted but not yet built, 1 facility built but not active, and 

1 facility whose permit application is pending. In 2008 and 2009, expansion of the fuel ethanol 

industry in Kansas has slowed dramatically. The actual emission rate of NOx for these plants is 

quite low. KDHE does not anticipate visibility impacts due to the operation of additional 

facilities. 

7.3 Nonpoint Sources 

Nonpoint source emissions were compiled from the final 2002 National Emissions Inventory 

(NEI) database. Although PM2.5 emissions values are not available from this data source, the 

NEI gives emissions estimates at a detailed level for source categories, so that source attribution 

is more easily analyzed. (Note also the ratio of PM2.5 to PM10, can for comparative purposes be 

approximated as 0.2). Only pollutants likely to contribute to regional haze (i.e., NOx, SO2, PM10, 

and VOC) were considered in this analysis. The relative contributions of these pollutants within 

the nonpoint source category are shown in Figure 7.1. 

Figure 7.1 2002 Emissions of Pollutants Contributing to Regional Haze from Kansas Nonpoint 

Sources 

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

P M1 0 VO C NO x S O 2

to ns/y r
27

PM10 accounts for by far the largest nonpoint source category, and can be attributed primarily to 

agricultural crop production (including burning of crop residue), unpaved and paved road dust, 

and dust from construction activities. Tables 7.5 through 7.8 give the relative contributions from 

the top sources of nonpoint emissions for the State for each of the four haze-causing pollutants. 

These values are based on the 2002 National Emissions Inventory. 

Table 7.5 2002 Top PM10 Emissions from Kansas Nonpoint (Area) Sources 

Source classification tons/yr % of nonpoint PM10 % of total PM10 

Unpaved roads 275,026 37.9% 36.6% 

Agricultural crop production 253,845 35.0% 33.8% 

Agricultural burning 99,292 13.7% 13.2% 

Road construction 48,050 6.6% 6.4% 

Paved roads 32,892 4.5% 4.4% 

Mining and quarrying 7,539 1.0% 1.0% 

Table 7.6 2002 Top VOC Emissions from Kansas Nonpoint (Area) Sources 

Source classification tons/yr 

% of nonpoint

VOC % of total VOC

Agricultural burning 55,058 41.4% 22.7% 

Residential fuel combustion 18,758 14.1% 7.7% 

Gasoline service stations 13,398 10.1% 5.5% 

Misc. commercial solvents 7,986 6.0% 3.3% 

Misc. consumer solvents 7,185 5.4% 3.0% 

Misc. industrial solvents 6,554 4.9% 2.7% 

Graphic arts solvents 6,476 4.9% 2.7% 

Surface coatings (solvent evap.) 5,704 4.3% 2.4% 

All other misc. solvent usage 4,044 3.0% 1.7% 
28

Table 7.7 2002 Top NOx Emissions from Kansas Nonpoint (Area) Sources 

Source classification tons/yr 

% of nonpoint 

NOx 

% of total NOx 

Agricultural burning 29,099 68.8% 7.6% 

Industrial fuel combustion 6,298 14.9% 1.6% 

Residential fuel combustion 4,203 9.9% 1.1% 

Table 7.8 2002 Top SO2 Emissions from Kansas Nonpoint (Area) Sources 

Source classification tons/yr % of nonpoint 

SO2 

% of total 

SO2 

Industrial fuel combustion 24,218 66.6% 12.9% 

Agricultural burning 10,949 30.1% 5.9% 

The nonpoint source category represents a large portion of the total anthropogenic emissions 

inventory for VOC emissions. This pollutant from nonpoint sources is projected to grow by 20% 

in 2018 from the 2002 estimate. In 2018, the estimate is for approximately 105,000 tons/yr of 

VOC from the nonpoint source category. Much of the nonpoint VOC category is from solvent 

utilization and residential heating. Because VOC is not anticipated to be a large contributor to 

visibility impairment in the Class I areas surrounding Kansas, the remaining focus will be on 

NOx and SO2 nonpoint source emissions. 

NOx and SO2 make up a relatively small proportion of the State’s nonpoint emissions inventory, 

at 42,282 tons/yr and 36,385 tons/yr, respectively. With the exception of agricultural burning, 

the major contributing source categories for NOx are associated with residential, industrial, and 

commercial natural gas combustion. These categories are projected to grow at a moderate pace 

between 2002 and 2018. For SO2, the major contributing categories are industrial fuel (primarily 

coal and distillate oil) combustion. These categories are also projected to grow at a moderate 

pace between 2002 and 2018. The nonpoint industrial coal combustion category in the National 

Emissions Inventory is overestimated, both in the 2002 and 2018 projected inventories, as most 

industrial sources utilizing coal are captured in the State’s point source inventory. In addition, 

the distillate and residual oil combustion in the nonpoint sector are likely to remain unchanged or 

decrease between 2002 and 2018. At worst, if the 2018 projections are correct, the nonpoint 

emissions for SO2 are still only a fraction of the point source SO2 emissions. 
29

7.4 On-Road Mobile Sources 

EPA’s MOBILE6.2 emissions model predicts reductions for NOx, SO2, and VOC from 2002 to 

2018 of 71.3%, 88.1%, and 56.1%, respectively. These reductions are due to vehicle turnover 

and full implementation of current federal regulations, including the federal emission standards 

for light-duty vehicles and light-duty trucks and the Tier 2 Program. These rules are discussed in 

more detail in Chapter 10. Note that growth in the total vehicle miles traveled (VMT) metric for 

the 2002 to 2018 period for Kansas increased from 28,825 million vehicle miles in 2002 to 

38,509 million vehicle miles in 2018, constituting a 34% increase. 

7.5 Nonroad Mobile Sources 

The nonroad mobile emissions category includes aircraft operations, marine vessels, recreational 

boats, railroad locomotives, and a broad category of other equipment ranging from large 

construction equipment to handheld string trimmers. Calculation methods for emissions from 

nonroad engine sources are based on information about equipment population, engine 

horsepower, load factor, emission factor, and annual usage. The EPA’s NONROAD 2005 model 

was used to estimate emissions for much of the nonroad category. For those categories not 

included in the NONROAD model, separate estimations were made. 

All pollutants in the nonroad category are projected to decrease from 2002 to 2018. The 

majority of predicted emissions reductions in the nonroad category occur for SO2, with projected 

reductions of 98%. This large reduction is due to the requirement to use low sulfur diesel fuel by 

2010. For the remaining pollutants, the reductions can be attributed to the use of newer 

equipment subject to more stringent emissions requirements, including the Clean Air Nonroad 

Diesel Rule, locomotive emission standards, the Large-Spark Ignition and Recreational Vehicle 

Rule, and Emissions Standards for New Nonroad Small Spark-Ignition Engines, Equipment, and 

Vessels. These rules are discussed in more detail in Chapter 10. 

7.6 Nonpoint Fires 

Fires within the nonpoint source category in Kansas make up a large portion of the State’s 

emissions inventory for certain pollutants. The majority of the fires are rangeland burning in the 

Flint Hills area, along with wheat stubble burning in counties just west of the Flint Hills. Both of 

these burning categories are very episodic in nature, with the rangeland burning occurring in the 

early spring and wheat stubble burning occurring after harvest in mid to late summer. Kansas is 

in the process of developing a Smoke Management Initiative, which will achieve reductions from 

both cropland and rangeland burning. The Smoke Management Initiative was developed after 

the completion of the emissions inventory and the associated reductions were not captured in the 

2018 estimations. The emissions used in the modeling for burning remained unchanged from 

2002 to 2018. 

Kansas will continue to pursue methods and techniques to better characterize the emissions 

associated with agricultural burning, including the temporal and spatial allocation of these 

emissions. For more information on these efforts refer to Appendix 10.4, Kansas Prescribed Fire 

Emissions. 
30

7.7 Reporting 

States are required by 40 CFR 51.308(d)(4)(v) to include in their SIPs a commitment to update 

their statewide emissions inventories periodically. In reference to the emissions inventory work 

carried out for regional haze purposes, Kansas expects to update its emissions inventory as new 

data become available. 

The State of Kansas tracks air emissions over time as required by current EPA regulations and 

the Air Emissions Reporting Rule (AERR). This federal rule, proposed in December 2005 and 

finalized in December 2008, consolidates the current emission inventory reporting requirements, 

and will require that emissions be reported every three years from the following source 

categories in all parts of the State, excluding sources located on tribal lands: 

• Point 

• Nonpoint 

• On-road mobile 

• Nonroad mobile 

In addition, all visibility-impairing pollutants are required to be included for the reportable 

categories listed above. These pollutants will include NOx, SO2, PM10, PM2.5, VOCs, and NH3. 

The rule states that beginning in 2009, emissions reports will be due 12 months after the end of 

the year instead of the current 17 months. The rule can be found at: 

http://www.epa.gov/ttn/chief/aerr/

Kansas intends to follow the reporting requirements of the AERR where funding and staffing 

allow. Kansas commits to updating its point source emissions inventory annually and to analyze 

sectors identified in the regional haze planning process that need improvement. 

In the past, Kansas provided complete point source inventories, and partial supplemental 

inventories for the nonpoint (area), on-road mobile, and nonroad mobile source categories. 

Kansas chose to supplement EPA-generated nonpoint, on-road, and nonroad inventories with 

more accurate information when available. Thus, except for point source categories, future 

inventories will likely continue to be a hybrid EPA/Kansas-generated product. 

It is anticipated that the initial five-year progress report will occur in 2014. The 2011 National 

Emissions Inventory will likely be the most current available inventory at that time and will be 

used as part of the progress report. It is expected that Kansas will also have access to a later 

point source inventory and continuous emissions monitoring systems (CEMS) data for EGUs. 

Where this more up-to-date information is available, it will used to supplement the 2011 

National Emissions Inventory. 

Kansas will use the latest available inventory for the five-year progress report, and compare that 

with the projected 2018 inventories. Because the 2018 projected inventory contains BART 

controls that may not yet be reflected in the 2011 inventory, these sources will be addressed 

individually in this review. For the remaining sectors, EGAS growth rates will be used, where 

applicable, and projected growth will be compared with actual emissions. If this comparison 
31

indicates overall emissions are growing at a rate significantly (i.e., more than 10%) higher, on an 

individual species basis than previously projected, Kansas will reassess the visibility impacts on 

potentially affected Class I areas and consult with the appropriate federal land manager (FLM) 

and EPA to identify additional measures. This could potentially include a SIP revision to 

address the visibility goal for the affected Class I area(s). 

List of Chapter 7 Appendices

 

7.1 2002 Emissions Inventory

7.2 2018 Emissions Inventory 

7.3 Emissions Inventory Technical Documentation 

7.4 Natural Gas Production Trends 
32

8. Modeling Assessment 

Modeling guidelines for conducting regional-scale modeling for particulate matter and visibility 

are provided in 40 CFR Part 51 Appendix W. In Appendix W, EPA recommends the use of 

three models to simulate pollutants impairing visibility: the Community Multiscale Air Quality 

(CMAQ) model, the Comprehensive Air quality Model with extensions (CAMx), and the 

Regional Modeling System for Aerosols and Deposition (REMSAD). CENRAP contractors 

performed regional modeling using CMAQ and CAMx. 

The CMAQ model is an Eulerian model that simulates the atmospheric and surface processes 

affecting the transport, transformation, and deposition of air pollutants and their precursors. An 

Eulerian model approximates the numerical solutions of partial differential equations of plumes 

on a fixed grid, while other models may lose accuracy or need re-gridding as the plumes expand. 

CAMx is a computer modeling system for the integrated assessment of photochemical and 

particulate air pollution. CAMx incorporates all of the technical attributes demanded of state-ofthe-art photochemical grid models, including two-way grid nesting, a subgrid-scale Plume-inGrid module to treat the early dispersion and chemistry of point source NOx plumes, and a fast 

chemistry solver. 

CAMx Mechanism 4 (M4) provides “one atmosphere” modeling for fine and coarse PM and 

ozone. Aqueous phase chemistry is modeled using the Regional Acid Deposition Model 

(RADM) mechanism. Inorganic sulfate/nitrate/ammonium chemistry is modeled with 

ISORROPIA thermodynamic equilibrium aerosol model. Secondary organic aerosols are 

modeled using a semi-volatile module in CAMx called SOAP. Wet and dry deposition processes 

are included for gases and particles. Gridded deposition information is outputted along with the 

concentrations. 

In the July 1, 1999 publication of the Regional Haze Rule in the Federal Register, EPA discussed 

the uses of regional modeling as follows: 

• Analyses and determination of the extent of emissions reductions needed from individual 

states 

• Analyses and determination of emissions needed to meet the reasonable progress goal for 

the Class I area 

• Analyses to support conclusion that the long-term strategy provides for reasonable 

progress 

• Analyses to calculate the resulting degree of visibility improvement that would be 

achieved at each Class I area 

• Analyses to compare visibility improvement between proposed control strategies 
33

8.1 Model Inputs 

For regional haze, the full 2002 modeling year was chosen as the episode period to evaluate. 

This year corresponds to the baseline emissions inventory available and is also included within 

the five-year monitoring baseline period used in establishing the glide slopes. 

As one of the five national regional planning organizations (RPOs), CENRAP chose to use the 

unified grid domain developed by all of the other RPOs. This domain covers all RPO areas and 

was chosen to enable sharing of data and results between RPOs in a consistent manner. The grid 

consists of 36km grid cells and is 148 x 112 in size. 

Generating the source inventory for modeling is intertwined with the creation of the pollutant 

inventory. Each emission source and the pollutants it emits must be specifically identified. For 

photochemical and aerosol modeling, each source must be classified as a point, nonpoint, mobile 

(on-road or nonroad), or biogenic source, then spatialized, temporalized, and speciated. In 

addition, three or more inventories need to be generated, including a base inventory for model 

performance evaluation, a typical inventory for the base year, and a future year inventory. 

Control strategy inventories are also developed to evaluate potential controls. In all, CENRAP 

developed multiple modeling inventories. The Base G inventory is the latest future year 

inventory and is considered the most reflective of future year emissions. The Base A through 

Base D inventories include known errors and should not be used in the analysis of future year 

visibility. Chapter 2 of the Technical Support Document (Appendix 8.1) provides the 

methodologies for the development of the emissions inventories; Kansas-specific emission 

inventory information can be found in Chapter 7 of this SIP. 

For meteorological inputs, the Fifth-Generation NCAR / Penn State Mesoscale Model (MM5) 

was selected. MM5 is the latest in a series that developed from a mesoscale model used by 

Anthes at Penn State in the early 1970s, and was later documented by Anthes and Warner(5). 

Since that time, MM5 has undergone many changes designed to broaden its usage. These 

changes include: (1) multiple-nest capability; (2) non-hydrostatic dynamics, which allows the 

model to be used at a few-kilometer scale; (3) multitasking capability on shared and distributed 

memory machines; (4) four-dimensional data assimilation capability; and (5) more physics 

options. The MM5 model is supported by several auxiliary programs, which are referred to 

collectively as the MM5 modeling system. Since MM5 is a regional model, it requires an initial 

condition as well as a lateral boundary condition to run. To produce a lateral boundary condition 

for a model run, gridded data is needed to cover the entire time period that the model is 

integrated. 

8.2 Model Performance Evaluation 

Model evaluations compared concentrations of various pollutants simulated by CMAQ and 

CAMx with observations from: 

• Interagency Monitoring of Protected Visual Environments (IMPROVE) 
34

• Clean Air Status and Trends Network (CASTNet) 

• Speciated Trends Network (STN) 

• Aerometric Information Retrieval Systems (AIRS) 

• South Eastern Aerosol Research and Characterization (SEARCH) 

Model performance evaluation summaries follow. Detailed model performance evaluations are 

found in Appendix 8.2 

A detailed model performance evaluation was performed on the 2002 Base F CMAQ simulation. 

As specified in the EPA guidance, a multi-layered approach to model performance testing was 

performed, with focus on the operational and diagnostic analyses. Performance evaluations were 

performed on all the visibility-impairing particulate species, including sulfate, nitrate, elemental 

carbon, organic carbon, soil, and coarse mass. Performance goals and criteria were established 

in the assessment of the modeling results. These goals and criteria are explained in detail in the 

CENRAP Technical Support Document (Appendix 8.2). Because Kansas was identified as a 

contributing state to visibility impairment in the Wichita Mountains Class I area, particular 

attention has been paid to performance for this area. 

Overall for the CENRAP domain, using the model performance criteria established in the TSD, 

the model performance for both CMAQ and CAMx models for sulfate and elemental carbon can 

be characterized as good with most areas meeting the performance criteria. Model performance 

for nitrate was variable, with a summer underestimation and winter overestimation, with some 

periods and areas not meeting the performance criteria. Organic mass carbon performance was 

fairly good with most areas meeting the performance criteria, while the coarse mass and soil 

performance was generally poor, especially in the southwest where there is a systematic soil 

underestimation. A more detailed pollutant-by-pollutant summary is provided below. The TSD 

contains a very detailed model performance, including performance evaluations at each Class I 

area in CENRAP. 

 8.2.1 Sulfate (SO4) Model Performance 

For the first 10 months of the year, SO4 was underpredicted across the CENRAP region. For the 

remaining two months, there is a slight overprediction. Overall, the SO4 performance met the 

performance goal approximately half of the time with all of the modeled predictions falling 

within the performance criteria. For the Wichita Mountains area on the 20% worst days, the 

model has a fractional bias of - 48% for SO4. Much of the underestimation occurred mainly 

during the summer months. During the winter months, when the predominant winds are from 

the north, SO4 prediction is much better, as can be seen in Figure 8.1 below. 

 8.2.2 Nitrate (NO3) Model Performance 

Monthly NO3 model performance across the CENRAP region is characterized by a summer 

underestimation and winter overestimation bias. Because nitrates are generally a small portion 

of the visibility problem in the summer in the CENRAP region, this underestimation is of 

relatively minor concern. In the winter, however, nitrates can be a significant portion of the 

visibility impairment, thus performance during this period is important. Overall across the entire 
35

domain, nitrate in the winter was overstated with some periods overestimated to such a degree 

that the performance criteria are not being met. In the Wichita Mountains for the 20% worst 

days, there are approximately eight days with a significant amount of nitrate impacts. For all but 

three of these days, the model underpredicts nitrate. On several other days the model 

overpredicts, with the worst overprediction occurring on Julian day 344 by a very significant 

amount. Because the CAMx PSAT modeling performed to date has indicated Kansas as a 

contributor due to nitrates, Kansas investigated this particular day further. 

