BART TSD - Texas 

Prepared by: 

Erik M. Snyder 

EPA Region 6 

Dallas, TX 

November 2014 
Page i 

EPA Texas’ BART Analysis TSD 

Table of Contents

GLOSSARY OF ACRONYMS .......................................................................................................... ii

A. Best Available Retrofit Technology (BART) Requirements: 40 CFR 51.308(e) ....................... 1

B. BART Eligible Source Identification: 40 CFR 51.308(e)(1)(i) .................................................. 2

Texas Source Survey ................................................................................................................... 4

C. Determination of Sources Subject to BART .............................................................................. 15

C-1 Cumulative Screening Modeling Using CAMx PSAT and Source Grouping ........................ 15

Modeling Approach .................................................................................................................. 16

Procedures For VOC and PM Emissions BART Screening Analysis ...................................... 22

VOC SCREENING ANALYSIS .............................................................................................. 34

Inert Primary PM Screening Analysis ...................................................................................... 35

C-2 Model Plant Screening Approach .......................................................................................... 58

NOX and SO2 Model Plant Approach and Screening ............................................................... 59

PM Model Plant Approach and Screening................................................................................ 63

EPA SUMMARY ..................................................................................................................... 64

D. Single Source Analysis ............................................................................................................. 67

D-1 CALPUFF Modeling ............................................................................................................. 67

CALPUFF Modeling Using CENRAP with No-OBS CALMET data ..................................... 67

CALPUFF Modeling Using Refined CALMET with OBS (pursuant to TCEQ refined 

CALPUFF modeling protocol) ................................................................................................. 70

SUMMARY .............................................................................................................................. 73

D-2 Source Specific CAMx Modeling ......................................................................................... 76

E. Post-BART Emissions Reductions/Removal of Facilities ........................................................ 78

F. Summary ................................................................................................................................... 81
Page ii 

EPA Texas’ BART Analysis TSD 

GLOSSARY OF ACRONYMS 

BAND Bandelier 

BART Best Available Retrofit Technology 

BIBE Big Bend 

bnatural Clean Natural Conditions 

BOAP Bosque del Apache 

BRET Breton 

bsource Total light extinction due to a source 

CAA Clean Air Act 

CACR Caney Creek 

CAIR Clean Air Interstate Rule 

CALPUFF California Puff Model 

CAMx Comprehensive Air Quality Model with extensions 

CCRS Coarse Crustal particulate matter 

CENRAP Central Regional Air Planning Association 

CMAQ Community Multiscale Air Quality Modeling System 

CPRM Coarse other Primary particulate matter 

del-dv change in deciview (delta-deciview) 

dv deciviews 

EC Elemental Carbon 

EGU Electric Generating Units 

EPA Environmental Protection Agency 

f(RH) Relative Humidity adjustment factor 

FCRS Fine Crustal particulate matter 

FLAG Federal Land Managers Air Quality Related Values Workgroup 

FLM Federal Land Manager 

FPRM Fine other Primary particulate matter 

FR Federal Register 

GREASD Greatly Reduced and Simplified Dynamics 

GRSA Great Sand Dunes 

GUMO Guadalupe Mountains 

HEGL Hercules-Glade 

Hg Mercury 

HI Haze Index 

IMPROVE Interagency Monitoring of Protected Visual Environments 

IRON Incremental Reactions for Organics and Nitrogen Oxides 

km Kilometers 

MEVE Mesa Verde 

MING Mingo

Mm-1 Inverse Megameters 

MRPO Midwest Regional Planning Organization 

MW Megawatt 

NH4 Ammonium 

NO3 Particulate Nitrate

non-EGU Non-Electric Generating Unit 
Page iii 

EPA Texas’ BART Analysis TSD 

NOx Nitrogen Oxides 

NSR New Source Review 

OC Organic Carbon 

OMC Organic Matter Carbon 

OSAT Ozone Source Apportionment Technology 

PGM Photochemical Grid Model 

PiG Plume-in-Grid 

PLUVUE Plume Visibility Model 

PM Particulate Matter 

PM10 Particulate Matter with aerodynamic diameters less than 10 microns 

PM2.5 Particulate Matter with aerodynamic diameters less than 2.5 microns 

PNO3 Particulate Nitrate 

POA Primary Organic Aerosol 

PSAT Particulate Matter Source Apportionment Technology 

PSD Prevention of Significant Deterioration 

PSO4 Particulate Sulfate 

QAPP Quality Assurance Program Plan 

Q/D Emissions of source / distance to nearest Class 1 area 

RH Relative Humidity 

RHR Regional Haze Rule 

RPO Regional Planning Organization 

SACR Salt Creek 

SAPE San Pedro Parks 

SIP State Implementation Plan 

SMOKE Sparse Matrix Operator Kernel Emissions 

SO2 Sulfur Dioxide 

SO4 Sulfate

SOA Secondary Organic Aerosol 

TCEQ Texas Commission on Environmental Quality 

TIP Tribal Implementation Plan 

tpy tons per year 

UARG Utility Air Regulatory Group 

UPBU Upper Buffalo 

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VOC Volatile Organic Compounds 

WEMI Weminuche 

WHIT White Mountain 

WHPE Wheeler Peak 

WHRI White River monitor considered a surrogate for Flat Tops, Maroon

Bells-Snowmass, West Elk, and Eagles Nest

WIMO Wichita Mountains 

WRAP Western Regional Air Partnership 
Page iv 

EPA Texas’ BART Analysis TSD 
Page 1 

EPA Texas’ BART Analysis TSD 

A. Best Available Retrofit Technology (BART) Requirements: 

40 CFR 51.308(e) 

Best Available Retrofit Technology (BART) requirements for regional haze visibility impairment. Texas 

must submit a SIP containing emission limitations representing BART and schedules for compliance with 

BART for each BART eligible source that may reasonably be anticipated to cause or contribute to any 

impairment of visibility in any mandatory Class I Federal area, unless it demonstrates that an emissions 

trading program or other alternative will achieve greater reasonable progress toward natural visibility 

conditions. 

Notes: The evaluation of whether the RH SIP contains “adequate emission limitations representing BART 

and schedules for compliance with BART for each BART eligible source that may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal 

area” is conducted within different modeling approaches to screen groups or individual sources as 

further discussed below for each BART eligible source based on visibility impacts. 

40 CFR 51.308(e)(2) – (3) concerning the use of a trading program or other alternative to BART are 

not applicable to this SIP. 
Page 2 

EPA Texas’ BART Analysis TSD 

B. BART Eligible Source Identification: 40 CFR 51.308(e)(1)(i) 

Texas must submit a SIP containing a list of all BART-eligible sources within the State. 

Note: This section is intended to cover the general question of whether the state identified which sources 

were subject to BART. Subsequent sections treat this determination in more detail. 

State Submittal 

TCEQ’s BART rule adopted on January 10, 2007 (TCEQ RH Appendix 9-2: Texas BART Rule – TAC 

Title 30 Part 1 Chapter 116 Subchapter M), identifies potentially affected sources as those: 

• belonging to one of 26 industry source categories; 

• having the potential to emit (PTE) 250 tons per year (tpy) or more of any visibilityimpairing pollutant; and 

• not operating prior to August 7, 1962, and in existence on August 7, 1977 

TCEQ followed EPA’s BART Guidelines that the state was not required to make a determination of BART 

for SO2 or NOX if a BART-eligible source has the PTE less than 40 tons per year of such pollutant(s) or less 

than 15 tons per year for PM10. We have listed the 26 BART categories for reference: 

1. Fossil-fuel fired steam electric plants of more than 250 million British thermal units (BTU) 

per hour heat input, 

2. Coal cleaning plants (thermal 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 tons 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 BTUs per hour heat input, 

23. Petroleum 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. 
Page 3 

EPA Texas’ BART Analysis TSD 

In their submittal Texas has made the determination that participation in CAIR is equivalent to BART. 

This exempted EGUs subject to CAIR requirements from a BART analysis for SO2 and NOx. As of the 

date of this SIP revision by TCEQ in 2009, CAIR remained in effect until replaced by an EPA rule 

consistent with the D.C. Circuit Court of Appeals’ remand of CAIR back to EPA. Based on this 

premise TCEQ developed their SIP and submitted it based on EPA’s prior determination that EGUs 

subject to the cap and trade system established by CAIR did not have to be evaluated for BART for SO2 

and NOx. On June 7, 2012, EPA issued a limited disapproval of the Texas regional haze SIP based on 

deficiencies arising from the State’s reliance on CAIR to meet certain regional haze requirements. In 

the same rulemaking, EPA found that CSAPR, like CAIR, provides for greater reasonable progress 

towards the national goal than would BART (77 FR 33641). The docket for this earlier EPA limited 

disapproval of Texas’s regional haze SIP may be found at Docket ID No. EPA-HQ-OAR-2011-0729. 

In our Federal Register Notice for this proposed rulemaking, we explain that at this time we are 

proposing a FIP to replace Texas’s reliance on CAIR with reliance on the trading programs of CSAPR 

as an alternative to BART for SO2 and NOX emissions from EGUs in the regional haze plan for Texas. 

If EPA’s proposed FIP concerning CSAPR for BART is finalized, EGUs in Texas subject to CSAPR 

requirements will continue to be exempt from a BART analysis for SO2 and NOx 

The TCEQ has also adopted the model plants approach, or option 2, developed by the EPA 

(500tpy/50 km and 1000 tpy/100 km); this is an approach for using model plants to exempt 

individual sources with common characteristics (70 FR 39162-3). TCEQ modified the EPA 

approach to use reported actuals. Sources which meet this model plant exemption are considered 

not to be negatively impacting visibility at Class I areas and are therefore not required to 

complete a BART analysis. 

