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



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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 Volatil e 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 With in 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 Ot her 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 2Appendix L.1 – July 6, 2005, Federal Register, BART Final Rule

Appendix L.2 – BART Le tters 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 Re sults for Sources Exempted From BART

Appendix L.8 – Kentucky Electric Generating Un its (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 Mode ling Results for BART-Subject Sources

Appendix L.13 – Summary of Kentucky BART Ex emption 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 re trofit (BART) controls under 40 CFR 51.308(e) as part of our Regional Haze SI P. 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 spec ific BART requirements. The discussion covers identification of BART-eligible sources, exemp tion modeling for BART eligible sources, and
BART determinations for source s found to be subject to BART.



### 1. Background

As required by the CAA, EPA included in the fina l 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 sour ces which have the potential to emit 250 tons or more of a visibili ty-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 categor ies. Under the CAA, BART is required for any BART-eligible source that a State determines “emits any air po llutant which may reasonably be anticipated to cause or contribute to any impairme nt 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 impairme nt. Although the appropriate thre shold 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 re sponsible 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 Stat es should include SO2, NOx, and di rect particulate matter (PM) emissions, including both PM10 and PM2.5, in dete rmining whether sources cause or contribute to visibility impairment. States may use th eir 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 s ubject to BART, states have several options. A state may consider all BART-eligible sources s ubject to BART; may perf orm analysis showing that the full group of BART-elig ible sources in a State cumula tively may not be reasonably anticipated to cause or contribute to any visi bility impairment in any Class I areas; or may
consider the individualized cont ribution of a BART-eligible source to determine whether a specific BART-eligible source is subject to BART.

Sources that are subject to BART must under go a BART determination. Section 169A(g)(7) of the CAA requires that States must consid er the following factors in making BART

Appendix L Kentucky Regional Haze SIP 4determinations: (1) The costs of compliance, (2 ) The energy and non-air quality environmental impacts of compliance, (3) Any existing pollution control technol ogy 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 re sult from the use of such technology. 1

To demonstrate the degree of improvement in visi bility from various BA RT control options, the States may run CALPUFF or anothe r 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 maxi mum 24-hour emission rates would be modeled for a period of three or five years of meteorologi cal data. States have the flexibility to develop
their own methods to ev aluate model results. 1



### 2. Approach to Implementa tion of BART Requirements

In order to meet the SIP submittal deadline, Ke ntucky has used the following approach for the implementation of the federal regi onal haze rule BART requirements. The approach consists of source identification efforts; requests to sour ces for information; providing EPA guidance and information to the BART-eligib le sources; particip ation in the VISTAS BART subgroup to resolve technical issues spanning states in th e VISTAS region; and ongoing consultation with affected sources; and EPA and FL Ms throughout the BART process.

As required by the Clean Air Act (CAA), Kentuc ky 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 vi sibility impairing pollutant, were in existence on August 7, 1977 and began operati on after August 7, 1962, and fa ll 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 cont ribute to visibility impairment and should be exempted. Non- exempt sources are required to undergo a
determination of best availa ble 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-eligib le 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 determ ine the population of potential BART-eligible sources. The data were initially queried fo r any sources emitting SO2, NOx, PM-10, VOC, or
ammonia. The data set was refine d based on emissions, whether emission units fit in any of the twenty-six listed source cate gories 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 we re 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, sour ce category and date criteria. Letters and correspondence to sources are available as Appendix L.2.

Appendix L Kentucky Regional Haze SIP 5Through this iterative review process, the list of potential BART-elig ible 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 refine ry, and three chemical manufact urers. 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 Coope rative 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 an d VISTAS 2002 SO2 emissi ons 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. Kentuc ky BART-eligible sources were provided the

Appendix L Kentucky Regional Haze SIP 6opportunity to submit modeling demons trations showing that they di d 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 sour ce that is responsible for a 1.0 deciview change or more should be considered to ‘cause’ visibility impairment.” The guideline
document also states that “t he appropriate threshold for determining whether a source ‘contributes to visibility impairment’ may reas onably differ across states,” but, “As a general matter, any threshold that you use for determining whether a source ‘contr ibutes’ to visibility impairment should not be higher than 0.5 deciview s.” The rationale for th ese instructions is provided in the preamble to the BART guidance, in the statemen t, “If ‘causing’ visibility impairment means causing a humanly perceptible cha nge in visibility in virtually all situations ( i.e. a 1.0 deciview change), then ‘c ontributing’ to visibility imp airment must mean having some lesser impact on the conditions aff ecting visibility that need not rise to the level of human perception.” (70 FR 39120, footnote 31). The guidan ce document itself also states that, “States
remain free to use a threshold lower than 0.5 deci views if they conclude that the location of a large number of BART-eligible sources within the St ate and in proximity to a Class I area justify this approach.”

