## Technical Support Document State of Iowa Regional Haze Submittal

Prepared by: Chrissy Wolfersberger Environmental Protection Specialist United States Environmental Protection Agency, Region 7

February 2012

Table of Contents

I. Summary of EPA’s a ction Page 3

II. Iowa’s regional h aze rulemaking Page 3

III. Regional h aze plan requirements Page 3

a. Affected Class I areas Page

i. Northern Midwest Class I areas

ii. Arkansas and Missouri Class I areas

iii. South Dakota Class I areas

b. Reasonable progress goals Page

c. Long term s trategy Page

i. Consultation with other States Page

1. Missouri and Arkansas

2. South Dakota

3. Oklahoma

4. Minnesota

5. Michigan

d. Best Available Retrofit Technology ( BART ) Page

i. BART eligible sources Page

ii. BART subject sources Page

1. Q/d screening

2. Mod el plant screening

3. CAMx screening

4. Holcim, ADM

- Clinton, and Equistar

5. BART for particulate matter

e. Monitoring strategy Page

f. Emissions inventory Page

g. Periodic SIP revisions and five year progress report Page

h. Consultation with Federal Land Man agers (FLMs) Page2 List of Figures Figur e 1 Map of the 156 mandatory Class I federal areas Figure 2 Areas within 300 km of a Class I area Figure 3 Geographical a rea of Regional Planning Organizations Figure 4 Distribution of the 2002 Iowa NH 3 emission inventory by source category Figure 5 Distribution of the 2002 Iowa VOC emissi on inventory by source category

List of Tables

Table 1 Percent contribution of Iowa, Minnesota, and Michigan to visibility impairment at the Northern Midwest Class I areas, 2 0% worst days

Table 2 Iowa’s absolute contribution to visibility impairment , Northern Midwest Class I

areas Table 3 Estimated 2018 level of visibility impairment in the absence of all Iowa emissions

sources Table 4 Facilities with BART

- eligible units in the State of Iowa

Table 5 Nearest Class I area & Q/d values for non

- EGU BART

- eligible sources

Table 6 Non

- EGU BART

- eligible facilities significant ly below Q/d screening tests

Table 7 Description of the IDNR BaseK cumulative modeling scenarios

Table 8 Scena rio k2002ia36b0v2r1: Class I area maximum impacts

Table 9 Scenario k2002ia36b0v2r2: Class I area maximum impacts

Table 10 Scenario k2002ia12b0v2r2: Class I area maximum impacts

Table 11 2002 Iowa emissions summary

Table 12 2018 Iowa projected emissions sum mary3 I. Summary of EPA’s Action The Environmental Protection Agency (EPA) is proposing a limited approval of a revision to the Iowa State Implementation Plan (SIP) submitted by the State of Iowa in March 2008 that addresses regional haze for t he first impl ementation period. This revision addresses the requirements of the Clean Air Act (CAA or “Act”) and the EPA’s rules that require S tates to prevent any future and remedy any existing anthropogenic impairment of visibility in mandatory

Class I areas caused b y emissions of air pollutants from numerous sources located over a wide geographic area (also referred to as the “regional haze program”). States are required to assure reasonable progress toward the national goal of achieving natural visibility condition s in Class I

areas.

EPA is proposing a limited approval of this SIP revision to implement the regional haze requirements for Iowa on the basis that the revision, as a whole, strengthens the Iowa SIP. In a separate action, o n December 30, 2011

, EPA prev iously proposed a limited disapproval of the Iowa regional haze SIP because of deficiencies in the State’s regional haze SIP arising from the remand by the U.S. Court of Appeals for the District of Columbia (D.C. Circuit ) to EPA of the

Clean Air Interstate Rule (CAIR). In that rulemaking, EPA proposed a Federal Implementation Plan (FIP) to replace reliance on the CAIR requirements in Iowa’s SIP with reliance on the

Cross

- State Air Pollution Rule (Transport Rule) as an alternative to BART.

II. Iowa’s Regiona l Haze rulemaking On May 1, 2007, the Iowa Environmental Protection Commission adopted revisions to 567 Iowa Administrative Code 22.9 related to regional haze. These rules became effective on Ju ne 27,

2007. The Iowa Department of Natural Resources (IDNR) r equested that EPA approve t hese changes into the federally

- approved SIP in a letter dated March 7, 2008

.

The State documented in its SIP the legal authority that the Iowa Environmental Protection Commission has for adopting rules related to regional haze ( a ppendix 2.1 of the SIP).

Opportunity for public comment on the Iowa regional haze SIP was advertised in the Des Moines Register on December 26, 2007, and the full SIP was posted on IDNR’s website. A public hearing was held on January 30, 2008 at the I DNR office in Urbandale, IA, with the public comment period open through January 31, 2008. Iowa received c omments from three organizations: USDA Forest Service, National Park Service, and EPA Region 7 . S ee appendix 2.1 of the SIP for full comments and resp onses

.

EPA believes that the State has met the requirements of the CAA sections 110( l ) and 110(a)(2) which require that the State adopt a SIP after reasonable notice and public hearing. EPA also believes that the State has met the requirements of the sp ecific procedural requirements for SIP revisions promulgated at 40 CFR Part 51, subpart F.

III. Regional Haze SIP requirements

a. Affected Federal Class I areas (40 CFR 51.308 (d)) States are required to identify each Class I area located within the State and e ach Class I area located outside the State which is affected by emissions from within the State.4 October 2002 Produced by NPS Air Resources Division National Park Service U.S. Department of the Interior 

# Areas within 300km of Class I Units

/ Roosevelt Campobello Intl. Park

FWS Class I

USFS Class I

NPS Class I Alaska Hawaii US Virgin Islands

Puerto Rico

0 500 1,000 250 Km Author: KLD Figure 1 : Map of the 156 mandatory Class I federal areas.

There are no Class I areas hosted by the State of Iowa, and no portion of land within the

State of Iowa is within 300 kilo meters (km) of a Class I area. States that host Class I areas are required to estimate the baseline, natural and current visibility cond itions of

those Class I areas. Iowa does not host a Class I area, therefore, it is not requ ir ed to

estimate these metrics.

Figure 2 : Areas

within 300 km of

a Class I

area. Iowa is the only

state
whose

border

does not

intersect

a 300 km buffer

zone.5 The State of Iowa participated in the planning efforts of the Central Regional Air Planning Ass ociation (CENRAP) which is affiliated with the Central States Air Resource Agencies (CENSARA). This RPO includes nine states

- Nebraska, Iowa, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana. CENRAP and its

contractors provided air qual ity modeling to the States to help them determin e whether sources located within the State can be reasonably expected to cause or contribute to visibility impairment in a Class I area. The modeling conducted relied on baseline year (2002) and future planni ng year (2018) emissions inventories that were prepared with participation from each of the CENRAP states. States relied on these inventories to develop control strategies to meet the visibility improvement goals of the regional haze

rule and to develop th eir State Implementation Plans (SIPs).

Figure 3 : Geographical a rea of Regional Planning Organizations

The State of Iowa relied upon the regional modeling work performed by CENRAP for determining the impact that sources with in the S tate might have on Class I areas in the region and beyond

. The modeling was based on PM Source Apportionment Technology (PSAT) for the Comprehensive Air Quality Model with extensions (CAMx) photochemical model. A detailed description of this modeli ng can be found in Appendix

7 of the SIP.

The following Class I areas were evaluated for contribution by the State of Iowa:

• Boundary Waters Canoe Area, Minnesota (BOWA)

• Voyageurs National Park, Minnesota (VOYA)

• Seney Wilderness Area, Michigan (SENE)

• Isl e Royal e National Park, Michigan (ISLE)6 • Hercules Glades Wilderness Area, Missouri (HEGL)

• Mingo Wilderness Area, Missouri (MING)

• Caney Creek Wilderness, Arkansas (CACR)

• Upper Buffalo Wilderness, Arkansas (UPBU)

• Badlands National Park, South Dakota (BADL)

• Wi nd Cave Na tional Park, South Dakota (WICA)

i. North ern Midwest Class I areas: Boundary Waters, Voyageurs, Seney, and Isle Royale According to the CENRAP PSAT results, the combined effect of all Iowa emissions upon the total modeled visibility impairment at t he four Northern

Midwest Class I areas is approximately 4

- 5% in both 2002 and 2018. The data

were calculated in accordance with the new IMPROVE equation 1 and are representative of those days which yielded the worst 20% visibility conditions. A

detailed des cription of the source apportionment methods utilized by CENRAP is available in Appendix 7.1 of the SIP.

Table 1: Percent contribution of Iowa, Minnesota, and Michigan to visibility impairment at the Northern Midwest Class I areas, 20% worst days

Iowa Minnesota Michigan

2002 2018 2002 2018 2002 2018 Boundary Waters 3.7 3.9 25.6 28.5 2.3 2.7 Voyagers 3.8 4.0 29.1 30.4 1.4 1.6 Isle Royale 4.5 4.9 11.5 12.5 11.1 12.8 Seney 4.2 4.8 3.9 4.4 9.6 12.7

The PSAT results provided above are in terms of per centages of total visibility impairment. The State of Iowa found them useful for determining the proportion

of the State ’ s contribution in relation to the total modeled visibility impairment at a Class I area. However, characterizing visibility impairment using just percentages can fail to identify the magnitude of the contribution. For example, Iowa’s percent contributions increase between 2002 and 2018, but the actual light

extinction values decrease between the same years.

Table 2: Iowa’s absolute cont ribution to visibility impairment , Northern

Midwest Class I areas Worst 20% Days Modeled Extinction (Mm

- 1)

Iowa Class I Area Total

2002 2018 2002 2018 Boundary Waters 2.39 2.08 64.87 53.44 Voyagers 2.60 1.97 56.45 48.84 Isle Royale 3.23 3.02 71.40 61.26 Seney 4.54 3.95 107.92 82.00

1 Interagency Monitoring of Protected Visual Environments (IMPROVE)7 Iowa’s contributions to visibility impairment, as calculated through light extinction using the new IMPROVE equation, are provided in Table 2. The total modeled visibility impairment for each Class I area are also sho wn in the table. Iowa emissions sources cumulatively contribute only 2.2

- 4.5 Mm

- 1 of the 56

- 107 Mm

- 1 total modeled visibility impairment at the Northern Midwest Class I

areas in 2002. Together , Iowa’s percentage and absolute contributions describe

the impacts emissions sources in Iowa may have upon nearby Class I areas. The State determined that when considered collectively, the data in Tables 1 and 2 show that Iowa sources were responsible for a minimal contribution to visibility impairment at the Nor thern Midwest Class I areas and that control of emissions of these sources offer little in terms of potential visibility improvement.