Figure 8.1 Light Extinction for 20% Worst Visibility Days at Wichita Mountains by Particulate 

Species, Showing Observed (Left) versus Modeled (Right) Values 

Worst 20% Obs (left) vs Typ02g (right) at WIMO1

0

50

100

150

200

250

29 83 95 101 110 113 125 128 131 143 170 173 176 179 218 221 224 242 245 254 260 269 272 344 _ Avg

Julian Day in Worst 20% group

bEXT (1/Mm)

bCM

bSOIL

bEC

bOC

bNO3

bSO4

From the PSAT results, the Kansas modeled nitrate contribution on Julian day 344 was 

approximately 18 Mm-1, or approximately 15% of the modeled impact for this day, versus the 

2% modeled average over the worst 20% days. This large impact (15%) represents a significant 

portion of this 2% modeled average. The majority of the impact on this day was attributed to 

elevated point sources (35%), on-road mobile (23%), and nonroad (21%) sources. Looking at 

the hourly PSAT modeling results, it appears that much of this impact is attributed to nitrates 

generated several days before, and these nitrates remained in the Wichita Mountains region on 

Julian day 344. Clearly for the Wichita Mountains, the performance is poor on several of the 

worst modeled visibility days. The nitrate prediction is an area needing further investigation in 

future studies to better understand these performance issues and how they might be impacted by 

emissions inventory and modeled chemistry. 
36

 8.2.3 Organic Matter Carbon (OMC) Model Performance 

Domain-wide, the performance for OMC at the IMPROVE sites is quite good throughout the 

year, with a slight winter overestimation and a slight summer underestimation. Both the 

performance goal and performance criteria were met for the IMPROVE sites for all months. For 

the Wichita Mountains, OMC is significantly underestimated (-69% overall). 

As seen in Figure 8.2, OMC accounts for nearly 15% of the monitored visibility impairment on 

the 20% worst days in 2002, which is more than nitrates; thus this modeled underestimation is of 

concern. As is the case with nitrates, additional analysis for OMC is warranted. 

Domain-wide for the IMPROVE monitoring network, elemental carbon (EC) modeling exhibits 

a large underprediction bias in the summer months (-40% to -60%) and a much lower absolute 

bias in the winter. Because the monitored and modeled EC concentrations are low overall, this 

underprediction bias has little effect on the overall visibility performance. At low concentrations 

a wider range of bias is also considered acceptable, and in this case the performance goals and 

criteria are met for the entire year even though there is a large underprediction bias. In the 

Wichita Mountains, the monitored EC fraction only represents 4% of the visibility impairment 

on the 20% worst days, thus the underprediction is relatively unimportant overall for this Class I 

area. 

Figure 8.2 Percent Visibility Extinction for the Best and Worst 20% Days at Wichita Mountains 

 8.2.4 Other PM2.5 (soil) Model Performance 

The domain-wide soil component is overestimated, and more so in the winter months. July is the 

only month where the soil is underpredicted. This underprediction is likely due to high 

windblown dust events that impact some IMPROVE monitors but are not accurately 

characterized by the model. For the Wichita Mountains, the soil component represents less than 

1% of the worst 20% days based on monitored data, thus the poor performance is not likely a 
37

factor for this Class I area. As seen in the overall performance, the modeled results do indicate 

an overprediction in the Wichita Mountains. However, this overestimation is still just a small 

fraction of the overall modeled visibility impact at this Class I area. 

8.3 Base G Model Simulations 

The 2018 Base G modeling simulations represent the final version of the modeling simulations 

prepared by CENRAP. The latest 2018 version reflects the projected emissions growth as well 

as the known “on the books” controls that will occur before 2018. For Kansas emission sources, 

this also includes estimated reductions for all five of the electric generating units (EGUs) subject 

to BART. All EGU emissions were projected based on IPM runs, and included the impacts of 

the CAIR trading program and other federal programs. Remaining point and nonpoint (area) 

sources were projected using the EGAS model. The mobile on-road and nonroad projections 

were performed with the MOBILE 6 and NONROAD models, respectively. 

The results of this 2018 Base G modeling run, along with the 2002 typical modeling run, were 

used to estimate the projected visibility improvements at each Class I area within the CENRAP 

region. For regional haze, two metrics are important: (1) the improvement of the average 

visibility for the 20% worst days, and (2) no degradation occurring on the 20% best visibility 

days. These 20% best and worst days are chosen based on the IMPROVE monitored days and 

are kept the same in the 2018 Base G run. The projected modeling results can then be compared 

to the 2018 uniform rate of progress (URP) glide path developed for each Class I area. This 

same analysis can also be performed for the 20% best visibility days. 

Figures 8.3 and 8.4 are examples of this analysis for the Wichita Mountains Class I area; with the 

upper trend line (blue) representing the projected modeling results. In this case, the model 

prediction is indicating the 2018 URP will not be met for the Wichita Mountains area. 

Overall, for the CENRAP region, the 2018 projections indicate that the central portion of the 

CENRAP area will meet the URP glide paths, while the northern and southern Class I areas in 

CENRAP will not meet their respective glide paths. The State of Missouri’s Class I areas are 

projected to meet the URP glide path based upon the modeling projections that included all of 

Kansas’ BART reductions. For Kansas, the main concern is the Wichita Mountains Class I area, 

as emissions from Kansas have not been predicted to significantly impact Class I areas in other 

surrounding states. Additional discussion on Kansas impacts and the 2018 modeling projections 

are included in Chapter 10. 
38

Figure 8.3 URP Glide Path for Wichita Mountains Class I Area with 2018 Projected Results – 

20% Worst Days 

Uniform Rate of Reasonable Progress Glide Path

Wichita Mountains - 20% Data Days

23.81

22.72

20.01

17.30

14.58

11.87

9.16

7.53

21.47

0

5

10

15

20

25

30

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

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

 Figure 8.4 URP Glide Path for Wichita Mountains Class I Area with 2018 Projected Results - 

20% Best Days 

Uniform Rate of Reasonable Progress Glide Path

Wichita Mountains - Best 20% Days

9.78 9.78 9.78 9.78 9.78 9.78 9.78 9.78

9.23

0

2

4

6

8

10

12

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

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Best Days) Observation Method 1 Prediction
39

8.4 Information from Modeling Performed by Other RPOs 

Chapter 5 of the TSD (Appendix 8.3) includes a discussion of the modeling being performed at 

the three RPOs surrounding CENRAP, the Visibility Improvement State and Tribal Association 

of the Southeast (VISTAS), Midwest Regional Planning Organization (MRPO), and Western 

Regional Air Partnership (WRAP). These RPOs have all performed either CMAQ or CAMx 

modeling for both 2002 and 2018. 

 8.4.1 MRPO 

In general, the MRPO modeling was less optimistic in 2018 for the Class I areas in states 

surrounding Kansas. This difference is likely a result of different emissions inventories. The 

2018 CENRAP Base F and G emissions inventories included BART reductions in the CENRAP 

region, while the MRPO inventory did not. The MRPO inventory was also not the latest 

available for the CENRAP region at the time of this run. 

 

 8.4.2 VISTAS 

The VISTAS modeling indicates very close agreement with the CENRAP modeling, with the 

VISTAS modeling being more optimistic in the Class I areas surrounding Kansas. 

 8.4.3 WRAP 

The WRAP modeling did not cover the Class I areas of most interest to Kansas. For the Class I 

areas that were covered, the CENRAP modeling and WRAP modeling were in fairly close 

agreement. 

Unfortunately, the Class I area of most interest to Kansas, the Wichita Mountains, was not 

included in any of the other surrounding RPO modeling. A comparison of all the modeling 

results to date is shown in Figure 8.5 above. The full discussion of regional visibility projection 

comparisons can be found in Chapter 5 of the TSD (Appendix 8.3). 
40

Figure 8.5 Comparison of 2018 Modeling Results from CENRAP, VISTAS, WRAP, and MRPO 

CMAQ Method 1 predictions with new IMPROVE algorithm at CENRAP+ sites Across RPOs

0%

20%

40%

60%

80%

100%

120%

140%

BIBE1

GUMO1

WIMO1

CACR1

UPBU1

HEGL1

MING1

BRET1

VOYA2

BOWA1

MACA1

SIPS1

ISLE1

SACR1

WHIT1

WHPE1

GRSA1

ROMO1

WICA1

BADL1

THRO1

LOST1

Percent of target reduction achieved

CENRAP 36k Base18g/Typ02g

VISTAS 12k 2018g2b/2002gt2a

WRAP 36k Base18b/Plan02b corrected

MwRPO 2018 R4S1a

CENRAP non-CENRAP

8.5 Control Strategy Simulations 

CENRAP performed one control strategy simulation using the 2018 Base G inventory. This 

control run identified several Kansas point sources based on a Q/d (i.e., tons NOx plus tons SO2

divided by distance) greater than or equal to 5 analysis with cost per ton reduced less than 

$5,000. The Kansas sources included in the control run are listed in Tables 8.1 and 8.2. 

The control run shows improvements in all the Class I areas surrounding Kansas. Because most 

of the controls identified occur in the central portion of the CENRAP region, most of the 

improvements are also seen in this area. Controls were identified in both Kansas and the 

surrounding states, and no source apportionment was performed in this control run. Therefore, 

the direct Kansas contribution to visibility improvements in the surrounding Class I areas from 

Kansas emissions reductions could not be determined. There were 181,107 tons/yr of total NOx

reductions identified in the overall control run, with the Kansas portion being 17,927 tons. For 

SO2, 725,025 tons/yr of overall reductions were identified, with the Kansas portion being 21,617 

tons/yr. 
41

Table 8.1 Kansas NOx Sources Included in the CENRAP Control Strategy Run Using the 2018 

Base G Inventory 

Table 8.2 Kansas SO2 Sources Included in the CENRAP Control Strategy Run Using the 2018 

Base G Inventory 

Plant ID Plant Name Control 

Measure 

Tons 

SO2

Tons 

Reduced 

Cost per 

Ton 

Reduced 

1770030 Westar Energy - Tecumseh FGD Wet 

Scrubber 2,631 2,368 $4,519

1770030 Westar Energy - Tecumseh FGD Wet 

Scrubber 4,199 3,779 $3,715

2090008 Kansas City BPU - Nearman FGD Wet 

Scrubber 8,999 8,099 $2,239

2090048 Kansas City BPU - Quindaro FGD Wet 

Scrubber 4,216 3,795 $3,522

2090049 Kansas City BPU - Kaw FGD Wet 

Scrubber 1,674 1,506 $4,658

2090049 Kansas City BPU - Kaw FGD Wet 

Scrubber 2,300 2,070 $4,095

Plant 

ID Plant Name Control Measure 

Tons 

NOx

Tons 

Reduced 

Cost per 

Ton 

Reduced 

2057022 Lafarge Midwest - Fredonia Mid-kiln 

Firing 1,416 425 $83 

0010009 Monarch Cement 

Biosolid 

Injection 

Technology 

1,559 359 $466 

0450014 Westar Energy - Lawrence LNC3 1,688 984 $407 

2090048 Kansas City BPU - Quindaro SCR 2,181 1,963 $738 

1490001 Westar Energy - Jeffrey LNC3 5,585 1,767 $1,043 

1490001 Westar Energy - Jeffrey LNC3 5,585 1,191 $1,560 

0450014 Westar Energy - Lawrence LNC3 3,403 565 $1,628 

1490001 Westar Energy - Jeffrey LNC3 5,585 1,106 $1,755 

0210002 Empire District Electric - 

Riverton SCR 992 840 $1,581 

1070005 KCP&L - La Cygne SCR 6,647 5,318 $2,308 

2090008 Kansas City BPU - Nearman LNBO 3,501 371 $3,144 

0550023 Sunflower Electric - Holcomb LNBO 3,683 390 $3,839 

1250015 Heartland Cement SNCR - 

Urea Based 1,336 668 $1,657 

0910057 AGC Flat Glass North America Oxy-Firing 2,330 1,981 $4,088 
42

For the Wichita Mountains, even with the controls identified in this control scenario, the 

modeling still does not predict the area will meet its URP target. This is also the case in other 

CENRAP Class I areas, such as in Texas and Minnesota, where Kansas is less likely to 

contribute to visibility impairment. For specific comparisons at other Class I areas, refer to 

Figure 8.6 below. 

Figure 8.6 Comparison of Modeling Results from Base G and Control Strategy Runs 

CMAQ BaseGc1 vs BaseG Method 1 predictions for CENRAP+ sites

0%

20%

40%

60%

80%

100%

120%

140%

160%

180%

200%

BIBE1

GUMO1

WIMO1

CACR1

UPBU1

HEGL1

MING1

BRET1

VOYA2

BOWA1

MACA1

SIPS1

ISLE1

SACR1

WHIT1

WHPE1

GRSA1

ROMO1

WICA1

BADL1

THRO1

LOST1

Percent of target reduction achieved

BaseGc1 BaseG

CENRAP non-CENRAP

Kansas evaluated the cost effective and technically feasible controls identified in the CENRAP 

control scenario above. A summary of that evaluation follows. 

For the NOx controls identified in this control run for Kansas, the State has evaluated all of the 

sources and controls identified. Several of the sources included in the control run will be 

controlled for NOx. They include: 

• Westar Energy - Jeffrey Unit 3 – Low NOx burners/overfire air 

• Westar Energy - Lawrence Units 3, 4, and 5 – Low NOx burners 

The two units at BPU Kaw facility are currently in cold stand-by and Kansas does not anticipate 

these units will be placed back into operation without additional SO2 control requirements. 

Westar Energy - Tecumseh, was evaluated for SO2 controls but it was determined they were not 

cost effective considering the predicted visibility improvements associated with those controls. 

Three sources identified in the control run above will be subject to controls as part of ozone 

contingency measures being implemented in the Kansas City metropolitan area: 
43

• Kansas City BPU – Nearman and Quindaro – Kansas City NOx Emission Reduction Rule 

• AGC Flat Glass North America – Kansas City NOx Emission Reduction Rule 

Two Westar Energy - Jeffrey EGUs identified in this control run are subject to BART and will 

not be subject to additional NOx controls for reasonable progress. The remaining sources 

identified in this control were evaluated as part of reasonable progress and it was determined that 

further controls at this time would not be pursued. These evaluations can be found in Chapter 

10. 

List of Chapter 8 Appendices

8.1 Emissions Modeling (TSD Chapter 2) 

8.2 Model Performance Evaluation (TSD Chapter 3) 

8.3 Additional Supporting Analysis (TSD Chapter 5) 
44

9. Best Available Retrofit Technology 

EPA’s 1999 Regional Haze Rule requires additional controls for certain older emission sources. 

The State of Kansas is required to have those older sources that contribute to visibility 

impairment in Class I areas to install Best Available Retrofit Technology (BART) or implement 

an emissions trading or other alternative program that will achieve greater reasonable progress 

than would be achieved through the installation and operation of BART. On July 6, 2005, EPA 

published a revised final rule, including Appendix Y to 40 CFR part 51 “Guidelines for BART 

Determinations under the Regional Haze Rule,” hereinafter BART Guidelines, which provides 

direction to states on determining which of these older sources may need to install BART and 

how to determine BART. 

The State of Kansas is requiring sources subject to BART to install, operate, and maintain BART 

rather than implement an emission trading program or other alternative measure in place of 

BART. 

9.1 BART Eligible Sources in the State of Kansas 

Kansas BART-eligible sources were identified using the methodology in the BART Guidelines. 

For an emission source to be identified as BART eligible, the State of Kansas used these criteria 

from the BART Guidelines: 

• One or more emissions units at the facility fit within one of the 26 categories listed in the 

BART Guidelines 

• The emission unit was in existence on August 7, 1977 and began operation at some point 

on or after August 7, 1962 

• The limited potential emissions from all emission units identified in the previous two 

bullets were 250 tons or more per year of any of these visibility-impairing pollutants: 

SO2, NOx, or PM10. 

To identify the sources that met the criteria above, Kansas performed a multi-step search and 

analysis including a database query of the permitted air sources in its point source emissions 

inventory database, and a survey of the facilities. Refer to detailed description of the 

identification process in Appendix 9.1. This analysis indicated there were 19 facilities in Kansas 

with BART-eligible units. The 19 facilities, along with their BART-eligible units, are listed in 

Table 9.1. 
45

Table 9.1 Facilities with BART-Eligible Units in the State of Kansas 

 BART Source 

Category Name Facility ID Facility Name BART-Eligible Emission Units 

0090002 

Aquila (now 

Sunflower Electric) - 

Arthur Mullergren 

Unit 3 (Stacks 1 and 2) 

1750001 

Aquila (now 

Sunflower Electric) - 

Cimarron River 

Unit 1 

0570001 

Aquila (now 

Sunflower Electric) - 

Judson Large 

Unit 4 

2090008 Kansas City BPU - 

Nearman Unit 1 

2090048 Kansas City BPU - 

Quindaro 

Unit 1 

Unit 2 

1070005 KCP&L - La Cygne 

Unit 1 

Unit 2 

1130014 McPherson Municipal 

Power Plan #2 Unit 1 

0550026 Sunflower Electric - 

Garden City Unit S2 

1730012 Westar Energy - 

Gordon Evans Unit 2 (Stacks 2 and 3) 

1550033 Westar Energy - 

Hutchinson Unit 4 (Stacks A and B) 

1490001 Westar Energy - 

Jeffrey 

Unit 1 

Unit 2 

0450014 Westar Energy - 

Lawrence Unit 5 

Fossil-Fuel Fired 

Electric Generating 

Units 

0350012 Winfield Municipal 

Power Plant #2 Unit 4 

Portland Cement 

Plants 0010009 Monarch Cement Co. 

No. 4 Kiln Stack, No.4 Kiln Clinker 

Cooler, No.5 Kiln Stack, No. 5 Kiln 

Clinker Cooler, Raw Material Unloading, 

Clinker Grinding and Cement Handling, 

Stone Quarry Processing 

0150004 Frontier El Dorado 

Refining Co. 