The TCEQ manages the emissions and emissions-related data that is reported annually by sources in the 

State of Texas Air Reporting System (STARS). TCEQ used the STARS data to determine which 

sources were potentially BART- eligible. This database does not store any permit related information 

such as build dates or permitted allowable emission levels. As a result of these database limitations the 

TCEQ surveyed companies regarding their potential to emit and construction dates in order to complete 

the initial BART determination (TCEQ RH Appendix 9-3: A Sample Survey). 

   
Page 4 

EPA Texas’ BART Analysis TSD 

Texas Source Survey 

Each of the 26 BART source categories were addressed for Texas. The Standard Industrial Codes 

(SIC) as well as the applicable Source Classifications Codes (SCC) were identified by TCEQ staff 

using the 26 applicable source categories listed in Section III (H) of the 40CFR Part 51, Regional Haze 

Regulations. The initial survey population was based on this SIC/SCC list only. 

As provided for in the EPA guidance document for BART, the TCEQ chose to adopt a model plant

analysis to reasonably eliminate smaller sources of NOX and SO2 emissions which were distant from a 

Class I area. The EPA guidance provides exemption of sources from consideration: if their actual 

emission of NOX or SO2 (or combination of NOX and SO2) were less than 500 tpy, as long as they were 

located more than 50 kilometers (km) from any Class I area; sources were also exempted if their 2002 

emissions of NOX or SO2 (or combination of NOX and SO2) were less than 1,000 tpy as long as they 

were located more than 100 km from any Class I area. The TCEQ reduced the emission threshold to 

750 tpy for sources greater than 100 km and 375 tpy for sources greater than 50 km to capture sources 

that might not have met EPA’s threshold based only on their 2002 actual emissions levels. TCEQ used 

75% of EPA’s model plant tpy emissions because they did not have a good database of potential 

emissions and only used one year of actual emissions. Given their distance from Class I areas, the 

relatively low emissions from the screened out sources are unlikely to significantly impact visibility at 

those areas. 

TCEQ supported the 75% factor based on an estimate by TCEQ staff that the actual emissions are 

typically 80 percent of the permitted amount. Using this estimate, TCEQ also assumed that companies 

with actual volatile organic compounds (VOC) emissions of 200 tpy would reasonably have a 

permitted potential to emit of 250 tpy. Companies with the applicable source categories and actual 

emissions at their sites of 200 tpy or more of VOC or PM10 were also asked to complete TCEQ’s 

initial BART survey. TCEQ noted that in 2002, PM2.5 data were collected but a review of the STARS 

database indicated that some companies did not fully report fine particulate matter until later 

inventories. As allowed by the BART guidelines, TCEQ chose to use PM10 as a surrogate in order to 

fully capture sources of particulate matter. 

TCEQ used a county level distance screen to avoid removing sources that barely exceeded distance 

calculations. If any portion of the county was within the applicable distance to the nearest Class I 

area, then all the sites within that county were considered within the applicable distance. TCEQ 

also surveyed all BART category sites within counties that were within 50 km of a Class I area. The 

Class I areas considered for the Texas screening included the Guadalupe Mountains, Big Bend, 

Carlsbad Caverns, Wichita Mountains, Caney Creek, Breton Island, and Salt Creek. 

Using the different approaches to screening the STARS database, TCEQ identified 254 sites/facilities 

(approximately 12 percent of the 2,165 sources in the 2002 STARS emissions inventory) as potentially 

BART-eligible based on distance and actual emissions. This list of 254 sources did not include any screening 

for year of construction (initial operation) or reconstruction dates. The survey was sent to these 254 sites to 

ask for site representatives to help in identifying construction or reconstruction dates and whether the PTE of 

the BART-eligible equipment exceeded 250 tpy. 

TCEQ provided an emission summary that contrasted the total 2002 actual emissions from the 254 

sources with the state total emissions from facilities in the STARS database. We have included the 

table as Table B-1: Emissions from Companies Surveyed as a Percentage of State Total Point Source 

Emissions. Sources emitting a large percentage of the actual emissions in the state were in the survey 
Page 5 

EPA Texas’ BART Analysis TSD 

population. Emissions covered in the survey ranged from 61.7 percent of the 2002 VOC inventory to 

97.7 percent of the SO2 inventory. This analysis supports that they surveyed a very large share of the 

facilities in Texas 

Table B-1: Emissions from Companies Surveyed as a Percentage of State Total Point

Source Emissions

Source Emissions (tpy)

PM10 SO2 NOX VOC

BART Survey 49,638 786,274 467,534 95,442 

2002 State Total 66,064 805,133 601,447 154,665 

TCEQ sent the surveys to 254 companies. TCEQ used a two-step process in the survey. 

Companies were first asked to identify if they have any equipment built or reconstructed 

during the applicable time period or if the PTE of their site were less than 250 tpy. TCEQ 

concluded that companies that did not have BART applicable equipment based on low 

emissions or construction dates were not asked to supply any further information and were 

considered not BART-eligible. 

If the site did possibly have BART applicable equipment, the survey asked them to complete a 

detailed survey of all operating and idle equipment at each site. The detailed survey asked 

whether each piece of equipment at the site was built or reconstructed between the applicable 

dates. The companies were asked if the PTE of their BART-eligible equipment exceeded the 

250 tpy threshold for the applicable emissions. Any source with a PTE from equipment built 

during the applicable period was considered BART-eligible. 

Based on results from the surveys completed by potentially BART-eligible sources and 

submitted to the TCEQ in 2005, 120 sources were initially identified as BART-eligible. Table 

B-2: BART- Eligible Sources Based on Results of TCEQ Survey (TX RH Table 9-2) includes the 

sources that TCEQ determined to be BART-eligible. Table B-2 also includes six additional 

sources identified by TCEQ as BART eligible during the development of their SIP (Numbers 

121-126) 

TCEQ also compiled a Table with the distances to different Class I areas within Texas and in 

areas surrounding Texas that is being included as Table B-3 below. 

EPA Findings 

We find that TCEQ has adequately identified all sources subject to BART within the 

State. 

   
Page 6 

EPA Texas’ BART Analysis TSD 

Table B-2: BART- Eligible Sources Based on Results of TCEQ Survey (TX RH Table 9-2) 

No. Account Source Regulated Entity SIC 

1 AC0017B Abitibi Consolidated Corp RN100220110 2621 

2 TG0044C AEP Texas RN101531226 4911 

3 CD0013K AEP Texas Central Company RN102560687 4911 

4 NE0024E AEP Texas Central Company RN100642040 4911 

5 NE0026A AEP Texas Central Company RN100552181 4911 

6 JI0030K AEP Texas North Company RN100215557 4911 

7 CB0003M Alcoa Alumina & Chemicals RN100242577 2819 

8 MM0001T Alcoa Inc RN100221472 3334 

9 HT0011Q Alon USA Lp RN100250869 2911 

10 ED0034O Ash Grove 

(Formerly North Texas Cement) 

RN100225978 3241 

11 HG0558G Atofina Chemicals Inc RN100209444 2869 

12 BL0021O BASF Corporation RN100218049 2869 

13 GB0001R BP Amoco Chemical Company RN102536307 2869 

14 GB0004L BP Products North America In Texas RN102535077 2911 

15 GH0003Q Cabot Corporation RN100221761 2895 

16 BG0045E Capitol Cement Div Capitol RN100211507 3241 

17 GH0004O Celanese Chemical RN101996395 2869 

18 MH0009H Celanese Limited RN100258060 2869 

19 ED0011D Chaparral Steel Midlothian RN100216472 3312 

20 BJ0001T Chemical Lime Ltd RN100219856 3274 

21 HG0310V Chevron Phillips Chemical RN103919817 2869 

22 BL0758C Chevron Phillips Chemical RN100825249 2869 

23 HW0013C Chevron Phillips Chemical Co RN102320850 2869 

24 NE0027V Citgo Refining & Chemicals RN102555166 2911 

25 BG0057U City Public Service RN100217975 4911 

26 BG0186I City Public Service RN100217835 4911 
Page 7 

EPA Texas’ BART Analysis TSD 

27 HW0018P Conoco Phillips (Formerly Phillips 66) RN102495884 2911 

28 CR0020C Copano Processing LP RN101271419 1321 

29 AB0012W DCP 

(Formerly Duke Energy Field Services) 

RN100218684 1321 

30 HW0008S Degussa Engineered Carbons RN100209659 2895 

31 HGA005E DOW RN104150123 2869 

32 HG0126Q DOW RN100227016 2869 

33 CI0022A Dynegy Midstream Services RN100222900 1321 

34 HH0042M Eastman Chemical Company RN100219815 2869 

35 HG0218K E.I. Dupont de Nemours & Co RN100225085 2869 

36 OC0007J E.I. Dupont de Nemours & Co RN100542711 2869 

37 EE0029T El Paso Electric Co RN100211309 4911 

38 TH0004D Electric Utility Dept RN100219872 4911 

39 CG0012C Enbridge Pipelines RN102166964 1321 

40 MQ0009F Entergy Gulf States Inc RN100226877 4911 

41 OC0013O Entergy Gulf States Inc RN102513041 4911 

42 BL0113I Equistar RN100218601 2869 

43 BL0268B Equistar Chemicals LP RN100237668 2821 

44 HG0033B Equistar Chemicals LP RN100542281 2869 

45 HG0228H Exxon Chemical Co RN102212925 2869 

46 JE0065M Exxon Mobil Chemical Co RN100211903 2821 

47 HG0229F ExxonMobil Chemical Co RN102574803 2869 

48 HG0232Q ExxonMobil Corp RN102579307 2911 

49 JE0067I ExxonMobil Oil Corp RN102450756 2911 

50 NE0120H Flint Hills Resources RN102534138 2911 

51 NE0122D Flint Hills Resources LP RN100235266 2911 

52 JE0052V Huntsman Corporation RN100219252 2869 

53 JE0135Q Huntsman Petrochemical Corp RN100217389 2869 

54 EB0057B Huntsman Polymers RN101867554 2869 

55 BL0002S INEOS Olefins & Polymers RN100238708 2869 
Page 8 

EPA Texas’ BART Analysis TSD 

56 CG0010G International Paper Co RN100543115 2621 

57 OCA002B Invista RN104392626 2869 

58 VC0008Q Invista 

(Formerly Du Pont De Nemours) 