An alternative means of assessing Iowa’s contribution to visibility impairment can be conducted through implementation of the dv metric. As shown by Table 3, visibility improvements resulting from the elimination of all Iowa sources yield impacts below 0.5 dv.

Table 3 : E stimated 2018 level of visibility impairment in the absence of all

Iowa emissions sources

2018 Worst

20% (dv) 2018 Worst 20%

Less Iowa’s Contribution (dv ) Iowa’s Visibility Impacts (dv)

Boundary Waters 18.5 18.1 0.4 Voyagers 17.7 17.4 0.3 Isle Royale 19.6 19.2 0.4 Seney 22.2 21.8 0.4

ii. Arkansas and Missouri Class I areas: Caney Creek, Upper Buffalo, Mingo,

Hercules Glades

Iowa’s contributions to the Arkansas and Missouri Class I areas ( HEGL, UPBU,

CACR , MING ) in terms of percentage contribution to visibility extension were less than to the Northern Midwest Class I areas. PSAT analysis showed that Iowa sources contributed approximately 1.6

- 2.7% to the total visibility extinction on the 20% worst visibility days in 2018 at these Class I areas.

iii. South Dakota Class I areas: Badlands and Wind Cave

T he PSAT analysis showed that Iowa sources contributed appro ximately 1.6% to the total visibility extinction on the 20% worst visibility days in 2018 at the

Badlands and approximately 1.2% to the total visibility extinction on the 20% worst visibility days in 2018 at the Wind Cave National Park , a contribution

whic h the State determined to be insignificant.8 b. Reasona ble progress goals (RPG ) : 40 CFR 51.308(d)(1 ) The RHR requires States and Tribes to establish a Reasonable Progress Goal (RPG) for

each Class I area within the state. The RPG is measured in deciviews a nd is to provide for reasonable progress towards achieving natural visibility conditions during the fi r st implementation period (through 2018). RPGs should represent an improvement in visibility for the most impaired days, and ensure no degradation in visi bility on the least impaired days.

Iowa does not have a Class I area within the state and therefore is not required to establish a RPG. States hosting Class I areas have established RPGs, and have made assessments regarding whether emission reductions ar e needed from sources in Iowa in

order to meet their RPG.

c. Long

- Term Strategy: 40 CFR 51.308(d)(3)(iii)

State s are required to submit a long

- term strategy (LTS) that addresses visibility impairment for each Class I area, inside and outside the State, whic h may be aff ected by

the State’s emissions. If emissions from the State are reasonably anticipated to contribute to visibility impairment in Class I areas in other States , the State is required to consult with other State(s) to develop coordinated emission management strategies. In the case where multiple State(s) cause or contribute to impairment of the same Class I area, States are required to obtain their share of the emission reductions needed to meet the reasonable progress goal for the Class I area.

In developing its LTS

, the State should consider:

• the anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions over the period addressed by the LTS;

• measures to mitigate the impacts of construction activiti es;

• source retirement and replacement schedules ;

• smoke management techniques for agricultural and forestry management; and

• enforceability of emissions limitations and control measures

.

The emissions inventory for Iowa projects changes to point, area

, and mobile source inventories by the end of the first implementation period resulting from population growth, industrial, energy and natural resources development, land management, and air pollution control. Iowa considered the minor and major nonattainment n ew source review

programs ( N NSR), prevention of significant deterioration permits (PSD), CAIR, the heavy duty highway diesel rule, the clean air non

- road diesel rule, other on

- road and non

road mobile source programs, operating permits, pertinent new sourc e performance standards (NSPS), national emissions standards for hazardous air pollutants (NESHAP),

associated maximum achievable control technology (MACT) standards, and Integrated Planning Model ( IPM ) 2 results in developing its long

- term strategy.

In a separate notice proposing limited disapproval of the regional haze SIPs of a number of States, including Iowa, EPA noted that these States relied on the trading programs of

2 http://www.epa.gov/airmarkets/progsregs/epa

- ipm/index.html9 CAIR to satisfy the BART requirement and the requirement for a LTS sufficient to

a chieve the State

- adopted reasonable progress goals. (76 FR 82219, December 30, 2011). In that notice, we proposed a limited disapproval of Iowa’s LTS insofar as it relied on CAIR. For that reason, we are not taking action on that aspect of the long

- term strategy in this notice.

In order to mitigate the impact of construction activities, Iowa’s rule on fugitive dust (567 IAC 23.3(2)“c”) state s that reasonable precautions shall be taken to prevent the discharge of visible emissions of airborne dust beyo nd the lot line of the property from which the emissions originated. Iowa also requires minor NSR permits for aggregate processing plants, concrete batch plants, and asphalt plants. Portable aggregate, concrete, or asphalt plants must notify the IDNR 30 da ys before transferring the equipment to a new location to allow for review of the emissions impacts on national ambient air quality standards (NAAQS). The IDNR would notify the portable plant if there are potential adverse impacts on the NAAQS. A more stri ngent emission standard and the installation of additional control equipment would be required if the relocation would prevent the attainment or maintenance of the NAAQS. Iowa determined that no additional measures were needed to mitigate the impacts of co nstruction activities, and EPA agrees with this

determination.

Iowa demonstrated that source retirement and replacement schedules were taken into account, to the extent possible, when developing inputs for the IPM that was used in the CENRAP modeling ana lysis.

Iowa does not have a smoke management program at this time. Iowa notes that t he

CENRAP PSAT modeling indicates that fires in Iowa do not significantly contribute to visibility impairment in Class I Federal areas and

, therefore

, believes that a smo ke management program is not needed for purposes of visibility improvement at this time.

i. Consultation with other States

1. Missouri and Arkansas Iowa participated with the central consultation group, a subset of the CENRAP. This group was coordinated by t he S tates of Missouri and Arkansas. Other participants include d Ohio, Indiana, Illinois, Oklahoma, Texas, Kentucky, Tennessee, FLMs, other RPOs, and tribes. In a letter dated July 23, 2007 (sent by the State of Arkansas and fou nd in Appendix

10 to the SIP ), the central consultation g roup determined that additional reductions beyond existing and proposed controls, through both state and federal requirements, would not be necessary from the State of Iowa in order for the uniform rate of progress to be met at each of the Class I areas in the States of Missouri and Arkansas (HEGL, MING, CACR, and the UPBU).

2. South Dakota

Iowa communicated directly with the State of South Dakota, via letters dated May 31, 2007 and June 18, 2007 (provided in Appendix 10 to the10 S IP) regarding visibility impacts at the Badlands a nd Wind Cave National

Park s

. The State of South Dakota asked the State of Iowa for any analysis

that it conducted to determine the impacts, if any, sources in Iowa may

have on the South Dakota Class I areas

. The State of Iowa responded that source PSAT analysis was available on the CENRAP website titled

“PSAT Viz Tool 27

- April 2007

. ” The State of Iowa explained the analysis showed that sources in the State contributed approximately 1.6% to the

total visibili ty extinction on the 20% worst visibility days in 2018 at the

Badlands and approximately 1.2% to the total visibility extinction on the 20% worst visibility days in 2018 at the Wind Cave National Park and as such was insignificant. The State of Iowa did no t receive a response or request for additional information fr om the State of South Dakota.

3. Oklahoma The State of Iowa also communicated directly with the State of Oklahoma regarding potential visibility impacts of Iowa sources on the Wichita

Mountains Wi ldlife Refuge

. In a letter dated February 25, 2008 (provided in Appendix 10 to the SIP), the State of Oklahoma invited states that had a projected contribution of at least 1 Mm

- 1 visibility impact in 2018 at WIMO to participat e in its consultation process. The letter goes on to determine that, after evaluati ng 2018 modeling projections for the 20% worst visibility days at the Class I area, anthropogenic emissions from the sources in the State of Iowa were not reasonably anticipated to contribute

to visibili ty impairment at the WIMO and that the State of Oklahoma was not requesting that the State of Iowa consider additional emission

reductions.

4. Minnesota In addition to participation in the CENRAP regional planning process, the SIP indicates that Iowa also p articipated in the Midwest Class I area consultation group, coordinated by the S tates of Minnesota and Michigan, which included participation from the S tates of Illinois, Indiana, Michigan, Ohio, and Wisconsin, as well as Tribal lands in the five S tates th at are part of the Midwest Planning Organization (MRPO). The states that comprise the CENRAP, the states that comprise the MRPO, the EPA, the FLMs and

the State of North Dakota participated in the Midwest Class I area consultation group

.

The State of Minn esota determined that the State of Iowa (among other states), via a lett er dated September 19, 2007 , was a significant contributor

to visibilit y impairment at VOYA and BOWA. Attachments provided with

the letter indicated that the State of Minnesota utilize d Lake Michigan Air

Directors Consortium ( LADCO ) trajectory analysis and CENRAP PSAT analysis (for baseline years) to determine if a state contributed 5% or more to visibility impairment at the two Minnesota Class I areas. A contribution

of 5% was consider ed by the State o f Minnesota to be significant. The11 LADCO trajectory analysis estimated contributions from emissions from the State of Iowa to be approximately 7.4% at BOWA an d approximately

10.2% at VOYA. The CENRAP PSAT modeling estimated contributions

f rom emissions from the State of Iowa to be approximately 3.5% at BOWA and approximately 3.8% at VOYA.

In its letter, the State of Minnesota asked the State of Iowa to “...evaluate

further reductions of SO 2 from electric generating units (EGU) in order to

r educe SO 2 emissions by 2018 to a rate that is more comparable to the rate projected for 2018 for Minnesota, approximately 0.2 5 lbs/MM Btu.” The

State of Minnesota also asked the State of Iowa to make a commitment to review, by 2013, the potential emission r eductions that c ould be gained from control of industrial, commercial, and institutional (ICI) b oilers and other point sources (such as reciprocating engines and turbines).

