Kentucky Energy and Environment Cabinet 

Kentucky Division for Air Quality 

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

Appendix L 

Best Available Retrofit 

Technology (BART) 

Related Documentation 

 Appendix L 

Kentucky Regional Haze SIP 
APPENDIX L 

TABLE OF CONTENTS 

PURPOSE....................................................................................................................................... 4

1. Background................................................................................................................................ 4

2. Approach to Implementation of BART Requirements.............................................................. 5

3. Identification of BART-eligible Sources................................................................................... 5

4. Contribution Threshold.............................................................................................................. 7

5. Exemption of Point Source Volatile Organic Compounds for BART Purposes....................... 9

5.1 Method................................................................................................................................. 9 

5.2 Conclusions........................................................................................................................ 11 

6. Treatment of Ammonia Emissions for BART Purposes.......................................................... 11

6.1 Method............................................................................................................................... 12 

6.2 Conclusions........................................................................................................................ 13 

7. Explanation of BART Exemption Modeling ........................................................................... 14

7.1 Background......................................................................................................................... 14 

7.2 Kentucky BART Sources Exemption Modeling ............................................................... 15 

7.3 BART Sources in Other States Within 300 km of Kentucky’s Class I Area...................... 19 

7.4 Use of New IMPROVE Equation....................................................................................... 20 

7.5 Conclusion .......................................................................................................................... 21

8. Other Sources Exempted From BART Based on Methodology in BART Guidelines ............ 21

9. BART Determinations............................................................................................................. 21

9.1 BART Subject Sources....................................................................................................... 22 

9.2 Final BART Determinations.............................................................................................. 26 

9.3 BART-Subject Sources in Other States Within 300 km of Kentucky’s Class I Area ........ 26 

9.4 Conclusions......................................................................................................................... 27

10. Kentucky BART Modeling Summary and BART Modeling Files ................................... 27

REFERENCES: ............................................................................................................................ 28

 Appendix L 

Kentucky Regional Haze SIP 

2
Appendix L.1 – July 6, 2005, Federal Register, BART Final Rule 

Appendix L.2 – BART Letters and Correspondence 

Appendix L.3 - Kentucky BART-Eligible Sources 

Appendix L.4 - BART Analysis Sensitivity Modeling 

Appendix L.5 - BART Modeling Protocols 

Appendix L.6 - BART Exemption Modeling Demonstrations 

Appendix L.7 – BART Exemption Modeling Results for Sources Exempted From BART 

Appendix L.8 – Kentucky Electric Generating Units (EGUs) Existing and Expected Emission 

Controls 

Appendix L.9 – New IMPROVE Equation 

Appendix L.10 – Other Sources Exempted From BART Based on BART Guidelines and EPA 

Guidance 

Appendix L.11 - BART Determination Modeling Submittals 

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

Appendix L.13 – Summary of Kentucky BART Exemption and BART Determination Modeling 

 Appendix L 

Kentucky Regional Haze SIP 

3
PURPOSE 

The purpose of this appendix is to outline the Kentucky strategy for complying with the 

requirements for establishing best available retrofit (BART) controls under 40 CFR 51.308(e) as 

part of our Regional Haze SIP. The BART requirements in 40 CFR 51.308(e) comprise a 

specific component of each state’s first long term strategy (LTS). An overview of the first LTS 

covering from the present until 2018 is provided in Appendix H. This appendix includes a 

discussion of our strategy for developing the specific BART requirements. The discussion covers 

identification of BART-eligible sources, exemption modeling for BART eligible sources, and 

BART determinations for sources found to be subject to BART. 

1. Background

As required by the CAA, EPA included in the final regional haze rule a requirement for Best 

Available Retrofit Technology (BART) for certain large stationary sources that were placed in 

operation between 1962 and 1977. The BART-eligible sources are those sources which have the 

potential to emit 250 tons or more of a visibility-impairing air pollutant, were placed in operation 

between August 7, 1962 and August 7, 1977, and whose operations fall within one or more of 26 

specifically listed source categories. Under the CAA, BART is required for any BART-eligible 

source that a State determines “emits any air pollutant which may reasonably be anticipated to 

cause or contribute to any impairment of visibility in any such area.” Accordingly, for stationary 

sources meeting these criteria, States must address the BART requirement when they develop 

regional haze SIPs.1 EPA has set guidance for identifying BART-eligible sources in 40 CFR Part 

51 Appendix Y. 

A BART-eligible source that is responsible for a 1.0 deciview (dv) change or more is considered 

to “cause” visibility impairment. Although the appropriate threshold may vary, the guidelines 

state that the contribution threshold used for BART applicability should not be higher than 0.5 

deciviews.1

 Thus a BART-eligible source that is responsible for a 0.5 dv change or more is 

considered to “contribute” to visibility impairment. Any source determined to cause or contribute 

to visibility impairment in any Class I area is subject to BART. 

The guidelines direct that States should include SO2, NOx, and direct particulate matter (PM) 

emissions, including both PM10 and PM2.5, in determining whether sources cause or contribute 

to visibility impairment. States may use their best judgment to determine whether VOC or 

ammonia emissions are likely to have an impact on visibility in an area.1 

To determine which BART-eligible sources are subject to BART, states have several options. A 

state may consider all BART-eligible sources subject to BART; may perform analysis showing 

that the full group of BART-eligible sources in a State cumulatively may not be reasonably 

anticipated to cause or contribute to any visibility impairment in any Class I areas; or may 

consider the individualized contribution of a BART-eligible source to determine whether a 

specific BART-eligible source is subject to BART. 

Sources that are subject to BART must undergo a BART determination. Section 169A(g)(7) of 

the CAA requires that States must consider the following factors in making BART 

 Appendix L 

Kentucky Regional Haze SIP 

4
determinations: (1) The costs of compliance, (2) The energy and non-air quality environmental 

impacts of compliance, (3) Any existing pollution control technology in use at the source, (4) 

The remaining useful life of the source, and (5) The degree of improvement in visibility which 

may reasonably be anticipated to result from the use of such technology.1 

To demonstrate the degree of improvement in visibility from various BART control options, the 

States may run CALPUFF or another appropriate dispersion model to predict visibility impacts. 

Scenarios would be run for the pre-controlled and post-controlled emission rates for each of the 

BART control options under review. The maximum 24-hour emission rates would be modeled 

for a period of three or five years of meteorological data. States have the flexibility to develop 

their own methods to evaluate model results.1 

2. Approach to Implementation of BART Requirements 

In order to meet the SIP submittal deadline, Kentucky has used the following approach for the 

implementation of the federal regional haze rule BART requirements. The approach consists of 

source identification efforts; requests to sources for information; providing EPA guidance and 

information to the BART-eligible sources; participation in the VISTAS BART subgroup to 

resolve technical issues spanning states in the VISTAS region; and ongoing consultation with 

affected sources; and EPA and FLMs throughout the BART process. 