The EPA’s documents strive to set these threshol ds in the context of the human perception of visibility change. As noted above, the EPA consid ers 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 a sserts 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 im pact (for which EPA c onsiders the practical threshold to be 1.0 dv) while “co ntributing” to visibility imp airment means having a smaller impact (for which EPA considers the threshold to be 0.5 dv or so me 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 lim it 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 tota l 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 7KYDAQ concluded that the EPA su ggested contribution threshold of 0.5 dv was appropriate in
this situation since there are a limited number of in and out of state s ources 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. Consider ing 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 overal l impacts were low from the

sources.

Appendix L Kentucky Regional Haze SIP 8Figure 4-1. Location of VISTAS BART-Eligible Sources



### 5. Exemption of Point Source Vola tile Organic Compounds for BART Purposes

Kentucky has determined through modeling that Volatile Organi c Compounds (VOC) from point sources are not anticipated to cause or contribute significantly to any impair ment of visibility in
Class I areas and should be exempt for BART purposes.

5.1 Method

Kentucky has determined through modeling that VOC s from point sources ar e not anticipated to cause or contribute significantly to any impair ment of visibility in Class I areas.

Modeling was conducted through The Visibility Im provement State and Tribal Association of the Southeast (VISTAS). VISTAS is a collabor ative effort of state governments, tribal governments, and various federal agencies establ ished to initiate and coordinate activities associated with the management of regional haze, visibility and other air quality issues in the
Southeastern United States. VISTAS contract ed 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 9Georgia 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 Nove mber 19 – December 1 9, 2002. The approach included calculating the extinction coefficient in dv (deciviews), then determining the maximum impact of point source VOCs. The char t below, taken from the VISTAS report BART in the VISTAS Region: Sensitivity to VO C, 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 0.6BRETBRIGCACRCHASCOHUDOSOEVERGRSMHEGLJARILIGOMACAMINGOKEFROMASAMASHENSHROSIPSSWANUPBUWOLFΔdV

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 fo r all Class I areas in the VISTAS domain.
Given that the fraction of the to tal point source VOC emissions th at are also BART-eligible in the state of Kentucky is just 8% 3 , the expected impact of contro lling VOCs from a BART source would be much less than the 0.5 dv threshold. VISTAS and Kentucky conc lude 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 ar eas in their areas of influence. One approach a State can use to determine whether applying BA RT will be needed is to evaluate the haze impacts of all current emissions from all BART-eli gible sources in the State. If the impact from
all sources in the state is less than the contri bution 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 s hould be exempt for BART purposes.

Appendix L Kentucky Regional Haze SIP 116.1 Method

Kentucky has determined through modeling that am monia 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 approximat ely 400 km south and west of
Mammoth Cave.

VISTAS contracted with Georgia Institute of Technology to perform mode l sensitivity runs to determine the impact of poi nt 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 su ch sensitivity run reduced, BART-eligible source ammonia by 100%. The pur pose 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 Cl ass I areas within the VISTAS domain. 3



## Maximum NH 3 

## Impact

0.0 0.5 1.0 1.5BRETBRIGCACRCHASCOHUDOSOEVERGRSMHEGLJARILIGOMACAMINGOKEFROMASAMASHENSHROSIPSSWANUPBUWOLFΔdV

Figure 6-1. Maximum NH3 Impact - Maximum contributions of all BART-eligible NH 3 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 na tural haze levels are based on EPA-default annual average natural concentrati ons for the East and monthl y-varying “climatologically representative” relative humidity at each Class I area. During the periods modeled the ammonia

Appendix L Kentucky Regional Haze SIP 12emissions from all BART-eligible sources contributed more than 0.5 dv to haze at Mammoth Cave National Park (MACA), Ke ntucky; Mingo Wilderness (MI NG), Missouri, Cape Romain National Wildlife Refuge Area (ROMA) South Carolina, and Swanquart er National Wildlife Refuge (SWAN), North Carolina.