The State of Iowa responded to the State of Minnesota vi a letter dated

November 1 , 2007, communicating that it would not commit to evaluate

further reductions of SO 2 from EGUs because the State was participating

in CAIR and because the State of Iowa had concerns with the State of Minnesota’s interpre tations of the LADCO/Minnesota four

- factor ana lysis for reasonable p rogress. The State of Minnesota used some information

from its four

- f actor analysis as an appendix to its request letter. The State of Iowa considered the State of Minnesota’s cost per dv improvement ($/dv) figures, in a ran ge of approximately $3 billion/dv to $3.3 billion/dv,

to be unreasonable for SO 2 control beyond CAIR for EGUs in the State of Iowa. The State of Iowa also considered the State of Minnesota’s $/dv figures, in a range of approximately $2.8 billion/dv to $3.4 billion/dv, to

be unreasonable for control of ICIs

. Iowa explained that a similar argument could be made for reciprocating engines and combustion engines.

The State of Iowa also questioned the State of Minnesota’s use of the LADCO trajectory analysis to determine significance of emissions from surrounding states because the trajectory analysis was based upon

theoretical air flow and did not account for chemical reactions in the atmosphere , which CENRAP PSAT modeling did. Because the CENRAP PSAT modeling i ndicated that emissions from the State of Iowa contribute less than 5% to impairment at Minnesota

- hosted Class I areas, the State of

Iowa did not consider emissions from sources within its boundaries to be significant ( using the State of Minnesota’s signif icance threshold of 5%).

Iowa determined that additional controls were unsupported at this first stage of the regional haze rule, because Minnesota did not request that

controls be installed on specific sources; did not provide justification on

how such controls would lead to visibility improvement at the Minnesota Class I areas; did not provide documentation or otherwise consult with12 Iowa regarding any specific visibility improvement at the Minnesota Class I areas which would result from controlling Iow a sources; and because of the cost and visibility issues mentioned above. However

, on page 38 of the SIP, the State of Iowa does commit to continued consultation with Minnesota in the future on issues involving regional haze as requested and

warranted.

5. M ichigan The State of Michigan wrote the State of Iowa a let ter, dated October 26,

2007 , stating that it was not asking other states to reduce emissions for purpose of meeting the requirements of the RHR.

In summary, Iowa developed an emissions inventory for 2018 which considered projected changes in point, area, and mobile source emissions, including source retirement and replacements; has a program in place to mitigate the impacts of construction activities; and considered a smoke management program. Th ese programs are fully enforceable and provide for the mitigation of new source impacts through new source permitting programs.

Iowa also consulted with the States which may be impacted by Iowa sources , directly and through the RPO process

. EPA proposes to find that Iowa met the consultation requirements of 40 CFR 51.308 (d)(1)(iv)

.

Iowa ultimately determined that no controls beyond those existing or on the way would

be needed in order for Iowa to address its share of emission reductions for other stat es’ reasonable progr ess goals. EPA agrees with this determination , and proposes to find that Iowa has adequately addressed the LTS requirements of 40 CFR 51.308(d)(3).

d. BART : 40 CFR 51.308 (e)

Section 169A of the CAA directs States to evaluate the use of retrofit controls at certain larger, often uncontrolled, older stationary sources in order to address visibilit y impacts

from these sources. Specifically, the CAA requires that certain categories of existing stationary sources built between 1962 and 1977 p rocure, install, and operate the “best available retrofit technology”, or BA RT, as determined by the State. 3 States are directed to conduct BART determinations for the sources that cause or contribute to any visibilit y impairment in a Class I area.

3 The set of “major st ationary sources” potentially subject to BART are listed in CAA section 169A(g)(7). The 26 source categories are: (1) Fossil

- fuel fired steam electric plants of more than 250 million British thermal units per hour heat input, (2) Coal cleaning plants (ther mal dryers), (3) Kraft pulp mills, (4) Portland cement plants, (5) Primary zinc smelters, (6) Iron and steel mill plants, (7) Primary aluminum ore reduction plants, (8) Primary copper smelters, (9) Municipal incinerators capable of charging more than 250 t ons of refuse per day, (10) Hydrofluoric, sulfuric, and nitric acid plants, (11) Petroleum refineries, (12) Lime plants, (13) Phosphate rock processing plants, (14) Coke oven batteries, (15) Sulfur recovery plants, (16) Carbon black plants (furnace process ), (17) Primary lead smelters, (18) Fuel conversion plants, (19) Sintering plants, (20) Secondary metal production facilities, (21) Chemical process plants, (22) Fossil

- fuel boilers of more than 250 million British thermal units per hour heat input, (23) P etroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, (24) Taconite ore processing facilities, (25) Glass fiber processing plants, and (26) Charcoal production facilities.13 On Jul y 6, 2005 , EPA published the Guidelines for BART Determi nations under the

RHR to assist states in determining which of their sources should be subject to the BART requirements and determin ing appropriate emissions limits for each BART

- subject

source.

In the BART determination process, States must address all significant visibility impairing pollutants. The most significant visibility impairing pollutants are SO 2 , NO

x , and P M. As indicated by the BART Guidelines, a State should use its best judgment in

d etermining whether VOCs, ammonia ( NH 3 ) or ammonia compounds impair visibility in particular Class I areas 4

. Iowa conducted a quantitative analysi s of emissions inventory

data to show that Iowa point source NH 3 and VOC emissions do not cause or contribute to any visibility impairment in any Class I area , as described below

.

Figure 4: Distribution of the 2002 Iowa NH3 emission inventory by source category. Point sources include all Iowa facilities, BART and non

- BART.

4 Appendix Y of 40 C.F.R. Part 51

- States should exerc ise judgment in deciding whether the following pollutants impair visibility in an area :( 4) Volatile organic compounds (VOC), and (5) Ammonia and ammonia compounds. A State should use its best judgment in deciding whether VOC or ammonia emissions from a s ource are likely to have an impact on visibility in an area. Certain types of VOC emissions, for example, are more likely to form secondary organic aerosols than others. Similarly, controlling ammonia emissions in some areas may not have a significant impa ct on visibility. A State need not provide a formal showing of an individual decision that a source of VOC or ammonia emissions is not subject to BART review. Because air quality modeling may not be feasible for individual sources of VOC or ammonia, a stat e should also exercise its judgment in assessing the degree of visibility impacts due to emissions of VOC and emissions of ammonia or ammonia compounds. A state should fully document the basis for judging that a VOC or ammonia source merits BART review, in cluding its assessment of the source's contribution to visibility impairment. 2002 Iowa NH3 Emissions (tons per year)

259640, 98% 57, 0%

3366, 1% 2863, 1%

Onroad Nonroad Point Area14 A simple scale analysis demonstrat es that point source emissions of NH 3 and VOC are insignificant in comparison to o ther sources and source types. Summing all (not just

BART

- eligible sources) 2002 Iowa point source NH 3 emissions yields an emission rate of 3366 tpy. Area source emissions ar e approximately seventy

- seven times higher, at ~260,000 tpy ( Figure 4 ). VOC emissions from Iowa’s BART

- eligible sources comprise only 4% of the total (anthropogenic plus biogenic) 2002 VOC inventory ( Figure 5 ) and are considered insignificant i n terms of visibility impacts. Therefore point

source NH 3 and VOC emissions were not evaluated for visibility impacts.

Figure 5 : Distribution of the 2002 Iowa VOC emission inventory by sourc e category.

To further support this conclusion, the State utilized CENRAP

- performed PSAT modeling sensitivity analyses. These analyses demonstrated that anthropogenic emissions

of VOC and NH 3 did not significantly impair visibility at the Class I areas in the CENRAP or MRPO regions. Thus, although emissions inventories were developed for

NH 3 and VOC, and applicable federal VOC reductions were incorporated into Iowa’s regional haze analyses, Iowa did not evaluate NH 3 and VOC emissions sources for potential controls under BART or for its LTS . Due to the limited improvement source

specific controls would have on visibility improvement at Class I areas in the CENRAP or MRPO regions, EPA agrees with this determination.

In making a BART determination for a fo ssil fuel

- fired generating plant with a total generating capacity in excess of 750 megawatts , a State must use the approach set forth in

the BAR T Guidelines. The BART Guidelines provide five steps toward identifying

BART control for these EGUs.

• Identify al l available retrofit control technologies;

• Eliminate technically infeasible control technologies;

• Evaluate the control effectiveness of remaining control technologies;

• Evaluate impacts and document the results;

• Evaluate visibility impact. 2002 Iowa VOC Emissions (tons per year)

70494, 11%

61455, 10%

73522, 12%

386174, 60% 16824.28418, 3%
22332, 4%

Onroad

Nonroad

Area

Biogenics

Point: BART

Point: Non-BART15 i. BART

- eligible so urces For an emission source to be identified as BART

- eligible, the State used these

cri teria from the BART Guidelines:

• One or more emissions units at the facility fit within one of the 26 categories

listed in the BART Guidelines ;

• The emission unit was in existence on August 7, 1977 and began operation at some point on or after August 7, 1962 ; and

• The limited potential emissions from all emission units identified in the previous two bullets were 250 tons or more per year of any of these visibility

- impairing pollutants: SO 2 , NO

x , or PM 10

.

To identify the sources that met the criteria above, Iowa performed a multi

- step
search and analysis including requiring sources to self identify as BART

- eligible by rule (Iowa Administrative Code 567

- 22.9 Special Requireme nts for Visibility

Protection ) on a form supplied by the State (BART Eligibility Certification Form

#542

- 8125). The State reviewed all in

- house permitting, Title V databases and the

submitted forms to determine if a source met the criteria explained above. This process is outlined in detail in Appendix 9 of the SIP. The twenty seven BART

eligible f acilities are l isted in Table 4. EPA proposes to find that Iowa appropriately identified the BART

- eligible units in the State.

