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Technical Support: Regional Haze SIP 

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

Incorporation of 40 C.F.R. 51.308 - Regional Haze Program Requirements

1. Identification of all regulated pollutants affected by the plan. [40 C.F.R. § 51, 

Appendix V, Section 2.2(a)]

The plan revision will incorporate the Regional Haze Rule requirements located at 40 

C.F.R. 51.308 into the Kansas State Implementation Plan (SIP). 

2. Identification of the location of affected sources including the EPA 

attainment/nonattainment designation of the locations and the status of the 

attainment plan for the affected areas. [2.2(b)]

The plan revision relates to the entire state. Kansas is classified as attainment for all 

national ambient air quality standards (NAAQS), with the two counties of the Kansas 

City area, Johnson and Wyandotte, being in attainment status for the 8-hour ozone 

standard. Although the 1-hour standard for ozone has been revoked for the Kansas City 

area, these two counties remain in maintenance status 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 from affected sources or, where 

appropriate, quantification of changes in actual emissions from affected sources 

through calculations of the differences between certain baseline levels and allowable 

emissions anticipated as a result of the revision. [2.2(c)]

 

Best Available Retrofit Technology (BART) is required 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 

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 
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As a result of the BART operational standards, the estimated annual emissions reductions 

are summarized below. 

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

 

 Please note that Gordon Evans Unit 2 has no presumptive limit, as it is a natural gas/oilburning unit that meets the presumptive plant and unit size threshold. 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, Kansas endorses this 

alternative BART control for NOx. 

 In addition to the units listed above, additional emissions decreases will be realized as a 

result of reasonable progress goals as stipulated at 40 C.F.R. 51.308(d). The results are 

summarized in the table below. 

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 
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4. The State’s demonstration that the national ambient air quality standards, 

prevention of significant deterioration increments, reasonable further progress 

demonstration, and visibility, as applicable, are protected if the plan is approved 

and implemented. [2.2(d)]

The following table shows the anticipated net visibility 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 detailed discussion of reasonable progress 

goals and long term strategy. 

5. Modeling information required to support the proposed revision, including input 

data, output data, models used, justification of model 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 limitations are based on continuous 

emission reduction technology. [2.2(f)]

The Agreements in Appendix 9.7 of the SIP specify emissions limits that are based on 

rolling 30-day averages. 

7. Evidence that the plan contains emissions limitations, work practice standards and 

recordkeeping/reporting requirements, where necessary, to ensure emission levels. 

[2.2(g)]

The Agreements found in Appendix 9.7 of the SIP include a requirement that each source 
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maintain 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. 

8. Compliance/enforcement strategies, including how compliance will be determined in 

practice. [2.2(h)]

Compliance will be demonstrated by use of continuous emissions monitoring systems as 

outlined in the amendments to the Agreements, found in Appendix 9.7 of the SIP. 

9. Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary. [2.2(i)]

 Not applicable.