Boiler B-105, Boiler B-107, Plant Process 

Heaters, Refinery Flare System B-1303, 

Plant Cooling Towers, Storage Tanks, Gas 

Oil Hydrotreater 

Petroleum 

Refineries 

1130003 National Cooperative Alky Heater HA-002, No.9 Boiler SB-009, 
46

Refinery Assoc. 

(NCRA) 

No.12 Boiler SB-012, Coker IR Comp. 

CR-003, Plat Stab Boil Htr HP-003, Plat 

Charge Htr HP-006, Fugitive Emissions 

1730070 

Basic Chemicals 

(now OxyChem - 

Wichita) 

Boiler 1; Boiler 2; Boiler 3; 

Chloromethanes 

Chemical 

Processing Plants 

0570003 Koch Nitrogen 

Ammonia plant - primary reformer; 

Ammonia plant - other; Nitric acid plant - 

absorber tail gas; Ammonium nitrate plant 

– neutralizer 

Glass Fiber 

Processing Plants 2090010 Owens Corning 

70 furnace - N exhaust; 70 furnace - S 

exhaust; 70 riser/channel/forehearth; 70 A 

forming; 70 B forming; 70 C forming; 70 

D forming; 70 curing oven charge end; 70 

curing oven discharge end; J5 furnace; J5 

riser/channel/forehearth; J6 A forming; J6 

B forming; J6 C forming; J6 curing oven 

charge end; J6 curing oven discharge end; 

J6 smoke stripper; J6 north cooling (A); J6 

south cooling (B); J6 asphalt coating; Raw 

material processing 

9.2 Determination of Sources Subject to BART 

Under the BART Guidelines, states have the following options regarding BART-eligible sources: 

(a) make BART determinations for all sources, or (b) consider exempting some sources from 

BART because they do not cause or contribute to visibility impairment in a Class I area. The 

State of Kansas chose option (b). If a state chooses that option, then the BART Guidelines 

suggest three sub-options for determining that certain sources need not be subject to BART: 

• Individual source attribution approach (dispersion modeling) 

• Use of model plants to exempt sources with common characteristics 

• Cumulative modeling to show that no sources in a state are subject to BART 

The State of Kansas chose the first sub-option above, individual source attribution, to determine 

which sources cause or contribute to visibility impairment, and therefore were subject to BART. 

The CALPUFF modeling protocol used for determining which BART-eligible facilities are 

subject to BART is included in Appendix 9.2. Pollutants modeled were NOx, SO2, and PM2.5. 

Based on the relatively large distances between BART-eligible sources in Kansas and Class I 

areas outside of the State and discussions with other member states in CENRAP, Kansas 

determined that the 0.5 deciview (dv) threshold was appropriate for the subject-to-BART process 

(40 CFR Part 51 Appendix Y Section (III)(A)(1)). Preliminary dispersion modeling was 

conducted to determine which of the BART-eligible units would create a greater than 0.5 

deciview impact for at least one day during the three-year period modeled at nine Class I areas. 

The one day in three-year period threshold, as well as the Class I areas selected for modeling, 
47

were based on recommendations made by staff at EPA Regions 6 and 7. The nine Class I areas 

chosen are the following: 

• Caney Creek Wilderness Area, Arkansas (CACR) 

• Upper Buffalo Wilderness Area, Arkansas (UPBU) 

• Great Sand Dunes Wilderness Area, Colorado (GRSA) 

• Rocky Mountain National Park, Colorado (ROMO) 

• Hercules-Glades Wilderness Area, Missouri (HEGL) 

• Mingo Wilderness Area, Missouri (MING) 

• Wichita Mountains Wilderness Area, Oklahoma (WIMO) 

• Badlands National Park, South Dakota (BADL) 

• Wind Cave National Park, South Dakota (WICA) 

Sources with preliminary CALPUFF modeling outcomes of at least one day of 0.5 dv visibility 

impact in a Class I area over the period modeled (2001-2003) are shown in Table 9.2. 

Table 9.2 Kansas BART-Eligible Emission Units with at Least One > 0.5 dv Visibility Impact 

Day on Selected Class I Areas during 2001–2003 

CACR UPBU GRSA ROMO HEGL MING WIMO BADL WICA Source Number of days during 2001-2003 with visibility impact >0.5 dv 

Kansas City BPU - 

Nearman Unit 1 23 21 3 1 30 16 15 3 2

 Kansas City BPU - 

Quindaro Units 1 & 2 13 13 1 1 18 6 9 0 0

KCP&L - La Cygne 

Units 1 & 2 204 249 17 21 278 233 142 46 38

Monarch Cement Kilns 

4 & 5 0 0 0 0 0 0 1 0 0

Westar Energy - 

Gordon Evans Unit 2 33 30 11 13 28 17 102 32 24

Westar Energy - 

Hutchinson Unit 4 14 7 6 5 6 3 17 9 4

Westar Energy - 

Jeffrey Units 1 & 2 150 161 27 28 182 158 165 82 55

Westar Energy -

Lawrence Unit 5 14 14 1 1 17 7 9 2 1

Each of the facilities listed in Table 9.2 submitted refined modeling results, based on CALPUFF 

modeling for individual source exemption provided in the modeling protocol. Monarch Cement, 

Kansas City BPU - Quindaro, Kansas City BPU – Nearman, Westar Energy - Hutchinson, and 

Westar Energy - Lawrence were able to show that the emissions from their BART-eligible units 

are not anticipated to cause or contribute to visibility impairment in Class I areas. The submittals 

for these sources can be found in Appendix 9.8. 
48

BPU submitted the Black & Veatch-prepared document Best Available Retrofit Technology 

Engineering Analysis for Nearman Unit 1 in February 2007. In November 2007, the Kansas 

Department of Health and Environment (KDHE) discovered a potential issue with the hourly 

emission rates used in the initial modeling determination making Nearman a BART source. 

KDHE informed BPU of this potential issue and BPU revised both the 24 hour maximum 

emission rates and the BART determination modeling they had performed. 

On December 19, 2007 the KDHE received revised 24 hour maximum emission rates from BPU 

for Nearman. Along with the revised emissions rate, BPU also submitted additional CALPUFF 

modeling for purposes of a BART determination. This new modeling indicated Nearman should 

not have been included as a BART source. The modeling BPU performed was based on the 

approved CALPUFF modeling protocol. It was therefore determined that BPU is not a source 

subject to BART. 

The facilities with BART-eligible units found to be subject to BART by the State of Kansas are 

shown in Table 9.3. These facilities were required to complete full BART analyses. Appendix 

9.3 contains more detailed results of the modeling analyses for each subject-to-BART source. 

Table 9.3 Kansas Facilities with Units Subject to BART under the Regional Haze Rule 

Facility ID Facility Name Emission Units 

Subject to BART 

1070005 KCP&L - La Cygne Unit 1 

Unit 2 

1730012 Westar Energy - Gordon Evans Unit 2 

1490001 Westar Energy - Jeffrey Unit 1 

Unit 2 

9.3 Determination of BART Requirements for Subject-to-BART Sources 

As part of the BART determination, KDHE developed a BART guidance document for those 

sources that were required to complete a full BART analysis. This document accounted for 

Kansas specific considerations, including the State’s authority to implement the regional haze 

rule. One of the more important guidance decisions in the document concerned electric 

generating units and facilities that met the presumptive threshold outlined in the EPA guidance. 

The KDHE guidance document includes the following guidance statement that was applied in 

several of the State’s BART analyses. 

KDHE note: KDHE expects these presumptive levels of control will be cost effective in 

most cases. If your facility falls in the EGU category described above and you propose 

controls at or beyond these presumptive levels, you need not take into account the 
49

remaining statutory factors, as BART will be met. If you propose controls above these 

presumptive levels, justification incorporating the statutory factors will be required. 

KDHE elected to include this guidance based on an examination of how EPA set these 

presumptive limits coupled with the EGU’s in the state that this would apply to. One of the 

major driving factors that shaped this guidance was the consideration of the State’s authority to 

implement the regional haze rule which includes a “no more stringent than” clause, see 

Appendix 2.1. KDHE believes this guidance provided an efficient means for presumptive BART 

units to meet BART while meeting the State’s authority to implement the regional haze program. 

BART determinations for the five subject-to-BART units in Kansas were carried out by thirdparty contractors on behalf of the sources’ two owners and submitted to the State for approval. 

Because all five of the BART units are electric generating units (EGUs) and are located at 750 

MW facilities, the State stipulated that the minimum BART control level would be the 

presumptive limits specified in the BART Guidelines. As discussed above, Kansas provided each 

owner with a guideline for conducting their determination, titled, Guidance for Facilities 

Conducting a BART Analysis, and found in Appendix 9.4. The resulting analyses are found in 

Appendix 9.5 (KCP&L) and Appendix 9.6 (Westar Energy) and are discussed below. 

The operational standards prescribed for the application of BART for sources will be in terms of 

maximum emission rates for the primary visibility-impairing pollutants NOx and SO2. In all 

cases here, added PM2.5 controls would help visibility only marginally, and would not be cost 

effective. These standards, along with presumptive limits from the BART Guidelines, are 

summarized in Table 9.4 and have been included in Agreements with each source. 

Table 9.4 BART Presumptive Limits and Operational Standards for NOx and SO2 at Subject-toBART Emission Units in Kansas 

Subject-to-BART Emission Unit BART Presumptive Limit BART Operational Standard 

NOx SO2 NOx SO2

lb/MMBtu 

KCP&L - La Cygne Unit 1 0.10 0.15 

KCP&L - La Cygne Unit 2 0.23 0.16* 0.15 0.15* 0.13* 0.10* 

Westar Energy - Jeffrey Unit 1 0.15 0.15 0.15 0.15 

Westar Energy - Jeffrey Unit 2 0.15 0.15 0.15 0.15 

* Weighted average 

9.3.1 Kansas City Power & Light (KCP&L) 

KCP&L submitted the document, BART Five Factor Analysis: Kansas City Power & Light La 

Cygne Generating Station, for La Cygne Units 1 and 2 in August 2007 (Appendix 9.5), prepared 

by Trinity Consultants. Both Units 1 and 2 meet the presumptive definition and the BART 

analysis submitted determined that presumptive limits were BART based on the BART guidance 

document provided by KDHE. KDHE concurred that presumptive limits were BART for this 
50

source. During the course of implementing an enforceable BART agreement, KCP&L proposed 

limits that were more restrictive than the presumptive BART limits. This proposal was made in 

order to be consistent with an agreement KCP&L had with the Sierra Club and with the 

knowledge that the Kansas City metro area has been close to nonattainment for ozone. KDHE 

agreed that the alternative emission limits proposed by KCP&L were better than the presumptive 

BART limits and KDHE has incorporated these limits into the KCP&L agreement. 

KCP&L proposes a more restrictive limit than the presumptive BART NOx emission rates for 

Units 1 and 2 of 0.10 lb/MMBtu and 0.23 lb/MMBtu, respectively (and 0.16 lb/MMBtu weighted 

average), to 0.13 lb/MMBtu on a 30-day rolling weighted average using the already permitted 

selective catalytic reduction (SCR) control for Unit 1 and some form of pre- or post-combustion 

control (e.g., low NOx burner, low NOx burner with overfire air, or SCR) for Unit 2. Compliance 

will be demonstrated via reconfiguring the continuous emission monitor system (CEMS) 

software to generate a daily report showing the two-unit 30-day rolling average. The average 

must remain below 0.13 lb/MMBtu, excluding periods of startup and shutdown. In the event 

Unit 2 suffers an outage in excess of 10 weeks, KCP&L also proposes meeting the 0.10 

lb/MMBtu presumptive limit for NOx at Unit 1. 

For SO2 control, KCP&L proposes a more restrictive emission limit than the presumptive limit 

of 0.15 lb/MMBtu (weighted average), to 0.10 lb/MMBtu on a 30-day rolling weighted average, 

by using some form of scrubbing technology (wet scrubber and spray dry absorber were 

mentioned). Compliance will be demonstrated by reconfiguring the CEMS software to generate 

a daily report showing the two-unit 30-day rolling average. The average must remain below 0.10 

lb/MMBtu, excluding periods of startup and shutdown. 

 9.3.2 Westar Energy 

Westar Energy submitted the document, Jeffrey Energy Center and Gordon Evans Energy 

Center: BART Five Factor Analysis, for its Jeffrey Units 1 and 2 and Gordon Evans Unit 2 in 

August 2007 (Appendix 9.6), prepared by Trinity Consultants. In May 2009 Westar amended 

the document with additional modeling analysis for Gordon Evans. Westar Energy proposes to 

meet the presumptive BART NOx emission rates for Jeffrey Units 1 and 2 of 0.15 lb/MMBtu 

using new low NOx burner systems for each unit. For Gordon Evans Unit 2, which is a natural 

gas/oil-burning unit that meets the presumptive plant and unit size threshold, there is no 

prescribed presumptive limit. KDHE indicated to Westar in early discussions that presumptive 

NOx controls consisting of “current combustion control technology” would be expected under 

the Regional Haze Rule. Westar’s original analysis and amendment went through the standard 

BART selection process which resulted in identifying a low NOx burner system. However, since 

the concurrent analysis for SO2 reduction led to a state-approved alternative means of control 

through fuel switching to natural gas, and since fuel switching results in visibility improvements 

in all five Class I areas modeled by Westar Energy (30% for Wichita Mountains, for example), 

Kansas endorses this alternative BART control for NOx. 

Westar Energy proposes to meet the SO2 presumptive limit of 0.15 lb/MMBtu for Jeffrey Units 1 

and 2 by rebuilding the wet scrubber on each unit. For Gordon Evans, which KDHE indicated 
51

would be required to meet a presumptive control (as an oil-fired unit) of burning oil with 1% 

sulfur content or less by weight, Westar Energy proposes switching fuel to natural gas, with 1% 

sulfur fuel oil available for emergency backup use only. Westar currently has an existing supply 

of No.6 fuel oil on site and will be allowed to exhaust this emergency backup supply, with any 

future fuel oil purchases being 1% sulfur content or less by weight. Kansas endorses this 

alternative BART control for SO2; the switch to natural gas would virtually eliminate SO2

emissions from Unit 2 in all cases, with the exception being an emergency when fuel oil would 

be allowed only for the duration of the emergency. 

9.4 Projected Emissions Reductions Resulting from Installation of BART Controls

The application of BART to all subject-to-BART sources provides an estimated emission 

reduction from the baseline year, 2002, of 43,686 tons per year of nitrogen oxides and 58,451 

tons per year of sulfur dioxide. These reductions are detailed in Table 9.5. 

Table 9.5 Projected Emissions Reductions from 2002 Levels after Installation of BART Controls 

for the Subject-to-BART Emission Units in Kansas. 

Projected BART Emissions Reductions 

Subject-to-BART Emission Unit (tons/yr) 

NOx SO2

KCP&L - La Cygne Unit 1 27,481.6 2,700.0

KCP&L - La Cygne Unit 2 2,133.2 15,362.4

Westar Energy - Gordon Evans Unit 2 1,885.6 3,210.5

Westar Energy - Jeffrey Unit 1 5,333.6 16,927.3

Westar Energy - Jeffrey Unit 2 6,852.1 20,250.7

Totals 43,686.1 58,450.9

9.5 Enforceability of BART Requirements 

• Kansas negotiated Agreements with two sources that are subject to BART, Westar and 

KCP&L. The agreements contain the applicable emission limits, compliance schedules, 

and monitoring requirements which will be federally enforceable upon EPA’s approval of 

this SIP. The Secretary of Health and Environment has the authority to sign Agreements 

and enforce them under Kansas Statutes. K.S.A. 65-3003 provides that the responsibility 

for air quality conservation and control of air pollution is placed with the Secretary of 

Health and Environment and the Secretary shall administer the Kansas Air Quality Act 

through the Division of Environment. K.S.A 65-3005 provides that the Secretary shall 

have the power to: (c) Issue such orders, permits and approvals as may be necessary to 

effectuate the purposes of this act and enforce the same by all appropriate administrative 

and judicial proceedings and (p) Enter into contracts and agreements with other state 

agencies or subdivisions, municipalities, the federal government or its agencies or private 

entities as is necessary to accomplish the purposes of the Kansas Air Quality Act. K.S.A. 

65-3011 provides that the Secretary may issue an order requiring action to implement a 
52

compliance plan. K.S.A. 65-3012 provides authority to enforce an administrative order 

in district court. 

The Agreements between affected sources and the State of Kansas require that each source 

subject to BART install and operate BART controls as expeditiously as practicable, but in no 

event later than five years after approval of this SIP or plan revision by EPA. The Agreements 

also include a requirement that each source maintain the control equipment and establish 

procedures to ensure such equipment is properly operated and maintained. The emissions limits 

in the agreements and compliance verification requirements will be incorporated into each 

facility’s Title V operating permit when they are reopened or approved. Amendments to the 

Agreements confirm and improve the monitoring, record keeping and reporting requirements and 

enforceability of the Agreements. 

The Agreements and Amendments for Westar and KCP&L are found in Appendix 9.7. If the 5-

year progress report and/or the 10-year SIP revision indicate that additional controls are 

necessary, Kansas will consider adoption of a Regional Haze Regulation. The Regional Haze 

Regulation would adopt relevant sections of 40 CFR part 51.301 and 40 CFR Part 51 Appendix 

Y by reference and would outline the process by which determinations would be made and 

enforced for BART and Reasonable Progress sources. 

The Agreements between KDHE and the affected BART sources currently exclude emissions 

associated with startup, shutdowns, and malfunctions (SSM) in the agreed upon emission limits. 

As part of the five-year review, KDHE will analyze SSM events and characterize the actual 

emission rates including and excluding these periods for the affected BART sources. Should the 

actual emissions rates including the SSM periods exceed the agreed upon emission rate limits, 

and be found to be adversely affecting visibility at Class I areas, KDHE commits to address these 

emissions with a SIP modification. 

9.6 Monitoring, Recordkeeping, & Reporting of BART Requirements 

Monitoring, recordkeeping, and reporting requirements to ensure compliance with the terms and 

conditions of 40 CFR Part 51 Appendix Y are required for all units subject to BART as 

authorized by Kansas Air Quality Regulation 28-19-512. Existing monitoring and recordkeeping 

requirements in place at each unit will provide KDHE with sufficient data to ensure compliance 

with BART requirements. As stated above, amendments to the Agreements confirm and improve 

the monitoring, record keeping and reporting requirements. 