Table 4: Facilities with BART

- eli gible units in the State of Iowa

Source Category Company Name Facility

Number BART Emission Units

Fossil Fuel

- fired

Steam Electric Pla n t Individually Greater

than 250

MMBtu/hour Cedar Falls Utilities 07

- 02

- 005 Unit #7 (EU10, 1A)

Central Iowa Power Coop erative (CIPCO)

– Summit

Lake Station 88

- 01

- 004 Combustion turbines (EU1, EU1G, EU2, EU2G)

Central Iowa Power Cooperative (CIPCO)

– Fair

Station 70

- 08

- 003 Unit #2 (EU2 & EU 2G)

City of Ames

– Steam Electric

Plant 85

- 01

- 006 Boiler #7 (EU2)

Interstate Power and Light

– Burlington 29

- 01

- 013 Main plant boiler

Interstate Power and Light

– Lansing 03

- 03

- 001 Boiler #4 Sixteen units total.

Interstate Power and Light

– ML Kapp 23

- 01

- 014 Boiler #2. Six units total.

Interstate Power and Light

– Prairie Creek 57

- 01

- 042 Boiler #4. Fourteen units total.

MidAmerican E nergy Company

– Council Bluffs 78

- 01

- 026 Boiler #3 (EU003)

MidAmerican Energy Company

– Neal North 97

- 04

- 010 Boiler #1

- 3 (EU001

- EU003)16 MidAmerican Energy Company

– Neal South 97

- 04

- 011 B oiler #4 (EU003)

Muscatine Power and Water 70

- 01

- 011 Boiler #8 Pella Municipal Power Plant 63

- 02

- 005 Boilers #6

- 8

Chemical Process

Plant Equistar Chemicals 23

- 01

- 004 301 emission units Koch Nitrogen Company 94

- 01

- 005 Ammonia vapor flares and primary reformer/auxiliary

boiler. 8 units total. Monsanto Company Muscatine 70

- 01

- 008 Boilers #5

- 7. 57 emission units

total. Terra Nitrogen Port Neal Comp 97

- 01

- 030 Boiler B & auxiliary boiler Petroleum Storage

and Transfer Units with a Total Storage BP

– Bettendorf Terminal 82

- 02

- 024 Truck loading

BP

– Des Moines Terminal 77

- 01

- 158 Truck loading

Portland Cement

Plant Holcim (US) Inc. 17

- 01

- 009 109 emission units

Fossil Fuel

- fired

Boiler ADM 23

- 01

- 006 #7 & 8 boilers. These boilers will permanently shu t down by

9/13/08.

Iron and Steel Mills Bloomfield Foundry, Inc 26

- 01

- 001 18 emission units Griffin Pipe Products Co. 78

- 01

- 012 10 emission units John Deere Foundry Waterloo 07

- 01

- 010 37 emission units Keokuk Steel Casings, A Matrix Metals Company LLC 56

- 01

- 025 67 emission units

The Dexter Company 51

- 01

- 005 Tumblers 5 & 6 Secondary Metal

Production Alcoa, Inc. 82

- 01

- 002 Hot line mill. 87 emissions

units total.

ii. BART

- subject sources Of the twenty seven BART

- eligible facilities, thirteen are fos sil

- fuel fired EGUs, and as such, are subject to CAIR for NO

x and SO 2 . As noted in EPA’s separate notice proposing revisions to the regional haze rule (76 FR 82219, December 30, 2011) a number of S tates, including Iowa, relied on CAIR to satisfy the BART requirements for SO 2 and NO X , in accordance with 40 CFR 51.308(e)(4). Prior to the CAIR remand, the State’s reliance on CAIR to satisfy BART for NO X and

SO 2 for affected CAIR EGUs was approvable and in accordance with 40 CFR 51.308(e)(4). As explained ab ove, we are not proposing to take action in today’s rulemaking on issues associated with Iowa’s reliance on CAIR in its regional haze SIP, including BART for SO 2 and NO

x for EGUs. The PM BART evaluation for

these EGU sources is described in section V.F.2 below.

Iowa used three screening approaches to determine if the fourteen non

- EGU

sources identified in table 4 were subject to BART:17 • Q/d (with "Q" being allowable emi ssions, in tons per year, and "d "
represent ing the distance in km to the nearest Class I area, multiplied by a prescribed constant) ; 5

• a variety of assessments using CAMx photochemical model (a regional scale model) ; and

• an emissions inventory analysis

.

The RHR established thresholds defining the terms “cause” and “co ntribute”. A

source is said to “cause” visibility impairment if its impact is equal to or greater

th an 1.0 dv at any Class I area. A source is said to “contribute” to visibility impairment if its impacts are equal to or greater than 0.5 dv at any Class I area. Although the RHR affords States the opportunity to adopt a more stringent

deminim i s threshold, the State of Iowa chose not to do so. However, for its three

step BART

- subject scre ening analyses, the State did utilize a threshold that considered the number of days a source’s impact was equal to or greater than 0.5 dv. The State chose seven days for this threshold. 6 The State’s “Variegated Protocol in Support of Best Available Ret rofit Technology Determinations

- May 2006” explains that if the State were to find no maximum d elta

- deciview (d dv) values greater than 0.5 dv from any of the three sc reening methods

, it would provide a state

- wide exemption of the BART

- eligible sources involved in the given scenario. Should initial cumulative modeling quantify ddv impacts exceeding 0 .5 dv, the state would refine its analyses. For each BART

- eligible source, information regarding Q/d analyses, CALPUFF model plant evaluation, and CAMx results were assembled and utilized in a weight

- of evidence approach in the final subject

- to

- BART determ ination. If a unit was not clearly identifiable

as either BART

- subject or exempt from the BART determination process, the State provided case

- by

- case discussion.

1. Q/d screening

Table 5 lists each of the fourteen non

- EGU BART

- eligible sources analyzed for Q /d estimates, where “Q” is the sum of NO

x , SO 2 and PM 10 emissions (PM 2.5 direct emission estimates were not available at the time of the calculations were performed by the State) and “d” is the distance

between the source and the nearest Class I area in k m. The Q/d estimates were completed using both actual and potential emissions and were multiplied by three different constants (20 as prescribed by the State of North Carolina, 10 and 5). Iowa used a 1.0 threshold as its Q/d screening

threshold. Note that potential emissions include only BART

- eligible units

5 The method, originally developed by the North Carolina Department of Environment and Natural Resources, is a tool to eliminat e distant, insignificant emission sources from ambi ent assessments submitted under the Prevention of Significant Deterioration (PSD) program. The Q/d method determines a source to be insignificant if the allowable emissions in tons per year (Q) divided by a constant times th e distance in kilometers (d) is greater than a value of 1. For example, North Carolina uses a constant of 20, which was determined empirically. Therefore, a source could be considered insignificant if its emissions divided by 20 times its distance, in km, from the nearest Class I area is less than 1. For this application, for determining exemption from BART, the combined emissions of S0 2 , NO

x , and PM 2.5 of a BART

- eligible unit could be divided by 20 times the distance to the nearest Class I area. If that quotient is less than 1, the sour ce would not be subject to BART. If a source is not found to be exempt under this approach, the CALPUFF screening analysis could still be used for an exemption determination. Page 25196 of 69 FR 2 5183.

6 This is discussed on pages 3 and 11 of the state’s “ Variegated Protocol in Support of Best Available Retrofit Technology Determinations”.18 while actual emissions represent facility wide totals, thus in certain cases actual emissions may exceed potentials.

Based on the six Q/d calculations the state categorized each of the fourteen

non

- EGU BART

- eligible sources into three categories: 1) those sources that clearly exceed the 1.0 threshold, 2) sources well below the 1.0 threshold and 3) tho se sources with mixed results. Table 5 shows that only

ADM

- Clinton and Holcim, Inc. exceed the 1.0 thresh old in nearly each of the six Q/d calculations.

Table 5: Nearest Class I area & Q/d values for non

- EGU BART

- eligible sources

Facility Name Nearest

Class I Distan

ce (km) BART Units Potential Emissions (tpy) Facility Wide Actual Emissions (tpy)

SO 2 NO

x PM 10 Q/20d Q/10d Q/5d SO 2 NO

x PM 10 Q/20d Q/10d Q/5

d Equistar

Chemical MING

531.2 3,883 3,433 258 0.71 1.43 2.85 1 728 52 0.07 0.15 0.29 Koch Nitrogen Company BOWA

615.4 40 1,399 23 0.12 0.24 0.48 0 442 20 0.04 0.08 0.15

Monsanto

Muscatine MING

486.8 4 30 168 81 0.07 0.14 0.28 465 192 8 0.07 0.14 0.27 Terra Nitrogen

Port Neal BADL

487.6 1 916 325 0.13 0.25 0.51 1 461 33 0.05 0.10 0.20

BP

- Bettendorf MING 499.9 0 0 0 0.00 0.00 0.00 0 0 0 0.00 0.00 0.00

BP

- Des Moines HEGL 547.0 0 0 0 0.00 0.00 0.00 0 0 0 0.00 0.00 0.00

Holcim, Inc. BOWA 527.0 28,715 4,738 1,000 3.27 6.54 13.07 3,826 2,813 190 0.65 1.30 2.59

ADM

- Clinton MING 531.9 6,051 2,117 507 0.82 1.63 3.26 6,479 5,003 1,272 1.20 2.40 4.80
Bloomfield Foundry, Inc. HEGL

448.8 136 68 605 0.09 0.18 0.3 6 1 0 22 0.00 0.01 0.01 Griffin Pipe

Products HEGL

563.6 190 235 211 0.06 0.11 0.23 2 88 111 0.02 0.04 0.07
John Deere Foundry

Waterloo BOWA

588.8 0 0 285 0.02 0.05 0.10 9 21 99 0.01 0.02 0.04
Keokuk Steel Casing MING

392.0 11 72 554 0.08 0.16 0.32 4 9 67 0.01 0.02 0.04
The Dexter Company MING

468.9 0 0 541 0.06 0.12 0.23 29 3 112 0.02 0.03 0.06

Alcoa, Inc. MING 501.8 15 400 1,092 0.15 0.30 0.60 2 137 209 0.03 0.07 0.14

A majority of the non

- EGU facilities were well below the 1.0 screening

t hreshold in all six Q/d tests. Eleven facilities, listed in Table 6 , yield Q/d values well below 1.0 at even the most stringent pote ntial to emit Q/5d

evaluation. The State subsequently determined that these sources were unlikely to be considered subject to BART. Iowa indicates, on page 13 of Appendix 9 to the SIP, that this conclusion is further supported through evaluation of the Q/d values using facility

- wide actual emissions. The actual emission Q/5d values average 0.09, with the upper limit at Monsanto Company Muscatine of only 0.27. The State determined that19 these low values suggested any emission reductions would be insignificant

at the nearest Class I area to the source.