The majority of ammonia emissions in the VI STAS region come from four BART-eligible
sources as shown in Table 6-1 below.

Table 6-1. Major BART NH 3 Sources in the VISTAS Region

Facility State NH 3 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 concentr ations indicates that the likely point source ammonia contributor to Mammoth Ca ve is the PCS Nitrogen Plant to the south and west near Memphis Tennessee.

6.2 Conclusions

The BART requirements of the re gional 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. Rem oval of the large NH3 emission sources results in minimal impact on visi bility at Class I areas in the VISTAS region. At their discretion states may as k those few large sources to evaluate NH3 impacts and potential controls for NH3. Based on the CMAQ sensitivity an alyses of the impact of ammonia emissions, the State determined that only one large TN s ource of ammonia emissions, PSC Nitrogen Plant, would be the likely cont ributor 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 m odeling. 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-e ligible sources can be excluded from BART determinations by demonstrating that the source cannot be reas onably expected to cause or contribute to visibility impairmen t in a Class I area. The threshol d 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 guide lines 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 pr eferred approach for determining cause or contribution is an assessment with an air quali ty model such as CALPUFF or other appropriate model followed by comparison of the estimated 24- hour visibility impact s against a threshold
above estimated natural conditions to be determ ined by the State. EPA recommends that the 98 th percentile value from the modeling be compared to the State’s chosen contribution threshold to
determine if a source does not contribute to visi bility impairment and thus is not subject to BART. Comparison of the 98 th percentile value to the threshol d must be made for each Class I area. For an annual period, this implies the 8 th highest 24-hr value at a particular Class I area is compared to the contribution threshold. For a 3-year modeling period, the 98 th percentile value may be interpreted as the hi ghest of the three annual 98 th percentile values at a particular Class I
area or the 22 nd highest value in the combined three year record, whichever is more conservative.

Kentucky worked with the regional planning orga nization (RPO) VISTAS on development of the
VISTAS Protocol for the Application of the CALPU FF 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 understand ing among the organizations performing BART analyses or reviewing BART modeli ng results in the VISTAS region.

The VISTAS protocol describe s common procedures for carryin g out air quality modeling to support BART determinations that are consistent with the 40 CFR Part 51 Appendix Y guidelines. The protocol provide s a consistent model, CALPU FF, and modeling guidelines for BART determinations, clearly delineated mode ling steps, a common CALPUFF configuration, guidance for site-specific modeling, and comm on expectations for reporting model results. Details of the CALPUFF system can be found in Chapter 3 of the VIST AS protocol, specific recommendations for its application for BART purposes are found in Chapter 4, and specific
information that should be included in si te-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 th e CALPUFF model is CALPUFF
Version 5.754 and CALMET Version 5.7.

For BART modeling purposes VISTAS made pub licly available 12-km CALMET output files for the entire VISTAS modeling domain (easte rn United States) and provided CALMET output

Appendix L Kentucky Regional Haze SIP 14files for five 4-km grid subdomains covering th e VISTAS states and VI STAS Class I areas. To generate the CALMET input files, the VISTAS contractor used the MM 5 databases developed by EPA for 2001, VISTAS for 2002, and Midwes t RPO for 2003. For the 12 km grid large domain covering the entire VIST AS 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 provide d with the CALMET file s 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 th e most recent 3 or 5 years. If maximum 24- hour actual emissions were not available, cont inuous emission data, permit allowable emissions, potential emissions, and emission f actors from AP-42 source profiles could be used as available.

Key points on specific CALPUFF, CALPOST, and POSTUTIL confi guration 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 shoul d be used as the background ozone input.

• The Pasquill-Gifford disper sion method should be used.

• In CALPOST Method 6 with monthly aver age RH for calculating extinction as recommended by EPA should be used.

• EPA default calculations of light extinc tion under current and natural background
conditions should be used. In addition a s ource may also calculate visibility using the recently revised IMPROVE algorithm.