All but one unit subject to BART are required to calibrate, operate, and maintain a certified 

Continuous Emission Monitoring system (CEMS) following procedures outlined in either 40 

CFR 60 or 40 CFR 75, depending on applicable requirements currently in place at each emission 

unit. Nitrogen oxide and sulfur dioxide emissions are monitored and recorded following 

procedures outlined in either 40 CFR Part 60 or 40 CFR 75. Semi-annual excess emission 

reports and monitoring systems performance reports are submitted and records are maintained 
53

following procedures in either 40 CFR 60 or 40 CFR 75. For the unit that will use fuel switching 

to meet the requirements of BART, the owner or operator will monitor and record the types and 

amounts of fuel oils fired and submit them as part of the semi-annual report. 

List of Chapter 9 Appendices

 

9.1 Identification of BART-Eligible Sources in the State of Kansas 

9.2 Modeling Protocol Used to Determine Subject-to-BART Sources 

9.3 Results of Modeling to Screen for Sources Subject to BART 

9.4 Guidance for Facilities Conducting a BART Analysis 

9.5 BART Analysis for KCP&L - La Cygne Units 1 and 2 

9.6 BART Analysis for Westar Energy - Gordon Evans Unit 2 and Jeffrey Units 1 and 2 

(including May 2009 addendum for GEEC) 

9.7 BART Agreements 

9.8 BART Exemption modeling – 

 Monarch Cement 

 Kansas City BPU – Quindaro 

 Kansas City BPU – Nearman 

 Westar Energy – Hutchinson 

 Westar Energy - Lawrence 
54

10. Reasonable Progress Goals / Long Term Strategy

The Regional Haze Rule stipulates that each state “must address regional haze in each mandatory 

Class I Federal area located within the state and in each mandatory Class I Federal area located 

outside the state which may be affected by emissions from within the state” [40 CFR 51.308(d)]. 

Although there are no Class I areas located within Kansas, the State is still required to address 

regional haze by determining any Class I area(s) that may be significantly impacted by emissions 

from sources within the State. As part of the CENRAP RPO process, regional modeling was 

performed that showed several surrounding Class I areas were being affected by sources in 

Kansas. It was projected that several of these Class I areas would not meet a linear uniform rate 

of progress in 2018. With this information, Kansas anticipated the surrounding states would 

request that we consult with them to address the requirements to meet reasonable progress at 

their Class I areas. Kansas prepared the following reasonable progress analysis to meet the 

requirements of the rule and to be prepared for the consultation process that was anticipated in 

light of the CENRAP modeling analysis. 

10.1 Determining Visibility Impact 

Kansas is required by 40 CFR 51.308(d)(3)(iii) to document the technical basis for the State’s 

apportionment of emission reductions necessary to meet reasonable progress goals in each Class 

I area affected by the State’s emissions. 

In order to address the issue of source attribution of regional haze for its member states, 

CENRAP contracted with ENVIRON to carry out PM Source Apportionment Technology 

(PSAT) modeling, a well known “probing tool” for the CAMx photochemical model. 

ENVIRON delivered its results in the form of a customized Microsoft Access database query 

tool, hereinafter the PSAT tool, which allows users to select among various inputs to produce 

charts and tables. Visibility impact can be represented in terms of absolute light extinction (Bext), 

inverse megameters (Mm-1), and percent total light extinction. Data can be queried from source 

categories within individual states on individual or grouped Class I area receptors, for the years 

2002, 2000-2005 (baseline), and 2018 (end of current planning period). The PSAT tool used for 

this document is the third version posted, dated July 18, 2007 and available at 

http://www.cenrap.org/projects.asp

Kansas used the PSAT tool to find projected absolute and percent total light extinction values at 

eleven Class I areas. The analysis helped determine which Class I areas may be impacted by 

Kansas sources, and also provides a quantifiable basis of discussion for meeting the reasonable 

progress goals for Class I areas potentially impacted by emission sources within Kansas. 

Figures 10.1 and 10.2 below show projected 2018 percent total extinction values for the worst 

20% visibility days for nine Class I areas nearest Kansas, and two Class I areas in Texas. The 

Texas Class I areas were included because Kansas participated in that State’s consultation 

process. Figure 10.1 breaks down source contribution by particulate species over all source 

categories, while Figure 10.2 shows source category contributions over all particulate species. 
55

Table 10.2 shows the numerical values for percent total extinction as well as for absolute 

extinction in terms of inverse megameters (Mm-1) for the 12 Class I areas. 

Note that the nine Class I areas chosen here (besides the two Texas areas) are the same as those 

selected by EPA Region 7 for Kansas for CALPUFF modeling of the State’s BART-eligible 

emission sources. They comprise the set of Class I areas nearest to Kansas in all directions 

around the State border. The eleven areas are: 

• Caney Creek Wilderness Area, Arkansas (CACR) 

• Upper Buffalo Wilderness Area, Arkansas (UPBU) 

• Great Sand Dunes Wilderness Area, Colorado (GRSA) 

• Rocky Mountain National Park, Colorado (ROMO) 

• Hercules-Glades Wilderness Area, Missouri (HEGL) 

• Mingo Wilderness Area, Missouri (MING) 

• Wichita Mountains Wilderness Area, Oklahoma (WIMO) 

• Badlands National Park, South Dakota (BADL) 

• Wind Cave National Park, South Dakota (WICA) 

• Big Bend National Park, Texas (BIBE) 

• Guadalupe Mountains National Park, Texas (GUMO) 

Figure 10.1 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas Sources, 

by Species, for All Source Categories during the Worst 20% Days 

0.0

1.0

2.0

3.0

4.0

5.0

6.0

CACR

UPBU

GRSA

ROMO

HEGLMING

WIMO

BADLWICA

BIBE

GUMO

Percent total extinction (%)

CM

Soil

EC

POA

NO3

SO4
56

Figure 10.2 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas Air 

Emission Sources, by Source Category, for All Species during the Worst 20% Visibility Days 

0.0

1.0

2.0

3.0

4.0

5.0

6.0

CACR

UPBU

GRSA

ROMO

HEGLMING

WIMO

BADLWICA

BIBE

GUMO

Percent total extinction (%)

Nonpoint (area)

Nonroad mobile

On-road mobile

Natural

Low-level point

Elevated point

Table 10.1 shows actual values for the overall percent extinction values (total bar heights) for 

each of the Class I areas presented in Figures 10.1 and 10.2. 

Table 10.1 2018 Percent Total and Absolute Light Extinction Value for Worst 20% Visibility 

Days at Eleven Class I Areas Due to Kansas Air Emission Sources 

Class I area Percent total 

extinction (%) 

Absolute total 

extinction (Mm-1) 

CACR 2.05% 1.65 

UPBU 1.53% 1.25 

GRSA 2.06% 0.55 

ROMO 1.62% 0.47 

HEGL 2.50% 2.15 

MING 1.71% 1.65 

WIMO 4.90% 3.53 

BADL 2.23% 0.93 

WICA 2.37% 0.87 

BIBE 1.33% 0.57 

GUMO 3.21% 1.45 

 

All CENRAP states relied upon the regional modeling work performed by CENRAP and their 

contractors for determining the impact that sources within a state might have on Class I areas in 
57

the region. For Kansas, the modeling indicated that Kansas sources were most likely to have the 

highest impact at the Wichita Mountains in Oklahoma, with the Guadalupe Mountains in Texas 

being the next highest impacted area by Kansas sources. KDHE choose to focus its reasonable 

progress analysis primarily on the Wichita Mountains because it was the location with modeling 

showing the highest impact from Kansas sources and was the closest Class I area where 

modeling indicated the linear uniform rate of progress for 2018 was unlikely to be met. KDHE 

choose not to perform a detailed analysis and discussion on each additional surrounding Class I 

area as KDHE believes that the emission reductions realized from Kansas BART sources and 

through the reasonable progress analysis will positively impact not only the Wichita Mountains 

but the remaining Class I areas. It is also important to note that CENRAP modeling indicates 

approximately a three percent or less light extinction from Kansas sources in the remaining Class 

I areas making a detailed analysis for each area a lower priority. Kansas instead chose to focus 

primarily on the Wichita Mountains, but did perform modeling and indicated the maximum 

impacted Class I area for each reasonable progress source analyzed as can be seen in Table 10.9. 

10.1.2 Light Extinction at Wichita Mountains 

Figures 10.1 and 10.2 reveal that the largest contributors to haze for Wichita Mountains from 

Kansas sources are nitrates (NO3) from point sources and nonpoint (area) sources. To get a more 

precise idea of relative contributions, the PSAT tool was used to generate tables for individual 

species, for the best 20% visibility days as well as for the worst 20% visibility days. The 

Regional Haze Rule requires reasonable progress goals to ensure no degradation in visibility for 

the least impaired days at each Class I area as well as improvement of the worst [40 CFR 

51.308(d)(1)]. Table 10.2 summarizes the PSAT tool-generated tables, which are found in 

Appendix 10.1. Table 10.2 shows percent total extinction values greater than 0.5% to represent 

percent total extinction for the respective source category and species combinations. Values of 

less than 0.5% were considered to be insignificant.

Table 10.2 2018 Percent Total Light Extinction > 0.5% Due to Kansas Sources for Worst and 

Best 20% Visibility Days for the Wichita Mountains Class I Area 

Source category / particulate species Percent total extinction > 0.5% (%)

Worst 20% visibility days (total extinction = 72.01 Mm-1) 

 Point sources – NO3 0.9572 

 Point sources – SO4 0.8404

 Area sources – POA 0.7210 

Best 20% visibility days (total extinction = 15.14 Mm-1)

 Point sources – NO3 0.7386 

 Point sources – SO4 1.6518 

 Area sources – SO4 0.5526 

 Area sources – POA 1.6600 

 Area sources – EC 0.6497 
58

Appendix D of the Technical Support Document was consulted to find light extinction values for 

Wichita Mountains (see Appendix 10.2). Figure 10.3 shows the glide path for Wichita 

Mountains in inverse megameters, in order to compare with the percent total extinction values 

derived from the PSAT tool. 

Figure 10.3 shows that the 2018 extinction value on the Wichita Mountains glide path is 73.97 

Mm-1, while the 2064 (natural) extinction value is 21.23 Mm-1. These values are derived from 

CMAQ, which is a different photochemical model than CAMx / PSAT. 

Figure 10.3 Glide Path for Wichita Mountains Wilderness Area, Oklahoma, in Terms of Light 

Extinction 

Uniform Rate of Reasonable Progress Glide Path

Wichita Mountains - 20% Data Days

108.20

97.03

73.97

56.39

42.99

32.78

24.99

21.23

87.81

0

20

40

60

80

100

120

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

Year

Bext (1/Mm)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

The PSAT-derived value for 2018 total extinction at Wichita Mountains from Kansas sources is 

72.01 Mm-1, and is less conservative than the CMAQ value shown on the glide slope. The 

CMAQ value will be used here. Table 10.3 shows the absolute light extinction values 

attributable to Kansas emission sources by source category and particulate species at Wichita 

Mountains, which result from combining percent total extinction with total extinction values. 

PSAT modeling shows that by the end of the current planning period (2018), Kansas emission 

sources are projected to contribute only moderately to haze conditions at Wichita Mountains. On 

the haziest days, Kansas contributions are predicted to be chiefly due to point sources (0.71 Mm1

by nitrates and 0.62 Mm-1 by sulfates), and to a lesser extent area sources (0.53 Mm-1 by 
59

primary organic aerosols), primarily from direct emissions from burning activities or natural gas 

combustion. On the clearest days, Kansas contributions will again be due chiefly to point 

sources (nitrates and sulfates), with minor contributions of nitrates from area, biogenic, and 

nonroad mobile source categories. 

Table 10.3 Light Extinction Attributable to Kansas Emission Sources at Wichita Mountains 

Class I Area, by Source Category and Particulate Species 

Source category / particulate 

species 

Percent 

total 

extinction > 

0.5%

2018 

projected 

total light 

extinction 

Kansas 

attributable 

light 

extinction 

% Mm-1

Worst 20% visibility days

 Point sources - NO3 0.9572 73.97 0.71 

 Point sources - SO4 0.8404 73.97 0.62 

 Area sources - POA 0.7210 73.97 0.53 

Best 20% visibility days

 Point sources – NO3 0.7386 21.23 0.16 

 Point sources – SO4 1.6518 21.23 0.35 

 Area sources – SO4 0.5526 21.23 0.12 

 Area sources – POA 1.6600 21.23 0.35 

 Area sources – EC 0.6497 21.23 0.14 

These amounts of projected light extinction are not large. For example, if the entire modeled 

2018 percent extinction contribution from Kansas (4.9%) were removed, the visibility at Wichita 

Mountains would improve by only 0.5 deciviews (dv). Calculations for this example are the 

following: 

Uniform rate of progress for 2018 at WIMO = 73.97 Mm

-1

Kansas modeled 2018 contribution from all sources = 4.9% x 73.97 Mm-1 = 3.62 Mm-1

Converting to deciviews: 73.97 Mm-1

  20.0 dv, 70.35 Mm-1  19.5 dv 

Visibility Improvement: 20.0 dv - 19.5 dv = 0.5 dv 

Because modeled overall percent light extinction exceeds the threshold for visibility impact at 

Wichita Mountains, and the projected 2018 visibility at Wichita Mountains fails to fall below the 

glide path, additional measures for reducing visibility-impairing emissions at Wichita Mountains 

from Kansas sources beyond those achieved by installing controls at Kansas sources subject to 

BART will be needed in the future. 
60

10.2 Selection of Kansas Sources for Reasonable Progress Evaluation 

Under the Regional Haze Rule 40 CFR 51.308(d), “states must address regional haze in each 

mandatory Class I Federal area located within the State and in each mandatory Class I Federal 

area located outside the State which may be affected by emissions from within the State. To meet 

the core requirements for regional haze for these areas, the State must submit an implementation 

plan containing the following plan elements and supporting documentation for all required 

analyses: (1) Reasonable progress goals. (2) Calculations of baseline and natural visibility 

conditions. (3) Long-term strategy for regional haze. (4) Monitoring strategy and other 

implementation plan requirements.” This language was the basis for Kansas to develop this 

process. 

According to the Rule, “In establishing a reasonable progress goal for any mandatory Class I 

Federal area within the state, the state must: consider the costs of compliance, the time necessary 

for compliance, the energy and non-air quality environmental impacts of compliance, and the 

remaining useful life of any potentially affected sources, and include a demonstration showing 

how these factors were taken into consideration in selecting the goal” [40 CFR 

51.308(d)(1)(i)(A)]. This part of the Regional Haze Rule is the basis for the four factor analysis. 

EPA’s Guidance for Setting Reasonable Progress Goals under the Regional Haze Program, 

states: 

In determining reasonable progress, CAA Section 169A(g)(1) requires states to take into 

consideration a number of factors. However, [states] have flexibility in how to take into 

consideration these statutory factors and any other factors that [states] have determined to 

be relevant. For example, the factors could be used to select which sources or activities 

should or should not be regulated, or they could be used to determine the level or 

stringency of control, if any, for selected sources or activities, or some combination of 

both. The factors may be considered both individually and/or in combination (6). 

In addition, EPA’s guidance suggests the following measures: 

 

• Identify the key pollutants and sources and/or source categories that are contributing to 

visibility impairment at each Class I area. The sources of impairment for the most 

impaired and least impaired days may differ. 

• Identify the control measures and associated emission reductions that are expected to 

result from compliance with existing rules and other available measures for the sources 

and source categories that contribute significantly to visibility impairment. 

• Determine what additional control measures would be reasonable based on the statutory 

factors and other relevant factors for the sources and/or source categories. 

• Estimate through the use of air quality models the improvement in visibility that would 

result from implementation of the control measures found to be reasonable and compare 

this to the uniform rate of progress. 
61

In order to perform this analysis for point sources, the State of Kansas developed a multi-step 

process, to apply the statutory factor analysis in a manner that is both equitable and simple. The 

first several steps used readily available actual emissions, visibility impact modeling, and cost of 

controls (i.e., cost of compliance) estimates to identify, screen, and rank the State’s large 

emission facilities. Geographic location was not considered, since this process was carried out 

before state consultations had begun. 

Each of the facilities remaining from the initial screening were then scrutinized for the statutory 

factors of time necessary, energy and non-air quality environmental impacts, and remaining 

useful life, resulting in a ranked list of facilities that would potentially be called on to install 

controls if further emission reductions are necessary to meet the reasonable progress goal at a 

given Class I area. 

The process steps are as follows: 

1. Identify all Kansas emission units that had greater than or equal to 500 tons for NOx

and/or SO2 

2. Identify the most effective control technologies and screen for excessive cost 

3. Model visibility impacts and screen for low-impact facilities 

4. Calculate, screen, and rank based on cost per ton per deciview 

5. Screen for non-cost statutory factors, i.e., time necessary for compliance, energy and nonair quality environmental impacts of compliance, and remaining useful life 

6. Re-sort and make final ranked list of potential facilities 

Step 1: Identify 500 ton NOx and SO2 emission units

Using the 2002 base year inventory, a database query was run on the Kansas point source 

emissions inventory to find all emission units whose NOx and/or SO2 emissions were 500 tons 

per year or more. Kansas chose to use 500 tons for two reasons. First, this is the level agreed 

upon in discussions among CENRAP members for this purpose; and second, visibility impacts 

from modeling that Kansas has performed on larger sources indicate a 500 ton source would not 

significantly impact (> 0.5 delta deciview) a surrounding Class I area. The latter reason applies 

for all locations within the State as Kansas contains no Class I areas. The closest Class I area is 

Hercules Glades, Missouri, and is a distance of 151 km from the Kansas state line. A total of 30 

NOx units and 28 SO2 units were found. Of this set of emission units, 8 NOx and 10 SO2 units 

were removed from the initial candidate list for the following reasons: 

 

The remaining set of 22 NOx units included 11 electric generating units (EGUs), 6 cement kilns, 

2 gas compressor engines, 1 refinery fluid-bed catalytic cracking unit (FCCU) , 1 ammonia plant, 

and 1 glass furnace, all located at 15 facilities. The 18 SO2 units were comprised of 13 EGUs, 4 

Reason for exclusion NOx units SO2 units

Already subject to BART 6 6 

Controls installed since 2002 (now <500 tons) 2 2 

Source has no commercially available controls 0 2 
62

cement kilns, and 1 refinery FCCU, all located at 12 facilities. These data are detailed in Table 

10.4. 