As required by the Clean Air Act (CAA), Kentucky implemented BART for sources identified 

pursuant to the BART guidelines per 40 CFR Part 51 Appendix Y. It applies to sources that 

have the potential to emit 250 tons or more of a visibility impairing pollutant, were in existence 

on August 7, 1977 and began operation after August 7, 1962, and fall within one of the 26 

industrial source categories listed in 40 CFR Part 51 Appendix Y guidelines. The federal rule 

allows affected sources to demonstrate that the source does not contribute to visibility 

impairment and should be exempted. Non-exempt sources are required to undergo a 

determination of best available retrofit technology. A copy of the July 6, 2005, Federal Register, 

that provided the BART final rule is available as Appendix L.1. 

3. Identification of BART-eligible Sources 

EPA provided guidance for identifying BART-eligible sources in 40 CFR Part 51 Appendix Y. 

Kentucky followed this guidance in identifying its BART-eligible sources. The Kentucky 2002 

air emissions inventory was reviewed to determine the population of potential BART-eligible 

sources. The data were initially queried for any sources emitting SO2, NOx, PM-10, VOC, or 

ammonia. The data set was refined based on emissions, whether emission units fit in any of the 

twenty-six listed source categories for BART, and available date information obtained through 

review of permit and inspection reports and discussion with permits section and regional office 

staff familiar with the facilities. 

Letters to the potential BART-eligible sources were sent to sources requesting information to 

verify whether the source was BART-eligible based on the federal BART guidelines, which 

included the source’s potential emissions, source category and date criteria. Letters and 

correspondence to sources are available as Appendix L.2. 

 Appendix L 

Kentucky Regional Haze SIP 

5
Through this iterative review process, the list of potential BART-eligible sources was pared 

down to twenty-six BART-eligible sources listed below. The facilities are scattered throughout 

the state with closest facility proximity to Class I areas ranging from an estimated 63 km to 290 

km. The facilities include two primary aluminum facilities, one paper manufacturer, fourteen 

electric utilities, one steel manufacturer, one primary metal (coke) manufacturer, two coal 

preparation plants, one oil refinery, and three chemical manufacturers. The following Table 3-1 

provides the list of BART-eligible sources in Kentucky. This list is also available in Appendix 

L.3. 

Table 3-1 Kentucky BART-Eligible Sources 

Sources Source ID County 

American Electric Power Big Sandy Plant 2112700003 Lawrence 

AK Steel Corp. - Coke Mfg Plant 2101900027 Boyd 

AK Steel Corporation - Steel Plant 2101900005 Boyd 

Alcan Primary Products Corporation 2110100029 Henderson 

Arch Chemicals Inc. 2116300001 Meade 

Calgon Carbon Corporation 2101900014 Boyd 

Century Aluminum 2109100004 Hancock 

Commonwealth Aluminum Lewisport LLC 2109100010 Hancock 

Duke Energy East Bend Station 2101500029 Boone 

E.ON KU/LGE Brown Station 2116700001 Mercer 

E.ON KU/LGE Cane Run Station 2111100126 Jefferson 

E.ON KU/LGE Ghent Station 2104100010 Carroll 

E.ON KU/LGE Mill Creek Station 2111100127 Jefferson 

East Kentucky Power Cooperative Cooper Station 2119900005 Pulaski 

East Kentucky Power Cooperative Spurlock Station 2116100009 Mason 

Henderson Power and Light 2110100012 Henderson 

Marathon Petroleum Company Refinery 2101900004 Boyd 

Martin County Coal Corporation 2115900002 Martin 

NewPage Corporation Wickliffe Paper Company 2100700002 Ballard 

Owensboro Municipal Utilities 2105900027 Daviess 

Pinnacle Processing Inc. 2115900004 Martin 

TVA Paradise Plant 2117700006 Muhlenberg 

Western Kentucky Energy Coleman Station 2109100003 Hancock 

Western Kentucky Energy Green Station 2123300052 Webster 

Western Kentucky Energy Reid/Henderson Station 2123300001 Webster 

Westlake Vinyls Inc. 2115700039 Marshall 

A table of Kentucky’s BART-eligible sources and VISTAS 2002 SO2 emissions and distance to 

Class I areas is available in Appendix L.3. 

Kentucky opted to consider its BART-eligible sources subject to BART unless the sources 

demonstrated exemption via modeling. Kentucky BART-eligible sources were provided the 

 Appendix L 

Kentucky Regional Haze SIP 

6
opportunity to submit modeling demonstrations showing that they did not contribute to visibility 

impairment, i.e., had less than 0.5 deciviews (dv) impact, on any Class I area within 300 km and 

thus could be exempt. 

4. Contribution Threshold 

Determining whether a source causes or contributes to visibility impairment is one step in the 

BART review process. The Guidelines for BART Determinations Under the Regional Haze Rule

(40 CFR 51, Appendix Y, Section III.A.1) state that “A single source that is responsible for a 1.0 

deciview change or more should be considered to ‘cause’ visibility impairment.” The guideline 

document also states that “the appropriate threshold for determining whether a source 

‘contributes to visibility impairment’ may reasonably differ across states,” but, “As a general 

matter, any threshold that you use for determining whether a source ‘contributes’ to visibility 

impairment should not be higher than 0.5 deciviews.” The rationale for these instructions is 

provided in the preamble to the BART guidance, in the statement, “If ‘causing’ visibility 

impairment means causing a humanly perceptible change in visibility in virtually all situations 

(i.e. a 1.0 deciview change), then ‘contributing’ to visibility impairment must mean having some 

lesser impact on the conditions affecting visibility that need not rise to the level of human 

perception.” (70 FR 39120, footnote 31). The guidance document itself also states that, “States 

remain free to use a threshold lower than 0.5 deciviews if they conclude that the location of a 

large number of BART-eligible sources within the State and in proximity to a Class I area justify 

this approach.” 