Table 6: Non

- EGU BART

- eligible facilities

significant ly below all Q/d screening test s Koch Nitrogen Company

Monsanto

- Muscatine Terra Nitrogen

- Port Neal

BP

- Bettendorf

BP

- Des Moines Bloomfield Foundry, Inc. Griffin Pipe Products John Deere Foundry

- Waterloo Keokuk Steel Casing The Dexter Company
Alcoa, Inc.

Equistar Chemical is the only fa cility listed in Table 5 above where results

are not clear cut

. Considering potential emissions, the Q/20d value is 0.71 with Q/10d and Q/5d exceeding 1.0. Actual emissions reveal that t he most conservative value, Q/5d, remains well below 1.0 at 0.29. Equistar Chemical reported facility wide SO 2 emissions in 2002 at one tpy, with

NOx emissions of 728 tpy. As shown in Table 5, the nearest Class I area receptor is located at Mingo, at a distance of approximately 531 km. The transport distance i n combination with low actual emissions produced the low Q /d value for Equistar Chemical. Under these circumstances, Equistar

Chemical is unlikely to be subject to BART. However, the State considered results from additional analyses, described below, befo re making any BART exemptions based solely on Q/d calculations.

2. Model plant screening

The BART G uidelines indicate that when determining if a source is

BART

- subject, CALPUFF

, or other appropriate models

, can be used to

determine if an individual source is anticipated to cause or contribute to impairment of visibility in Class I areas 7

. The State explains in Appendix 9 to the SIP, and in its Variegated Protocol, that because each BART

eligible unit located within the State was an average of 516 km (with a

m inimum of 392 km) away from the nearest Class I area, it experienced difficulties using the CALPUFF model to determi ne if a unit was BART

subject

. Because of the potential to over

- predict single source impacts when the source is located long

- range distance s from the nearest Class I

7 CALPUFF is a multi

- layer, multi

- species non

- steady

- state puff dispersion model that simulates the effects of time

- and

space

- varying meteorological conditions on pollut ion transport, transformation and removal. CALPUFF can be applied on

scales of tens to hundreds of kilometers. It includes algorithms for sub grid scale effects (such as terrain impingement), as

well as longer range effects (such as pollutant removal due to wet scavenging and dry deposition, chemical transformation, and visibility effects of particulate matter concentrations). http://www.epa.gov/ttn/scram/dispersion_prefrec.htm#c alpuff20 area, the State has flexibility to utilize other methods to determine single

source impacts at Class I areas. The State did use CALPUFF as the modeling tool for its model plant approach described in more detail below.

In the BAR T G uideline s
, EPA describe s a modified approach, using model plants based on representative sources sharing certain

char acteristics that the States may use to simplify the BART determination process either to exe mpt (individually or as a group) those small sources that are not reasonably anticipated to cause or contribute to visibility impairment, or to identify those large sources that clearly should be subject to BART review. The BART guidelines indicate that Stat es could

use the CALPUFF model to estimate levels of visibility impairment

associated with different combinations of emissions and distances to the nearest Class I area. In carrying out this approach, the State could then reflect groupings of specific types of sources with important common

charact eristics, such as emissions, stack heights and plume characteristics, and develop "composite model plants." Based on CALPUFF analyses of these model plants, a State may find that certain types of sources are clearly reasonably anticipated to cause or contr ibute to visibility impairment. Conversely, representative plant analyses may show that certain types of sources are not reasonably anticipated to cause or contribute to visibility impairment. Based on the modeling results, a State could exempt from BART a ll sources that emit less than a certain amount per year and that are located a certain distance from the nearest Class I

area.

For the model plant analysis, the State utilized combined (SO 2 and NO

x ) emission rates of 5,000 tpy and 3,000 tpy per source. A detailed description of the State’s model plant approach and any deviations from the EPA recommended approach is provided in Section 5.2 of Appendix 9

to the SIP.

It should be noted that the State utilized visibility assessment Method 6 8

, and therefo re had to utilize Class I area specific natural background

conditions. The State chose to use the following Class I areas based on

th eir distance from Iowa sources: BADL, BOWA, VOYA, MING, HEGL, ISLE and SENE. Natural background concentrations were extract ed from

the EPA’s Guidance for Estimating Natural Visibility Conditions under the Regional Haze Program

. 9

During the State’s analyses, each model plant simulation required fourteen iterations: two natural background scenarios across seven Class I areas.

8 Monthly f(RH) (increase in the aerosol scattering coefficient with relative humidity) adjustment factors were applied directly to the background and modeled sulfate and nitrate concentrations, as recommended in the BART guidelines.

9 http://www.epa.gov/ttn/oarpg/t1/memoranda/rh_envcurhr_gd.pdf21 R esults for each Class I area assessment were tabulated and ranked individually. Both maximum and 98 th percentile values were considered when determining the levels at which emissions may cause (dv impacts greater than or equal to 1.0) or contribute (dv imp acts greater than or equal to 0.5) to visibility impairment.

The analyses were completed considering the 2002

- 2004 base years. For each year, the model was run using both the emission scenario where the model plant emits 2,500 tpy of SO 2 , 2,500 tpy of NO

x (or 5

, 000 tpy combined), and 50 tpy of PM 2.5 and the emissions scenario where the model plant emits 1,500 tpy of SO 2 and NO

x each (or 3

, 000 tpy combined), and 50 tpy of PM 2.5 . For each scenario, impacts were compared against annually averaged natural back ground conditions and against the 20 percent best natural background conditions. The State counted the number of days in which dv impacts greater than or equal to

0.5 dv were produced. When evaluating the 98 th percentile, the State

utilized a maximum of se ven days of dv impacts exceeding 0.5 dv as a threshold. The State also looked at the maximum dv impacts at each of the

seven Class I areas.

The results of the analysis (given on page 28 and 29 of Appendix 9 to the SIP) showed that the model plant, with 5, 000 tpy of NO

x and SO 2 combined (and 50 tpy of PM 2.5 ) did not yield any dv impacts greater than 0.5 dv at the 98th percentile as compared against annually averaged natural background conditions. In the years 2002 and 2003, a maximum of 5 days exceed the 0. 5 dv impact threshold, occurring at the BADL, likely

due to utilization of the cleaner w estern natural background conditions 10

. During 2004, six days exceed the 0.5 dv impact threshold. The remaining six Class I area evaluations yield counts less than or eq ual to five days with impacts greater than 0.5 dv. Considering individual daily maximum impacts, 2002 values remain near the 0.5 dv level; slightly higher maximum impacts occur in 2003. In 2004 maximum impacts were consistently above 1.0 dv. When compare d against the 20 percent best natural background conditions, each year, for each site, had more than seven days with maximum impacts exceeding 0.5 dv. As expected, maximum individual daily impacts show a corresponding increase versus annually averaged nat ural background conditions.

The results of the model plant analysis with 3,000 tpy of NO

x and SO 2 combined (and 50 tpy of PM 2.5 ) showed that the 98 th percentile is never exceeded, regardless of the natural background scenario. Additionally, at 3,000 tpy NO

x and SO 2 maximum impacts for the years 2002 and 2003, as compared against annually averaged natural background conditions, do

10 Annual average natural background concentrations are not strictly Class I area specific. Alternatively, sites are assigned

one of two datasets: Eastern or Western. Of the seven Class I areas examined within the Iowa domain, all are considered Eastern sites with the exception of the Badlands . Page 23 of Appendix 9 to the SIP.22 not exceed 0.5 dv. The year 2004 does produce impacts above 0.5 dv. Two days above 0.5 dv are modeled for the BADL, and one da y above 0.5 dv are shown for the remaining Class I areas. Consulting the 20% best natural background conditions, maximum daily impacts remain below 0.5 dv for all but SENE in 2002. In 2003, impacts greater than 0.5 dv are found for each site, but occur on no more than two days. Again, 2004 stands out as producing the highest impacts, but the impacts do not exceed the 98 th percentile.

Based upon the above results, the State concluded that any BART

- eligible source that emitted less than 3,000 tpy of combined NO

x , SO 2 and PM 2.5 would likely be exempt from being BART

- subject. At the 3,000 tpy level, evaluation against the stringent 20% best natural background conditions yields no more than five days with dv impacts exceeding 0.5 dv. Utilizing

the emissions data (provided in Table 5 above), the State determined that

eleven of the fourteen non

- EGU BART

- eligible sources would remain well below the 3,000 tpy combined potential to emit. These happen to be the same facilities already identified in Table 6 as being be low the Q/d screening thresholds.

3. CAMx screening

As a final tool in the BART

- subject screening process, the State utilized the CAMx regional modeling system to model cumulative impacts across

all BART

- eligible sources at Class I areas. As set forth in th e BART guidelines, a State may consider exempting all its BAR T

- eligible sources by conduct ing analyses that show that all of th e emissions from BART

eligible sources in t he State, taken together, are not reasonably anticipated

to cause or contr ibute visibi lity impairment. To make such a showing, a State could use CALPUFF or another appropriate d ispersion model to

evaluate the i mpacts of individual sources on down wind Class I areas, aggregating those impacts to determine the collective contribution from all

BART

- eligible s o urces in the State. A Sta te with a sufficiently large

number of BART

- e ligible sources could also make such a showing using a phot o chemical grid model

. 11 The EPA determined that the option of allowing a Sta te to demonstrate that the full grou p of BART

- eligible

sources in the State does not contribute to visibility impairmen t would, by default, satisfy an individual source contribution assessment. As previously discussed the State had concerns with the use of CALPUFF so it elected to use the ph otochemical model CAMx to model cumulative impacts of all BART

- eligible sources across Class I areas.