RN102663671 2869 

59 WE0005G Laredo Power RN100213909 4911 

60 MB0123F Lehigh Cement Company RN100218254 3241 

61 NE0025C Lon C Hill Power RN100215979 4911 

62 BC0015L Lower Colorado River Authority RN102038486 4911 

63 FC0018G Lower Colorado River Authority RN100226844 4911 

64 HG1575W Lyondell Chemical RN100633650 2869 

65 HG0048L Lyondell Citgo Refining RN100218130 2911 

66 GB0055R Marathon Ashland Petroleum RN100210608 2911 

67 HH0019H NORIT Americas Inc RN102609724 2819 

68 GB0037T NRG Texas (Formerly Texas Genco LP) RN101062826 4911 

69 ED0051O Owens Corning RN100223585 3296 

70 HG1451S Oxyvinyls LP RN102518065 2821 

71 HG0175D Pasadena Refining RN100716661 2911 

72 JE0042B Premcor Refining Group RN102584026 2911 

73 MC0002H Regency Tilden Gas 

(Formerly Enbridge) 

RN100216621 2819 

74 HG0697O Rhodia Inc RN100220581 2819 

75 HG0632T Rohm & Haas Texas RN100223205 2869 

76 HG0659W Shell Oil Co RN100211879 2911 

77 HW0017R Sid Richardson Carbon RN100222413 2895 

78 HT0027B Sid Richardson Carbon Co RN100226026 2895 

79 BL0038U Solutia Inc RN100238682 2869 

80 TF0012D Southwestern Electric Power RN100213370 4911 

81 GJ0043K Southwestern Electric Power RN102156916 4911 

82 ME0006A Southwestern Electric Power RN100542596 4911 

83 PG0040T Southwestern Public Service RN100224641 4911 

84 PG0041R Southwestern Public Service RN100224849 4911 
Page 9 

EPA Texas’ BART Analysis TSD 

85 LN0081B Southwestern Public Service RN100224765 4911 

86 JE0091L Sun Marine Terminal RN100214626 4226 

87 WN0042V Targa RN102552387 1311 

88 CY0019H Targa (Formerly Dynegy Midstream) RN102551785 1311 

89 OC0019C Temple-Inland RN100214428 2621 

90 CI0012D Texas Genco LP RN100825371 4911 

91 FG0020V Texas Genco LP RN100888312 4911 

92 HK0014M Texas Lehigh Cement Co RN102597846 3241 

93 HG0562P Texas Petrochemicals LP RN100219526 2869 

94 BL0082R The Dow Chemical Co RN100225945 2869 

95 JE0039N The Goodyear Tire And Rubber Co RN102561925 2822 

96 NE0022I Ticona Polymers Inc RN101625721 2869 

97 JE0005H Total Petrochemicals RN102457520 2911 

98 ED0066B TXI Operations LP RN100217199 3241 

99 FI0020W TXU Big Brown Company LP RN101198059 4911 

100 DB0251U TXU Electric Company RN101559854 4911 

101 FB0025U TXU Generation Company LP RN102285855 4911 

102 HQ0012T TXU Generation Company LP RN100664812 4911 

103 MB0116C TXU Generation Company LP RN102566494 4911 

104 MM0023J TXU Generation Company LP RN102147881 4911 

105 MO0014L TXU Generation Company LP RN102285848 4911 

106 RL0020K TXU Generation Company LP RN102583093 4911 

107 TA0352I TXU Generation Company LP RN100693308 4911 

108 WC0028Q TXU Generation Company LP RN102183969 4911 

109 YB0017V TXU Generation Company LP RN102563426 4911 

110 TF0013B TXU Generation Company LP RN102285921 4911 

111 GB0076J Union Carbide Corp RN100219351 2869 

112 CB0028T Union Carbide Corporation RN102181526 2869 

113 HR0018T Valence Midstream Ltd RN100213685 1321 

114 GB0073P Valero Refining Co Texas RN100238385 2911 
Page 10 

EPA Texas’ BART Analysis TSD 

115 NE0043A Valero Refining Company RN100211663 2911 

116 MR0008T Valero McKee RN100210517 2911 

117 WH0014S Vetrotex Wichita Falls Plant RN100218601 3229 

118 VC0003D Victoria Power RN100214980 4911 

119 JB0016M Vintage Petroleum Inc RN100214592 1311 

120 JC0003K Westvaco RN102157609 2631 

1211 JE0343H BMC Holdings Inc 

122 AG0024G Pueblo Midstream Gas Corp 

123 GBA007G INEOS 

124 HG0130C Valero Refining Texas LP 

125 JH0025O Johns Manville International 

126 PE0024Q Regency Gas Services 

                                                            

1

 Numbers 121-130 were not included in TCEQ’s initial list of 120 sources potentially subject to BART but were added 

during their review and development of the SIP. 
Page 11 

EPA Texas’ BART Analysis TSD Table B-3 (From TCEQ SIP Table 9-4) BART- Eligible Sources’ Distance to Class I Areas In Texas and Near Texas. 

Regulated

Entity Company

Distance to Class I Area (km)

BigBend

BretonIsle

CaneyCreek

Carlsbad Caverns

Guada-lupeMtns

SaltCreek

UpperBuffalo

WhPea

RN100220110 ABITIBI CONSOLIDATED CORP 851 580 343 937 968 946 514 RN102560687 AEP TEXAS CENTRAL CO 652 957 979 945 953 1054 1152 RN100642040 AEP TEXAS CENTRAL CO 608 862 815 860 874 951 988 RN100552181 AEP TEXAS CENTRAL CO 590 865 797 838 852 926 970 RN100215557 AEP TEXAS NORTH CO 497 1071 556 460 495 455 681 RN101531226 AEP TEXAS NORTH CO 351 1125 684 393 420 442 821 RN100221472 ALCOA INC 609 792 510 731 758 769 679 RN100242577 ALCOA WORLD ALUMINA LLC 652 759 680 859 878 927 854 RN100250869 ALON USA LP 373 1223 720 295 329 316 837 RN100225978 ASH GROVE TEXASLP 693 827 342 710 744 700 496 RN100209444 ATTOFINA CHEMICALS INC 780 609 526 932 957 972 698 RN100219872 AUSTIN ENERGY 553 843 563 690 715 738 731 RN100218049 BASF CORPORATION 760 641 613 942 965 996 785 RN102536307 BP AMOCO CHEMICAL CO 804 590 566 969 993 1014 736 RN102535077 BP PRODUCTS NORTH AMERICA 805 562 564 970 994 1014 735 RN100221761 CABOT CORPORATION 721 1296 642 497 535 377 686 RN100211507 CAPITOL CEMENT DIV 466 924 677 652 672 724 843 RN101996395 CELANESE CHEMICAL 717 1297 645 492 531 373 689 RN100258060 CELANESE LTD 702 703 642 894 915 955 816 RN100216472 CHAPARRAL STEEL 687 828 348 707 741 699 503 RN100219856 CHEMICAL LIME LTD 603 858 443 658 689 672 601 RN103919817 CHEVRON PHILLIPS CHEMICAL 805 584 515 953 979 990 686 RN102320850 CHEVRON PHILLIPS CHEMICAL 733 1332 676 494 531 365 715 RN100825249 CHEVRON PHILLIPS CHEMICAL 726 673 612 908 930 964 785 RN102555166 CITGO REFINING & CHEMICALS 557 866 798 837 852 926 971 RN100217975 CITY PUBLIC SERVICE 475 917 693 673 692 748 861 RN100217835 CITY PUBLIC SERVICE 470 923 701 671 689 748 868 RN102495884 CONOCO PHILLIPS 732 1333 677 492 530 363 716 RN101271419 COPANO PROCESSING LP 640 751 598 813 835 868 771 RN100218684 DCP MIDSTREAM LP 350 1355 837 167 204 198 943 
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EPA Texas’ BART Analysis TSD 

Regulated

Entity Company

Distance to Class I Area (km)

BigBend

BretonIsle

CaneyCreek

Carlsbad Caverns

Guada-lupeMtns

SaltCreek

UpperBuffalo

WhPea

RN100209659 DEGUSSA ENG CARBONS 728 1337 683 486 524 357 722 RN100227016 DOW CHEMICAL CO 791 600 539 947 972 988 710 RN104150123 DOW CHEMICAL CO 796 598 536 951 975 987 717 RN100222900 DYNEGY MIDSTREAM SERVICES 807 583 513 954 980 991 684 RN100219815 EASTMAN CHEMICAL COMPANY 886 623 224 927 960 915 397 RN100225085 EI DUPONT DE NEMOURS & CO 794 596 530 947 972 987 701 RN100542711 EI DUPONT DE NEMOURS & CO 918 472 484 1053 1080 1080 646 RN100211309 EL PASO ELECTRIC CO 428 1689 1178 178 146 260 1273 RN102166964 ENBRIDGE PIPELINES LP 940 647 135 952 987 924 308 RN100226877 ENTERGY GULF STATES INC 753 643 461 878 906 908 634 RN102513041 ENTERGY GULF STATES INC 907 484 487 1043 1070 1071 650 RN100210574 EQUISTAR 777 619 582 948 971 996 753 RN100237668 EQUISTAR CHEMICALS LP 777 618 582 948 972 997 754 RN100542281 EQUISTAR CHEMICALS LP 787 603 517 935 961 973 688 RN100211903 EXXON MOBIL CHEMICALS 889 501 482 1024 1051 1053 647 RN102212925 EXXONMOBIL CHEMICAL CO 796 594 524 947 972 986 695 RN102574803 EXXONMOBIL CHEMICAL CO 795 594 525 947 972 986 696 RN102579307 EXXONMOBIL CORP 796 598 526 944 970 982 697 RN102450756 EXXONMOBIL OIL CORP 888 502 482 1023 1050 1052 647 RN102534138 FLINT HILLS RESOURCES LP 590 865 798 838 852 927 971 RN100235266 FLINT HILLS RESOURCES LP 580 874 800 829 843 918 972 RN100219252 HUNTSMAN CORP 899 491 492 1037 1064 1067 656 RN100217389 HUNTSMAN CORP 897 493 501 1038 1065 1069 666 RN101867554 HUNTSMAN POLYMERS CORP 293 1303 819 212 241 277 936 RN100238708 INEOS USA LLC 779 617 584 951 974 1000 756 RN100543115 INTERNATIONAL PAPER CO 974 619 128 988 1023 960 296 RN104392626 INVISTA 918 472 484 1053 1080 1080 646 RN102663671 INVISTA S.A.R.L. 614 797 693 824 842 896 866 RN100213909 LAREDO WLE LP 411 1069 918 703 710 818 1086 RN100218254 LEHIGH CEMENT COMPANY 623 820 438 694 725 712 601 RN100215979 LON C HILL LP 571 882 802 820 834 911 974 
Page 13 