Step 2: Identify most effective control technologies and screen for excessive cost

Next, each of the 500 ton or greater units was aligned with the emission control technology 

selected for it by the CENRAP contractor, Alpine Geophysics, utilizing the least marginal cost. 

For units not identified by Alpine, EPA’s AirControlNET version 4.1 was used to identify 

control technologies, control efficiencies, and costs. The most appropriate control identified by 

the AirControlNET program was selected. Refinements to this selection process were made for 

two facilities, and are summarized in Table 10.5. 

Table 10.4 Kansas Emission Units Not Subject to BART Emitting at Least 500 Tons/Yr of NOx

or SO2 in 2002 

2002 NOx 2002 SO2

Source ID Facility Unit ton/yr 

0910057 AGC Flat Glass North America Glass furnace 1,375 [234.2] 1

1330001 Ash Grove Cement Kiln 2,121 747

0210002 Empire District Electric - 

Riverton 

Unit 7 582 2,393

0210002 Empire District Electric - 

Riverton 

Unit 8 1,040 866

0150004 Frontier El Dorado Refinery FCCU 688 856

1250015 Heartland Cement Kiln 928 1,007

2090048 Kansas City BPU - Quindaro Unit 1 1,599 1,288

2090048 Kansas City BPU - Quindaro Unit 2 1,330 2,123

2090008 Kansas City BPU – Nearman Unit 1 3,860 7,625 

0930012 Kinder Morgan - Lakin Station EU-2 579 [0.1]

0570003 Koch Nitrogen Ammonia 

plant 

585 [0.5]

2057022 Lafarge Midwest - Fredonia Kiln 1 596 660

2057022 Lafarge Midwest - Fredonia Kiln 2 883 978

0010009 Monarch Cement Kiln 4 652 [74.7]

0010009 Monarch Cement Kiln 5 972 [254.6]

0670035 ONEOK - Ulysses Station Clark 1 619 [0.1]

0550023 Sunflower Electric - Holcomb Unit 1 3,781 1,669

1730012 Westar Energy - Gordon Evans Unit 1 [208.5] 618

1550033 Westar Energy - Hutchinson Unit 4 [209.2] 734

1490001 Westar Energy – Jeffrey Unit 3 10,481 23,206

0450014 Westar Energy – Lawrence Unit 3 738 1,965

0450014 Westar Energy – Lawrence Unit 4 2,037 1,430

0450014 Westar Energy – Lawrence Unit 5 3,762 4,354

1770030 Westar Energy – Tecumseh Unit 7 1,531 2,693

1770030 Westar Energy – Tecumseh Unit 8 1,877 4,515

 1 Values within brackets indicate 2002 emissions less than 500 tons per year.
63

Table 10.5 Refinements to AirControlNET Control Technology Determinations 

Emission unit 

Alpineselected 

control 

Control 

actually 

selected 

Comment 

Sunflower 

Electric - 

Holcomb Unit 1 

Low NOx

burner with 

overfire air 

Low NOx

burner 

Source stated boiler 

configuration prohibits use of 

overfire air 

AGC Flat Glass 

North America Oxy-firing 

Selective noncatalytic 

reduction 

Source stated extra O2 impacts 

glass quality adversely 

Also, in conformance with cost levels agreed upon by CENRAP members as excessive, control 

technologies whose cost exceeded $10,000/ton reduced at a given emission unit were screened 

out at this step. As a result, eight SO2 emission units were dropped from the list of candidate 

units, and are listed in Table 10.6, which shows each unit’s cost per ton reduced that was over 

$10,000/ton. 

Table 10.6 Sources with Cost per Ton Reduced Greater than $10,000/ton 

 

SO2 emission unit Cost per ton reduced 

Frontier El Dorado Refinery FCCU $14,069 

Empire District Electric - Riverton Unit 7 $11,066 

Heartland Cement Kiln $28,435 

Westar Energy - Lawrence Unit 4 $40,598 

Sunflower Electric - Holcomb Unit 1 $10,767 

Ash Grove Cement Kiln $24,305 

Lafarge Midwest - Fredonia Kiln 1 $20,127 

Lafarge Midwest - Fredonia Kiln 2 $13,586 

Calculations for fuel switching at Westar’s Hutchinson Energy Center Unit 4 and Gordon Evans 

Energy Center Unit 1 involved analysis of the price of natural gas and #6 residual oil based on 

publicly available information from the Energy Information Administration (7). Calculations for 

Hutchinson Unit 4 included switching to all natural gas with the equivalent heat input of the 

4,195 thousand gallons (Mgal) of #6 oil and 1,240 million cubic feet (MMcf) of natural gas 

burned in 2002. Gordon Evans Unit 1 included fuel switching to all natural gas based on 3,930 

Mgal #6 oil and 865 MMcf natural gas in 2002. The price of natural gas used in the calculations 

was $1,200/Mgal for #6 oil and was $8,000/MMscf for natural gas. Prices from June 2005 to 

November 2006 were used to reflect more current prices. Negative cost results for both units 

(-$135/ton and -$37/ton, respectively) imply that the residual oil burned in 2002 was purchased 

at a lower price than the amount used for this analysis. Also, although fuel switching for these 

two units was selected as a control strategy for SO2, some control of NOx was achieved as well, 

and was included in the CALPUFF modeling in Step 3 below. 
64

Table 10.7 shows a summary of Step 2 results. 

Table 10.7 Most Effective Control Technologies with Acceptable Control Costs for Kansas 500-

Ton NOx and SO2 Emission Units 

Source ID Facility Unit 

Selected 

control 

measure 

Control 

efficiency 

(%) 

Cost per ton 

reduced ($2002 

AirControlNET 

or $2005 Alpine) 

Source 

NOx sources

0910057 

AGC Flat 

Glass North 

America

Glass 

Furnace SNCR 40.0 $1,041 AirControlNET 

1330001 Ash Grove 

Cement 

Cement 

Kiln LNB 25.0 $509 AirControlNET 

0210002 

Empire District 

Electric - 

Riverton 

Unit 7 LNBO 55.9 $1,398 Alpine 

0210002 

Empire District 

Electric - 

Riverton 

Unit 8 LNC3 53.1 $873 Alpine 

0150004 

Frontier El 

Dorado 

Refinery 

FCCU LNB + FGR 55.0 $5,314 Alpine 

1250015 Heartland 

Cement 

Cement 

Kiln Mid-kiln firing 30.0 $83 Alpine 

2090008 

Kansas City 

BPU – 

Nearman 

Unit 1 LNB+OFA+NN 45.2 $750 BPU – 2006 

dollars 

2090048 

Kansas City 

BPU - 

Quindaro 

Unit 1 NGR 50.0 $579 Alpine 

2090048 

Kansas City 

BPU - 

Quindaro 

Unit 2 LNB 40.3 $849 AirControlNET 

0930012 Kinder Morgan 

- Lakin Station EU-2 A/F + IR 30.0 $2,027 AirControlNET 

0570003 Koch Nitrogen Ammonia 

Plant OT + WI 65.0 $688 Alpine 

2057022 

Lafarge 

Midwest - 

Fredonia 

Kiln 1 Mid-kiln firing 30.0 $83 Alpine 

2057022 

Lafarge 

Midwest - 

Fredonia 

Kiln 2 Mid-kiln firing 30.0 $83 Alpine 

0010009 Monarch 

Cement Kiln 4 Biosolid injection 23.0 $466 Alpine 

0010009 Monarch Kiln 5 Biosolid 23.0 $466 Alpine 
65

Cement injection 

0670035 ONEOK - 

Ulysses Station Clark 1 A/F + IR 30.0 $323 Alpine 

0550023 

Sunflower 

Electric - 

Holcomb 

Unit 1 LNB 16.0 $1,383 AirControlNET 

1490001 Westar Energy 

- Jeffrey Unit 3 LNC3 58.3 $1,560 Alpine 

0450014 Westar Energy 

- Lawrence Unit 3 LNC1 33.1 $683 Alpine 

0450014 Westar Energy 

- Lawrence Unit 4 LNC1 43.3 $325 Alpine 

0450014 Westar Energy 

- Lawrence Unit 5 LNC3 58.3 $1,628 Alpine 

1770030 Westar Energy 

- Tecumseh Unit 7 LNC1 33.1 $432 Alpine 

1770030 Westar Energy 

- Tecumseh Unit 8 LNC3 53.1 $518 Alpine 

SO2 sources

0210002 

Empire District 

Electric - 

Riverton 

Unit 8 FGD wet 

scrubber 90.0 $5,782 Alpine 

2090008 

Kansas City 

BPU – 

Nearman 

Unit 1 Semi-Dry 

scrubber 88.5 $2,024 BPU - 2006 dollars 

2090048 

Kansas City 

BPU - 

Quindaro 

Unit 1 FGD wet 

scrubber 90.0 $5,825 Alpine 

2090048 

Kansas City 

BPU - 

Quindaro 

Unit 2 FGD wet 

scrubber 90.0 $3,522 Alpine 

1730012 Westar Energy 

- Gordon Evans Unit 1 Fuel switching 99.9 ($37) KDHE 

1550033 Westar Energy 

- Hutchinson Unit 4 Fuel switching 99.9 ($135) KDHE 

1490001 Westar Energy 

- Jeffrey Unit 3 FGD wet scrubber 75.0 $1,695 AirControlNET 

0450014 Westar Energy 

- Lawrence Unit 3 FGD wet scrubber 90.0 $5,339 Alpine 

0450014 Westar Energy 

- Lawrence Unit 5 FGD wet scrubber 79.2 $9,265 AirControlNET 

1770030 Westar Energy 

- Tecumseh Unit 7 FGD wet scrubber 90.0 $4,519 Alpine 

1770030 Westar Energy 

- Tecumseh Unit 8 FGD wet scrubber 90.0 $3,715 Alpine 
66

Step 3: Model visibility impacts and screen for low-impact facilities

Visibility impact modeling with NOx and SO2 impacts combined

For the 22 NOx and 10 SO2 units within 17 facilities remaining, the next step involved measuring 

visibility impacts at each of the same nine Class I areas chosen for finding facilities subject to 

BART. Essentially the same CALPUFF protocol was followed as for BART screening, so 

modeling was carried out on a facility-by-facility basis, and NOx and SO2 impacts were 

calculated together. Post-control model inputs for emissions were calculated using the control 

efficiencies included with each control technology selected in Step 2. Instead of looking at 

number of days with greater than 1 dv impact as was done for BART screening, in this analysis 

actual deciview values for each facility’s nine modeled impacts were pulled from the 

postprocessing file and examined. Pre- and post-control 98th percentile deciview values for the 

Class I area with greatest impact were recorded, and are presented in the following table. 

Respective differences in deciview are labeled as visibility improvements and the Class I areas 

with greatest impact is shown. 

In addition, facilities whose highest pre-control 98

th percentile impacts were less than 0.100 dv 

were screened out in this step. These are shown in the CALPUFF results table below in gray 

shading: 

Table 10.8 Overall Visibility Improvements Resulting from Application of Most Effective 

Controls at Selected Kansas 500-Ton NOx and SO2 Emission Units 

Source 

ID Facility 

Max. 98th 

percentile 

pre-control 

Max. 98th 

percentile 

post-control 

Visibility 

improvement 

(pre - post) 

Class I area 

impacted 

dv dv dv 

0910057 AGC Flat Glass 

North America 0.065 0.043 0.022 Upper Buffalo 

1330001 Ash Grove 

Cement 0.110 0.086 0.024 Upper Buffalo 

0210002 

Empire District 

Electric - 

Riverton 

0.257 0.165 0.092 HerculesGlades 

0150004 Frontier El 

Dorado Refinery 0.068 0.053 0.015 Wichita Mountains 

1250015 Heartland Cement 0.069 0.053 0.016 HerculesGlades 

2090048 Kansas City BPU 

- Quindaro 0.215 0.082 0.133 HerculesGlades 

0930012 Kinder Morgan - 

Lakin Station 0.021 0.015 0.006 Wichita Mountains 

0570003 Koch Nitrogen 0.028 0.010 0.018 Wichita 

Mountains 

2057022 Lafarge Midwest 0.111 0.105 0.006 Wichita 
67

- Fredonia Mountains 

0010009 Monarch Cement 0.074 0.066 0.008 Upper Buffalo 

0670035 ONEOK - 

Ulysses Station 0.026 0.018 0.008 Wichita Mountains 

0550023 

Sunflower 

Electric - 

Holcomb 

0.189 0.173 0.016 Wind Cave 

1730012 Westar Energy - 

Gordon Evans 0.117 0.006 0.111 Wichita Mountains 

1550033 Westar Energy - 

Hutchinson 0.039 0.008 0.031 Wichita Mountains 

1490001 Westar Energy - 

Jeffrey 1.174 0.341 0.833 Wichita Mountains 

0450014 Westar Energy - 

Lawrence 0.428 0.285 0.143 HerculesGlades 

1770033 Westar Energy - 

Tecumseh 0.308 0.094 0.214 HerculesGlades 

Note that Kansas City BPU Nearman was not evaluated in this table because at the time this modeling was 

performed, the Nearman facility was determined to be a BART source (see Chapter 9). The facility is 

included below in Table 10.9. 

Visibility impact modeling with NOx and SO2 impacts separated

As a refinement to Step 3, CALPUFF was rerun for the five largest remaining sources, all of 

which are EGUs, and the impacts of NOx and SO2 were calculated separately. 

The following table summarizes Step 3 results. 

Table 10.9 Selected Kansas 500-ton NOx and SO2 Emission Units Showing Significant Visibility 

Improvement Resulting from Application of Most Effective Controls 

Source 

ID Facility 

Max. 98th 

percentile 

pre-control 

Max. 98th

percentile 

post-control 

Visibility 

improvement 

Class I area 

impacted 

Dv 

NOx SO2 NOx SO2

1330001 Ash Grove Cement 0.110 0.090 0.024 Upper Buffalo 

0210002 Empire District Electric - 

Riverton 0.257 0.205 0.145 0.052 0.112 Hercules-Glades 

2090048 Kansas City BPU - 

Quindaro 0.215 0.174 0.142 0.041 0.073 Hercules-Glades 

2090008 Kansas City BPUNearman 0.378 0.318 0.198 0.060 0.180 Hercules-Glades 

2057022 Lafarge Midwest - 

Fredonia 0.111 0.105 0.006 Wichita Mountains 

0550023 Sunflower Electric - 

Holcomb 0.189 0.170 0.016 Wind Cave 

1730012 Westar Energy - Gordon 

Evans 0.117 0.010 0.111 Wichita Mountains 
68

1490001 Westar Energy - Jeffrey 1.174 1.06 0.469 0.114 0.705 Wichita Mountains 

0450014 Westar Energy - 

Lawrence 0.428 0.329 0.310 0.099 0.118 Hercules-Glades 

1770033 Westar Energy - 

Tecumseh 0.308 0.271 0.159 0.037 0.149 Hercules - Glades 

 

Step 4: Calculate, screen, and rank based on cost per ton per deciview 

The final calculation is the derivation of cost per ton per unit of change in deciview, the metric 

used to sort the remaining sources for meeting reasonable progress goals. The single value of 

cost per ton per deciview combines cost and visibility improvement in such a way that its 

numeric value increases: (1) as cost of controls increases; and (2) as visibility improvement 

decreases. Thus, the facility with the lowest cost per ton per deciview would be the first to be 

reviewed for possible controls to meet reasonable progress goals if further emission reductions of 

NOx or SO2 are needed. 

For the five higher-impact sources (from Step 3), NOx and SO2 impacts were kept separate for 

this step, since future needs may call for cuts in NOx only or SO2 only. Following is a summary 

table, Table 10.10, showing Step 4 results. 

Table 10.10 Ranked List of Kansas Facilities, Emission Units, and Controls after Cost and 

Visibility Screening 

Source 

ID Facility Pollutant Emission unit(s) 

Cost per 

ton1

Visibility 

improvement 

Class I 

area (98th

percentile) 

Cost per ton 

per dv 

$2002 Dv $2002/ton-dv 

1330001 Ash Grove Cement NOx

Cement 

kiln $509 0.024 Upper Buffalo $21,208 

0210002 Empire District 

Electric - Riverton NOx

Units 7 & 

8 $9842

 0.052 HerculesGlades $18,923 

0210002 Empire District 

Electric - Riverton SO2 Unit 8 $5,326 0.112 HerculesGlades $47,554 

2090048 Kansas City BPU - 

Quindaro NOx

Units 1 & 

2 $660 0.041 HerculesGlades $16,098 

2090048 Kansas City BPU - 

Quindaro SO2

Units 1 & 

2 $4,045 0.073 HerculesGlades $55,411 

2090008 Kansas City BPU - 

Nearman NOx Unit 1 $7433

 0.060 HerculesGlades $12,383 

2090008 Kansas City BPU - 

Nearman SO2 Unit 1 $2,0243

 0.213 Caney 

Creek $9.502 

2057022 Lafarge Midwest - 

Fredonia NOx

Kilns 1 & 

2 $76 0.006 Wichita Mountains $12,667 

0550023 Sunflower Electric - 

Holcomb NOx Unit 1 $1,383 0.016 Wind Cave $86,438 
69

1730012 Westar Energy - 

Gordon Evans SO2 Unit 1 ($37) 0.111 Wichita Mountains ($333) 

1490001 Westar Energy - 

Jeffrey NOx Unit 3 $1,437 0.114 Wichita Mountains $12,605 

1490001 Westar Energy - 

Jeffrey SO2 Unit 3 $1,695 0.705 Wichita Mountains $2,404 

0450014 Westar Energy - 

Lawrence NOx

Units 3, 4, 

& 5 $989 0.099 HerculesGlades $9,990 

0450014 Westar Energy - 

Lawrence SO2

Units 3 & 

5 $7,791 0.118 HerculesGlades $66,025 

1770030 Westar Energy - 

Tecumseh NOx

Units 7 & 

8 $450 0.037 HerculesGlades $12,162 

1770030 Westar Energy - 

Tecumseh SO2

Units 7 & 

8 $3,699 0.149 HerculesGlades $24,826 

1

 Alpine Geophysics reported costs in $2005, which have here been adjusted to 2002 dollars using a factor derived 

the ratio of Consumer Price Index average price data values for the two years, or 179.9/195.3 = 0.92115 (8) 

2

 Empire submitted estimates of $2,427 (60% efficient) and $1,826 (30% efficient) for NOx controls on Units 7 and 

8, respectively. The values shown are from Alpine, however, since further visibility modeling was not carried out for 

the source. 