11 For regional haze applications, regional scale modeling typically involves use of a photochemical grid model that is capable of simulating aerosol chemistry, transport, and deposition of airborne pollutants, including particulate matter and ozone. Regional scale air quality models are generally applied for geog raphic scales ranging from a multistate to the continental scale. Because of the design and intended applications of grid models, they may not be appropriate for BART assessments, so States should consult with the appropriate EPA Regional Office prior to c arrying out any such modeling.23 For its CAMx analysis the State used 2002 as the base year due to the availability of model

- ready emission inventories and the associated

baseline estab lished by one

- atmosphere modeling efforts under the RHR

. A 36 km domain (from LADCO) provided the fundamental horizontal structure. The impacts of a finer resolution 12 km grid were also assessed. The meteorological data driving the CAMx system was derived from the State’s 2002 MM5v363 36/12 km simulation (discussed in greater detail in Appendix 9 of the SIP). The LADCO 2002 Base J and Base K emissions

inventories 12 were used to populate the model. Similar to the Q/d analysis, the State utilized a 0.5 dv imp act as screening a threshold of the CAMx modeling results.

For all cumulative CAMx modeling scenarios, the scenario design involved zeroing the actual point source emissions of BART

- eligible sources on a facility

- wide basis. In zeroing BART

- eligible facil ity emissions, emphasis was placed upon the elevated point source emissions. Point source emissions are divided between two file types in the LADCO CAMx modeling system: elevated point and low point. Elevated point

sources were identified in the emissions modeling stage through implementation of an idealized plume rise calculation. Using each stack’s specific characteristics, a representative plume rise calculation was performed. Stacks yielding a plume rise exceeding a user supplied threshold were assigned to the elevated stack file; all other units were placed in the low point file and treated as an area source. Low point source file modification required complex emissions modeling (while actual low point emission rates are expected to be negligible). Focu sing upon the elevated point sources allowed a scenario to be constructed using a simple post processor. Therefore, the State utilized modeling scenarios that were capable of zeroing elevated stack emissions. The effectiveness of this method is briefly dis cussed in section 6.4.1 of Appendix 9 to the SIP. Again, resolutions included 36 and 12 kilometers. The BART

- eligible

source list included distinctions for CAIR versus non

- CAIR units (in lieu of CAIR as BART).

Table 7: Description of the IDNR BaseK cumul ative modeling scenarios

Scenario Resolution (km) BART Source Emissions Processing Description

K2002ia36b0v2r1 36 All BART source emissions were zeroed out (both EGU and non

- EGU facilities). Only elevated point source emissions were zeroed (low point

e missions were not modified). Emissions were removed facility

- wide (not just BART units). The LADCO LAMB (low, area, mobile, biogenic) emissions files were not modified.

K2002ia36b0v2r2 36 Similar to K2002ia36b0v2r1, except only non

- EGU BART emissions

wer e zeroed. (Again, only elevated point source units were impacted,

12 http://www.ladco.org/reports/rpo/emissions/24 with emissions zeroed facility

- wide.) As above, the LADCO LAMB files

were used.

K2002ia36b0v2r2 12 The same emissions scenario as K2002ia36b0v2r2 was implemented within a 12 km grid throug h flexi

- nesting of the emissions data. 12 km meteorological data was processed independent of the 36 km grid (i.e. the meteorological data was not flexi

- nested).

As outlined in Table 7, scenario k2002ia36b0v2R1 eliminated all elevated point source emi ssions from both EGU and non

- EGU BART

- eligible sources. Maximum values are provided in Table 8 below. Impacts ranged between 2.23 ddv at the BADL and 3.17 ddv at SENE under annually averaged natural background conditions. The number of days registering

an impact greater than or equal to 0.5 ddv ranged between 22 at the BADL and 47 at the SENE. As expected, the impacts increased when compared against the 20% best natural background conditions, ranging from 2.79

ddv at the BADL to 4.41 ddv at the SENE with th e number of days registering an impact greater than or equal to 0.5 ddv between 28 at the BADL and 73 at MING. Based on these results, the State concluded that

in the absence of CAIR

, Iowa BART

- eligible sources would not be eligible for cumulative exclusio n from being subject to BART.

Table 8: Scenario k2002ia36b0v2r1: Class I area maximum impacts

Site Annual Average Natural Background 20% Best Natural Background

Maximum

DDV Number of Days
DDVs ≥0.5 Maximum

DDV Number of Days
DDVs ≥0.5

BADL 2.23 22 2. 79 28

BOWA 2.97 41 4.16 53

HEGL 2.65 36 3.72 71

ISLE 2.70 41 3.72 56

MING 2.34 40 3.32 73

SENE 3.17 47 4.41 63

VOYA 2.40 33 3.41 49

Tabular results from scenario k2002ia36b0v2r2, the scenario with only

non

- EGU emissions modified, are shown in Table 9. In contrast to scenario k200ia36b0v2r1, where impacts greater than 0.5 ddv are common and frequent, only three of the seven sites registered impacts above 0.5 ddv: BOWA, ISLE, and SENE (when considering annual average natural background). In terms of frequency, BOWA and SENE each registered one day with an impact greater than 0.5 ddv. ISLE registered two days with a ddv greater than or equal to 0.5. The maximum impacts predicted under annually averaged natural background conditions ranged from 0.15

ddv at the BADL to 0.64 ddv at the ISLE.25 The evaluation conducted against the 20% best natural background conditions showed that six of the seven Class I areas registered impacts greater than 0.5 ddv. The BADL was the only Class I ar ea under the 0.5

ddv threshold. ISLE again exhibited the highest impact, at 0.92 ddv, with the other five Class I areas at or above 0.53 ddv. The BADL is the only area which did not register an increase in the frequency of ddv impacts greater than 0.5 dv when evaluated against the 20% best natural background conditions, while ISLE exhibited the most variability, with a four day increase. All other areas demonstrate only moderate variability, with one or two additional daily impacts greater than 0.5 ddv.

Table 9: Scenario k2002 ia36b0v2r2: Class I area maximum impacts

Site Annual Average Natural Background 20% Best Natural Background

Maximum

DDV Number of Days
DDVs ≥0.5 Maximum

DDV Number of Days
DDVs ≥0.5

BADL 0.15 0 0.20 0

BOWA 0.62 1 0.91 3

HEGL 0.38 0 0.57 1

ISLE 0.64 2 0.92 6

MING 0.41 0 0.60 1

SENE 0.58 1 0.85 3

VOYA 0.36 0 0.53 2

Table 9 provides the cumulative visibility impacts upon nearby Class I

areas from all non

- EGU BART

- eligible sources. If one considers natural background conditions and maximum impacts, a 0.64 ddv is produced (ISLE). However, a maximum of only two days are of concern. If one considers the 20% best natural background conditions, the maximum impact increases to 0.92 ddv (ISLE), with the frequency of impacts increasing to six days.

In a third run of the model, modeling run k2002ia12b0v2r2

, the State utilized a 12 km grid in place of the 36 km grid. Differences between the 12 and 36 km results (provided in Table 10 with parentheses; positive values indicate the 12 km grid generated greate r visibility impacts) exhibited no pattern. Both increases and decreases in visibility impacts are found among the sites. Assessment of the annually averaged natural background conditions shows the largest change in visibility impacts occurs at VOYA, with impacts increasing 0.17 ddv, from 0.36 to 0.53 ddv. Alternatively, the impacts at SENE are reduced 0.15 dv, from 0.58 to 0.43 dv. The number of days with impacts at or above 0.5 dv fluctuates by no more than one day. As expected, a similar result is produc ed under the 20% best natural background conditions. Considering 20% best natural conditions, the 12 km grid increased the visibility impacts at VOYA by 0.25 dv, while impacts at SENE were reduced by 0.21 dv. The number of26 days in which the 12 km results p ushed the impacts above the 0.5 ddv threshold (versus 36 km data) changed by no more than two days. Given the increased sensitivity of the 20% best natural background conditions to changes in concentrations, the variability is expected.

Table 10: Scenario k2002ia12b0v2r 2: Class I area maximum impacts Values in parentheses indicate the differences as compared to the 36 km results. Calculated as (k2002ia12b0v2r2

- k2002ia36b0v2r2)

Site Annual Average Natural Background 20% Best Natural Background

Maximum

DDV Number of Days
DDVs ≥0.5 Maximum

DDV Number of Days
DDVs ≥0.5

BADL 0.24 (0.09) 0 (0) 0.30 (0.10) 0 (0)

BOWA 0.63 (0.01) 1 (0) 0.93 (0.02) 2 (

- 1)

HEGL 0.52 (0.14) 1 (1) 0.76 (0.19) 3 (2)

ISLE 0.62 (

- 0.02) 2 (0) 0.90 (

- 0.02) 5 (

- 1)

MING 0.34 (

- 0.07) 0 (0) 0.50 (

- 0.10) 1 (0)

SENE 0.43 (

- 0.15) 0 (

- 1) 0.64 (

- 0.21) 2 (

- 1)

VOYA 0.53 (0.17) 1 (1) 0.78 (0.25) 2 (0)

In general, the variability encountered through comparison of the 12 km grid was well within expectations. Whil e ddv changes up to 0.25 dv were shown (VOYA), such a change required only a modest modification in species concentrations. The number of days in which ddv impacts greater than or equal to 0.5 dv occurred showed only minor fluctuations (at most two days at HEGL). The results suggested the 12 km simulations lead to more active chemistry, as expected, but major anomalies between the 12

and 36 km results are not created. In summary, considering a 12 km grid,

emissions from non

- EGU BART

- eligible sources and nat ural background conditions, the maximum impact modeled is 0.63 ddv (BOWA) with a maximum of only two days above the 0.5 ddv threshold (ISLE). Under the 20% best natural background conditions, the maximum impact increases to 0.93 ddv (BOWA), and the maximum frequency of impacts greater than 0.5dv is five days (ISLE). Be c aus e there were impacts greater than the 0.5 dv threshold, the State could not provide a blanket exemption for all non