EPA Texas’ BART Analysis TSD 

Regulated

Entity Company

Distance to Class I Area (km)

BigBend

BretonIsle

CaneyCreek

Carlsbad Caverns

Guada-lupeMtns

SaltCreek

UpperBuffalo

WhPea

RN102038486 LCRA 583 810 559 727 752 775 729 RN100226844 LCRA 630 760 558 783 807 831 730 RN100633650 LYONDELL CHEMICAL CO 787 603 518 936 962 975 690 RN100218130 LYONDELL CITGO REFINING 775 615 529 928 953 969 703 RN100210608 MARATHON PETROLEUM 806 587 564 971 995 1015 734 RN102609724 NORIT AMERICAS INC 915 603 209 954 988 940 381 RN101062826 NRG TEXAS LP 799 593 552 960 984 1003 723 RN100223585 OWENS-CORNING 701 811 336 724 758 717 494 RN102518065 OXY VINYLS LP 789 601 528 941 966 981 699 RN100716661 PASADENA REFINING SYSTEM 777 613 528 930 955 971 703 RN102584026 PREMCOR REFINING GROUP 897 493 505 1039 1066 1070 669 RN100216621 REGENCY FS (FIELD SERVICES) 468 953 788 711 725 804 957 RN100223205 RHODIA, INC. 797 593 524 948 973 987 695 RN100223205 ROHM & HAAS TEXAS 788 602 528 940 965 980 699 RN100211879 SHELL OIL CO 785 604 530 938 964 979 701 RN100222413 SID RICHARDSON CARBON 727 1337 683 486 524 357 722 RN100226026 SID RICHARDSON CARBON 218 1407 945 142 153 275 1063 RN100238682 SOLUTIA INC 777 618 582 948 972 997 754 RN102156916 SOUTHWESTERN ELEC POWER 888 616 231 932 965 921 403 RN100542596 SOUTHWESTERN ELEC POWER 915 632 178 941 975 921 351 RN100213370 SOUTHWESTERN ELEC POWER 900 668 165 914 949 890 338 RN100224641 SOUTHWESTERN PUBLIC SERV 679 1346 705 435 473 308 754 RN100224849 SOUTHWESTERN PUBLIC SERV 681 1347 705 436 474 309 754 RN100224765 SOUTHWESTERN PUBLIC SERV 490 1282 712 304 344 248 803 RN100214626 SUN MARINE TERMINAL 896 494 505 1038 1065 1070 670 RN102551785 TARGA MIDSTREAM SERVICES 251 1327 859 196 219 288 979 RN102552387 TARGA MIDSTREAM SERVICES 684 925 361 647 684 617 488 RN100214428 TEMPLE-INLAND 921 471 466 1050 1077 1074 628 RN100888312 TEXAS GENCO 736 656 565 901 925 949 738 RN100825371 TEXAS GENCO 804 585 523 955 980 993 694 RN102597846 TEXAS LEHIGH CEMENT CO 525 867 599 678 701 734 767 
Page 14 

EPA Texas’ BART Analysis TSD 

Regulated

Entity Company

Distance to Class I Area (km)

BigBend

BretonIsle

CaneyCreek

Carlsbad Caverns

Guada-lupeMtns

SaltCreek

UpperBuffalo

WhPea

RN100219526 TEXAS PETROCHEMICALS LP 772 617 534 927 952 968 706 RN102561925 THE GOODYEAR TIRE & RUBBER 874 516 492 1013 1040 1044 659 RN101625721 TICONA POLYMERS INC 562 911 839 824 836 920 1011 RN102457520 TOTAL PETROCHEMICALS USA 904 485 493 1043 1070 1072 657 RN100217199 TXI OPERATIONS LP 688 827 347 708 742 700 503 RN101198059 TXU BIG BROWN CO LP 741 719 340 802 833 806 511 RN101559854 TXU GENERATION COMPANY 720 841 312 716 751 695 459 RN102285855 TXU GENERATION COMPANY 809 822 227 781 818 745 366 RN100664812 TXU GENERATION COMPANY 630 886 402 645 678 640 550 RN102566494 TXU GENERATION COMPANY 651 797 413 719 750 733 578 RN102147881 TXU GENERATION COMPANY 610 791 509 732 758 770 679 RN102285848 TXU GENERATION COMPANY 403 1178 674 343 376 355 793 RN102583093 TXU GENERATION COMPANY 889 604 242 939 972 930 414 RN100693308 TXU GENERATION COMPANY 680 865 352 680 715 665 498 RN102285921 TXU GENERATION COMPANY 885 685 170 897 932 872 342 RN102183969 TXU GENERATION COMPANY 255 1360 884 162 186 261 1001 RN102563426 TXU GENERATION COMPANY 612 991 441 567 603 541 563 RN102181526 UNION CARBIDE CORP 634 783 702 848 867 921 876 RN100219351 UNION CARBIDE CORP 802 591 565 967 991 1012 735 RN100213685 VALENCE MIDSTREAM 842 717 204 853 888 831 372 RN100210517 VALERO MCKEE 751 1387 728 490 527 350 760 RN100238385 VALERO REFINING CO TEXAS 806 588 565 971 995 1015 735 RN100211663 VALERO REFINING CO TEXAS 559 867 798 836 851 925 971 RN100218601 VETROTEX AMERICA 671 1019 419 587 625 539 521 RN100214980 VICTORIA WLE LP 607 799 682 813 832 883 855 RN100214592 VINTAGE PETROLEUM LLC 646 761 669 847 867 914 842 RN102157609 WESTVACO 891 503 451 1016 1044 1040 617 
Page 15 

EPA Texas’ BART Analysis TSD 

C. Determination of Sources Subject to BART 

Under the EPA’s BART guidelines, the state has two options regarding its BART-eligible 

sources: 

• make BART determinations for all sources; or 

• consider exempting some sources from BART because they do not cause or 

contribute to visibility impairment in a Class I area. 

The TCEQ chose the second option that considers exempting some sources. 

When exempting sources from BART because they do not cause or contribute to visibility impairment 

in a Class I area, the guidelines suggest three sub-options for determining that certain sources are not 

subject to BART: 

• the use of model plants to exempt sources with common characteristics 

(70 FR 39162-3); 

• a cumulative modeling analysis to show that groups of sources are not subject to BART; 

• and finally; an individual source attribution approach. 

The TCEQ exercised all three sub-options above to determine which sources were subject to 

BART. These options are explained further below, in the order in which the TCEQ and the 

sources performed the analyses. 

Section C-1 describes the cumulative modeling analyses that the TCEQ performed for the sources

identified as BART-eligible. Because there was such a large number of BART-eligible sources in 

Texas, the TCEQ performed cumulative modeling analyses using CAMx PSAT technology. Once the 

TCEQ had completed the CAMx modeling analysis, several BART- eligible sources were determined 

to be insignificant (screened out) and several remained potentially BART-eligible (did not screen out). 

Screening out is a process that further examines and evaluates sources for inclusion or exclusion in the 

BART program. Sources that did not screen out through the cumulative modeling analysis were 

required to perform source-specific screening modeling analyses using either the CALPUFF or the 

CAMx model setup developed by the TCEQ. TCEQ then evaluated some of the sources using sources 

that had been in groups that screened out in CAMx in Section C-2. Section D-1 discusses the sources 

that decided to conduct refined CAMx analysis for potential screening. D-2 discusses the sources that 

either did CALPUFF modeling based on the CENRAP BART MODELING GUIDELINES (Appendix 

A) or did refined CALPUFF modeling. BART- eligible sources that did not screen out in any of the 

modeling analyses had the option of reducing the emissions from their BART-eligible units using an 

enforceable mechanism, such as a permit, or performing an engineering analysis. The BART-eligible 

sources that chose to reduce potential emissions are discussed in Section E. There were also some 

sources that provided additional information to TCEQ that allowed the sources to be dropped from 

BART eligible consideration. 

C-1 Cumulative Screening Modeling Using CAMx PSAT and Source 

Grouping 

Because of the large number of sources that needed to be further evaluated, EPA Region 6 and TCEQ 

discussed potential options of using the CENRAP 2002 modeling to conduct some visibility impact 

analysis. TCEQ wanted to investigate if there were some groups of VOC and/or PM emissions from 

potential BART-eligible sources in Texas that could be shown to contribute insignificantly to visibility 

impairment at Class I areas. TCEQ also inquired about using the same modeling platform to assess if 

VOC and/or PM emissions from potential BART-eligible sources in Texas could be shown to 
Page 16 

EPA Texas’ BART Analysis TSD 

contribute insignificantly to visibility impairment at Class I areas. These tests were implemented to try 

to screen out as many sources as possible from any further BART analysis before having to conduct 

more refined modeling of a source specific nature or conducting a full BART evaluation. 