The EPA’s documents strive to set these thresholds in the context of the human perception of 

visibility change. As noted above, the EPA considers a 1.0-deciview change in visibility to be 

humanly perceptible “in virtually all situations.” Also, the preamble to the BART guidance 

(70 FR 39119, Footnote 28) cites an analysis in an appendix of a NAPAP (National Acid 

Precipitation Assessment Program) report, which asserts that “changes in light extinction of 5 

percent will evoke just noticeable changes in most landscapes.”2

 (A 5% change is approximately 

0.5 dv.) But, as noted above, the preamble also states that perceptibility is not a prerequisite for 

choosing a contribution threshold. Putting all this together, it appears that “causing” visibility 

impairment means having a humanly perceptible impact (for which EPA considers the practical 

threshold to be 1.0 dv) while “contributing” to visibility impairment means having a smaller 

impact (for which EPA considers the threshold to be 0.5 dv or some smaller value) that may or 

may not be perceptible. 

The EPA argues that a contribution threshold of less than 0.5 dv impact per source is appropriate 

when multiple sources contribute, in order to limit the combined effect of these sources. As an 

example, EPA asserts that if there were 100 sources, each affecting visibility by 0.1 dv 

(presumably an imperceptible amount), their total impact would be 10 dv, which can be expected 

to be quite perceptible (70 FR 39121. 1st column). The point remains that multiple sources can 

cause a larger impact than a single one. For BART purposes, visibility impacts are calculated as 

24-hr averages of 1-hr plume impacts, so if the plumes from the various sources each impact the 

point of interest at some time during a 24-hr period (not necessarily all at the same hour) then the 

24-hr average will reflect their combined impact. 

 Appendix L 

Kentucky Regional Haze SIP 

7
KYDAQ concluded that the EPA suggested contribution threshold of 0.5 dv was appropriate in 

this situation since there are a limited number of in and out of state sources that impact the 

various Class I areas in the state. In addition there are a limited number of sources in close 

proximity to each of the Class I areas. Considering results of the visibility impacts modeling 

conducted (see Section 7), a 0.5 dv threshold was appropriate and a lower threshold was not 

warranted since the majority of the visibility impacts were well below 0.5 deciviews. Also even 

though several sources impacted each Class I area, the overall impacts were low from the 

sources. 

 Appendix L 

Kentucky Regional Haze SIP 

8
Figure 4-1. Location of VISTAS BART-Eligible Sources 

5. Exemption of Point Source Volatile Organic Compounds for BART 

Purposes 

Kentucky has determined through modeling that Volatile Organic Compounds (VOC) from point 

sources are not anticipated to cause or contribute significantly to any impairment of visibility in 

Class I areas and should be exempt for BART purposes. 

5.1 Method 

Kentucky has determined through modeling that VOCs from point sources are not anticipated to 

cause or contribute significantly to any impairment of visibility in Class I areas. 

Modeling was conducted through The Visibility Improvement State and Tribal Association of 

the Southeast (VISTAS). VISTAS is a collaborative effort of state governments, tribal 

governments, and various federal agencies established to initiate and coordinate activities 

associated with the management of regional haze, visibility and other air quality issues in the 

Southeastern United States. VISTAS contracted with Georgia Institute of Technology to 

perform model sensitivity runs to determine the impact of point source VOCs on visibility in 

Class I areas. 

 Appendix L 

Kentucky Regional Haze SIP 

9
Georgia Tech performed emission sensitivities to examine the impact of emission reductions on 

regional haze, annual PM2.5, and 8-hour ozone concentrations using CMAQv4.4_SOAmods on 

the VISTAS 12 km modeling domain, using the 2009 OTW (on the way) BaseD emissions. One 

such sensitivity run reduced anthropogenic, point source VOCs by 100%. The purpose was to 

quantify the impact of VOC emissions from VISTAS BART sources on Class I areas. The 

percent of BART-eligible to total point source emissions in Kentucky is 8%.3 Two episodes 

were examined: June 1-July 10, 2002 and November 19 – December 19, 2002. The approach 

included calculating the extinction coefficient in dv (deciviews), then determining the maximum 

impact of point source VOCs. The chart below, taken from the VISTAS report BART in the 

VISTAS Region: Sensitivity to VOC, NH3, and Primary PM Emissions, included as Appendix 

L.4, shows the impact on the following twenty-two Class I areas within the VISTAS domain. 3 

BRET = Breton, LA 

BRIG = Brigantine NWR, NJ 

CACR = Caney Creek, AR 

CHAS = Chassahowitzka, FL 

COHU = Cohutta, GA 

DOSO = Dolly Sods, WV 

EVER = Everglades, FL 

GRSM = Great Smoky Mountains National Park 

HEGL = Hercules Glade, MO 

JARI = James River Face, VA 

LIGO = Linville Gorge, NC 

MACA = Mammoth Cave, KY 

MING = Mingo, MO 

OKEF = Okefenokee, GA 

ROMA = Cape Romain, SC 

SAMA = Saint Marks, FL 

SHEN = Shenandoah, VA 

SHRO = Shining Rock, NC 

SIPS = Sipsey Wilderness, AL 

SWAN = Swanquarter, NC 

UPBU = Upper Buffalo Wilderness, AR 

WOLF = Wolf Island, GA 

 Appendix L 

Kentucky Regional Haze SIP 

10
Maximum Point VOC Impact

Maximum VOC Impact

0.0

0.1

0.2

0.3

0.4

0.5

0.6

BRET

BRIG

CACRCHAS

COHU

DOSO

EVER

GRSM

HEGL

JARI

LIGO

MACA

MING

OKEF

ROMA

SAMA

SHEN

SHRO

SIPS

SWAN

UPBU

WOLF

ΔdV

Figure 5-1. Maximum Point VOC Impact 

5.2 Conclusions 

The results show that the maximum impact from eliminating all point source VOC emissions in 

the VISTAS 12 km domain is less than a 0.5 dv for all Class I areas in the VISTAS domain. 

Given that the fraction of the total point source VOC emissions that are also BART-eligible in 

the state of Kentucky is just 8%3, the expected impact of controlling VOCs from a BART source 

would be much less than the 0.5 dv threshold. VISTAS and Kentucky conclude that VOCs from 

point sources are not a visibility impairing pollutant for BART purposes and that BART-eligible 

sources do not need to consider VOC emissions. 

6. Treatment of Ammonia Emissions for BART Purposes 

Similar to its treatment of VOCs, EPA guidance allows States the discretion to decide whether or 

not ammonia emissions are to be considered for BART purposes based on evaluations of the 

contributions of the emissions to haze at Class I areas in their areas of influence. One approach a 

State can use to determine whether applying BART will be needed is to evaluate the haze 

impacts of all current emissions from all BART-eligible sources in the State. If the impact from 

all sources in the state is less than the contribution threshold established by the State, 0.5 dv for 

Kentucky, then source by source analysis for BART is not needed. 