EGU BART

- eligible sources considering just the results of the CAMx

model ing

. The S tate did not consider these analyses to be definitive so it considered actual emissions of visibility impairing pollutants from the

sourc es evaluated in the modeling. Because e leven of the non

- EGU

BART

- eligible sources (the same eleven as previou sly identified in Table 6) comprise approximately 11% (2,547 tpy of SO2, NOx and PM) of the total of actual emissions (22,911 tpy of SO2, NOx and PM) from all

fourteen non

- EGU BART

- eligible sources, the State determined that these

eleven sources were unlik ely to play a significant role in the cumulative modeled visibility impacts.27 Although Iowa did not strictly follow the G uidelines for exempting a source, specifically with respect to modeling a BART

- eligible source using maximum actual emissions, we belie ve that Iowa’s alternative analysis should result in an acceptable conclus ion to exempt these eleven sources for the following reasons. First

, Iowa’s analysis used both actual emissions on a facility

- wide basis and potential emission s for the BART eligible units. When looking at the actual emissions f acility

- wide, for many of the sources, it was clear that had the maximum actual emissions been modeled using CALPUFF, the results would indicate mini mal visibility impacts. This was apparent when comparing the modeled plant analysis emission inp uts with the actual emissions. In almost all cases the sum of the actual emissions of visibility impairing emissions were significantly less than those used in the model plant analysis. The same is

also true when looking at the potential emissions for many of these

sources. Given that most of these non

- EGU units do not have continuous emission monitoring systems ( CEMS ) that can be used for an accurate

calculation of actual maximum 24

- hour emission rate, using both the

actu al annual emissions facility

- wide and potential emissions for the

BART

- eligible units gives us confidence that these sources can be excluded as BART sources. Second, the Q/d analysis Iowa used provided a good indication of those sources where additional an alysis m ight be warranted. Although we have not specifically relied on the Q/d analysis for our approval of BART exemption s, we do believe it was informative and the use of Q/5d is fairly conservative for this type of an analysis. We

believe that the State reasonably demonstrated that the eleven non

- EGU

BART

- eligible sources (listed in t able 6) are not BART

- subject.

4. Holcim, ADM

- Clinton, and Equistar

Because the Stat e’s multi

- st e p analyses demonstrated that eleven of the

fourteen non

- EGU BART

- eligible sou rces (listed in Table 6) were not

BART

- subject, the remaining discussion of this section will focus on the three remaining non

- EGU BART

- eligible units that could not be easily exempted based on the thresholds established by the State: Holcim,

ADM

- Clinton, and Equistar.

Equistar Chemical’s potential and actual emissions are dominated by VOCs, not SO 2 , NO

x or PM. While potential emissions of SO 2 and NO

x exceed the 5,000 tpy model plant threshold, the actual emissions are far below the 3,000 tpy threshold

– 729 tons per year of NO

x and SO 2 combined. As such, the State determined that Equistar Chemical would not contribute impacts exceeding 0.5 dv, and was therefore not BART

subject. EPA agrees with this determination.

Both Holcim and ADM

- Clinton fail the Q /d and CALPUFF model plant analyses. Almost all Q/d metrics exceed the 1.0 significance level, while

SO 2 and NO

x emissions (potentials and actual emissions) exceed both the28 3,000 and 5,000 tpy scenarios examined with the C ALPUFF model plant application. Th e State decided to look at both ADM

- Clinton and Holcim

on a case

- by

- cas e basis.

As mentioned above, t he State found the uncertainties of using the CALPUFF modeling system for determining single source visibility impacts from sources far removed from Clas s I areas very challenging.

The State decided to use an alternative process, scaling the cumulative modeling impacts according to emission rates. The State utilized the maximum dv impacts from the most relevant CAMx modeling scenario (k2002ia12b0v2r2), at the most stringent 20% best natural background conditions, a value of 0.93 dv to scale actual SO 2 , NO

x and PM emissions

for both sources. The State zeroed out the actual SO 2 , NO

x and PM emissions in the following scenario. If Holcim’s SO 2 , NO

x and PM

emiss ions account for 6,828 tpy of the 22,911 tpy total non

- EGU BART

eligible sources’ SO 2 , NO

x and PM emissions, Holcim’s would acc ount
for 30% of the emissions. If ADM

- Clinton’s SO 2 , NO

x and PM emissions account for 12,755 tpy of the 22,911 tpy total non

- EGU BART

- eligible

sources’ SO 2 , NO

x and PM emissions, ADM

- Clinton would account for 56% of the emissions. The State then scaled the visibility impact

attribut able to Holcim and ADM

- Clinton. If the maximum visibility impact from all non

- EGU BART

- eligible source s was figured to be 0.93 dv, and Holcim was found to contribute approximately 30% to that impairment, it could be estimated that Holcim would contribute approximately 0.28 dv visibility impairmen t (below the 0.5 dv threshold). Using the same method, ADM

- Cl inton was found to contribute approximately 56% to the maximum visibility impairment, or approximately 0.52 dv, above the 0.5 dv threshold. The State found that this additional information supported a determination that Holcim did not

cause or contribute t o visibility impairment at any Class I area, and was

not BART

- subject, however, the same determination for ADM

- Clinton could not be made according to this analysis.

EPA believes the State's approach to the photochemical modeling analysis does not fully account for the non

- linear aspects of photochemical modeling and does not fully acknowledge that modeled impacts will not necessarily be directly proportional to the modeled emissions. However, EPA believes it is unlikely that Holcim will have visibility i mpacts on a Class I area greater than 0.5 dv for the following reasons. First, all modeled sources, including Holcim, are located a significant distance from any Class I area, with Holcim being 527 km from the nearest Class I area. Second, the modeling in puts showed that emissions from Holcim constituted only 30 percent of total emissions from the modeled sources. Third, the maximum modeled impacts from this group of sources at any Class I area using average natural background conditions is 0.64 dv with

a t most 2 days of impacts over 0.5 dv. Fourth, looking at all the maximum29 modeled impacts at all seven Class I areas shows an average maximum impact of 0.44 dv, indicating that no single source is likely the cause for the majority of impacts at any single Class I area. Finally, ADM

- Clinton represents 56 percent of the visibility impairing emissions of the modeled sources and this source's BART eligible units have been permanently shut down, thus EPA anticipates impacts from the remaining group of sources

wo uld have less than a 0.5 dv impact. Based on these factors, EPA believes that State adequately de monstrated that Holcim does not cause or contribute to visibility impairment in any Class I areas , and therefore is not subject to BART.

As discussed previous ly, ADM

- Clinton could not be screened out with any of the three analyses described above. However, at the time the State drafted the SIP, ADM

- Clinton was going through a PSD permitting activity to construct new boilers. In the permit for the new boilers ( P ermit

05

- A

- 314), ADM

- Clinton was required to shut down boilers 1

- 14 no later than 180 days after the startup of the new boilers. 13 This includes the two

BART

- eli gible boilers, numbers 7 and 8. We have confirmed with the

State that these boilers have indeed shut down. In the PSD permit for the new boilers that replaced boilers 7 and 8, the facility was required to install and operate a baghouse, selective non

- catalytic reduction, and limestone injection flue gas desulfurization on the new boiler units (three coal burning and two natural gas; five in total). The construction permit limited the emissions of the replacement boiler units through an annual cap applicable across all five new units. SO 2 emissions are not to exceed 3,629 tpy and NO

x emissions are not to exceed 1,445 tpy. These limits represent best available control technology (BACT) emission rates as required under the PSD program. 14 Because the BART

- eligible boilers were permanently shut down pursuant to an enforceable PSD permit, and the replacement boilers satisfy BACT, the State concluded that ADM

Clinton was not subject to BART. EPA agrees with this determination.

5. EGU BART evaluation for PM Although Iowa presum ed that CAIR satisfied SO 2 and NO

x BART for EGUs, Iowa was still required to evaluate e ach BART

- s ubject EGU for

PM BART . T here is no PM presumptive emission rate for EGUs with a capacity o f 750 MW or greater. The State again relied on its CALPUFF model plant analysis for analyzing EGU PM emissions. Model year 2004 was selected in order to ge nerate maximum impacts (the S tate ’ s analysis showed that 2004 data generated impacts that exceeded 2002 and 2003 data). Two scenarios were completed, using emission rates of 10,000 and 5,000 tpy of PM. No NO

x or SO 2 emissions were modeled. The model plant configuration was modified to reflect idealized EGU stack

13 https://aqbweb.iowadnr. gov/data/23/2301006/05A314P.pdf

14 The applicable State permit numbers are 05

- A

- 313

- P, 05

- A

- 31 4

- P, 05

- A

- 315

- P for the coal

- fired boilers, and 05

- A

- 316

- P,

05

- A

- 317

- P for the natural gas fired boilers.30 parameters, obtained from the EPA’s CALPUFF Analys is in Support of

the June 2005 c hanges to the RHR . Graphical results are given on page 46 of Appendix 9 to the SIP.

No impacts above 0.5 dv were o bserved at any Class I area under annually averaged natural background conditions with PM emissions of 10,000 tpy. Under the 20% best natural background conditions no impacts exceeding

the 98 th percentile occur. Reducing the emissions to 5,000 tpy, no impa cts above 0.5 dv were produced under annually averaged background conditions or 20% best natural background conditions. In terms of scale, Iowa’s largest PM 10 source (an EGU that is not BART

- eligible) emits 3,174 tpy (based on a facility

- wide value)

, appro ximately 36.5% below the emission rate which yielded no visibility impacts. Based upon these results the State concluded, and the EPA agrees, that PM emissions from BART

eligible EGUs in the State of Iowa would not cause or contribute to visibility impairm ent at any nearby Class I area s, and are therefore not subject to BART for PM.

e. Monitoring strategy : 40 CFR 51.308 (d)(4)

Because it does not host a Class I area, Iowa is not required to develop a monitoring strategy for measuring, characterizing, and rep orting regional haze impairment that is representative of C lass I areas within the State. However, Iowa is required to establish procedures by which monitoring data and other information is used to determine the

contribution of emissions from within the St ate to regional haze impairment at Class I

areas outside of the State.