3

 Cost supplied by Kansas City BPU in an engineering analysis report. Costs are in 2006 dollars. 

Step 5: Screen for non-cost statutory factors

The table below presents a summary of the three non-cost statutory factors analyzed for the 

source remaining after cost and visibility impact was considered. 

Table 10.11 Summary of Reasonable Progress Non-Cost Statutory Factors for Selected Kansas 

Point Sources 

Source ID Facility Pollutant Emission 

unit(s) 

Selected 

control 

measure 

Compliance 

Timeframe 

Non-air 

quality 

environmental 

impacts 

Remaining 

useful life 

NOx

1330001 Ash Grove 

Cement NOx

Cement 

kiln LNB 

Potential 

permitting 

issues, control 

device energy 

requirements 

10-30 years 

0210002 

Empire District 

Electric - 

Riverton 

NOx Unit 7 LNBO 

0210002 

Empire District 

Electric - 

Riverton 

NOx Unit 8 LNC3 

3-4 years 

following 

SIP approval 

Potential 

permitting 

issues, 

reduction in 

electricity 

production 

capacity 

5-10 years 
70

2090048 

Kansas City 

BPU - 

Quindaro 

NOx Unit 1 NGR 

2090048 

Kansas City 

BPU - 

Quindaro 

NOx Unit 2 LNB 

30-50 years 

2090008 

Kansas City 

BPU - 

Nearman 

NOx Unit 1 LNB+OFA+NN 

Potential 

permitting 

issues, 

reduction in 

electricity 

production 

capacity 30-50 years 

2057022 

Lafarge 

Midwest - 

Fredonia 

NOx Kilns 1 & 2 Mid-kiln firing 

Control device 

energy 

requirements 

10-30 years 

0550023 

Sunflower 

Electric - 

Holcomb 

NOx Unit 1 LNB 

1490001 Westar Energy 

- Jeffrey NOx Unit 3 LNC3 

0450014 Westar Energy 

- Lawrence NOx Units 3 & 4 LNC1 

1770030 Westar Energy 

- Tecumseh NOx Unit 7 LNC1 

1770030 Westar Energy 

- Tecumseh NOx Unit 8 LNC3 

Potential 

permitting 

issues, 

reduction in 

electricity 

production 

capacity 

30-50 years 

SO2

0210002 

Empire District 

Electric - 

Riverton 

SO2 Unit 8 FGD wet 

scrubber 5-10 years 

2090048 

Kansas City 

BPU - 

Quindaro 

SO2 Units 1 & 2 FGD wet 

scrubber 

3-4 years 

following 

SIP approval 

Potential 

permitting & 

wastewater 

issues, 

reduction in 

electricity 

production 

capacity 

2090008 

Kansas City 

BPU - 

Nearman 

SO2 Unit 1 Semi-Dry 

scrubber 

3-4 years 

following 

SIP approval 

Potential 

permitting 

issues, 

reduction in 

electricity 

production 

capacity 

1730012 Westar Energy 

- Gordon Evans SO2 Unit 1 Fuel switching Currently feasible — 

1490001 Westar Energy 

- Jeffrey SO2 Unit 3 FGD wet scrubber 

1770030 Westar Energy 

- Tecumseh SO2 Units 7 & 8 FGD wet scrubber 

3-4 years 

following 

SIP approval 

Potential 

permitting & 

wastewater 

issues, 

reduction in 

electricity 

production 

capacity 

30-50 years 
71

The two EGUs at Empire District - Riverton, Units 7 and 8, have startup dates of 1950 and 1954, 

respectively, and it is likely they will be retired before 2018. It is unknown why the IPM 3.0 

future year modeling did not reflect this, but merely indicated reduced (controlled) SO2

emissions for Unit 7 starting in 2010. In addition, there is currently a question about Westar 

Energy’s ability to use wet scrubbers at its Jeffrey facility, which is comprised of Units 1 and 2 

(subject to BART) and 3 (under scrutiny here), due to environmental concerns for wastewater 

sulfur levels. 

Step 6: Source ranking

The final step is source ranking, which is simply listing the sources from Step 5 in increasing 

order of cost per ton per deciview, and trimming the list at a natural break in the results, which 

occurred at $15,000 per ton per dv. The final ranked list is given below in Table 10.12. 

Table 10.12 Ranked List of Sources under the Reasonable Progress Analysis 

Rank Source 

ID Facility Emission unit(s) Pollutant Visibility improvement 

Cost per ton per 

deciview 

Dv $2002/ton-dv

1 1730012 Westar Energy - 

Gordon Evans Unit 1 SO2 0.111 ($333) 

2 1490001 Westar Energy – 

Jeffrey Unit 3 SO2 0.705 $2,404 

3 2090008 Kansas City BPU - 

Nearman Unit 1 SO2 0.213 $9,502a

4 0450014 Westar Energy – 

Lawrence 

Units 3, 4, & 

5 NOx 0.099 $9,990 

5 1770030 Westar Energy – 

Tecumseh Units 7 & 8 NOx 0.037 $12,162 

6 2090008 Kansas City BPU - 

Nearman Unit 1 NOx 0.060 $12,383 

7 1490001 Westar Energy – 

Jeffrey Unit 3 NOx 0.114 $12,605 

8 2057022 Lafarge Midwest – 

Fredonia Kilns 1 & 2 NOx 0.006 $12,667 

a Cost is based on 2006 dollars at Caney Creek. Hercules-Glades cost is $11,244 again in 2006 dollars. 
72

10.3 Reasonable Progress Conclusions 

The results of this process are described below. Kansas determined that controls or fuel 

switching on the sources listed below are reasonable and will result in significant visibility 

improvements at the Wichita Mountains Wilderness Area: 

• Westar Energy – 

o Gordon Evans Unit 1 — Westar will implement fuel switching to natural 

gas at all times, with the only exception being a gas curtailment order from 

the gas supplier, in which case the facility will be allowed to utilize 

backup #6 fuel oil. 

o Jeffrey Unit 3 — Westar will install controls for both NOx and SO2. 

Emissions limits will be established at control levels of 0.15 lb/MMBtu for 

SO2 and 0.15 lb/MMBtu for NOx. 

o Lawrence Units 3, 4, & 5, and Tecumseh Units 7/9 & 8/10 — Westar has 

agreed to controls or emission limits at each of these units and are outlined 

in Table 10.14 in section 10.4.3.3. 

For the remaining facilities identified in the table above: 

• BPU - Nearman Unit 1. This source primarily impacts the Class I areas in Missouri 

and Arkansas. Through the consultation process with Missouri and Arkansas it was 

determined that no additional controls beyond expected BART and on the books 

controls would be needed for the Class I areas in these states. However, with the 

vacatur of the Clean Air Interstate Rule (CAIR), an on the books rule covering many 

sources in Missouri and Arkansas, that occurred on July 11, 2008, and subsequent 

December 23, 2008, remanding of the case back to EPA without vacatur so that EPA 

could remedy CAIR’s flaws as were discussed in the courts July ruling, it may be 

necessary to revisit the consultation process with Missouri and Arkansas and 

reconsider whether controls on Nearman Unit 1 should be required. This consultation 

would occur once a final CAIR decision is made and would be initiated by Missouri 

and/or Arkansas. 

• Lafarge Midwest - Fredonia Kilns 1 & 2- Kansas held a conference call with 

representatives from each of the four cement facilities in the State. A request for 

information was made for feedback regarding the technical feasibility and cost 

estimates for the controls identified by Alpine and AirControlNET. The 2018 

estimates show a growth in emissions for three of the state’s facilities to be in the 

range of 40-60 % increases between 2002 and 2018. Industry representatives did not 

agree with these estimates. Additionally, information received from the information 

request raised concerns regarding design and lay-out constraints of some of the 

control technologies identified. These considerations combined with the small level 

of improvements in visibility gained by controls at this facility (0.006 dv for Wichita 
73

Mountains), led to the decision not to require controls at this time. Additional 

technical and cost evaluations will be conducted during the five-year progress review. 

Overall, the State expects to achieve reductions of approximately 11,500 tons/yr of reductions in 

NOx and 26,000 tons/yr of reductions in SO2 from the sources required to control as part of the

regional haze reasonable progress goals. Table A10.3.1 in Appendix 10.3 shows the derivation 

for these values. 

CENRAP has also performed a control strategy run (discussed in Chapter 8) that included 

sources identified above along with several additional sources. This control run identified the 

following Kansas sources based on selection criteria approved by the CENRAP Policy Oversight 

Group (POG). The selection criteria and modeled controls can be found on the CENRAP 

website at http://www.cenrap.org/projects.asp. The Kansas sources identified are shown in 

Table 10.13 below. 

Table 10.13 Kansas Sources Identified in the Control Strategy PSAT Run 

Source ID Facility 

Pollutant: NOx

2057022 Lafarge Midwest - Fredonia 

0010009 Monarch Cement 

0450014 Westar Energy - Lawrence 

2090048 Kansas City BPU - Quindaro 

1490001 Westar Energy - Jeffrey 

0910057 AGC Flat Glass North America

0210002 Empire District - Riverton 

1070005 KCP&L - La Cygne 

2090008 Kansas City BPU - Nearman 

0550023 Sunflower Electric - Holcomb 

1250015 Heartland Cement 

Pollutant: SO2

1770030 Westar Energy - Tecumseh 

2090008 Kansas City BPU - Nearman 

2090048 Kansas City BPU - Quindaro 

2090049 Kansas City BPU - Kaw 

Kansas City BPU - Kaw has been on cold stand-by since 2001 (Unit 1) and 2003 (Unit 3); Unit 2 

was retired in 1992. Any additional controls required for this facility would be determined and 

implemented should the facility restart. 

The State of Kansas is currently finalizing a NOx Emission Reduction Rule as part of the 

implementation of the Kansas City Ozone Maintenance Plan (see section 10.4.3.1.9). The 

timeframe for implementation of the NOx Emission Reduction Rule will achieve emission 
74

reductions sooner than would have been achieved under the Regional Haze Rule, therefore, we 

are not pursuing further NOx controls from the Nearman facility at this time. 

Kansas commits to review emissions changes and potential new technology developments that 

may apply to the sources identified above as part of the five-year progress report. If a 

determination is made that controls are feasible, cost-effective, and needed for visibility 

improvements, the State will explore additional controls at that time. 

10.4 Long-Term Strategy 

Kansas is required by 40 CFR 51.308(d)(3) to submit a long-term strategy that addresses 

visibility impairment for each mandatory Class I Federal area within and outside the State which 

may be affected by emissions from within the State. The long-term strategy must include 

enforceable emissions limitations, compliance schedules, and other measures necessary to 

achieve the reasonable progress goals established by states where the Class I areas are located. 

This section describes how Kansas meets the long-term strategy requirements. 

10.4.1 Share of Emission Reductions 

Kansas is required by 40 CFR 51.308(d)(3)(ii) to demonstrate that its implementation plan 

includes all measures necessary to obtain its fair share of emission reductions needed to meet 

reasonable progress goals. 

The technical analysis discussed in Chapter 10 demonstrates that the State’s long-term strategy, 

when coordinated with other state/tribes’ strategies, is sufficient to meet reasonable further 

progress goals. 

10.4.1.1 Baseline Inventory 

Kansas is required by 40 CFR 51.308(d)(3)(iii) to identify the baseline inventory on which the 

long-term strategy is based. 

Kansas used the 2002 CENRAP Base G Emissions Inventory as its baseline inventory. See 

Table 7.1, Chapter 7. 

10.4.2 Anthropogenic Sources of Visibility Impairment 

Kansas is required by 40 CFR 51.308(d)(3)(iv) to identify all anthropogenic sources of visibility 

impairment considered by the State in developing its long-term strategy. 

Appendix 7.1 provides the 2002 emissions inventory used in developing this SIP. 
75

10.4.3 Factors the State Must Consider 

Kansas is required by 40 CFR 51.308(d)(3)(v) to consider several factors in developing its longterm strategy. These are discussed below. 

10.4.3.1 Emission Reductions Due to Ongoing Air Pollution Programs 

Kansas is required by 40 CFR 51.308(d)(3)(v)(A) to consider emission reductions from ongoing 

air pollution control programs. 

Kansas considered the following ongoing programs in developing its long-term strategy: onboard refueling vapor recovery (ORVR), on-board diagnostics (OBD), federal on-road and 

nonroad emission standards, low sulfur fuel standards, the Kansas City Ozone Maintenance Plan, 

the Clean Air Interstate Rule (CAIR), National Emission Standards for Hazardous Air Pollutants 

(NESHAP), and Agreements between the State and certain facilities. 

Significant reductions in NOx, PM, and SO2 are expected due to existing and new federal 

standards for on-road and nonroad engines and fuels. 

 

 10.4.3.1.1 On-Board Refueling Vapor Recovery (ORVR) 

In 1994, federal standards were promulgated requiring new vehicles to be equipped with onboard refueling vapor recovery (ORVR) technology. The phase-in of ORVR was completed as 

follows: 

• Light duty vehicles (<6,000 lbs) began in 1998 and were completed in 2000 

• Pickup trucks and SUVs (6,001-8,500 lbs) began in 2001 and were completed in 2003 

• Heavy duty vehicles (8,501-10,000lbs) began in 2004 and will be completed with the 

2006 model year 

 

 10.4.3.1.2 On-Board Diagnostics (OBD) 

The first version of On-Board Diagnostic systems (OBD I) was implemented in 1988. A second 

version (OBD II) was developed to expand on the earlier technology. The Clean Air Act 

Amendments of 1990 mandated that beginning in 1996, all light-duty cars and trucks be 

equipped with OBD II systems. Beginning in the model year 2004, all medium duty vehicles 

weighing up to 14,000 pounds were also required to be equipped with OBD II. Beginning with 

the model year 2010, all heavy-duty vehicles weighing over 14,000 pounds are required to be 

equipped with OBD II. 

 10.4.3.1.3 Tier 2 Vehicle and Gasoline Sulfur Program 

Under the Tier 2 program, which was adopted in 1999, new emission standards were developed 

for passenger cars, light duty trucks, and larger passenger vehicles which were placed in a new 

classification called “medium-duty passenger vehicles.” The medium-duty vehicles include pickup trucks, sports utility vehicles (SUVs), and vans. The phase-in of new standards began with 

model year (MY) 2004, and was completed in MY 2007 for cars and light-duty trucks, and in 
76

2008 for medium-duty vehicles. By 2007, the emission limit for NOx was 0.07 grams per mile 

(g/mi). In addition to more stringent emission standards for vehicles, the Tier 2 program also 

required reductions in sulfur levels in gasoline to be phased in between the years 2000 and 2006. 

The sulfur levels in gasoline were capped at 300 parts per million (ppm) and limited to an 

average of 120 ppm in 2004, and by 2006 the cap was lowered to 80 ppm with a limit on average 

sulfur levels of 30 ppm. 

 10.4.3.1.4 Clean Air On-Road Diesel Rule (2007 Highway Rule) 

In December of 2000, the EPA promulgated the Clean Air On-Road Diesel Rule, also called the 

2007 Highway Rule. The rule has two components, emission standards and diesel fuel 

regulation. The new emission standards include limits on PM, NOx, and non-methane 

hydrocarbons (NMHC). The PM standard took effect in the 2007 model year, while the NOx and 

NMHC standards will be phased in between 2007 and 2010. The diesel fuel regulation limits the 

sulfur content in on-highway diesel fuel to 15 ppm. Ultra low sulfur diesel fuel became available 

nationwide in October 2006. 

 10.4.3.1.5 Clean Air Nonroad Diesel Rule 

The first federal standards (Tier 1) for new nonroad diesel engines over 50 horsepower (hp) were 

adopted in 1994 and were phased in between 1996 and 2000. In 1998 EPA finalized a new rule, 

which applied Tier 1 to equipment under 37 hp and applied more stringent Tier 2 and Tier 3 

standards to all equipment with phase-in schedules between 2000 and 2008. The Tier 1–3 

standards consisted primarily of engine design standards, with no or very limited use of exhaust 

after-treatment. In May 2004, EPA finalized the Clean Air Nonroad Diesel Rule, also known as 

Tier 4 standards. Tier 4 standards will be phased in over the period of 2008 to 2010, and will 

consist of exhaust after-treatment (oxidation catalysts) and other control technologies. Another 

component of the Tier 4 standards will reduce the sulfur content of nonroad diesel fuel to enable 

the use of sulfur-sensitive control technology. The sulfur content was to be reduced to 500 ppm 

by June 2007 and reduced to 15 ppm by June 2010. When fully implemented, the Tier 4 

standards are expected to reduce NOx and PM emissions by 90%. 

 10.4.3.1.6 Locomotive Emission Standards 

The first emission standards regulating locomotive engines (Tier 0-2) were adopted in 1997. The 

Tier 0-2 standards regulated the emission of NOx, PM, CO, and hydrocarbons (HC) for new 

engines or any engine built after 1973 being remanufactured. The rule became effective in 2000 

and was implemented by the following schedule: 

• Tier 0 standards applied to locomotive engines built between 1973 and 2001 

• Tier 1 standards applied to engines built between 2002 and 2004 

• Tier 2 standards applied to engines built in 2005 and later years 

On March 2, 2007, EPA published a proposed ruling for locomotives and marine engines. The 

proposed rule would require stricter emission standards for locomotives being remanufactured 

starting in 2010. The rule also established Tier 3 standards for newly built locomotive and diesel 
77

marine engines starting in 2009. Tier 4 standards, which require exhaust after-treatments, will 

become effective for marine engines in 2014 and for locomotives in 2015. 