TCEQ documented how they conducted screening modeling analyses as in the CAMx modeling 

protocol, Screening Analysis of Potentially BART-Eligible Sources in Texas, and the final CAMx 

modeling report, Final Report, Screening Analysis of Potential BART-Eligible Sources in Texas, 

presented in Appendixes B and C (TX RH SIP Appendix 9-3 and 9-4) respectively. We will provide a 

very brief overview of the modeling and refer the reader to the Appendices for more details. 

Prior to performing the Texas BART screening analysis with CAMx, a modeling protocol was 

prepared that provided details on the modeling approach to be used for the Texas group BART 

screening analysis (ENVIRON, 2005b). The modeling protocol was reviewed by TCEQ, EPA and 

FLM representatives specialized in air quality analyses and BART prior to performing the analysis. 

The Texas BART screening analysis modeling protocol contained a summary of the BART 

requirements taken from EPA’s BART guidelines. 

To evaluate the visibility impacts of a potential BART-eligible source at Class I areas beyond 50 

kilometers (km) from the source, EPA modeling guidance (EPA, 2003c) recommends the use of the 

California Puff Model (CALPUFF) model. For modeling the impact of sources closer than 

50 km to a Class I area, EPA’s BART guidance recommends that expert modeling judgment be used 

“giving consideration to both CALPUFF and other methods.” The Plume Visibility Model- II 

(PLUVUE) model is mentioned as a possible model to consider in addition to CALPUFF within 50 km 

of a source. The EPA guidance notes that regional scale photochemical grid models may have merit, 

but such models are resource intensive relative to CALPUFF. Photochemical grid models are clearly 

more appropriate for cumulative modeling options such as in the determination of the aggregate 

contribution of all BART-eligible sources to visibility impairment, but such use should involve 

consultation with the appropriate EPA Regional Office. 

EPA’s 2005 BART Guidelines indicated that CALPUFF is recommended for ascertaining whether a 

potential BART-eligible source may need to perform further BART analysis for distances greater than 

50 km. The Guidelines continue that if a source is determined to be subject to BART, CALPUFF or 

another appropriate model should be used to evaluate the improvement in visibility resulting from the 

application of BART controls. Emissions reflecting periods of start-up, shutdown, and malfunction are 

not to be considered in determining the appropriate emission rates. EPA recommends that states use 

the highest 24-hour average actual emission rate for the most recent five-year period (excluding 

periods with start-up, shutdown, and malfunctions). Visibility improvements may be evaluated on a 

pollutant-specific basis. 

EPA’s BART Guidelines also allows states to “submit to EPA a demonstration, based on an analysis 

of overall visibility impacts, that emissions from BART-eligible sources in your state, considered 

together, are not reasonably anticipated to cause or contribute to any visibility impairment in a Class I 

area, and thus no source should be subject to BART” (EPA, 2005). This approach was pursued in the 

Texas BART screening analysis with CAMx. EPA guidance notes that “you may also use a 

photochemical grid model” and “if you wish to use a grid model, you should consult with the 

appropriate EPA Regional Office to develop an appropriate modeling protocol” (EPA, 2005). The 

TCEQ entered into discussions with EPA Region 6 and FLM representatives and developed a group 

screening modeling approach that was agreed to as acceptable. 

Modeling Approach 

As mentioned above, Texas used CAMx for its BART screening analysis. Given the large number of 

sources that can be evaluated in a single modeling run with CAMx, compared to over 100 model runs 
Page 17 

EPA Texas’ BART Analysis TSD 

with CALPUFF, the approach has some time saving benefits. Many of the BART-eligible sources in 

Texas are very far away from a Class I area and CAMx provides a scientifically defendable platform 

for assessment of visibility impacts. CAMx is also more suited than some other modeling approaches 

for evaluating the impacts of SO2, NOX, VOC and PM emissions as it has a more robust chemistry 

mechanism and assesses emissions in a cumulative manner. CAMx also provided the ability to more 

easily evaluate if VOCs or PM from the sources could be determined insignificant.

The Texas BART screening analysis was built upon the regional photochemical modeling (Morris et 

al., 2005d) being conducted by CENRAP. In particular, the CENRAP 2002 36 km modeling database 

for the Comprehensive Air Quality Model with extensions (CAMx) (ENVIRON, 2005a) was enhanced 

to include a 12 km grid over Texas and nearby Class I areas. CAMx zero-out VOC and PM emissions 

from BART sources and inert primary PM BART sources emissions modeling was conducted to 

determine whether potential BART-eligible sources’ VOC and PM emissions could be shown to 

contribute insignificantly to visibility impairment at any Class I area. The CAMx PM Source 

Apportionment Technology (PSAT) modeling was also conducted for groups of potential BARTeligible sources’ SO2 and NOX emissions. A potential BART-eligible source in a group that is shown 

not to contribute significantly to visibility impairment at any Class I area may be excluded from further 

steps in the BART process. TCEQ and EPA agreed to several refinements for a more accurate 

assessment. These included using: 

 12 kmflexi-nest over TX and the surrounding Class I areas of more immediate 

concern, 

 Particulate Source Apportionment Tool (PSAT) that allows tracking of the impacts 

of BART sources or groups of BART sources within a single run, 

 Plume in Grid (PiG) provide more accurate treatment of the near-source transport, 

plume dispersion, 

 TCEQ funded ENVIRON to make the PSAT and Pig with full plume chemistry 

work together for this evaluation of the BART sources and alleviated concerns of 

artificially dispersing emissions over a 12km grid cell. 

The most recent version of CAMx at the time, CAMx V4.4, was used in this work and incorporated all 

of these features. 

The analyses consisted of two basic elements: 

• VOC and PM Modeling Analyses: An analysis of the VOC and PM emissions from all 

potential BART-eligible sources was performed. Followed by analysis of VOC from all potential 

BART-eligible sources. Finally, analyses of the PM emissions from the BART- eligible sources was 

performed using grouped sources because the initial PM modeling was significant with all the sources. 

• PSAT Modeling Analyses for SO2 and NOX emissions: Screening analyses for groups of 

potential BART-eligible non-EGU sources’ SO2 and NOX emissions were performed to determine 

whether the group’s visibility impacts at Class I areas were insignificant. 

Both elements of the BART screening analyses used the same 36/12 km 2002 annual database for 

CAMx (ENVIRON, 2005a) based on the database developed by CENRAP (www.cenrap.org). The 

VOC and PM emission screening analyses were performed using emissions zero-out modeling and, for 

primary PM only, inert simulations. The group of sources’ SO2 and NOX emissions screening analyses 

were performed using an updated version of the CAMx PSAT. 

MODEL PLATFORM --2002 ANNUAL 36/12 KM MODELING DATABASE 

The BART screening modeling was performed using the CAMx Version 4.4 model and the 2002 

annual regional photochemical modeling database developed as part of the CENRAP (Morris, 
Page 18 

EPA Texas’ BART Analysis TSD 

2005d). CENRAP developed a 2002 annual modeling database for CAMx on the 36 km unified 

national Regional Planning Organization (RPO) grid that covers the continental United States. This 

database was developed following the procedures outlined in the CENRAP Modeling Protocol (Morris 

et al., 2004c) and CENRAP modeling Quality Assurance Program Plan (QAPP) (Morris and 

Tonnesen, 2004b). The CENRAP preliminary base case model performance evaluation results for the 

CAMx model on the national 36 km grid using the CENRAP base A emissions is given in Morris et 

al., (2005d). The CENRAP modeling protocol, QAPP, and preliminary base A evaluation reports 

provide details on the development of the CENRAP 2002 36 km annual modeling database. Provided 

below is a summary of the enhancements made to the CENRAP database for use in this BART 

screening analysis. Additional details can be found in the modeling protocol (ENVIRON, 2005b). 

Enhancements to the CENRAP 2002 Modeling Database 

The CENRAP 2002 36 km annual CAMx evaluation using the base A emissions and CAMx Version 

4.20 is reported in Morris and co-workers (2005d). CENRAP was updating the 2002 base case 

emissions and updated CMAQ and CAMx simulations as the RH modeling work continued. For the 

Texas BART screening modeling, the base B base case database was used (the most current available 

at the time). 

The CENRAP Base B 2002 36 km annual CAMx photochemical modeling database was updated to 

include a 12 km nested-grid that covers Texas and Class I areas in and near Texas including: 

• National Parks: Big Bend (BIBE), Guadalupe Mountains (GUMO), and Carlsbad 

Caverns 

• Wildlife Refuges: Salt Creek (SACR) and Wichita Mountains (WIMO) 

• Wilderness Areas: White Mountain (WHIT), Caney Creek (CACR), Upper Buffalo 

(UPBU), and Hercules-Glade (HEGL). 

Figure C-1 displays the 36/12 km nested grid structure used for the CAMx BART screening modeling 

analysis. The locations of the potential BART-eligible sources and Interagency Monitoring of 

Protected Visual Environments (IMPROVE) sites that includes Class I areas within the 12 km 

modeling domain are shown in Figure C-2. The CAMx flexi-nesting feature was used to specify a 12 

km Texas fine grid within the CENRAP 36 km modeling domain. Full flexi-nesting was used in 

CAMx which results in the model internally interpolating meteorological data, emissions and other 

inputs from the 36 km grid to the 12 km grid. 

 
Page 19 

EPA Texas’ BART Analysis TSD 

Figure C-1 from ENVIRON Figure 2-1. Texas BART modeling 36/12 km modeling domain and the 

locations of the IMPROVE monitoring sites that include Class I areas, indicated by circles. Note: the 

one circle in North central LA and two circles in Northern Oklahoma are not Class I areas. 

 
Page 20 

EPA Texas’ BART Analysis TSD 

Figure C-2 from ENVIRON Figure 2-2 Texas BART modeling 12 km modeling domain and the 

locations of the IMPROVE monitoring sites (circles) that include Class I areas and locations of 

potential BART-eligible sources in Texas (triangles). 

