## Kentucky Energy and Environment Cabinet Kentucky Division for Air Quality



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Appendix L.12 BART Determination Modeling Results for BART-Subject Sources

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### Table 9-1 Kentucky BART Determination Mo deling Results for BART-Subject Sources*

Source Class I Areas BART Controls to Be Installed* 98 th

Percentile

Impact Before BART Controls (Change in dv) 98 th

Percentile Impact with BART Controls (Change in dv) BART Determination Control Visibility Improvement

From 98 th

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

### Table 9-1 Kentucky BART Determination Mo deling Results for BART-Subject Sources*

Source Class I Areas BART Controls to Be Installed* 98 th

Percentile

Impact Before BART Controls (Change in dv) 98 th

Percentile Impact with BART Controls (Change in dv) BART Determination Control Visibility Improvement

From 98 th

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 li me 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 TV A 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.

### 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

### 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 i ndicated 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 th at 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.