10.4.3.1.7 Large Spark-Ignition and Recreational Vehicle Rule 

In 2002, EPA adopted new standards for emissions of NOx, HC, and carbon monoxide (CO) 

from several groups of previously unregulated nonroad engines, including spark-ignition (SI) 

engines powered by: gasoline, liquid propane gas and compressed natural gas rated over 19 

kilowatts (kW), snowmobiles, off-highway motorcycles, all terrain vehicles, and diesel marine 

engines over 37 kW. The emission standards were phased in between 2004 and 2007.

10.4.3.1.8 Proposed Emission Standards for New Nonroad Small Spark-Ignition 

Engines, Equipment, and Vessels 

In April 2007, EPA released proposed exhaust emission standards for marine spark-ignition 

engines and small land-based nonroad engines. The new standards apply to SI nonroad engines 

rated below 25 horsepower (19 kW) used in household and commercial applications, including 

lawn and garden equipment, utility vehicles, generators, and a variety of other construction, 

farm, and industrial equipment. The new standards also apply to spark-ignition engines used in 

marine vessels, including outboard engines, personal watercraft, and stern-drive/inboard engines. 

For SI nonroad engines, the EPA proposed HC+NOx exhaust emission standards of 10 g/kW-hr 

for Class I engines starting in the 2012 model year and 8 g/kW-hr for Class II engines starting in 

the 2011 model year. The proposed standards for SI marine engines above 40 kW are 16 g/kWhr for HC+NOx and 200 g/kW-hr for CO. For marine engines below 40 kW, the standards 

increase gradually based on the engine’s maximum power. The new standards include 

requirements to control fuel tank permeation, fuel line permeation, and diffusion emissions for 

nonroad and marine engines. 

 10.4.3.1.9 Kansas City Ozone Maintenance Plan 

The Kansas City Maintenance Area (KCMA) is currently designated as an attainment area for 

the 8-hour ozone standard and as a maintenance area under the previous 1-hour ozone standard. 

Based on these designations, the KCMA is required to have a maintenance plan under Section 

110(a)(1) of the Clean Air Act (CAA) and the provisions of the EPA’s Phase 1 Implementation 

Rule for the 8-hour Ozone Standard (40 CFR Section 51.905(a)(3) and (4)). KDHE prepared a 

maintenance plan to meet all of the requirements for the 8-hour ozone standard for its portion of 

the KCMA. 

The 8-hour ozone maintenance plans constitute revisions to the State Implementation Plans and 

provide for continued maintenance of the 8-hour ozone standard for a period of 10 years, ending 

in 2014. The plans also provide contingency control measures to be implemented if a violation 

of the 8-hour ozone standard occurs. On June 15, 2007, one of the monitors in the KCMA 

registered an 8-hour average ozone concentration in exceedance of the ozone standard, thereby 

violating the standard. The contingency measures will be implemented in two phases. 

The control measure in Phase I, Measure #1, is to reduce NOx emissions from point sources in 

Johnson and Wyandotte counties. This will be implemented via a new set of Kansas 
78

Administrative Regulations, K.A.R. 28-19-713 through 28-19-713d. These new regulations will 

affect a total of three facilities in Johnson and Wyandotte counties. Two are power generating 

facilities, and the remaining one is a flat glass manufacturing plant. 

The two power generating facilities are Nearman Creek Power Station and Quindaro Power 

Station, both of which are owned by the Kansas City Board of Public Utilities (BPU), and 

located in northeastern Wyandotte County. When K.A.R. 28-19-713 through 28-19-713d are 

implemented, the combined NOx emissions from these two sources will be reduced by 

approximately 2,948 tons/year (8.08 tons/day). 

The flat glass manufacturing facility is AGC Flat Glass North America, located near Spring Hill 

in southern Johnson County. When K.A.R. 28-19-713 through 28-19-713d are implemented, 

emissions are projected to be reduced by approximately 292 – 487 tons/year (0.8 – 1.33 

tons/day), depending on the control technology implemented. 

The control measure in Phase I, Measure #2, is to reduce idle time of heavy-duty diesel vehicles 

in Johnson and Wyandotte counties. This will also be implemented via a new set of Kansas 

Administrative Regulations, K.A.R. 28-19-712 through 28-19-712d. These new regulations will 

apply to all owners and operators of commercial, public and institutional diesel vehicles in 

Johnson and Wyandotte counties having a gross vehicle weight rating greater than 14,001 

pounds. 

In the event that technical feasibility or other conditions change after the submittal date of this 

SIP that would result in any of the Phase I contingency measures not being able to be 

implemented, the State of Kansas will evaluate the need to propose alternate measures that 

would result in equivalent or greater emissions reductions. The EPA’s desired timeline for 

adoption and implementation of control measures is as expeditious as practicable, but no longer 

than 24 months. It is anticipated that all of these control measures can meet the desired 

timeframe. 

Control options being considered for the Kansas portion of the KCMA for Phase II include: 

• Reductions in NOx emissions from point sources >100 tons of actual annual emissions from 

the entire facility averaged over the last three years of complete, quality assured inventory 

data from Wyandotte and Johnson Counties. This would be accomplished through either NOx

Emission Reduction Rules or signed agreements with the affected sources. 

• Reduction in NOx emissions from point sources >1000 tons of actual annual emissions from 

the entire facility averaged over the last three years of complete, quality assured inventory 

data in areas located south of the KCMA (Miami and Linn Counties). Based on the current 

emissions inventory, this would affect two sources. Because of this fact, these two counties 

would not be incorporated into the KCMA. This would be accomplished through either a 

regional NOx administrative regulation or signed agreements with the affected sources. 

• Open burning restrictions in Wyandotte and Johnson Counties 
79

• Lower threshold for major sources of VOC, to 75 tons/yr in Wyandotte and Johnson 

Counties. KDHE would evaluate remaining large VOC emitters subject to existing VOC 

RACT rules to determine if further reductions could be achieved. (VOC RACT rules can be 

found at K.A.R. 28-19-63–74, -76, -77, -714, -717, and -719.)

• VOC control for 46 sources associated with the source classification code Architectural and 

Industrial Maintenance Coatings, including traffic coatings in Wyandotte and Johnson 

Counties.

• Diesel engine chip re-flash regulation in Wyandotte and Johnson Counties 

Control measures will be selected from the above list based on emission reduction benefits, cost 

effectiveness, and timeframe of implementation. In order to aid in determining the most 

beneficial control measures, photochemical modeling may be used as a tool for evaluation. 

Adoption and implementation of controls shall take place no later than 18–24 months after 

KDHE makes a determination, based on quality-assured ambient data, that a trigger established 

by this plan has been exceeded. 

 10.4.3.1.10 Clean Air Interstate Rule 

At the onset of the regional haze consultation process, states relied heavily on the Clean Air 

Interstate Rule (CAIR), a rule that addresses the interstate transport of air pollution to downwind 

states. CAIR covered 28 eastern states plus the District of Columbia, and would have reduced 

SO2 emissions by an estimated 5.4 million tons and NOx emissions by an estimated 2 million 

tons by 2015. Affected states had the choice of either meeting the state’s emission budget by 

requiring power plants to participate in a cap and trade system, or by means of a measure of the 

state’s choosing. 

Although Kansas was not included in the final CAIR rulemaking, the rule was a major 

component in the underlying assumptions used to determine source apportionment because of the 

reductions expected in neighboring states with Class I areas. 

In July 2008, the D.C. District Court of Appeals vacated the CAIR rule in its entirety. On 

September 24, 2008 EPA filed a petition for rehearing or for a remand of the case without 

vacatur. On December 23, 2008, the D.C. District Court of Appeals remanded the case to EPA 

without vacatur so that EPA could remedy CAIR’s flaws as were discussed in their July ruling. 

At this time, it is unclear what the ramifications of this decision may be to the regional haze 

program. Kansas will continue to engage with states in the CENRAP region and will participate 

in future consultation processes if necessary to address reasonable progress goals at Class I areas. 

 10.4.3.1.11 NESHAP MACT Standards 

National Emission Standards for Hazardous Air Pollutants (NESHAP) have been promulgated in 

recent years that will not only achieve reductions in hazardous air pollutants (HAPs), but will 

also reduce visibility impairing pollutants such as SO2, NOx, and PM. Emission standards for 

stationary reciprocating internal combustion engines (RICE) and industrial, commercial, and 
80

institutional boilers are NESHAP’s most notable Maximum Achievable Control Technology 

(MACT) standards related to reductions in pollutants contributing to regional haze. Additional 

MACT-related reductions are also expected from the following industries in Kansas: cellulose 

products manufacturing, hazardous waste combustion, and secondary aluminum production. 

 10.4.3.1.12 Kansas City Power & Light (KCP&L) Collaboration Agreement 

On January 31, 2006, the MoDNR issued a Prevention of Significant Deterioration (PSD) permit 

for KCP&L’s Iatan project, which included the installation of new pollution control technology 

on Iatan Unit 1, to set a permit limit on the heat input rate of Iatan Unit 1, and to construct a 

second pulverized coal-fired boiler (Iatan Unit 2). Upon issuance of the PSD permit, the Sierra 

Club filed a complaint with the Missouri Air Conservation Commission (MACC) to appeal the 

issuance of the Iatan PSD permit, urging that the MDNR require more stringent emission limits 

at Iatan Units 1 and 2. On March 19, 2007, KCP&L signed a collaboration agreement with the 

Sierra Club and the Concerned Citizens of Platte County. As part of the agreement, KCP&L 

agreed to more stringent emission limits for Iatan Units 1 and 2 for NOx, SO2, opacity, and 

sulfuric acid. The emission limits that relate to regional haze purposes are as follows: 

• Iatan Unit 1 

o NOx – 0.09 lbs/MMBtu, based on a 30-day rolling average

o SO2 – 0.07 lbs/MMBtu, based on a 30-day rolling average 

• Iatan Unit 2 

o NOx – 0.07 lbs/MMBtu, based on a 30-day rolling average

o SO2 – 0.06 lbs/MMBtu, based on a 30-day rolling average 

In addition to tighter controls at Iatan, KCP&L agreed to accept emissions limits for their two 

BART-eligible units at La Cygne, Kansas (La Cygne Units 1 and 2) that will be lower than 

presumptive limits in the Regional Haze Rule for NOx, SO2, filterable PM10, and total PM10. 

These emission limits are as follows: 

• NOx – 0.13 lbs/MMBtu, based on a 30-day rolling average, excluding periods of startup 

and shutdown 

• SO2 – 0.1 lbs/MMBtu, based on a 30-day rolling average, excluding periods of startup 

and shutdown 

• PM10 (filterable) – 0.015 lbs/MMBtu, based on either an average of 3 one-hour stack tests 

annually, or a Continuous Assurance Monitoring (CAM) plan before baghouses go 

online 

• PM10 (total) – 0.024 lbs/MMBtu, based on either an average of 3 one-hour stack tests 

annually, using EPA Method 202 or a CAM plan before baghouses go online 

 10.4.3.1.13 Visibility Requirements under the New Source Review Program 

Section 40 CFR 52.21(o) requires owners or operators of new major sources or modifications to 

provide an analysis of visibility impairment as part of the prevention of significant deterioration 

process. New sources or modifications also require notification and consultation with federal 
81

land managers (FLMs) of Class I areas which may be affected. Kansas has adopted the federal 

regulation by reference at K.A.R. 28-19-350. 

10.4.3.2 Measures to Mitigate the Impacts of Construction Activities 

Kansas is required by 40 CFR 51.308(d)(3)(v)(B) to consider measures to mitigate the impacts of 

construction activities. 

When EPA first promulgated the Regional Haze Rule in 1999, emissions related to construction 

activities such as windblown dust and nonroad diesel engines were a major concern. This was 

especially a problem in rapidly growing metropolitan areas such as Los Angeles and Phoenix. 

Construction activities are directly related to population growth. Kansas has not experienced 

rapid growth and is not forecasted to in the future. Figure 10.4 below shows the population 

growth for Kansas between the years of 1980 and 2005, with projected figures out to 2020 

appearing in red triangles (9). 

Between the years 1990 and 2000, over half of Kansas counties underwent a decline in 

population, mostly in rural counties but also in parts of the Kansas City metropolitan area (10). 

Population growth is projected to remain at a steady pace and construction activities are not 

expected to cause a significant impact to visibility. In fact, construction permitting in Kansas 

and new regulations on diesel equipment will achieve reductions in the future. 

Construction projects in Kansas that disturb one acre or more are required to obtain a general 

permit under the National Pollutant Discharge Elimination System (NPDES). The permitting 

program was implemented to protect the waters of the State from sediment and other 

contaminants, and may also reduce the amount of particulate matter emissions from these 

activities. 

Figure 10.4 Population Growth for the State Of Kansas 1980-2005 and Projected Growth 2010-

2020 

Kansas Population (in thousands)

0

500

1,000

1,500

2,000

2,500

3,000

3,500

1980 1985 1990 1995 2000 2005 2010 2015 2020
82

The NPDES permits require permitted entities to develop a storm water pollution prevention 

plan containing best management practices to control erosion and runoff. Many of the best 

management practices employed to prevent erosion and runoff are also effective at preventing 

windblown dust. For example, the use of wind fences, sprinkling, or using vegetative cover such 

as geotextiles can reduce the amount of airborne particles. 

Emissions from diesel engines in the construction industry are expected to decline with the 

implementation of new federal standards for both on-road and nonroad engines. Additionally, 

the use of ultra-low sulfur diesel fuel, which is now mandatory for on-road use and is scheduled 

for all nonroad use in 2010, will achieve reductions in the future. 

10.4.3.3 Emission Limitations and Schedules of Compliance 

Kansas is required by 40 CFR 51.308(d)(3)(v)(C) to consider emissions limitations and 

schedules for compliance to achieve reasonable progress goals.

Emissions reductions by Westar through emissions limitations or work practices are summarized 

in Table 10.14. The enforceable mechanisms and schedules of compliance for these measures 

are contained in the Agreement for the affected facilities, found in Appendix 9.7. 

Table 10.14 Additional Measures Implemented under the Long-Term Strategy to Meet 

Reasonable Progress Goals 

Emission limit or work practice Facility/Unit NOx SO2 

Westar - Gordon Evans Unit 1 Natural gas only 

Westar - Hutchinson Unit 4 Natural gas only 

Westar - Jeffrey Unit 3 0.15 lb/MMBtu 0.15 lb/MMBtu

Westar - Lawrence Unit 3 0.18 lb/MMBtu 

Westar – Lawrence Unit 4 0.18 lb/MMBtu 0.15 lb/MMBtu 

Westar – Lawrence Unit 5 0.15 lb/MMBtu 0.15 lb/MMBtu 

Westar - Murray Gill Unit 1 Natural gas only 

Westar - Murray Gill Unit 2 Natural gas only 

Westar - Murray Gill Unit 3 Natural gas only 

Westar - Murray Gill Unit 4 Natural gas only 

Westar - Neosho Unit 7 Natural gas only 

Westar - Tecumseh Unit 7/9 0.18 lb/MMBtu 

Westar - Tecumseh Unit 8/10 0.18 lb/MMBtu 
83

 10.4.3.4 Source Retirement and Replacement Schedules 

Kansas is required by 40 CFR 51.308(d)(3)(v)(D) to consider source retirement and replacement 

schedules in developing reasonable progress goals. The Integrated Planning Model (IPM) runs 

projected the closure of several gas-fired boilers in Kansas. However, communication with 

owners of these sources revealed that these projections are incorrect. Kansas is aware of two 

coal-fired EGU sources that could potentially be retired within the next 10 years. The first, 

Kansas City BPU - Kaw, has two units that have been on cold stand-by since 2001 (Unit 1) and 

2003 (Unit 3). Unit 2 was retired in 1992. This source would be subject to existing SIP 

requirements pertaining to PSD permitting should BPU decide to restart. In addition, as part of 

its long-term planning process, BPU is evaluating options for adding new capacity and may 

decide to retire another existing facility in the future. The second source, Empire District 

Electric - Riverton Units 7 and 8, have startup dates of 1950 and 1954, respectively, and will 

likely be retired before 2018. Beyond these two sources, Kansas is not aware of additional 

sources scheduled for retirement or replacement. Any additional sources that retire or are 

replaced will be managed in conformance with the existing Kansas SIP requirements pertaining 

to PSD and NSR permitting. 

 10.4.3.5 Agricultural and Forestry Smoke Management 

Kansas is required by 40 CFR 51.308(d)(3)(v)(E) to consider smoke management techniques for 

the purposes of agricultural and forestry management in developing reasonable progress goals. 

Kansas will work to implement smoke management techniques to address rangeland burning. 

See Appendix 10.4 for Kansas Prescribed Fire Emissions. 

10.4.3.6 Enforceability of Emission Limitations and Control Measures 

Kansas is required by 40 CFR 51.308(d)(3)(v)(F) to ensure that emission limitations and control 

measures used to meet reasonable progress goals are enforceable. 

Kansas has ensured that all emission limitations and control measures are enforceable by 

embodying these in the Agreements found in Appendix 9.7. The agreements contain the 

applicable emission limits and compliance schedules, which will be federally enforceable upon 

EPA’s approval of this SIP. The emissions limits and compliance verification requirements will 

be incorporated into each facility’s Title V operating permit when they are reopened or 

approved. 

10.4.3.7 Anticipated Net Effect on Visibility Resulting from Projected Changes to 

Emissions 

Kansas is required by 40 CFR 51.308(d)(3)(v)(G) to address the net effect on visibility resulting 

from changes projected in point, area, and mobile source emissions by 2018. 

The 2002 to 2018 projected visibility improvement at the nine Class I areas selected for analysis 

and discussed in Chapter 8 will, for the State of Kansas, result chiefly from the implementation 

of NOx and SO2 controls on the five electric generating units (EGUs) subject to BART. These 
84

projected visibility improvements are shown in Table 10.15, based on the ENVIRON PSAT tool, 

and shown in terms of light extinction. 

The impact on the Wichita Mountains from Kansas sources is expected to be reduced by 1.03715 

Mm-1, which represents a 23% change in Kansas’ impact on the Wichita Mountains between 

2002 and 2018. Further improvement will come from the “beyond-BART” controls at sources 

referred to in Chapter 10. 