 
Page 21 

EPA Texas’ BART Analysis TSD 

As briefly mentioned above, PM Source Apportionment Technology (PSAT) was used to conduct the 

SO2 and NOX potential BART-eligible screening analysis. In Version 4.4 of CAMx, the PSAT was 

updated to be compatible with the CAMx full chemistry Plume-in-Grid (PiG) module. The next 

discussion briefly describes the PSAT technique and the enhancements that were made to the CAMx 

PiG and PSAT to make them compatible with each other. More details are provided in the modeling 

protocol (Appendix B & C). 

PSAT is designed to source apportion the following PM species modeled in CAMx: 

• Sulfate (SO4) 

• Particulate nitrate (NO3) 

• Ammonium (NH4) 

• Particulate mercury (Hg(p)) 

• Secondary organic aerosol (SOA) 

• Six categories of primary particulate matter (PM) 

 Elemental carbon (EC) 

 Primary organic aerosol (POA) 

 Fine crustal PM (FCRS) 

 Fine other primary PM (FPRM) 

 Coarse crustal PM (CCRS) 

 Coarse other primary PM (CPRM) 

PSAT performs PM source apportionment for each user defined source group. A source group 

consists of a combination of a geographic regions and emissions source categories. Examples of source 

regions include: countries, states, nonattainment areas, or counties. Examples of source categories 

include: area sources, mobile sources, biogenic sources, elevated point sources or individual point 

sources. The user defines a map to specify the source regions. The user then defines each source 

category. For example, separate gridded low-level emissions and/or elevated point source emissions. 

The model then determines each source group by joining the source categories with the source region 

map. 

The PSAT “reactive tracers” that are added for each source category/region combination (i). In 

general, a single tracer can track primary PM species, whereas secondary PM species require several 

tracers to track the relationship between gaseous precursors and the resulting PM. Particulate nitrate 

and secondary organics are the most complex species to apportion because the emitted precursor gases 

(NOx and VOCs) are several steps removed from the resulting PM species (NO3 and SOA). There is 

a PSAT convention that tracer names for particulate species begin with the letter “P.” 

This PSAT included a total of 32 tracers for each source group (i) if source apportionment is applied to 

all types of PM. Because source apportionment may not always be needed for all species, the PSAT 

implementation is flexible and allows source apportionment for any or all of the chemical classes in 

each CAMx simulation (i.e. the SO4, NO3, SOA, Hg and primary PM classes listed above). For 

example, source apportionment for sulfate/nitrate/ammonium requires just nine tracers per source 

group. 

One fundamental assumption in PSAT is that PM is apportioned back to the primary precursor for each 

type of PM. For example, SO4 is apportioned to SOx emissions, NO3 is apportioned to NOx 

emissions, NH4 is apportioned to NH3 emissions, etc. 

The CAMx PSAT and PiG algorithms were updated to treat the near-source dispersion and chemistry 

of secondary PM formation in the PM source apportionment calculations. A new full- chemistry PiG 

module was developed that has been extended to PSAT and Ozone Source Apportionment Technology 

(OSAT). The full-chemistry PiG treats the gas-phase and aqueous- phase reactions associated with 

ozone, sulfate and nitrate formation. 
Page 22 

EPA Texas’ BART Analysis TSD 

 

Procedures For VOC and PM Emissions BART Screening Analysis 

Two types of screening analyses were performed to assess the visibility impacts of VOC and PM 

emissions from potential BART-eligible sources: 

(1) zero-out VOC and PM emissions modeling; and 

(2) inert PM emissions modeling. 

The first BART screening analysis evaluated the cumulative visibility impacts at Class I areas of VOC 

and PM emissions from all potential BART-eligible sources in Texas using two 2002 annual CAMx 

36/12 km simulations: 

• 2002 BART base case emissions scenario (with estimated 24-hour maximum VOC and PM 

emissions for BART-eligible sources); and 

• 2002 BART VOC and PM emissions zero-out scenario. 

The 2002 BART base case emissions scenario was based on the CENRAP 2002 typical base B base 

case emissions scenario. The BART guidelines require that BART modeling use the maximum actual 

24-hour emissions for each BART-eligible source. The CENRAP 2002 typical scenario includes 

average actual emissions for all sources. The maximum 24-hour actual emission rates are not readily 

available for most sources. To account for the differences between maximum 24-hour actual and 

average typical actual, the average typical actual emissions for potential BART-eligible sources in the 

CENRAP 2002 typical base B base case emissions scenario were doubled at the suggestion of EPA 

Region 6. EPA noted that this assumption should provide a conservative estimate of maximum actual 

24-hour emissions for most sources. 

Visibility impacts were calculated at each Class I area using the differences in 24-hour PM 

concentrations between the 2002 BART base case and 2002 BART zero-out case following the 

procedures given in EPA’s BART modeling guidance (EPA, 2005). The BART procedures were 

outlined in the Federal Land Managers Air Quality Related Values Workgroup report (FLAG, 

2000) and EPA regional haze guidance documents. These procedures use the IMPROVE reconstructed 

mass extinction equation. Instead of using measured PM concentrations from an IMPROVE monitor, 

incremental PM concentrations from the differences in the CAMx 2002 BART base case and 2002 

BART VOC/PM zero-out runs were used in the equation. 

The IMPROVE reconstructed mass extinction equation was used to estimate visibility at Class I areas 

using IMPROVE monitoring data and has also been used for evaluating visibility impacts at Class I 

areas due to new sources using modeling output of a single source or group of sources. 

The total light extinction due to a source (bsource), in units of inverse Megameters (Mm-1), is 

assumed to be the sum of the light extinction due to the source’s individual PM species concentration 

impacts times an extinction efficiency coefficient: 

bsource = bSO4 + bNO3 + bOC + bEC+ bsoil + bcoarse 

bSO4 = 3 [(NH4)2SO4]f(RH) bNO3 = 3 [NH4NO3]f(RH) bOC = 4 [OMC] 

bEC = 10 [EC] 

bSoil = 1 [Soil] 

bcoarse = 0.6 [Coarse Mass] 
Page 23 

EPA Texas’ BART Analysis TSD 

Here f(RH) are relative humidity adjustment factors. As recommended by EPA BART modeling 

guidance, Class I area specific monthly average f(RH) values were used (EPA, 2005; 2003a). The 

concentrations in the square brackets are in μg/m3 and are based on the differences in concentrations 

between the 2002 BART base case and 2002 BART VOC/PM zero-out case. Although CAMx 

explicitly models ammonia and ammonium, the IMPROVE extinction equation assumes that SO4 and 

NO3 are completely neutralized by ammonium. The OMC in the above equation is Organic Matter 

Carbon, and OC is Organic Carbon. When using IMPROVE measurements, the current IMPROVE 

extinction equation assumed an OMC/OC ratio of 1.4 (i.e., the IMPROVE OC measurement is 

multiplied by 1.4 to obtain OMC). Because CAMx directly models OMC, the 1.4 factor was not used. 

The following species mappings were used to map the CAMx species to those used in the IMPROVE 

reconstructed mass extinction equation given above: 

[(NH4)2SO4] = 1.375 x PSO4 [NH4NO3] = 1.290 x PNO3 

[OMC] = POA + SOA1 + SOA2 + SOA3 + SOA4+SOA5 [EC] = PEC 

[Soil] = FPRM + FCRS [Coarse Mass] = CPRM + CCRS 

Here PSO4 and PNO3 are the CAMx particulate sulfate and nitrate species. POA is the CAMx primary 

Particulate Organic Aerosol species, whereas SOA1 through 5 are the five Secondary Organic Aerosol 

species carried in CAMx. Primary Elemental Carbon is represented by PEC in CAMx. CAMx carries 

two species that represent the other PM2.5 components (i.e., fine particles that are not SO4, NO3, EC 

or OC), one for the crustal (FCRS), and the other for the remainder of the primary emitted PM2.5 

species (FPRM). Similarly, CAMx carries two species to represent Coarse Mass (PM10- 2.5), one for 

crustal (CCRS), and one for other (CPRM). 

The Haze Index (HI) for the source is calculated in deciviews from the source’s extinction plus natural 

background using the following formula: 

HIsource = 10 ln[(bsource + bnatural)/10] 

Here, bnatural is the Class I area specific clean natural visibility background (natural conditions); 

EPA’s default values are used in this analysis (EPA, 2003b). 

The source’s HI is compared against natural conditions to assess the significance of the source’s 

visibility impact. EPA guidance lists natural conditions (bnatural) by Class I areas in terms of Mm-1 

(EPA, 2003b) and assumes clean conditions with no man-made or weather interference. The visibility 

significance metric for evaluating BART sources is the change in deciview (del-dv) from the source’s 

and natural conditions Haze Indices: 

del-dv = HIsource – HInatural = 10 ln[(bsource + bnatural)/10] - 10 ln[bnatural/10] 

= 10 ln[(bsource + bnatural)/bnatural] 

The visibility impacts from the CAMx BART VOC/PM zero-out run was first calculated using all PM 

species (i.e., those associated with both VOC and PM precursors). They then made separate visibility 

calculations using just those PM species associated with the elimination of the BART VOC emissions 

(i.e., SOA1, SOA2, SOA3, SOA4, and SOA5) and then just those species associated with the 

elimination of the primary PM emissions (i.e., PSO4, PNO3, POA, PEC, FCRS, FPRM, FCRS and 

CCRS). 

