EPA’S Proposal on the Oklahoma 

and Texas Regional Haze and 

Visibility Transport SIPs and FIPs

January 13, 2015, Austin, Texas

January 15, 2015, Oklahoma City, Oklahoma
Preliminaries
What’s a SIP?

• The State Implementation Plan (SIP) shows how a 

state will meet federal CAA requirements

• SIPs are basically legally enforceable documents 

that state governments develop to address federal 

air quality requirements

• SIPs include planning documents and regulations 

that States intend to use to address, as here, 

visibility and regional haze
How Can I Have Input to the SIP Process ?

• OK and TX submitted regional haze SIPs to us for 

review

• We propose to partially approve & partially 

disapprove those SIPs, and implement FIPs

• We will hold two hearings and you can provide 

comments until April 20, 2015

• We will carefully consider those comments 

• We will issue a final decision in the FR, containing 

our response to comments
Regional Haze

• Regional haze is visibility impairment caused by air 

pollution from numerous sources located over a 

wide geographic area

• Caused mainly by sulfates, nitrates, organic 

carbon, black carbon, and wind-blown soil

• Particles absorb/scatter light – impairing visibility

• Sources include major and minor stationary 

sources, mobile sources, and area sources

• Goal of the regional haze program is to improve 

visibility at Class I areas

Why Did We Evaluate TX and OK Together?

• We explain in our 2011 OK proposal we did 

not take action on OK’s RPGs because we 

first had to review the TX RH SIP

• The TX and OK RH SIPs document that the 

impacts of sources in TX are several times 

greater than the impact from OK’s own 

point sources
Texas Impacts on Wichita Mountains, 2018

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

9.0%

10.0%

11.0%

12.0%

13.0%

14.0%

15.0%

16.0%

17.0%

18.0%

19.0%

20.0%

21.0%

22.0%

23.0%

24.0%

25.0%

26.0%

27.0%

28.0%

% of total extinction to 2018 Deciview Haze Index at WIMO (CENRAP PSAT 

results)

Boundary Condition

Initial Concentration

SOAB

SOAA

Non-EGU Point (Tx only)

EGU Point (Tx only)

Area

Non-Road Mobile

O n-Road Mobile

Natural

Low-Level Point

Elevated Point

2018 Total Light Extinction: 75.56 Mm-1

TX Non-EGU point, 6.3%

TX EGU point, 7.7%

OK point, 3.9%

Percent Extinction Source: CENRAP-2007

(back) 8
Summary Of Our Regional Haze Proposal

• Disapprove Oklahoma’s Reasonable Progress Goals 

• Disapprove Texas’ calculation of natural visibility at its 

two Class I areas – Big Bend and the Guadalupe 

Mountains

• Disapprove Texas’ Reasonable Progress Goals for its 

Class I areas

• Disapprove Texas’ long-term strategy for its Class I areas 

and for the Wichita Mountains in Oklahoma

• Promulgate a Federal Implementation plan to control 

15 units, located at 8 coal-fired power plants
(back)
Summary of Our Interstate Transport of 

Visibility Impairing Pollution Proposal

• Basic requirement:

Ensure air pollution sources in TX don’t 

interfere with other states’ measures to 

protect visibility 

• TX intended that its regional haze plan satisfy 

this requirement

• We believe our proposed actions on TX’s 

regional haze plan will satisfy this 

requirement
What Are The Details Of Our Proposed FIPs?

• Sulfur Dioxide (SO2) emission limits at fifteen units, located 

at eight coal-fired power plants

• Based on 7 SO2scrubber retrofits, 7 SO2scrubber upgrades, 

and 1 maintenance of a scrubber upgrade

• SO2Limits based on 30 boiler operating day average

• Compliance in 5 years for scrubber retrofits, 3 years for 

scrubber upgrades, and 1 year for the scrubber 

maintenance

• Revised natural conditions for Big Bend and the Guadalupe 

Mts

• Revised RPGs for the Wichita Mountains, Big Bend and the 

Guadalupe Mts
How Did We Reach Our Proposed FIP 

Determination?

• Conducted a Q/D analysis on all facilities in Texas, 

reducing potential control candidates from over 1,600 

facilities to 38 facilities

• Used CAMx photochemical modeling to investigate the 

visibility impacts of individual facilities

• Also investigated the visibility improvement if SO2

scrubbers or Dry Sorbent Injection (DSI) were installed

• Analyzed the cost of SO2 scrubbers and DSI, and 

scrubber retrofits

• Selected a control set that we believe represents the 

best combination of cost effectiveness and visibility 

benefit
Other Parts of Our Proposed FIPs

•Natural conditions calculations for Big 

Bend and the Guadalupe Mountains

• Calculation depends on all sources of natural 

visibility impairment

• Texas assumed all coarse mass and fine soil was 

natural

•Reasonable Progress Goals (RPGs) for the 

Wichita Mountains, Big Bend and the 

Guadalupe Mountains
Other Benefits of Our Proposal 

• Sulfur dioxide (SO2) is one of a group of highly reactive gasses 

known as “oxides of sulfur.” The largest sources of SO2

emissions are from fossil fuel combustion at power plants 

(73%) and other industrial facilities (20%)

• In 2010, EPA strengthened the SO2 National Ambient Air 

Quality Standard for SO2

• SO2can cause adverse respiratory effects include narrowing of 

the airways which can cause difficulty in breathing and 

increased asthma symptoms

• We estimate that if finalized as proposed, our plan will reduce 

the SO2 emitted by Texas sources by over 230,000 tons per 

year
What Are The Next Steps?

• We’ll break into informal groups for questions

• If you’d like to comment during the hearing 

that follows this open house, please see the 

folks who are registering commenters 

• We’ll hold our hearing

• We’ll further collect comments

• Our target date for a final decision is 

9/4/2015
Submit your comments, identified by Docket No. EPA-R06-OAR2014-0754, by one of the following methods:

• Federal e-Rulemaking Portal: http://www.regulations.gov.

• E-mail: R6_TXOKRegionalHaze@epa.gov.

• Mail: Mr. Guy Donaldson, Chief, Air Planning Section (6PD–L), 

Environmental Protection Agency, 1445 Ross Avenue, Suite 

1200, Dallas, Texas 75202-2733.

• Hand or Courier Delivery: Mr. Guy Donaldson, Chief, Air 

Planning Section (6PD–L), Environmental Protection Agency, 

1445 Ross Avenue, Suite 700, Dallas, Texas 75202-2733. Such 

deliveries are accepted only between the hours of 8 a.m. and 

4 p.m. weekdays, and not on legal holidays. Special 

arrangements should be made for deliveries of boxed 

information.

• Fax: Mr. Guy Donaldson, Chief, Air Planning Section (6PD–L), 

at fax number 214-665-7263.
(The following slide is jumped to from 

another slide within the presentation)
Our 

Proposed 

SO

2

Emission 

Limits

Unit

Proposed SO

2 Emission Limit 

(lbs/MMBtu)

Scrubber Upgrades

Sandow 4 0.20

Martin Lake 1 0.12

Martin Lake 2 0.12

Martin Lake 3 0.11

Monticello 3 0.06

Limestone 2 0.08

Limestone 1 0.08

San Miguel 0.60

Scrubber Retrofits

Big Brown 1 0.04

Big Brown 2 0.04

Monticello 1 0.04

Monticello 2 0.04

Coleto Creek 1 0.04

Tolk 172B 0.06

Tolk 171B 0.06

(back)