Kentucky has determined through modeling that with one exception ammonia (NH3) emissions 

from point sources are not anticipated to cause or contribute significantly to any impairment of 

visibility in Class I areas and should be exempt for BART purposes. 

 Appendix L 

Kentucky Regional Haze SIP 

11
6.1 Method 

Kentucky has determined through modeling that ammonia emissions from point sources are not 

anticipated to cause or contribute significantly to any impairment of visibility in Class I areas 

with the exception of one large point source that is approximately 400 km south and west of 

Mammoth Cave. 

VISTAS contracted with Georgia Institute of Technology to perform model sensitivity runs to 

determine the impact of point source ammonia on visibility in Class I areas. 

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on 

regional haze using CMAQv4.5 with SOA mods on the VISTAS 12 km modeling domain, using 

the VISTAS 2009 OTW (on the way) Base F4 emissions. One such sensitivity run reduced, 

BART-eligible source ammonia by 100%. The purpose was to quantify the impact of ammonia 

emissions from VISTAS BART sources on Class I areas. Two episodes were examined: June 1-

July 10, 2002 and November 19 – December 19, 2002. The approach included calculating the 

extinction coefficient in dv (deciviews), then determining the maximum impact of BARTeligible source ammonia. The chart below, taken from the VISTAS report BART in the VISTAS 

Region: Sensitivity to VOC, NH3, and Primary PM Emissions, included as Appendix L.4, shows 

the impact on the following twenty-two Class I areas within the VISTAS domain. 3 

Maximum NH3 Impact

0.0

0.5

1.0

1.5

BRET

BRIG

CACRCHAS

COHU

DOSO

EVER

GRSM

HEGL

JARI

LIGO

MACA

MING

OKEF

ROMA

SAMA

SHEN

SHRO

SIPS

SWAN

UPBU

WOLF

ΔdV

Figure 6-1. Maximum NH3 Impact - Maximum contributions of all BART-eligible NH3 point sources in the 

VISTAS region to haze in Class I areas during the CMAQ-modeled periods. Note that in this graphic the 

maximum ammonia impact at Cape Romain may be overestimated as a result of an emissions error 

discovered after its generation. 

The chart shows the largest haze impact in delta dv over the two timeframes at each Class I area. 

These delta dv changes represent the haze contribution of all BART source ammonia emissions 

relative to assumed natural haze levels. The natural haze levels are based on EPA-default annual 

average natural concentrations for the East and monthly-varying “climatologically 

representative” relative humidity at each Class I area. During the periods modeled the ammonia 

 Appendix L 

Kentucky Regional Haze SIP 

12
emissions from all BART-eligible sources contributed more than 0.5 dv to haze at Mammoth 

Cave National Park (MACA), Kentucky; Mingo Wilderness (MING), Missouri, Cape Romain 

National Wildlife Refuge Area (ROMA) South Carolina, and Swanquarter National Wildlife 

Refuge (SWAN), North Carolina. 

The majority of ammonia emissions in the VISTAS region come from four BART-eligible 

sources as shown in Table 6-1 below. 

Table 6-1. Major BART NH3 Sources in the VISTAS Region 

Facility State NH3 Emissions 

(tpy) 

Distance to Nearest 

Class 1 Area (km) 

Meadwestvaco Corp. SC 130 30 

PCS Phosphate NC 206 31 

PCS Nitrogen TN 1252 180 

PCS Nitrogen GA 1765 220 

Analysis of spatial and temporal distributions of ammonia concentrations indicates that the likely 

point source ammonia contributor to Mammoth Cave is the PCS Nitrogen Plant to the south and 

west near Memphis Tennessee. 

 

6.2 Conclusions 

The BART requirements of the regional haze rule allow states to determine whether or not 

ammonia is to be considered a visibility impairing pollutant to be addressed for BART purposes. 

NH3 emissions from BART sources may impair visibility; however the majority of NH3 

emissions in the VISTAS region are from a few BART sources. Removal of the large NH3 

emission sources results in minimal impact on visibility at Class I areas in the VISTAS region. 

At their discretion states may ask those few large sources to evaluate NH3 impacts and potential 

controls for NH3. Based on the CMAQ sensitivity analyses of the impact of ammonia emissions, 

the State determined that only one large TN source of ammonia emissions, PSC Nitrogen Plant, 

would be the likely contributor to Mammoth Cave visibility regarding ammonia. The PSC 

Nitrogen Plant has the potential to emit of at least 1,252 tons per year. Thus, this source’s 

ammonia emissions were included in the PSC Nitrogen BART exemption modeling. A 

Tennessee air pollution control staff related to KYDAQ that PSC Nitrogen did model below 0.5 

dv pursuant to the source’s BART exemption modeling. Requiring the remaining smaller point 

sources of ammonia emissions to model ammonia impacts is not necessary. 

 Appendix L 

Kentucky Regional Haze SIP 

13
7. Explanation of BART Exemption Modeling 

7.1 Background 

 

Kentucky opted to consider its BART-eligible sources subject to BART unless the source 

demonstrated exemption via modeling. BART-eligible sources can be excluded from BART 

determinations by demonstrating that the source cannot be reasonably expected to cause or 

contribute to visibility impairment in a Class I area. The threshold for determining that a source 

causes visibility impairment is set at 1.0 dv change from natural conditions over a 24 hour 

averaging period. The BART guidelines also propose that the threshold at which a source may 

“contribute” to visibility impairment should not be higher than 0.5 deciviews; however, 

depending on factors affecting a specific Class I area it may be set lower than 0.5 deciviews. 

As stated in the BART regulation EPA’s preferred approach for determining cause or 

contribution is an assessment with an air quality model such as CALPUFF or other appropriate 

model followed by comparison of the estimated 24-hour visibility impacts against a threshold 

above estimated natural conditions to be determined by the State. EPA recommends that the 98th

percentile value from the modeling be compared to the State’s chosen contribution threshold to 

determine if a source does not contribute to visibility impairment and thus is not subject to 

BART. Comparison of the 98th percentile value to the threshold must be made for each Class I 

area. For an annual period, this implies the 8th highest 24-hr value at a particular Class I area is 

compared to the contribution threshold. For a 3-year modeling period, the 98th percentile value 

may be interpreted as the highest of the three annual 98th percentile values at a particular Class I 

area or the 22nd highest value in the combined three year record, whichever is more conservative. 

Kentucky worked with the regional planning organization (RPO) VISTAS on development of the 

VISTAS Protocol for the Application of the CALPUFF Model for Analyses of Best Available 

Retrofit Technology (BART) (available in Appendix L.5). The common protocol was established 

to provide the basis for a common understanding among the organizations performing BART 

analyses or reviewing BART modeling results in the VISTAS region. 