VOC: bsource = 4 [SOA1+SOA2+SOA3+SOA4+SOA5] 

PM: bsource = 3 f(RH)([1.375PSO4]+[1.290PNO3]) + 4[POA] + 10[PEC] + 

1[FPRM+FCRS] + 0.6[CPRM+CCRS]) 

The del-dv impacts were calculated by ENVIRON at each Class I area within the CENRAP southern 

BART modeling region that contains Texas, as specified in the Appendix A (CENRAP BART 

Modeling Protocol -Alpine and ENVIRON, 2005). Table C-1 lists the Class I areas included in the 
Page 24 

EPA Texas’ BART Analysis TSD 

BART screening analysis and also includes the deciviews and the extinctions associated with the 

Annual Average Natural Conditions and Best 20% Natural Conditions of these Class I areas 

(EPA,2003b). Because the PSAT runs are computationally resource intensive, not all of the Class I 

sites analyzed were included in the 12 km domain. Sites analyzed, which were in the 36 km domain, 

are noted is Table C-1. 
Page 25 

EPA Texas’ BART Analysis TSD 

Table C−1. From ENVIRON App. C Table 2-1:Class I areas included in the analysis. 

EPA’s BART guidance suggests that a significance threshold to determine whether a source 

contributes significantly to visibility impairment at a Class I area should be no greater than 0.5 dv. 

Thus, if the del-dv due to all potential BART-eligible sources VOC and/or PM emissions at every 

Class I area and for all days from 2002 are < 0.5 dv, then VOC and PM emissions from all potential 

BART-eligible sources may be determined to contribute insignificantly to visibility impairment. 

Therefore, the VOC and/or PM emissions from each potential BART source would not be significant. 

Under these conditions, VOC and/or PM emissions would no longer need to be considered. 

Because there were days in 2002 for which the del-dv is > 0.5 dv in the BART VOC/PM zero-out 

screening analysis, the results were examined in more detail, including the analysis of the frequency, 

magnitude and duration of the visibility impacts. The BART guidance suggests comparing the 98th 

percentile del-dv at any Class I area with the 0.5 dv significant threshold to determine whether a 

significant visibility impact would reasonably be expected to occur in the context of CALPUFF 

analyses. Using one year of modeling results (2002) the 98th percentile would correspond to the eighth 

highest 24-hour average visibility impact at each Class I area. PM and VOC were also analyzed 

separately to determine if one of these pollutants could be determined to impact insignificantly to 

visibility impairment at the Class I areas. 

EPA’s BART guidance lists a significance threshold for contributing to visibility impairment at a Class I 

area as a 0.5 change in deciview (del-dv) over natural conditions (EPA, 2005). The guidance also states 

that the 98th percentile (e.g., eighth highest in a year) change in deciview value should be compared 

against the 0.5 del-dv significance threshold. EPA’s visibility natural conditions guidance document 

lists three default natural condition values corresponding to best 20% days, worst 20% days, and annual 

IMPROVE

sites Longitude Latitude Class I Area Domain

Best 20% Annual average

dv

bntural

(Mm-1) dv

bnatural

(Mm-1)

BAND1 -106.27 35.78 Bandelier 12km 1.90 12.1 4.46 15.6 

BIBE1 -103.18 29.30 Big Bend 12km 1.81 12.0 4.37 15.5 

BOAP1 -106.85 33.87 Bosque del Apache 12km 1.85 12.0 4.41 15.5 

CACR1 -94.14 34.45 Caney Creek 12km 3.65 14.4 7.49 21.1 

GUMO1 -104.81 31.83 Guadalupe Mountains,

Carlsbad Caverns 

12km 1.91 12.1 4.47 15.6 

HEGL1 -92.92 36.61 Hercules-Glade 12km 3.59 14.3 7.43 21.0 

SACR1 -104.40 33.46 Salt Creek 12km 1.87 12.1 4.43 15.6 

SAPE1 -106.85 36.01 San Pedro Parks 12km 1.91 12.1 4.47 15.6 

UPBU1 -93.20 35.83 Upper Buffalo 12km 3.60 14.3 7.44 21.0 

WHIT1 -105.54 33.47 White Mountain 12km 1.86 12.0 4.42 15.6 

WHPE1 -105.45 36.59 Wheeler Peak, Pecos 12km 1.95 12.2 4.51 15.7 

WIMO1 -98.71 34.73 Wichita Mountains 12km 3.39 14.0 7.23 20.6 

WHRI1 -106.82 39.15 Flat Tops, Maroon 

Bells-Snowmass, 

West 

36km 1.96 12.2 4.52 15.7 

BRET1 -89.21 29.12 Breton 36km 3.85 14.7 7.69 21.6 

GRSA1 -105.52 37.72 Great Sand Dunes 36km 1.98 12.2 4.54 15.7 

WEMI1 -107.80 37.66 La Garita, Black 

Canyon of the 

Gunnison, 

36km 1.94 12.1 4.50 15.7 

MEVE1 -108.49 37.20 Mesa Verde 36km 1.97 12.2 4.53 15.7 

MING1 -90.14 36.97 Mingo 36km 3.59 14.3 7.43 21.0 
Page 26 

EPA Texas’ BART Analysis TSD 

average. The guidance recommends that natural conditions corresponding to the best 20% days be used 

when calculating the BART visibility significance metric. However, the use of the best 20% natural 

conditions in the BART significance test was challenged by the Utility Air Regulatory Group (UARG). 

As part of the settlement to this challenge, EPA then allowed the use of annual average natural 

conditions in the calculation of the BART visibility significance metrics (Paise, 2006 a, b). The CAMx 

analysis analyzed the change in deciview (del-dv) due to each group of BART sources in Class I areas 

using both the maximum and 98th percentile values, and both the best 20% and annual average natural 

conditions. The final recommendation on the significance determination was based on the 98th

percentile change in deciview over annual average natural conditions. 

We note that this initial screening being discussed in C-1 and C-2 for the VOC/PM2.5 and NOx/SOx 

source groups and initial model plants was conducted in 2006. In February 2007 EPA raised concern 

with using the 98th percentile for sources analyzed with CAMx, which does not have the same 

overestimation bias concerns that CALPUFF has that led to the selection of using the 98th percentile 

after the original BART Guidelines proposed using the 1st High. Based on comments and concerns 

about CALPUFF overestimating impacts (chemistry, etc.) EPA finalized the BART Guidelines using 

the 98th percentile in 2005. EPA discussed the concerns with TCEQ and evaluated the existing 

screening that was done at the time that is being discussed in C-1.and C-2. Based on our evaluation of 

the modeling and the sources that screened out we (TCEQ and EPA) did not see the need to redo the 

analysis for the sources that had been screened out as there was enough information to evaluate and 

conclude that more analysis of 1st High would not lead to different conclusions as there was still 

conservatism as source groups had 3 or 4 or more facilities and the cumulative impacts were below 0.5 

deciviews with the 8th High. TCEQ and EPA agreed that further evaluation and screening would be 

done using the Maximum (1st High) for work after February 2007 (Work discussed in Section D). We 

will discuss in more detail why the initial analysis was still acceptable in the discussion of the technical 

analysis and conclusions in C-1.and C-2. (EPA-Snyder 2007, TCEQ -Knud 2007, TCEQ BART 

Screening Clarification 2007). 

BART-Eligible Sources’ VOC and PM10 Emissions 

Initially the CAMx modeling performed was the BART screening analysis estimating the visibility 

impacts at Class I areas from VOC and PM emissions from all potential BART-eligible sources in 

Texas. The visibility impacts at Class I areas are expressed as the change in deciview (del-dv) 

compared to natural conditions. If the estimated 98th percentile del-dv compared to the annual average 

natural conditions due to VOC and PM emissions from all potential BART-eligible sources is < 0.5 at 

all Class I areas, then VOC and PM emissions from each BART source would be < 0.5 del-dv and 

therefore may require no further BART analyses. 

Table C-2 lists the EGU BART sources with VOC and/or PM2.5/PM10 emissions that are the annual 

average emission estimates from the CENRAP 2002 database. To estimate the highest 24-hour actual 

emissions to be used in the BART analysis, the modeling used doubled annual average emissions 

(double the values in the table). 

We note that TCEQ contacted and provided summaries of how sources were modeled in the CAMx 

modeling to each of the facilities that screened out. TCEQ requested concurrence and certification 

from each facility that the emission rates and stack parameters were appropriate to support the 

conclusions. This information was included in the TX RH SIP Appendix 9-7 document. 
Page 27 

EPA Texas’ BART Analysis TSD 

Table C-2 From ENVIRON App. C Table 3-1. Potential BART-eligible EGU sources and their VOC/PM10 emissions

VOC (tpy) VOC PM Zero- 

ID Account Company Plant PM10 Zero- Out Out group 

(tpy) 

1 BC0015L LOWER COLORADO RIVER AUTHORITY LOWER COLORADO RIVE 32 52 pass 3A 2 BG0057U CITY PUBLIC SERVICE SOMMERS DEELY SPRUC 147 1473 pass 1A 3 BG0186I CITY PUBLIC SERVICE V.H. BRAUNIG PLANT 43 58 pass 3A 4 CD0013K AEP TEXAS CENTRAL COMPANY LA PALMA POWER STAT 13 30 pass 2 5 CI0012D TEXAS GENCO LP CEDAR BAYOU STATION 113 157 pass pass 6 DB0251U TXU ELECTRIC COMPANY NORTH LAKE STEAM EL 22 27 pass 2 7 EE0029T EL PASO ELECTRIC CO NEWMAN STATION 31 54 pass 2 8 FB0025U TXU GENERATION COMPANY LP VALLEY STEAM ELEC. 44 58 pass 3A 9 FC0018G LOWER COLORADO RIVER AUTHORITY FAYETTE POWER PROJE 167 1255 pass 2 