Additional discussion of the CALPUFF model a nd 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 VI STAS modeling protocol in development of their site specific protocols and explain any deviat ions that they proposed to use. In the sitespecific modeling demonstrations submitted by Kentucky’s BART-eligible sources, the CALPUFF model incorporating thr ee years of pre-processed MM5 me teorological 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 us ing the 12 km datase t with no obs, per the VISTAS protocol, the maximum de lta-deciview (dv) value was determined at each Class I area and compared to the 0.5 dv contribution thres hold. For exemption modeling using the 4 km dataset, the 98 th 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 up on the VISTAS modeling protocol. Exemption modeling for nine Kentucky BART -eligible sources was conducte d by the VISTAS contractor

Appendix L Kentucky Regional Haze SIP 15using the VISTAS common protocol. The BART site-specific modeling protocols are found in Appendix L.5 and the BART exemption modeli ng demonstrations are found in Appendix L.6 The BART modeling protocols were reviewed by KY DAQ staff that worked with and shared the BART protocols with both EPA and FLMs for th eir review and comment. Their comments were
shared with the facilities and addr essed 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 demonstra tion (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 source s have less than 0.5 deciview (dv) impact on any
Class I area within 300 km of the source. So urces demonstrating less than 0.5 dv impact are considered exempt. Sources cont ributing 0.5 dv impact or greate r are considered subject to BART and required to proceed to a BART determin ation 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 ex emption. 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 98 th percentile value re presented by 8th highest dv value ove r a three year period, which was more conservative over a three-year pe riod. Based upon these exemption modeling demonstration results, KYDAQ proposes the exempti on 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 16Table 7-1. Kentucky BART Exemption Modelin g 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 8 th Highest dv value Mingo (289 km) 0.053 4km 8 th 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 Mammot h 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 17Table 7-1. Kentucky BART Exemption Modelin g 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 Mammot h 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 regula tion requirements and EPA guidance, BART-eligible sources at electric utilities complying w ith EPA’s Clean Air Interstate Rule (CAIR) that wished to demonstrate exemption were allowed to mode l only PM emissions. Co mpliance with CAIR
constitutes BART for these source s for emissions of NOx and SO2.

Kentucky adopted its CAIR regulations with stat e effective dates of February 2, 2007, and June 13, 2007. KYDAQ submitted its CAIR State Implem entation Plan (SIP), which included the CAIR regulations, to EPA Region 4 for SIP a pproval 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 tw enty-six BART-Eligible sources are electric generating units (EGUs). All of Kentucky’s BART-eligible EGUs ar e subject to CAIR. Most of these sources have already instal led or are installing SO2 controls . A table that summarizes the existing and expected Kentucky EGU controls, in cluding BART EGUs, is available in Appendix
L.8.

Appendix L Kentucky Regional Haze SIP 18Five 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 th ese 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
98 th percentile represented by the 8 th 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 Mo deling 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 BA RT 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 wi thin 300 km of the source. At this time the VISTAS states are

Appendix L Kentucky Regional Haze SIP 19at various points in their processes for addr essing BART. For information regarding BART sources outside of Kentucky w ithin 300 km of Kentucky’s Cla ss 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 pr ocess, 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 IMPROV E equation can be found in Appendix C.

VISTAS contracted Dr. Ivar Tombach to develo p a post processor to allow CALPOST outputs to be used with the new IMPROVE equation. A disc ussion of the rationale for use of the new IMPROVE equation follows. The new IMPROVE pos tprocessor and instruct ions are included in Appendix L.9.

Rationale for Need for Use of New IMPROVE Equation The new IMPROVE equation is a much better repres entation of the effect s of particulate matter on light extinction than the old equation and takes in to account the latest scientific understanding of several parameters.

1. The new algorithm overcomes biases of the old algorithm on the h aziest days and the clearest days as demonstrated by comp aring the measured light extinction from nephelometers at Class I areas to light exti nction calculated using each of the equations.
2. The new algorithm recognizes spatial and tem poral variation in light extinction as size distribution of the aerosol changes by increasin g 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 in creasing relative humidity re cognizing 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 greate r than represented by the old equation.
5. The new algorithm includes a NO 2 term to represent times when light absorption by
NO 2 is a meaningful contribu tor to light extinction.
6. The new algorithm incorporates site-speci fic 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 st rategies since the bene fits of control of concentrations of each species will be repres ented more correctly with the new algorithm.

Appendix L Kentucky Regional Haze SIP 20Three of Kentucky’s BART-eligible sources, We stern Kentucky Energy Reid/Henderson station, NewPage Corporation, and Century Aluminum us ed 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 Kent ucky’s twenty-six BART-e ligible sources were able to demonstrate that they did not cause or c ontribute to visibility im pairment 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 Po wer (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 fi ve sources were required to conduct BART determination modeling containing their evaluati on of potential BART options and a proposed
BART determination. Discussion of the BART dete rmination modeling for these five sources is included in Section 9.0 below.