There are two IMPROVE monitoring protocol sites (sites that are not managed directly by IMPROVE (a federal program), but by the operating agency) w hich are operated in

the State. One is located at Lake Viking State Park in southwestern Iowa, and the second is located at Lake Sugema Wildlife Management Area in southeastern Iowa. The monitors began operation in June 2002. Descriptions of these monitoring sites and

methods for data valid ation can be found in Chapter 6 of the State’s Regional Haze SIP. The State has provided a commitment in Chapter 6 of the SIP to maintain the IMPROVE protocol monitoring sites contingent upon continued national funding.

Data from IMPROVE protocol monitors is analyzed by a national laboratory (funded via an interagency agreement between the EPA and the National Park Service) and uploaded by the laboratory into two publicly available databases at http:/ /vista.cira.colostate.edu/improve and http://vista.cira.colostate.edu/views/ . Any supplemental monitoring data from additional monitoring equipment at each site is publicly available at http://www.epa.gov/ttn/airs/airsaqs

.

EPA believes the State’s commitment to utilize data from these sites, or any other EPA

approved monitoring network location, to characterize and model conditions within the

state and to compare visibility conditions in the state to visibility impairment at Class I31 areas hosted by other states , and proposes that Iowa has satisfied the requirements of 40 CFR 51.308(d)(4).

f. Emissions inventory : 40 CFR 51.308 (d)(4)(v)

Iowa provided an inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any Class I area : VOCs, NO

x , SO 2 , PM 2.5 , PM 10 and NH 3

. As required, the inventory include s emissions for a baseline year (2002)

, the mo st recent year for which data are available, and estimates of future year (2018) projected emissions along with a commitment to up date the inventory periodically.

The 2002 point source inventory was derived from the 2002 National Emission Inventory (NEI)

. 15 All other source category emission inventories were developed by CENRAP and its contractors as part o f the development of a baseline inventory for the 2002 modeling inventory

. 16 A summary of the 2002 baseline emissions inventory can be found in Chapter 7 of the SIP. Methodologies for the development of the 2002 emissio ns inventories can be found in a ppendix 7.1 of the SIP.

To estimate the 2018 future year emissions, the State grew the 2002 emissions using the Economic Growth Analysis System (EGAS) 5, MOB ILE 6 and NONROAD vehicle

emissions software. The State also used the IPM to forecast EGU emissions.

As shown in T able 1 2 , the State made a modification to the estimated 2018 SO 2 emissions for the point source EGU source category. In tables 7 and 8, the 2002 and 2018 point source EGU SO 2 emissions are 135,833 and 160,733 tons per year (tpy), respectively. The State was concerned with the accuracy of the 2018 (160,733 tpy) value. CENRAP utilized the “RPO version 2.1.9” IPM (referred to as IPM v2.1.9) pred ictions to generate the 2018 BaseG scenario

, in which total Iowa EGU SO 2 emissions were forecast to be approximately 147,305 tpy. 17 During review of the CENRAP BaseE2 modeling, errors were identified in the 2018 Iowa EGU emissions. Among the

errors, certa in EGU emissions were overestimated when a growth methodology was applied twice, once with EGAS and then again within IPM. Following error identification, corrections were submitted for inclusion in the BaseF (and subsequent BaseG) modeling scenarios. Aft er the corrections, 2018 EGU SO 2 emissions totaled 151,354 tpy. Thus, the State believed the value of 160,733 tpy provided through the emissions inventory report developed by a CENRAP contractor to be inaccurate. 18 The

State found that the corrected EGU S O 2 emissions estimate of 151,354 tpy for 2018 is conservative, given updated results from IPM version 3.0 (discussed in Chapter 11 of the SIP) and Iowa’s participation in CAIR.

15 http://www.epa.gov/ttn/chief/net/2002inventory.html

16 http://www.cenrap.org/html/projects.php

17 The CENRAP modeling emissions inventory consists of several distinct datasets: the 2002 basecase for model performance evaluation, 2002 t ypical, 2018 basecase, and the 2018 control strategy scenario. The inventory was refined through several rounds of CENRAP workgroup review and revision, beginning with the initial BaseA version and culminating in the BaseG inventory.

18 The “Consolidation of Emissions Inventories”

- Pechan Report No. 05.03.002/9500.00332 The EPA believes the 2002 and 2018 statewide emissions inventories and the St ate’s method for developing the 2018 emissions inventory for Iowa meets the requirements of 40 CFR 51.308(d)(4)(v) of the Regional Haze Rule.

Table 11 : 2002 Iowa emissions summary ( tons per year )

VOC NOx PM 2.5 PM 10 NH3 SO2

Ammonia 0 0 0 0 258,915 0

Area 106,712 6,782 11,540 12,182 6.560 3,184

Area Fire 1,120 138 4,681 4,893 0 160 Fugitive Dust 0 0 38,666 193,331 0 0

Off road 63,694 92,595 8,904 9,707 79 9,037

On road 87,392 120,621 1,747 2,373 3,064 3,200

Point EGU 1,075 81,761 4,527 9,424 0 13 5,833

Point Fire 545 33 594 700 48 35

Point NonEGU 41,184 35,812 7,651 17495 3,317 51,836

Road dust 0 0 19,525 127,882 0 0

Wildfire 5 29 218 224 0 8 Biogenic 408,291 25,732

TOTAL 710,018 363,503 98,053 378,211 271,983 203,293

Table 12 : 2018 Iow a projected emissions summary ( tons per year )

VOC NOx PM 2.5 PM 10 NH3 SO2

Ammonia 0 0 0 0 302,012 0

Area 127,849 7,476 10,677 11,510 13,304 3,224

Area Fire 1,120 138 4,681 4,893 0 160 Fugitive Dust 0 0 40,608 203,044 0 0

Off road 37,143 60,210 5,5 82 6,088 101 220

On road 36,404 33,975 708 708 4,225 400

Point EGU 1,802 65,629 9,578 11,232 713 151,354

Point Fire 547 33 596 702 49 36

Point NonEGU 56,714 40,964 10,151 21,737 5,763 42,862

Road dust 0 0 17,712 114,889 0 0

Wildfire 5 29 218 224 0 8 Biogenic 408,291 25,732

TOTAL 669,875 234,186 100,511 375,027 326,167 198,264

g. Periodic SIP revisions and five year progress report : 40 CFR 51.308 (f)

- (h )

I owa acknowledged the requirement under 40 CFR 51.308 (f) to submit periodic progress

reports and regional haze SIP revisions, with the first report due by July 31, 2018

, and

revisions due every ten years thereafter. Iowa committed to meeting this requirement.

I owa also acknowledged the req uirement under 40 CFR 51.308 (g) to submit a progress

rep ort in the form of a SIP revision every five years following this initial SIP submittal.

Iowa committed to submitting the required five year SIP revision by December 17, 2012.33 However, EPA has since advised that five year SIPs are not due until five years after this initial SIP is submitted, meaning that Iowa’s five year progress SIP is not due until March

2013.

The report will evaluate the progress made towards the RPGs for each mandatory Class I area which may be affected by emissions from Iowa sources

. Iowa committed to addressing all the requirements of 40 CFR 51.308 (g), including a review of the changes in the emission inventory, a review of the periodic reporting requirements, and a determination of whether additional action is needed according to 4 0 CFR 51.308(h). Depending on the findings of the five

- year progress report, Iowa commits to taking one

of the following action s :

• Iowa determines that the existing SIP requires no further substantive revision in

order to achieve established goals. Iowa pro vides the Administrator a negative

declaration that further revision of the SIP is not needed at this time.

• Iowa determines that the existing SIP may be inadequate to ensure reasonable progress due to emissions from other states which participated in the r egional planning process. Iowa provides notification to the Administrator and the states that participated in regional planni ng. Iowa collaborates with states through the regional planning process to address the SIP’s deficiencies.

• Iowa determines that the current SIP may be inadequate to ensure reasonable progress due to emissions fro m another country. Iowa provides notification, along with available information, to the Administrator.

• Iowa determines that the existing SIP is inadequate to ensure reasonable progress due to emissions within the State of Io wa. Iowa will revise its SIP to ad dress the plan’s deficiencies.

h. Consultation with Federal Land Managers : 40 CFR 51.308(i)

40 CFR 51.308 (i) requires that States identify in writing to the FLMs the title o f the official to which any FLM ca n submit recommendations. Iowa has met this requirement by identifying Catharine Fitzsimmons, Air Quality Bureau Chief as the cognizant official at IDNR concerning regional haze.

States are also required to provide the F LMs an opportunity for consultation, in person and at least 60 days prior to holding any public hearin g on the SIP (or its revision). Consultations should include the opportunity for the FLMs to discuss their assessment of impairment of visibility in any C lass I area; and recommendations on the development of the RPG and on the development and implementation of strategies to address visibility impairment.

Iowa met this consultation requirement by sending the draft SIP to the FLMs on November 26, 2007, and notifying the FLMs of the public hearing on January 30, 2008.

40 CFR 51.308(i)(3) requires that States provide a description of how they addressed any comments provided by the FLMs. Iowa has provided this in a ppendix 2.1 of the SIP. EPA

believes that Iowa adequately responded to the comments received from the FLMs

.34 Finally, regional haze SIPs must provide procedures for continuing consultation between the State and FLMs on the implementation of 40 CFR 51.308, including development and

review of SIP revis ions and 5

- year progress reports, and on the implementation of other programs having the potential to contribute to impairment of visibility in Class I areas.

Iowa has committed to continuing to coordinate and consult with the FLMs during the development o f future progress reports and plan revisions, as well as during the implementation of programs having the potential to contribute to visibility impairment in the mandatory Class I Federal areas.

Iowa currently notifies the appropriate FLM in writing of p roposed major source or major modifications that may affect a Class I area and requires applicants to submit ambient impact assessments for Class I areas consistent with the Prevention of Significant

Deterioration (PSD) regulatory requirements for the revi ew of impacts on Class I areas, and plans to continue his practice in the future.

Iowa plans to continue to utilize the RPOs as the primary mec hanism for consultation

with the FLMs. Should the RPO structure disappear, I owa has committed to meeting

these c onsultation requirements.

We propose that Iowa has satisfied the requirements of 40 CFR 51.308 (i).