Table 10.15 Net 2002 to 2018 Improvement in Visibility at Selected Class I Areas Due to BART 

Controls in Kansas 

Class I area Net 2002-2018 light extinction difference 

(improvement) from Kansas sources (Mm-1)

Caney Creek (Arkansas) 0.63493 

Upper Buffalo (Arkansas) 0.44533 

Great Sand Dunes (Colorado) 0.03322 

Rocky Mountain (Colorado) 0.06051 

Hercules-Glades (Missouri) 0.56911 

Mingo (Missouri) 0.58719 

Wichita Mountains (Oklahoma) 1.03715 

Badlands (South Dakota) 0.12856 

Wind Cave (South Dakota) 0.16741 

List of Chapter 10 Appendices

10.1 PSAT Tool-Generated Tables 

10.2 2018 Visibility Projections for CENRAP Class I Areas (TSD Appendix D) 

10.3 Calculations for Emissions Reductions for Kansas Reasonable Progress Goals 

10.4 Kansas Prescribed Fire Emissions 
85

11. Consultation 

Kansas does not contain any Class I Areas. Kansas participated in state consultation processes 

with Arkansas, Missouri, Texas, and Oklahoma. A summary of these consultation processes is 

given below. In each case, the states established a threshold to determine whether neighboring 

states would be expected to contribute emissions reductions for meeting their Class I areas’ 

reasonable progress goals. Kansas fell below the established thresholds for all but one Class I 

area. Kansas is anticipated to contribute to visibility impairment at the Wichita Mountains 

Wilderness Area in Oklahoma. 

11.1 Consultation 

Kansas is required by 40 CFR 51.308(d)(3)(i) to consult with other states/tribes to develop 

coordinated emission strategies. This requirement applies both where emissions from the state 

are reasonably anticipated to contribute to visibility impairment in Class I areas outside the state 

and when emissions from other states/tribes are reasonably anticipated to contribute to visibility 

impairment in Class I areas within the state/tribe.

Kansas consulted with other states and tribes by participation in CENRAP in an effort to develop 

coordinated strategies to meet reasonable progress goals. In addition, Kansas participated in 

discussions focused on Class I areas in Arkansas, Missouri, Texas, and Oklahoma. Following is 

a summary of the calls, and the conclusions reached through the consultation process. 

 11.1.1 Arkansas and Missouri 

The States of Arkansas and Missouri elected to combine their consultation processes for the 

central Class I areas contained within their boundaries: 

• Caney Creek Wilderness Area (Arkansas) 

• Upper Buffalo Wilderness Area (Arkansas) 

• Hercules Glades Wilderness Area (Missouri) 

• Mingo Wilderness Area (Missouri) 

Arkansas and Missouri developed a consultation plan in which they outlined the consultation 

process and timeline, described the methodology for determining the significantly contributing 

states, and delineated the roles and responsibilities of the various agencies involved in the 

consultation process. Three conference calls were scheduled to facilitate consultation, and were 

held on April 3, May 11, and June 7, 2007. 

Arkansas and Missouri’s consultation plan included a methodology in which three criteria were 

used to determine whether a neighboring state significantly contributes to visibility impairment 

at on or more of the Class I areas listed above. If any state was indicated in two of the three 

criteria, they were determined to be significant contributors. A fourth index, quantity of 

emissions over distance (Q/d), was also used for informational purposes. The states of Arkansas 
86

and Missouri did not request emission reduction commitments from the State of Kansas beyond 

its BART reductions. 

 11.1.2 Texas 

The State of Texas contains the following Class I areas: 

• Big Bend National Park 

• Guadalupe Mountains National Park 

Texas initiated their consultation process in July 2007, with three conference calls that took place 

on July 11, 18, and 31. Texas developed and distributed a series of technical papers before the 

calls, outlining their positions on the estimation of natural conditions, uniform rate of progress, 

IPM, and reasonable progress. Of particular interest to Kansas, Texas Commission on 

Environmental Quality (TCEQ) staff have recommended that course mass and fine soil 

contributions to haze be considered natural (i.e., non-anthropogenic), and therefore held constant 

when projecting to 2018. In addition, TCEQ staff intends to present two glide slopes for each 

Class I area in their Regional Haze SIP. The first would be a standard glide slope with a 2064 

target of natural visibility conditions at the Class I areas; the second glide slope would have a 

target of zero U.S. anthropogenic contribution by 2064. 

TCEQ chose a threshold of 3% total contribution to light extinction at their two Class I areas for 

determining which states would participate in consultation. Although Kansas contributed 

slightly more than 3% at Guadalupe Mountains (3.21%), over 50% of that impact can be 

attributed to soil and coarse mass, which are being discounted by Texas as non-anthropogenic 

sources. Texas informed Kansas that it will not expect Kansas to contribute emissions 

reductions for meeting their Class I areas’ reasonable progress goals for the first planning period 

beyond the BART reductions for Kansas included in the PSAT modeling. 

 11.1.3 Oklahoma 

The State of Oklahoma contains the Wichita Mountains Wilderness Area. Oklahoma initiated 

the process of consultation for Wichita Mountains in August 2007, with a series of conference 

calls. Oklahoma distributed their consultation plan, which included an overview of the 

consultation objectives, technical information used to identify contributing states, and outlined 

the roles and responsibilities of each of the participants in the consultation process. Kansas 

participated in calls held by Oklahoma on August 14, August 30, and September 13, 2007. 

Instead of using percent total extinction, Oklahoma selected a threshold of absolute extinction 

from all sources and particulate species greater than 1.0 Mm-1 to determine which states should 

participate in their consultation process. Kansas’ overall 2018 absolute extinction contribution to 

Oklahoma’s Wichita Mountains Wilderness Area is projected to be 3.53 Mm-1 (and percent 

extinction to be 4.90%), which Kansas recognizes as a potentially significant impact to visibility 

at that Class I area. 
87

In applying the criteria for meeting reasonable progress goals at Wichita Mountains, Oklahoma 

identified three Kansas facilities that they concluded had the potential to impact visibility in the 

Wichita Mountains. The Kansas sources identified are listed in the table below. 

Table 11.1 Kansas Sources Identified by Oklahoma as Potentially Impacting Visibility at 

Wichita Mountains 

Source ID Facility / Emission Units1 

0450014 Westar Energy - Lawrence Units 3, 4, and 5 

0550023 Sunflower Electric - Holcomb Unit 1 (and proposed Units 2 and 3) 

1490001 Westar Energy – Jeffrey Unit 3 (Units 1 and 2 are already subject to BART)

 1 Oklahoma named only facilities; unit information is supplied editorially

These three sources were identified for potential NOx impacts only, since one of the selection 

criteria used by Oklahoma was the “area of influence” (AOI) tool, a source contribution mapping 

tool developed by CENRAP contractor Alpine Geophysics prior to PSAT, and based largely on 

back trajectory analysis. The Wichita Mountains AOI for nitrates runs along or through 72 

counties, more or less through the center of Kansas. Only 4 counties in extreme southeast 

Kansas lie along or inside the AOI boundary for sulfates. Thus, nearly all the candidate Kansas 

sources considered by Oklahoma at the start of their analysis were large NOx emitters. All three 

of these sources have also been addressed in Kansas’ own analysis of reasonable progress, 

described in Chapter 10. 

As part of the first consultation call, Oklahoma requested any additional information Kansas 

could provide on potential visibility impacts, control applicability—both technical feasibility and 

costs for controls, future life of source, and any known or projected growth. Kansas provided 

this information on August 24, 2007. Information provided included CALPUFF modeling 

Kansas performed on the sources for prior regional haze purposes, along with CALPUFF and 

CAMx modeling that was performed as part of a visibility analysis for a proposed expansion at 

Sunflower Electric - Holcomb. A summary of that information follows. 

Sunflower Electric Power had planned to build two 700 MW EGUs alongside their current 349 

MW EGU (Unit 1), located in Holcomb, Kansas. Current plans now call for one 895 MW coalfired power plant to be constructed in Holcomb. Emissions from the existing boiler are 

controlled by low NOx burners, a spray dry absorber scrubber and a low ratio, reverse-air 

baghouse. The existing boiler is permitted to burn Powder River Basin (PRB) coal. Sunflower 

proposes to install Holcomb Unit 2, a supercritical 895 MW pulverized coal-fired boiler. The 

existing coal, lime, and ash handling equipment with the addition of equipment to double 

throughput capability will be utilized. The Holcomb Unit 2 boiler will fire PRB subbituminous 

coal and low-sulfur bituminous coal as primary fuel and natural gas as a backup fuel. 

Kansas performed CAMx PSAT modeling on this expansion as originally proposed (three 

700MW EGUs), relying on the 2002 Base F CENRAP emissions datasets, along with the 2002 

MM5 dataset to perform the CAMx modeling (see Appendix 11.1). Version 4.42 of CAMx was 

used with the PSAT/OSAT “point source override” feature. The worst-case normal operating 
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rate, excluding startups, shutdowns, malfunctions, and maintenance activities, was modeled. It 

was determined that the rates would be 0.09 lb/MMBtu for SO2 and 0.05 lb/MMBtu for NOx for 

each unit. Because these two pollutants dominate the visibility impacts, no other pollutants were 

modeled. CAMx requires emissions to be speciated and expressed in moles per hour; therefore, 

the emissions rates used in CAMx were NO - 5,769 moles/hr, NO2 - 641 moles/hr, and SO2 - 

12,427 moles/hr (note this represents all three initially proposed units operating - Sunflower is 

now only proposing one 895 MW unit). Results of the modeling indicated a maximum visibility 

impact at the Wichita Mountains Class I area of 0.47 delta deciview. 

In addition to the CAMx modeling review, Sunflower Electric was required to submit a FLAG 

visibility analysis to the State as part of the permit application. This analysis included both a 

CALPUFF Method 2 and Method 6 evaluation of the visibility impacts. The method 2 results 

indicated a maximum 30.6 % extinction in the Wichita Mountains. The method 6 results 

indicated a 98% impact of 0.331 delta deciview. The maximum Method 6 impact was 1.107 

delta deciview. The source concluded, and Kansas concurred, that the proposed Holcomb 

expansion is not expected to adversely affect the visibility at the Wichita Mountains. A full 

description of modeling and results can be found in Appendix 11.2. 

In summary, Kansas has not yet been asked by any other state to reduce emissions beyond those 

required under BART during the consultation processes. However, going into the consultation 

process, modeling provided by CENRAP indicated that Class I areas in both Texas and 

Oklahoma were being impacted by Kansas emissions. These states, and perhaps others impacted 

by the vacatur of the Clean Air Interstate Rule (CAIR), may be required to request additional 

emission reductions from Kansas in the future. Certainly, additional emission reductions from 

Kansas sources will be the subject of consultation discussions in the future. 

 

List of Chapter 11 Appendices

11.1 Sunflower Visibility Analysis Performed by KDHE 

11.2 Holcomb Class I Visibility Modeling Report 
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12. Plan Revisions and Progress Reports 

Kansas is required by 40 CFR 51.308(f) to revise its regional haze implementation plan and 

submit a plan revision to EPA by July 31, 2018, and every ten years thereafter. In accordance 

with the requirements listed in 40 CFR 51.308(f) of the federal rule for regional haze, Kansas 

commits to revising and submitting this regional haze implementation plan by July 31, 2018 and 

every ten years thereafter. 

In addition, 40 CFR 51.308(g) requires periodic reports evaluating progress towards the 

reasonable progress goals established for each mandatory Class I area. In accordance with the 

requirements listed in 40 CFR 51.308(g) of the federal rule for regional haze, Kansas commits to 

submitting a report on reasonable progress to EPA every five years following the initial submittal 

of the SIP. The report will be in the form of a SIP revision. The reasonable progress report will 

evaluate the progress made towards the reasonable progress goal for each mandatory Class I area 

located outside Kansas, which may be affected by emissions from within Kansas. All 

requirements listed in 40 CFR 51.308(g) shall be addressed in the SIP revision for reasonable 

progress. The first five-year progress report will be completed by October 26, 2014.
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13. Determination of the Adequacy of the Existing Plan 

Depending on the findings of the five-year progress report, Kansas commits to taking one of the 

actions listed in 40 CFR 51.308(h). The findings of the five-year progress report will determine 

which action is appropriate and necessary. 

List of Possible Actions – 40 CFR 51.308(h) 

1) Kansas would determine that the existing SIP required no further substantive revision in 

order to achieve established goals. Kansas would provide to the Administrator a 

declaration that further revision of the SIP will not be needed at that time. 

2) Kansas would determine that the existing SIP may be inadequate to ensure reasonable 

progress due to emissions from other states which participated in the regional planning 

process. Kansas would provide notification to the Administrator and the states that 

participated in regional planning. Kansas would collaborate with states through the 

regional planning process to address the SIP’s deficiencies. 

3) Kansas would determine that the existing SIP may be inadequate to ensure reasonable 

progress due to emissions from another country. Kansas would provide notification, 

along with available information, to the Administrator. 

4) Kansas would determine that the existing SIP is inadequate to ensure reasonable progress 

due to emissions within Kansas. Kansas would revise its SIP to address the plan’s 

deficiencies within one year. 
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14. Reference Information 

14.1 List of References 

1. Protecting Visibility in National Parks and Wilderness Areas. National Research 

 Council. Washington, DC: 1993. 

2. Guidance for Estimating Natural Visibility Conditions under the Regional Haze Rule. 

 U.S. Environmental Protection Agency. Research Triangle Park: 2003. 

3. Trijonis, J., et. al. Visibility: Existing and Historical Conditions- Causes and Effects. 

State of the Science/Technology Report 24, Volume III of the National Acid 

 Precipitation Assessment Program. Washington DC: 1990. 

4. Analysis of the Causes of Haze for the Central States Phase II. Sonoma Technology, Inc. 

 Petaluma: 2005. 

5. Anthes, R.A. and T.T. Warner. 1978. Development of Hydrodynamic Models Suitable 

 for Air Pollution and Other Mesometeorological Studies. Monthly Weather 

 Review, 106, 1045-1078. 

6. Guidance for Setting Reasonable Progress Goals under the Regional Haze Rule. US 

 Environmental Protection Agency. Research Triangle Park: 2007. 

7. Petroleum Marketing Monthly February 2007. Energy Information Administration. 

 Accessed online: 

http://www.eia.doe.gov/pub/oil_gas/petroleum/data_publications/petroleu

 m_marketing_monthly/historical/2007/2007_02/pdf/pmmall.pdf

8. Consumer Price Index: All Urban Consumers, US City Average. Bureau of Labor 

 and Statistics. Accessed online: http://www.bls.gov/cpi/

9. U.S. Census Bureau. 2007 Statistical Abstract. 

10. U.S. Census Bureau. County and City Data Book, 2000. 

14.2 List of Acronyms and Abbreviations 

A/F Air/fuel (adjustment) 

AERR Air Emissions Reporting Rule 

AIRS Aerometric Information Retrieval Systems 

AOI Area of influence 

AQS Air Quality System 

BART Best available retrofit technology 

Bcf Billion cubic feet 

BPU (Kansas City) Board of Public Utilities 

CAA Clean Air Act 

CAIR Clean Air Interstate Rule 

CAMx Comprehensive Air Quality Model with extensions 

CASTNet Clean Air Status and Trends Network 

CEMS Continuous emissions monitor 

CENRAP Central Regional Air Planning Association 
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CM Coarse mass 

CMAQ Community Multiscale Air Quality 

CO Carbon monoxide 

dv Deciview 

EC Elemental carbon 

EGAS Economic Growth Analysis System 

EGU Electric generating units 

EPA United States Environmental Protection Agency 

FCCU Fluid-bed catalytic cracking unit 

FGD Flue gas desulfurization 

FGR Flue gas recirculation 

FLM Federal land managers 

FOFEM First Order Fire Effects Model 

GCVTC Grand Canyon Visibility Transport Commission 

GVWR Gross vehicle weight rating 

IMPROVE Interagency Monitoring of Protected Visual Environments 

IPM Integrated Planning Model 

IR Ignition retard 

LNB Low NOx burner 

LNBO Low NOx burner with overfire air 

LNC1 Low NOx coal-and-air nozzles with cross-coupled overfire air 

LNC3 Low NOx coal/air nozzles with close-coupled and separated overfire air 

LTS Long term strategy 

MACT Maximum achievable control technology 

Mgal/yr Million gallons per year 

Mm-1 Inverse megameters 

MM5 Mesoscale Model (5th generation) 

MRPO Midwest Regional Planning Organization 

NEI National Emissions Inventory 

NESHAP National emission standards for hazardous air pollutants 

NGR Natural gas reburn 

NH3 Ammonia 

NO2 Nitrogen dioxide 

NO3 Nitrate 

NOx Nitrous oxides 

OBD On-board diagnostics 

OMC Organic matter carbon 

ORVR On-board refueling vapor recovery 

OT Oxygen trim 

PM2.5 Particulate matter (fine) 

PM10 Particulate matter (coarse) 

POA Primary organic aerosol 

POG Policy Oversight Group 
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ppb Parts per billion 

ppm parts per million 

PSAT PM Source Apportionment Technology 

PSD Prevention of significant deterioration 

QA/QC Quality assurance/quality control 

RACT Reasonably achievable control technology 

RADM Regional Acid Deposition Model 

REMSAD Regional Modeling System for Aerosols and Deposition 

RH Relative humidity 

RHR Regional Haze Rule 

RICE Reciprocating internal combustion engines 

RPO Regional planning organization 

RRF Relative response factor 

SCC Source classification code 

SCR Selective catalytic reduction 

SEARCH South Eastern Aerosol Research and Characterization 

SIC Standard industrial classification 

SIP State Implementation Plan 

SMOKE Sparse matrix operator kernel emissions 

SNCR Selective non-catalytic reduction 

SO2 Sulfur dioxide 

SO4 Sulfate 

SSM Startup, shutdowns and malfunctions 

STI Sonoma Technology, Inc. 

STN Speciated Trends Network 

TSD Technical Support Document 

ULSD Ultra-low sulfur diesel 

URP Uniform rate of progress 

VIEWS Visibility Information Exchange Web System 

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VMT Vehicle miles traveled 

VOC Volatile organic compound 

WI Water injection 

WRAP Western Regional Air Partnership 
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Appendices 

The appendices for the Regional Haze SIP are located on the enclosed compact disc.