The VISTAS protocol describes common procedures for carrying out air quality modeling to 

support BART determinations that are consistent with the 40 CFR Part 51 Appendix Y 

guidelines. The protocol provides a consistent model, CALPUFF, and modeling guidelines for 

BART determinations, clearly delineated modeling steps, a common CALPUFF configuration, 

guidance for site-specific modeling, and common expectations for reporting model results. 

Details of the CALPUFF system can be found in Chapter 3 of the VISTAS protocol, specific 

recommendations for its application for BART purposes are found in Chapter 4, and specific 

information that should be included in site-specific protocols is found in Chapter 5. 

VISTAS contracted EarthTech (now TRC) to develop a version of the CALPUFF model 

appropriate for BART purposes. The VISTAS version of the CALPUFF model is CALPUFF 

Version 5.754 and CALMET Version 5.7. 

For BART modeling purposes VISTAS made publicly available 12-km CALMET output files 

for the entire VISTAS modeling domain (eastern United States) and provided CALMET output 

 Appendix L 

Kentucky Regional Haze SIP 

14
files for five 4-km grid subdomains covering the VISTAS states and VISTAS Class I areas. To 

generate the CALMET input files, the VISTAS contractor used the MM5 databases developed 

by EPA for 2001, VISTAS for 2002, and Midwest RPO for 2003. For the 12 km grid large 

domain covering the entire VISTAS region, the No-Obs setting was used. For the 4 km grid 

available surface and upper air observations were used in addition to MM5 meteorological model 

outputs. Specific model settings were provided with the CALMET files and via the CALPUFF 

website so that work could be replicated. 

For CALPUFF modeling, source emissions were to be defined using the maximum 24-hour 

actual emission rate during normal operation for the most recent 3 or 5 years. If maximum 24-

hour actual emissions were not available, continuous emission data, permit allowable emissions, 

potential emissions, and emission factors from AP-42 source profiles could be used as available. 

Key points on specific CALPUFF, CALPOST, and POSTUTIL configuration that were to be 

used for BART modeling are: 

• After running CALPUFF for an individual facility, NO3 should be repartitioned in 

POSTUTIL. 

• Ozone data from non-urban monitors should be used as the background ozone input. 

• The Pasquill-Gifford dispersion method should be used. 

• In CALPOST Method 6 with monthly average RH for calculating extinction as 

recommended by EPA should be used. 

• EPA default calculations of light extinction under current and natural background 

conditions should be used. In addition a source may also calculate visibility using the 

recently revised IMPROVE algorithm. 

Additional discussion of the CALPUFF model and VISTAS recommended settings can be found 

in the VISTAS protocol in Appendix L.5. 

7.2 Kentucky BART Sources Exemption Modeling 

KYDAQ requested that its sources follow the VISTAS modeling protocol in development of 

their site specific protocols and explain any deviations that they proposed to use. In the sitespecific modeling demonstrations submitted by Kentucky’s BART-eligible sources, the 

CALPUFF model incorporating three years of pre-processed MM5 meteorological data was used 

to evaluate the deciview change compared to natural background conditions at each of the Class 

1 areas within 300 km of the source. The 12 km and/or 4 km MM5 datasets prepared by 

VISTAS were used. For exemption modeling using the 12 km dataset with no obs, per the 

VISTAS protocol, the maximum delta-deciview (dv) value was determined at each Class I area 

and compared to the 0.5 dv contribution threshold. For exemption modeling using the 4 km 

dataset, the 98th percentile delta-deciview (dv) value was determined at each Class I area and 

compared to the 0.5 dv contribution threshold. 

Seventeen of twenty-six Kentucky facilities submitted site-specific modeling protocols and 

subsequent modeling demonstrations based upon the VISTAS modeling protocol. Exemption 

modeling for nine Kentucky BART-eligible sources was conducted by the VISTAS contractor 

 Appendix L 

Kentucky Regional Haze SIP 

15
using the VISTAS common protocol. The BART site-specific modeling protocols are found in 

Appendix L.5 and the BART exemption modeling demonstrations are found in Appendix L.6 

The BART modeling protocols were reviewed by KYDAQ staff that worked with and shared the 

BART protocols with both EPA and FLMs for their review and comment. Their comments were 

shared with the facilities and addressed before the modeling was conducted. 

All of the individual facility BART exemption modeling demonstrations are being provided in 

this Regional Haze SIP submittal. Resulting changes in response to protocol comments are 

reflected in the exemption modeling demonstration (see Appendix L.6) and/or the modeling 

protocol (see Appendix L.5) submitted by each facility. KYDAQ staff reviewed the 

demonstrations to determine whether the sources have less than 0.5 deciview (dv) impact on any 

Class I area within 300 km of the source. Sources demonstrating less than 0.5 dv impact are 

considered exempt. Sources contributing 0.5 dv impact or greater are considered subject to 

BART and required to proceed to a BART determination analysis of what control measures, if 

any, constitute BART for the source. 

Review of the demonstrations submitted led to the determination that the BART-eligible 

source(s) at each facility in Table 7-1 should be exempt from BART determination requirements. 

All of the facilities in Table 7-1 were able to demonstrate exemption from BART using the old 

IMPROVE equation with the exception of one facility that is identified as using the new 

IMPROVE equation exclusively for its BART exemption. Table 7-1, provides Kentucky BART 

exemption modeling demonstrations that utilized the maximum delta-deciview value for all 12 

km exemption modeling per the VISTAS protocol or for 4 km exemption modeling that utilized 

the 98th percentile value represented by 8th highest dv value over a three year period, which was 

more conservative over a three-year period. Based upon these exemption modeling 

demonstration results, KYDAQ proposes the exemption of all twenty-one facilities listed in 

Table 7-1 and available in Appendix L.7. Two of the facilities are primary aluminum facilities, 

one a paper manufacturer, fourteen electric utilities, one steel manufacturer, one primary metal 

(coke) manufacturer, two are coal preparation plants, one an oil refinery, and three are chemical 

manufacturers. 

