Kentucky Energy and Environment Cabinet 

Kentucky Division for Air Quality 

------------------------------------------- 

Appendix L.12 

BART Determination Modeling 

Results for BART-Subject 

Sources 

 Appendix L.12 - 1

Kentucky Regional Haze SIP
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Appendix L.12 - 2

Kentucky Regional Haze SIP
Table 9-1 Kentucky BART Determination Modeling Results for BART-Subject Sources* 

Source Class I Areas BART Controls to 

Be Installed* 98th 

Percentile 

Impact 

Before 

BART 

Controls 

(Change in 

dv) 

98th

Percentile 

Impact with 

BART 

Controls 

(Change in 

dv) 

BART 

Determination 

Control 

Visibility 

Improvement 

From 98th

Percentile 

value 

(Change in dv)

East Kentucky 

Power Cooperative 

(EKPC) Spurlock 

Station 

Mammoth Cave (251 km) 

EKPC per a consent 

decree and for BART 

will install a wet FGD 

and wet ESP at EKPC 

Spurlock Units 1 and 

2 that will address 

condensible 

particulate emissions 

and other visibility 

impairing pollutants.

1.834 0.213 1.621 

East Kentucky 

Power Cooperative 

(EKPC) Cooper 

Station 

Mammoth Cave (130) km 7.376 0.252 7.124 

Great Smoky Mountains National Park 

(162 km) 6.763 0.219 6.544 

Joyce Kilmer-Slickrock Wilderness 

(178 km) 4.974 0.122 4.852 

Cohutta Wilderness Area (221 km) 3.363 0.087 3.276 

Shinning Rock (233 km) 2.022 0.049 1.973 

Linville Gorge Wilderness Area 

 (267 km) 

EKPC per a consent 

decree and for BART 

will install a wet FGD 

and wet ESP at EKPC 

Cooper Units 1 and 2 

that will address 

condensible 

particulate emissions 

and other visibility 

impairing pollutants.

1.885 0.046 1.839 

TVA Paradise 

Fossil Steam 

Plant** 

Mammoth Cave (63 km) 

U1- 1.285 

U2- 1.285 

U3- 1.842

 4.412 

3.930 

0.606 

0.606 

0.836

2.048 

2.048 

0.679 

0.679 

1.006

2.364 

1.882 

Mingo (283 km) 

**Although not for 

BART, TVA 

previously indicated 

to KYDAQ its 

plans to install 

hydrated lime 

injection controls 

on TVA Paradise 

Units 1-3 to 

mitigate opacity due 

to SO3 emissions.

U1- 0.251 

U2- 0.251 

U3- 0.381

 0.883 

0.865 

0.116 

0.116 

0.166

0.398 

0.398 

0.135 

0.135 

0.215

0.485 

0.467 

Appendix L.12 - 3

Kentucky Regional Haze SIP
Table 9-1 Kentucky BART Determination Modeling Results for BART-Subject Sources* 

Source Class I Areas BART Controls to 

Be Installed* 98th 

Percentile 

Impact 

Before 

BART 

Controls 

(Change in 

dv) 

98th

Percentile 

Impact with 

BART 

Controls 

(Change in 

dv) 

BART 

Determination 

Control 

Visibility 

Improvement 

From 98th

Percentile 

value 

(Change in dv)

American Electric 

Power Big Sandy 

Plant (AEP) 

Dolly Sods (291 km) 1.027 0.496 0.531 

James River Face (279 km) 1.052 0.457 0.595 

Linville Gorge (256 km) 0.835 

 

0.364 0.471 

Otter Creek (266 km) 

Per a consent decree 

and BART, AEP will 

install ammonia 

injection on Unit 1 

and a FGD scrubber 

on Unit 2 to address 

condensible 

particulate emissions 

and other visibility 

impairing pollutants.

1.285 0.558 0.697 

E.ON U.S Mill*** 

Creek Station Mammoth Cave (90 km) 

***E.ON U.S. for 

BART will install 

sorbent injection 

controls on the larger 

Units 3-4 to mitigate 

condensable 

particulate emissions.

2.265 1.440 0.825 

*Existing and expected EGU controls and EPA web links to EKPC and AEP consent decrees are available in Appendix 

L.8. **Since TVA had previously indicated to the KYDAQ its plans to install hydrated lime injection controls on TVA 

Paradise Units 1-3 to mitigate opacity due to SO3 emissions and that additional controls are not cost-effective at this 

time, the KYDAQ has determined BART to be no control for TVA Paradise Units 1-3. ***Given the extra cost for the 

lesser additional dv improvement for Units 1 and 2, the Cabinet agreed that BART for Mill Creek is the installation of 

sorbent injection controls on the larger Units 3 and 4. 