### 8. Other Sources Exempted From B ART Based on BART Guidelines

The following five KYDAQ sources were determin ed not to be BART-eligible based on the BART methodology in the BART Guidelines. Th ese sources were discussed with EPA in January 2006. Documentation and corresponde nce regarding why these sources were not considered BART-eligible source s 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 vari ous control options and selecting the best alternative taking into consideration any pollution control equipment in us e at the source, the co sts of compliance with control options, the remaining useful life of the facility, the energy and non air-quality environmental impacts of compliance, and the de gree of improvement in visibility that may reasonably be anticipated to result from the us e of such technology. U nder Kentucky’s approach, sources that are subject to BART were requi red to conduct BART determination modeling and propose BART controls for the facility while considering the statutory factors.

Appendix L Kentucky Regional Haze SIP 219.1 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 impairme nt of visibility in any Class I area. The five Kentucky sources, East Kentucky Power Cooperative (EKPC) Spur lock Station, East Kentucky Power Cooperative (EKPC) Coope r Station, TVA Paradise, Amer ican Electric Power (AEP) Big Sandy, and E.ON U.S. Mill Creek St ation were unable to demonstrat e a contribution of less than
0.5 dv at all Class I areas within 300 km from th eir BART-eligible sources, which caused those sources to be considered “subject to BART.” These five sources were required to conduct BART determination modeling co ntaining their evalua tion 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 conde nsible particulate emissions are summarized in Table 9-1 and available in Appendix L.12. Applicable BART controls and emission limits will be incorporated into th e sources’ Title V permit as appropriate or upon renewal. In addition, since T VA had previously indicated to the KYDAQ its plans to install hydrated lime injection controls on TVA Paradi se 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 Para dise 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 re duction in visibility impacts listed in the Draft Implementation Plan (Kentucky Regional Haze SI P); and will be included in TVA Paradise’s Title V permit. Specifically, regarding the instal lation of hydrated lime injection controls for TVA Paradise Units 1-3, TVA has communicated to KYDAQ its proposed pl an 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; an d for controls to be operating on all three TVA Paradise units possibly by the fa ll of 2010. Also, as indicated in the E.ON U.S. Mill Creek BART determination submittal, th e average cost for installing so rbent 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 cap ital investment of $8.8 million as compared to controls only on the larger Units 3 and 4. Theref ore, E.ON U.S. concluded that BART should be the installation of sorbent injection controls on th e larger Mill Creek Unit s 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 an d available in Appendix L.12, in addition to the emission controls, provides the source’s BART em ission limits and timeframes for compliance.

Appendix L Kentucky Regional Haze SIP 22Table 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

Appendix L Kentucky Regional Haze SIP 23Table 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 d ecrees are available in Appendix L.8. **Since TVA had previously indicat ed to the KYDAQ its plans to inst all hydrated lim e 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 24Table 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 25Table 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 indica ted to the KYDAQ its plans to inst all hydrated lime injection co ntrols on TVA Pa radise Units 1-3 to mitigate opacity due to SO3 emissions and that additi onal controls ar e not cost-effective at this time, the KYDAQ has
determined BART to be no control for TVA Pa radise 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’ BA RT modeling determinations a nd considering the statutory factors, KYDAQ staff has conclude d that the controls proposed by all the five Kentucky EGU BART-Subject sources are reasona ble and appropriate for addres sing condensible particulates and their impacts on nearby Class I areas.

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

The authority and responsibility for conducting BA RT 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 wi thin 300 km of the source. At this time the VISTAS states are at various points in their processes for addr essing BART. For information regarding BART sources outside of Kentucky w ithin 300 km of Kentucky’s Cla ss I area, please refer to the governing state’s regional haze SIP submittal as it becomes available.

Appendix L Kentucky Regional Haze SIP 269.4 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 i ndicated 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 Cla ss I areas, except the hydr ated 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) su bmitted by the five BART-Subject sources and in consideration of the five statutory fact ors 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 Re gional Haze SIP, with the possible exception of the fl ue 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 Bi g Sandy Unit 2 as expeditiously as practicable.



### 10. Kentucky BART Modeling Su mmary and BART Modeling Files

A summary of the Kentucky BART exemption a nd 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: Ex isting and Historical Conditions -- Causes and Effects. National Acid Precipitati on 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