 Appendix L 

Kentucky Regional Haze SIP 

16
Table 7-1. Kentucky BART Exemption Modeling Results For Sources Exempted From BART

Source Class I Area Impact 

(Change 

in DV) 

Modeling 

Duke Energy East Bend Station Mammoth Cave (210 km) 0.242 12 km Max dv value 

Owensboro Municipal Utilities Mammoth Cave (93 km) 0.432 4km 8th Highest dv value 

Mingo (289 km) 0.053 4km 8th Highest dv value 

AK Steel Corporation - Steel Plant Dolly Sods (287 km) 0.346 4km Max dv value 

James River Face (295 km) 0.386 4km Max dv value 

Linville Gorge (293) 0.358 4km Max dv value 

Otter Creek (261) 0.442 4km Max dv value 

Great Smokey Mt. (308 km) 0.190 4km 8th Highest dv value 

AK Steel Corp. – Coke Mfg Plant Dolly Sods (282 km) 0.180 12 km Max dv value 

Great Smokey Mt. 1 (304 km) 0.262 12 km Max dv value 

James River Face (288 km) 0.182 12 km Max dv value 

Linville Gorge (287 km) 0.155 12 km Max dv value 

Otter Creek (257 km) 0.208 12 km Max dv value 

Martin County Coal Corporation Dolly Sods1 (305 km) 0.068 12 km Max dv value 

Great Smokey Mt. (226 km) 0.135 12 km Max dv value 

James River Face (265 km) 0.085 12 km Max dv value 

Joyce Kilmer-Slickrock (285 km) 0.121 12 km Max dv value 

Linville Gorge (207 km) 0.131 12 km Max dv value 

Otter Creek (280 km) 0.077 12 km Max dv value 

Shining Rock (259 km) 0.103 12 km Max dv value 

Pinnacle Processing Inc. Great Smokey Mt. (235 km) 0.108 12 km Max dv value 

James River Face (262) 0.070 12 km Max dv value 

Joyce Kilmer-Slickrock (294 km) 0.053 12 km Max dv value 

Linville Gorge (214 km) 0.077 12 km Max dv value 

Otter Creek (272 km) 0.015 12 km Max dv value 

Shining Rock (268 km) 0.021 12 km Max dv value 

Arch Chemicals Inc. Mammoth Cave (83 km) 0.417 4km 8th Highest dv value 

Commonwealth Aluminum Lewisport LLC Mammoth Cave (94 km) 0.489 12 km Max dv value 

Mingo (304 km) 0.052 12 km Max dv value 

Henderson Power and Light Mammoth Cave (134 km) 0.302 12 km Max dv value 

Mingo (238 km) 0.084 12 km Max dv value 

Calgon Carbon Corporation Dolly Sods (284 km) 0.133 12 km Max dv value 

Great Smokey Mt. (290 km) 0.191 12 km Max dv value 

James River Face (282 km) 0.098 12 km Max dv value 

Linville Gorge (273 km) 0.103 12 km Max dv value 

Otter Creek (259 km) 0.157 12 km Max dv value 

Westlake Vinyls Inc. Mammoth Cave (183 km) 0.150 12 km Max dv value 

Mingo (156 km) 0.167 12 km Max dv value 

Sipsey1 (309 km) 0.084 12 km Max dv value 

Century Aluminum* Mammoth Cave (100 km)* 0.446 4km 8th Highest dv value 

Alcan Primary Products Corporation Mammoth Cave (118 km) 0.467 4km 8th Highest dv value 

Mingo (244 km) 0.184 4km 8th Highest dv value 

 Appendix L 

Kentucky Regional Haze SIP 

17
Table 7-1. Kentucky BART Exemption Modeling Results For Sources Exempted From BART

Source Class I Area Impact 

(Change 

in DV) 

Modeling 

NewPage**Corporation Wickliffe PaperCo. Mammoth Cave (250 km)** 0.102 4km 8th Highest dv value 

Mingo (91 km) 0.291 4km 8th Highest dv value 

Sipsey (319 km) 0.060 4km 8th Highest dv value 

Western Kentucky Energy Coleman Station Mammoth Cave (91 km) 0.368 4km 8th Highest dv value 

Western Kentucky Energy Reid/Henderson 

Station*** 

Mammoth Cave (118 km) 0.464*** ***4km 8th Highest dv 

value 

Mingo (244 km) 0.072 4km 8th Highest dv value 

Western Kentucky Energy Green Station Mammoth Cave (118 km) 0.217 4km 8th Highest dv value 

Mingo (244 km) 0.039 4km 8th Highest dv value 

 Marathon Petroleum Company Dolly Sods (287 km) 0.055 12 km Max dv value 

Great Smokey Mt. (293 km) 0.056 12 km Max dv value 

James River Face (287 km) 0.079 12 km Max dv value 

Linville Gorge (276 km) 0.041 12 km Max dv value 

Otter Creek (261 km) 0.086 12 km Max dv value 

E. ON U.S. Brown Station Mammoth Cave (130) km) 0.410 4km 8th Highest dv value 

Great Smokey Mt. (250 km) 0.210 4km 8th Highest dv value 

Joyce Kilmer-Slickrock (265 km) 0.153 4km 8th Highest dv value 

E. ON U.S. Cane Run Station Mammoth Cave (100) km) 0.378 4km 8th Highest dv value 

E. ON U.S. Ghent Station Mammoth Cave (190) km) 0.292 4km 8th Highest dv value 

*Century Aluminum and **NewPage modeled below 0.5 dv with and without the new improve equation. 

***Western Kentucky Energy Reid/Henderson Station BART exemption modeling was based exclusively on the use 

of the new improve equation. A copy of a request to EPA Region 4 requesting approval of the use of the new 

improve equation and a letter from EPA granting its approval of the request for these three sources are available in 

Appendix L.9. The modeled values in the above table for Century Aluminum and NewPage are for the old improve 

equation. The values for Western Kentucky Energy Reid/Henderson are for the new improve equation. 

Consistent with BART regulation requirements and EPA guidance, BART-eligible sources at 

electric utilities complying with EPA’s Clean Air Interstate Rule (CAIR) that wished to 

demonstrate exemption were allowed to model only PM emissions. Compliance with CAIR 

constitutes BART for these sources for emissions of NOx and SO2. 

Kentucky adopted its CAIR regulations with state effective dates of February 2, 2007, and June 

13, 2007. KYDAQ submitted its CAIR State Implementation Plan (SIP), which included the 

CAIR regulations, to EPA Region 4 for SIP approval on April 4, 2007. Kentucky is expecting 

approval of its CAIR SIP in the near future. Kentucky’s CAIR regulations are available in 

Appendix H.7. 

As previously noted, fourteen of Kentucky’s twenty-six BART-Eligible sources are electric 

generating units (EGUs). All of Kentucky’s BART-eligible EGUs are subject to CAIR. Most of 

these sources have already installed or are installing SO2 controls. A table that summarizes the 

existing and expected Kentucky EGU controls, including BART EGUs, is available in Appendix 

L.8. 