Appendix L.12 - 4

Kentucky Regional Haze SIP
Table 9-2 Kentucky BART Controls, Emission Limits, and Compliance Timeframes for BARTSubject Sources 

Kentucky BART 

Subject Source 

BART Controls To 

Be Installed 

BART Emission 

Limits 

Inclusion in 

Title V 

Permit 

Timeframe for 

Compliance with 

BART Emission 

Limits\Controls 

East Kentucky 

Power Cooperative 

(EKPC) 

Spurlock Units 1 

and 2 and Cooper 

Units 1 and 2 

Install wet FGD and 

wet ESP on Spurlock 

Units 1 and 2 and 

Cooper Units 1 and 2.

A 07/02/07 EKPC 

consent decree 

provides a filterable 

PM emission rate of 

0.030 lb/MMBTU, 

which was utilized to 

demonstrate modeled 

visibility 

improvement. 

Emission 

limits and 

controls will 

be included in 

the source’s 

Title V Permit 

as appropriate 

or on renewal. 

Expeditiously as 

practicable, but 

no later than 5 

years after EPA 

approves 

Kentucky’s 

Regional Haze 

SIP. 

AEP Big Sandy 

Unit 1 

Unit 2 

Install ammonia 

injection controls on 

Unit 1 and a FGD on 

Unit 2. 

Inorganic 

Condensible 

Particulate Limits 

(modeled as sulfates): 

101.0 lb/hr (H2SO4) 

127.0 lb/hr (H2SO4) 

Emission 

limits and 

controls will 

be included in 

the source’s 

Title V Permit 

as appropriate 

or on renewal. 

Expeditiously as 

practicable, but 

no later than 5 

years after EPA 

approves 

Kentucky’s 

Regional Haze 

SIP. 

KYDAQ will 

work with AEP to 

install the FGD 

scrubber on AEP 

Big Sandy Unit 2 

as expeditiously 

as practicable. 

TVA Paradise* 

Unit 1 

Unit 2 

Unit 3 

*Although not for 

BART, TVA 

previously indicated 

to KYDAQ its plans 

to install hydrated 

lime injection 

controls on TVA 

Paradise Units 1-3 to 

mitigate opacity due 

to SO3 emissions. 

*NA *Although not 

for BART, 

TVA has 

indicated that 

its planned 

SO3 controls 

for Paradise 

Units 1-3 will 

be included in 

its Title V 

Permit as 

appropriate or 

on renewal. 

*Although not for 

BART, TVA in 

its BART 

Determination 

has indicated the 

SO3 controls will 

be in place on 

Paradise Units 1-

3 well before 

BART controls 

are required. 

Specifically, TVA 

has related to 

Appendix L.12 - 5

Kentucky Regional Haze SIP
Table 9-2 Kentucky BART Controls, Emission Limits, and Compliance Timeframes for BARTSubject Sources 

Kentucky BART 

Subject Source 

BART Controls To 

Be Installed 

BART Emission 

Limits 

Inclusion in 

Title V 

Permit 

Timeframe for 

Compliance with 

BART Emission 

Limits\Controls 

KYDAQ its 

proposed plan to 

have hydrated 

lime injection 

controls operating 

on all three TVA 

Paradise units 

possibly by the 

fall of 2010. 

E.ON U.S.** 

Mill Creek 

Unit 3 

Unit 4 

**Install sorbent 

injection controls on 

larger Units 3 and 4 

to control SO3 

emissions and 

continue to utilize 

existing ESPs to 

control PM emissions 

for Units 1 through 4. 

SO3 Limit: 

0.015 lb/MMBTU 

0.015 lb/MMBTU 

**Emission 

limits and 

controls will 

be included in 

the source’s 

Title V Permit 

as appropriate 

or on renewal. 

**Expeditiously 

as practicable, but 

no later than 5 

years after EPA 

approves 

Kentucky’s 

Regional Haze 

SIP. 

*Since TVA had previously indicated to the KYDAQ its plans to install hydrated lime injection controls on TVA 

Paradise Units 1-3 to mitigate opacity due to SO3 emissions and that additional controls are not cost-effective at this 

time, the KYDAQ has determined BART to be no control for TVA Paradise Units 1-3. **Given the extra cost for the 

lesser additional dv improvement for Units 1 and 2, the Cabinet agreed that BART for Mill Creek is the installation of 

sorbent injection controls on the larger Units 3 and 4. 

Appendix L.12 - 6

Kentucky Regional Haze SIP