Technical Support: Regional Haze SIP Page G-1

October 2009 

# Technical Support: Regional Haze SIP

(Response to Elements of 40 C.F.R. Part 51, Appendi x V, Section 2.2)



### Incorporation of 40 C.F.R. 51.308 - Regional Haze P rogram Requirements

1. Identification of all regulated pollutants affec ted by the plan. [40 C.F.R. § 51, Appendix V, Section 2.2(a)]

The plan revision will incorporate the Regional Haz e Rule requirements located at 40 C.F.R. 51.308 into the Kansas State Implementation Plan (SIP).

2. Identification of the location of affected sourc es including the EPA attainment/nonattainment designation of the locatio ns and the status of the attainment plan for the affected areas. [2.2(b)]

The plan revision relates to the entire state. Kan sas is classified as attainment for all national ambient air quality standards (NAAQS), wit h the two counties of the Kansas City area, Johnson and Wyandotte, being in attainme nt status for the 8-hour ozone standard. Although the 1-hour standard for ozone h as been revoked for the Kansas City area, these two counties remain in maintenance stat us for the 1-hour ozone standard.

3. Quantification of the changes in plan allowable emissions from the affected sources; estimates of changes in current actual emissions fr om affected sources or, where appropriate, quantification of changes in actual em issions from affected sources through calculations of the differences between cer tain baseline levels and allowable emissions anticipated as a result of the revision. [2.2(c)]

Best Available Retrofit Technology (BART) is requir ed by the Regional Haze Rule to address visibility impairment of mandatory Class I Federal areas. The following table lists the Kansas sources subject to BART under the Regional Haze Rule, and quantifies the presumptive and operational BART standards for those sources.

Subject-to-BART Emission Unit BART Presumptive Limit BART Operational Standard

NO

x SO 2 NO

x SO 2

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 averageTechnical Support: Regional Haze SIP Page G-2

October 2009 As a result of the BART operational standards, the estimated annual emissions reductions
are summarized below.

Projected BART Emissions Reductions (tons/yr) Subject-to-BART Emission Unit

NO

x SO 2 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

Please note that Gordon Evans Unit 2 has no presum ptive limit, as it is a natural gas/oilburning unit that meets the presumptive plant and u nit size threshold. KDHE indicated to Westar in early discussions that presumptive NO

x controls consisting of “current combustion control technology” would be expected un der the Regional Haze Rule. Westar’s original analysis and amendment went throu gh the standard BART selection process which resulted in identifying a low NO

x burner system. However, since the concurrent analysis for SO 2 reduction led to a state-approved alternative mean s of control through fuel switching to natural gas, and since fu el switching results in visibility improvements in all five Class I areas modeled by W estar Energy, Kansas endorses this
alternative BART control for NO

x .

In addition to the units listed above, additional emissions decreases will be realized as a result of reasonable progress goals as stipulated a t 40 C.F.R. 51.308(d). The results are
summarized in the table below.
Emission limit or work practice Facility/Unit NO

x SO 2
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/MMBt u Westar – Lawrence Unit 5 0.15 lb/MMBtu 0.15 lb/MMBt u 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/MMBtuTechnical Support: Regional Haze SIP Page G-3

October 2009 4. The State’s demonstration that the national ambi ent air quality standards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are p rotected if the plan is approved and implemented. [2.2(d)]

The following table shows the anticipated net visib ility improvement (from 2002 to 2018)
at 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

Please refer to Chapter 10 of the SIP for a detaile d discussion of reasonable progress goals and long term strategy.

5. Modeling information required to support the pro posed revision, including input data, output data, models used, justification of mo del selections, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis. [2.2(e)]

Please refer to Chapter 8 of the SIP for modeling information.

6. Evidence, where necessary, that emission limitat ions are based on continuous emission reduction technology. [2.2(f)]

The Agreements in Appendix 9.7 of the SIP specify e missions limits that are based on rolling 30-day averages.

7. Evidence that the plan contains emissions limita tions, work practice standards and recordkeeping/reporting requirements, where necessa ry, to ensure emission levels. [2.2(g)]

The Agreements found in Appendix 9.7 of the SIP inc lude a requirement that each sourceTechnical Support: Regional Haze SIP Page G-4

October 2009 maintain control equipment and establish procedures to ensure such equipment is properly operated and maintained. The emissions lim its in the Agreements and compliance verification requirements will be incorp orated 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.

8. Compliance/enforcement strategies, including how compliance will be determined in practice. [2.2(h)]

Compliance will be demonstrated by use of continuou s emissions monitoring systems as outlined in the amendments to the Agreements, found in Appendix 9.7 of the SIP.

9. Special economic and technological justification s required by any applicable EPA policies, or an explanation of why such justificati ons are not necessary. [2.2(i)]

Not applicable.