 Appendix L 

Kentucky Regional Haze SIP 

18
Five of the Kentucky’s twenty-six BART-eligible facilities were unable to demonstrate less than 

0.5 dv impact via modeling. All five facilities were EGUs. The 4 km exemption modeling 

visibility impact results for these five facilities are included in Table 7-2. For the exemption 

modeling, the five EGU sources were required to model only PM emissions. In each case the 

98th percentile represented by the 8th highest value over a 3 year period was the more 

conservative result and was compared to the 0.5 dv exemption threshold. 

Table 7-2. Kentucky BART Exemption Modeling Results for BART-Subject Sources.

Source Class I Area 

Impact 

(Change 

in DV) 

Modeling 

East Kentucky Power (EKPC) 

Cooperative Spurlock Station Mammoth Cave (251 km) 1.834 4km 8th Highest dv value

East Kentucky Power (EKPC) 

Cooperative Cooper Station Mammoth Cave (130 km) 7.376 4km 8th Highest dv value

Great Smoky Mountains National Park 

(162 km) 6.763 4km 8th Highest dv value

Joyce Kilmer-Slickrock Wilderness 

(178 km) 4.974 4km 8th Highest dv value

Cohutta Wilderness Area (221 km) 3.363 4km 8th Highest dv value

Shinning Rock (233 km) 2.022 4km 8th Highest dv value

Linville Gorge Wilderness Area (267 km) 1.885 4km 8th Highest dv value

TVA Paradise Fossil Steam Plant Mammoth Cave (63 km) 3.93 4km 8th Highest dv value

Mingo (283 km) 0.865 4km 8th Highest dv value

American Electric Power (AEP) 

Big Sandy Plant Dolly Sods (291 km) 1.027 4km 8th Highest dv value

James River Face (279 km) 1.052 4km 8th Highest dv value

Linville Gorge (256 km) 0.835 4km 8th Highest dv value

Otter Creek (266 km) 1.285 4km 8th Highest dv value

E. ON U.S. Mill Creek Station Mammoth Cave (90 km) 2.265 4km 8th Highest dv value

7.3 BART Sources in Other States Within 300 km of Kentucky’s Class I Area 

The authority and responsibility for conducting BART analyses under the regional haze rule lies 

with the state in which the BART eligible source is located. Sources must conduct an analysis of 

their impact on any Class I area within 300 km of the source. At this time the VISTAS states are 

 Appendix L 

Kentucky Regional Haze SIP 

19
at various points in their processes for addressing BART. For information regarding BART 

sources outside of Kentucky within 300 km of Kentucky’s Class I area, please refer to the 

governing state’s regional haze SIP submittal as it becomes available.

7.4 Use of New IMPROVE Equation 

During the regional haze SIP development process, the IMPROVE Steering Committee made 

recommendations for a new IMPROVE equation. Among other things, the new equation includes 

components that take into account the effects of sea salt and site specific Rayleigh scattering. 

Additional discussion of the new IMPROVE equation can be found in Appendix C. 

VISTAS contracted Dr. Ivar Tombach to develop a post processor to allow CALPOST outputs to 

be used with the new IMPROVE equation. A discussion of the rationale for use of the new 

IMPROVE equation follows. The new IMPROVE postprocessor and instructions are included in 

Appendix L.9. 

Rationale for Need for Use of New IMPROVE Equation

The new IMPROVE equation is a much better representation of the effects of particulate matter 

on light extinction than the old equation and takes into account the latest scientific understanding 

of several parameters. 

1. The new algorithm overcomes biases of the old algorithm on the haziest days and the 

clearest days as demonstrated by comparing the measured light extinction from 

nephelometers at Class I areas to light extinction calculated using each of the equations. 

2. The new algorithm recognizes spatial and temporal variation in light extinction as size 

distribution of the aerosol changes by increasing extinction efficiency as sulfate, nitrate 

and organics concentrations increase. 

3. The new algorithm incorporates a term to reflect the contribution of fine sea salt and 

its hygroscopic growth with increasing relative humidity recognizing research findings 

showing that fine sea salt can be an important contributor to light extinction in coastal 

areas. 

4. The new algorithm reflects research finding that the mass concentration of particulate 

organic matter in rural areas is greater than represented by the old equation. 

5. The new algorithm includes a NO2 term to represent times when light absorption by 

NO2 is a meaningful contributor to light extinction. 

6. The new algorithm incorporates site-specific Rayleigh scattering values to better 

represent sites close to sea level or with very hot or cold climates. 

With this combination of revisions to the IMPROVE equation, the resulting apportionment of 

extinction to various components is more accurate on the haziest and clearest days. This is 

important for development of emission control strategies since the benefits of control of 

concentrations of each species will be represented more correctly with the new algorithm. 

 Appendix L 

Kentucky Regional Haze SIP 

20
Three of Kentucky’s BART-eligible sources, Western Kentucky Energy Reid/Henderson station, 

NewPage Corporation, and Century Aluminum used the new improve equation in their BART 

exemption modeling. A copy of a request to EPA Region 4 requesting approval of the use of the 

new improve equation and a letter from EPA granting its approval of the request for these three 

sources are available in Appendix L.9. 

7.5 Conclusion 

As reflected in Table 7-1, twenty-one of Kentucky’s twenty-six BART-eligible sources were 

able to demonstrate that they did not cause or contribute to visibility impairment in any Class I 

area within 300 km of the source. One source used the new IMPROVE equation exclusively in 

efforts to demonstrate BART exemption. Five Kentucky sources, East Kentucky Power 

Cooperative (EKPC) Spurlock Station, East Kentucky Power Cooperative (EKPC) Cooper 

Station, TVA Paradise, American Electric Power (AEP) Big Sandy, and E.ON U.S. Mill Creek 

Station, as reflected in Table 7-2, were unable to demonstrate a contribution of less than 0.5 dv at 

all Class I areas within 300 km from their BART-eligible sources, which caused those sources to 

be considered “subject to BART.” These five sources were required to conduct BART 

determination modeling containing their evaluation of potential BART options and a proposed 

BART determination. Discussion of the BART determination modeling for these five sources is 

included in Section 9.0 below. 

8. Other Sources Exempted From BART Based on BART Guidelines 

The following five KYDAQ sources were determined not to be BART-eligible based on the 

BART methodology in the BART Guidelines. These sources were discussed with EPA in 

January 2006. Documentation and correspondence regarding why these sources were not 

considered BART-eligible sources is available in Appendix L.10. 

• Arkema (Formerly Atofina Chemicals) 

• E.I. Dupont Inc. 

• Cc Metals & Alloys Inc. 

• ISP Chemicals Inc. 

• Kingsford Manufacturing Co. 

9. BART Determinations 

For those facilities subject to BART, the state must determine what constitutes BART controls 

for the source by considering various control options and selecting the best alternative taking into 

consideration any pollution control equipment in use at the source, the costs of compliance with 

control options, the remaining useful life of the facility, the energy and non air-quality 

environmental impacts of compliance, and the degree of improvement in visibility that may 

reasonably be anticipated to result from the use of such technology. Under Kentucky’s approach, 

sources that are subject to BART were required to conduct BART determination modeling and 

propose BART controls for the facility while considering the statutory factors. 

 Appendix L 

Kentucky Regional Haze SIP 

21
9.1 BART Subject Sources 

Only five BART-eligible sources in Kentucky emit any air pollutant which may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any Class I area. The five 

Kentucky sources, East Kentucky Power Cooperative (EKPC) Spurlock Station, East Kentucky 

Power Cooperative (EKPC) Cooper Station, TVA Paradise, American Electric Power (AEP) Big 

Sandy, and E.ON U.S. Mill Creek Station were unable to demonstrate a contribution of less than 

0.5 dv at all Class I areas within 300 km from their BART-eligible sources, which caused those 

sources to be considered “subject to BART.” These five sources were required to conduct 

BART determination modeling containing their evaluation of potential BART control options 

and a proposed BART determination. 

KYDAQ staff reviewed the BART determination modeling and is submitting all five BART 

determination modeling submittals in this Regional Haze SIP submittal. The five BART 

determination modeling submittals are available in Appendix L.11. The BART determination 

modeling results and the proposed BART controls to address condensible particulate emissions 

are summarized in Table 9-1 and available in Appendix L.12. Applicable BART controls and 

emission limits will be incorporated into the sources’ Title V permit as appropriate or upon 

renewal. In addition, 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. However, as related by TVA, 

the hydrated lime injection controls for TVA Paradise Units 1-3 will be in place well before the 

BART controls are required; will achieve the reduction in visibility impacts listed in the Draft 

Implementation Plan (Kentucky Regional Haze SIP); and will be included in TVA Paradise’s 

Title V permit. Specifically, regarding the installation of hydrated lime injection controls for 

TVA Paradise Units 1-3, TVA has communicated to KYDAQ its proposed plan that provides for 

permitting activities to proceed in July 2008; for construction to begin in mid-2009 on Unit 3 

with construction for Unit 1 and 2 to follow; and for controls to be operating on all three TVA 

Paradise units possibly by the fall of 2010. Also, as indicated in the E.ON U.S. Mill Creek 

BART determination submittal, the average cost for installing sorbent controls on all four Mill 

Creek units is about the same (an estimated 5.1 million $/dv). However, sorbent injection at all 

four units would mean an additional total capital investment of $8.8 million as compared to 

controls only on the larger Units 3 and 4. Therefore, E.ON U.S. concluded that BART should be 

the installation of sorbent injection controls on the larger Mill Creek Units 3 and 4 since they can 

achieve an estimated 70 percent of the total dv improvement achieved by controlling all four 

units. 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 that follows and available in Appendix L.12, in addition to the 

emission controls, provides the source’s BART emission limits and timeframes for compliance. 

 Appendix L 

Kentucky Regional Haze SIP 

22
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 

Kentucky Regional Haze SIP 

23
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 

Kentucky Regional Haze SIP 

24
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 

Kentucky Regional Haze SIP 

25
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. 

9.2 Final BART Determinations 

After reviewing the sources’ BART modeling determinations and considering the statutory 

factors, KYDAQ staff has concluded that the controls proposed by all the five Kentucky EGU 

BART-Subject sources are reasonable and appropriate for addressing condensible particulates 

and their impacts on nearby Class I areas. 

9.3 BART Subject Sources in Other States Within 300 km of Kentucky’s Class I Area 

The authority and responsibility for conducting BART analyses under the regional haze rule lies 

with the state in which the BART eligible source is located. Sources must conduct an analysis of 

their impact on any Class I area within 300 km of the source. At this time the VISTAS states are 

at various points in their processes for addressing BART. For information regarding BART 

sources outside of Kentucky within 300 km of Kentucky’s Class I area, please refer to the 

governing state’s regional haze SIP submittal as it becomes available.

 Appendix L 

Kentucky Regional Haze SIP 

26
9.4 Conclusions 

East Kentucky Power Cooperative (EKPC) Spurlock Station, East Kentucky Power Cooperative 

(EKPC) Cooper Station, TVA Paradise, American Electric Power (AEP) Big Sandy Plant, and 

E.ON U.S. Mill Creek Station were all found to be subject to BART. As indicated in Tables 9-1 

and 9-2, all of these sources have agreed to install emission controls for BART to address 

condensible particulate impacts on nearby Class I areas, except the hydrated lime injection 

controls for TVA Paradise Units 1-3 are not for BART. Based on a review of the BART 

Modeling Determinations (see Appendix L.11) submitted by the five BART-Subject sources and 

in consideration of the five statutory factors and applicable consent decrees, KYDAQ agrees 

with BART emission controls as determined by the BART-Subject sources as provided in Tables 

9-1 and 9-2. KYDAQ expects that all the BART determination controls in Tables 9-1 and 9-2 

will be in place no later than five years after EPA approves Kentucky’s Regional Haze SIP, with 

the possible exception of the flue gas desulfurization (FGD) scrubber for AEP Big Sandy Unit 2, 

which per a consent decree is required by December 31, 2015. However, KYDAQ will work 

with AEP to install the FGD scrubber on AEP Big Sandy Unit 2 as expeditiously as practicable. 

10. Kentucky BART Modeling Summary and BART Modeling Files 

A summary of the Kentucky BART exemption and BART determination modeling results is 

available in Appendix L.13. In addition, BART exemption and BART determination modeling 

files are being made available on a KYDAQ FTP site pursuant to the after hearing submittal of 

Kentucky’s Regional Haze SIP to EPA. 

 

 Appendix L 

Kentucky Regional Haze SIP 

27
REFERENCES: 

1. 40 CFR Part 51 Appendix Y 

2. The Quadratic Detection Model” by W. Malm. Appendix D in Acidic Deposition: State of 

Science and Technology, Report 24, Visibility: Existing and Historical Conditions -- Causes 

and Effects. National Acid Precipitation Assessment Program, Washington, DC. 1990. 

3. Boylan Ph.D., James, 2006, April,VISTAS Joint Tech Analysis-Planning Call. Power Point 

Presentation: Summary BART_VOC_NH3_PM.ppt. 

 Appendix L 

Kentucky Regional Haze SIP 

28