10 FG0020V TEXAS GENCO LP W A PARISH STATION 89 281 pass 2 11 FI0020W TXU BIG BROWN COMPANY LP BIG BROWN 134 933 pass 3A 12 GB0037T TEXAS GENCO LP P H ROBINSON STATIO 43 62 pass 1A 13 GJ0043K SOUTHWESTERN ELECTRIC POWER 17 24 pass 2 14 HQ0012T TXU GENERATION COMPANY LP DECORDOVA STEAM ELE 85 113 pass 2 15 JI0030K AEP TEXAS NORTH COMPANY W.T.U.-FT. PHANTOM 26 36 pass 1A 16 LN0081B XCEL ENERGY JONES STATION 43 85 pass 3A 17 MB0116C TXU GENERATION COMPANY LP TRADINGHOUSE STM EL 89 116 pass 3A 18 ME0006A SOUTHWESTERN ELECTRIC POWER WILKES WILKES POWER PLT 41 56 pass 2 19 MM0023J TXU GENERATION COMPANY LP SANDOW STEAM ELECTR 67 735 pass 1A 20 MO0014L TXU GENERATION COMPANY LP MORGAN CREEK STEAM 25 32 pass 1A 21 MQ0009F ENTERGY GULF STATES INC LEWIS CREEK PLANT 65 89 pass 2 22 NE0024E AEP TEXAS CENTRAL COMPANY BARNEY M DAVIS POWE 46 66 pass 2 
Page 28 

EPA Texas’ BART Analysis TSD 

23 NE0025C LON C HILL POWER LON C HILL 7 10 pass 1A 24 NE0026A AEP TEXAS CENTRAL COMPANY NUECES BAY POWER ST 28 39 pass 3A 25 OC0013O ENTERGY GULF STATES INC SABINE PLANT 168 234 pass 3A 26 PG0040T SOUTHWESTERN PUBLIC SERVICE NICHOLS STATION 10 19 pass 1A 27 PG0041R SOUTHWESTERN PUBLIC SERVICE HARRINGTON STATION 97 1546 pass 2 28 RL0020K TXU GENERATION COMPANY LP MARTIN LAKE ELECTRI 257 881 pass 1A 29 TA0352I TXU GENERATION COMPANY LP EAGLE MOUNTAIN STAT 19 27 pass 1A 30 TF0012D SOUTHWESTERN ELECTRIC POWER WELSH POWER PLANT 89 1755 pass 3B 31 TF0013B TXU GENERATION COMPANY LP MONTICELLO STM ELE 245 3297 pass 1B 32 TG0044C AEP TEXAS 12 23 pass 3A 33 TH0004D ELECTRIC UTILITY DEPT DECKER CREEK POWER 5 69 pass 1A 34 VC0003D VICTORIA POWER 5 8 pass 1A 35 WC0028Q TXU GENERATION COMPANY LP PERMIAN BSN STM ELE 60 82 pass 3A 36 WE0005G LAREDO POWER 11 19 pass 2 37 YB0017V TXU GENERATION COMPANY LP GRAHAM STEAM ELECTR 19 27 pass 2 
Page 29 

EPA Texas’ BART Analysis TSD 

Table C-3 From ENVIRON App. C Table 3-2. Potential BART-eligible non-EGU sources and their VOC/PM10 emission

VOC 

ZeroOut 

PM 

ZeroOut 

ID Account Company Plant VOC (tpy) PM10 F

A

(tpy) 

1 AB0012W DUKE ENERGY FIELD SERVICES FULLERTON GAS PLANT 317 20 Pass 3 

see 

2 AC0017B ABITIBI CONSOLIDATED CORP 81 3 Pass note 

see 

3 AC0019U EXAS FOUNDRIES 180 226 Pass note 

see 

4 AG0024G PUEBLO MIDSTREAM GAS CORP FASHING PLANT 39 1 Pass note 5 BG0045E CAPITOL CEMENT DIV CAPITOL PORTLAND CEMENT 95 40 Pass 2C 6 BJ0001T CHEMICAL LIME LTD CHEMICAL LIME--CLIF 4 224 Pass 3 7 BL0002S AMOCO CHEMICAL CO CHOCOLATE BAYOU PLN 417 130 Pass 1A 

see 

8 BL0021O BASF CORPORATION FREEPORT SITE 38 4 Pass note 9 BL0038U SOLUTIA INC 264 23 Pass 2AC 

10 BL0082R THE DOW CHEMICAL CO PLANT B 517 78 Pass 2C 11 BL0113I EQUISTAR 282 65 Pass 1A 12 BL0268B EQUISTAR CHEMICALS LP 397 13 Pass 3 13 BL0758C CHEVRON PHILLIPS CHEMICAL SWEENY COMPLEX 109 103 Pass 1A 

see 

14 CA0011B J.L. DAVIS GAS PROCESSING LULING GAS PLANT 9 1 Pass note 15 CB0003M ALCOA ALUMINA & CHEMICALS POINT COMFORT PLANT 176 296 Pass 1A 16 CB0028T UNION CARBIDE CORPORATION SEADRIFT PLANT 492 60 Pass 1A 17 CG0010G INTERNATIONAL PAPER CO 1322 578 Pass 2AA 

see 

18 CG0012C ENBRIDGE PIPELINES BRYANS MILL PLANT 2 1 Pass note 
Page 30 

EPA Texas’ BART Analysis TSD 

19 CI0022A DYNEGY MIDSTREAM SERVICES 553 21 Pass 3 20 CR0020C COPANO PROCESSING LP 551 10 pass 1A 

see 

21 CY0019H DYNEGY MIDSTREAM SERVICES WADDELL COMPRESSOR 35 1 pass note 22 EB0057B HUNTSMAN POLYMERS 878 107 pass 1A 

see 

23 EB0197H DUKE ENERGY FIELD SERVICES 245 7 pass note 24 ED0011D CHAPARRAL STEEL MIDLOTHIAN 340 157 pass 3 25 ED0034O NORTH TEXAS CEMENT COMPANY NORTH TEXAS CEMENT 15 448 pass 1B 26 ED0051O OWENS CORNING 100 298 pass 3 27 ED0066B TXI OPERATIONS, L.P. MIDLOTHIAN PLANT 18 85 pass 1A 28 FG0036G TXI OPERATION LP CLODINE EXPANDED SH 5 77 pass 1A 29 GB0001R BP AMOCO CHEMICAL COMPANY BP AMOCO CHEMICAL T 500 93 pass 3 

BP PRODUCTS NORTH AMERICA IN 

30 GB0004L TEXAS TEXAS CITY REFINERY 1180 737 pass 2B 31 GB0055R MARATHON ASHLAND PETROLEUM TEXAS CITY REFINERY 478 272 pass 3 32 GB0073P VALERO REFINING CO TEXAS TEXAS CITY REFINERY 153 150 pass 3 

see 

33 GB0076J UNION CARBIDE CORP VINYL ACETATE FACIL 154 0 pass note 34 GH0003Q CABOT CORPORATION PAMPA PLANT 1025 55 pass 3 35 GH0004O CELANESE CHEMICAL CHEMICAL 

MANUFACTUR

644 194 pass 1A 

36 HD0029C A.N.R. PIPELINE COMPANY E.G. HILL COMPRESSO 82 33 pass 2B 

see 

37 HG0033B EQUISTAR CHEMICALS LP CHANNELVIEW COMPLEX 29 0 pass note 38 HG0048L LYONDELL CITGO REFINING L P LYONDELL-CITGO REFI 888 284 pass 1A 39 HG0126Q HOECHST CELANESE CHEMICAL CLEAR LAKE PLANT 334 601 pass 3 40 HG0130C VALERO REFINING TEXAS LP HOUSTON REFINERY 252 188 pass 2C 41 HG0175D CROWN CENTRAL PETROLEUM PASADENA PLANT 570 687 pass 1B 
Page 31 

EPA Texas’ BART Analysis TSD 

42 HG0218K EI DUPONT 306 35 pass 3 43 HG0228H EXXON CHEMICAL CO BAYTOWN OLEFINS PLA 209 50 pass 2C 44 HG0229F EXXONMOBIL CHEMICAL CO BAYTOWN CHEMICAL PL 746 75 pass 3 45 HG0232Q EXXONMOBIL CORP EXXONMOBIL REF & SU 3983 761 pass 1B 46 HG0310V CHEVRON PHILLIPS CHEMICAL CHEVRON CHEMICAL CO 364 211 pass 1A 

see 

note 

47 HG0558G ATOFINA CHEMICALS INC ATOFINA INC 11 1 pass 48 HG0562P TEXAS PETROCHEMICALS LP TX PETROCHEMICALS L 48 51 pass 3 49 HG0632T ROHM & HAAS TEXAS DEER PARK PLANT 578 234 pass 3 50 HG0659W SHELL OIL CO DEER PARK PLANT 2219 359 pass 2AB 51 HG0697O RHODIA, INC. HOUSTON PLANT 3 28 pass 1A 52 HG1451S OSYVINYLSLP 245 36 pass 2C 53 HH0019H NORIT AMERICAS INC NORIT AMERICAS INC 163 168 pass 3 54 HH0042M EASTMAN CHEMICAL COMPANY TEXAS OPERATIONS 4257 273 pass 1B 55 HK0014M TEXAS LEHIGH CEMENT CO TEXAS LEHIGH CEMENT 153 272 pass 2AC 

see 

note 

56 HR0018T VALENCE MIDSTREAM LTD COMO PLT 7 6 pass 57 HT0011Q ALON USA LP BIG SPRING REFINERY 517 91 pass 2B 58 HT0027B SID RICHARDSON CARBON CO BIG SPRING CARBON B 17 19 pass 2C 

DEGUSSA ENGINEERED CARBONS 

59 HW0008S BORGER BORGER CARBON BLACK 100 71 pass 2AC 

see 

note 

60 HW0013C CHEVRON PHILLIPS CHEMICAL CO 407 9 pass 61 HW0017R SID RICHARDSON CARBON BORGER CARBON 

BLACK

2 111 pass 1A 

62 HW0018P PHILLIPS 66 CO BORGER REFINERY 145 21 pass 3 

see 

note 

63 HX2897U BP AMOCO POLYMERS INC 249 8 pass 64 JB0016M VINTAGE PETROLEUM, INC. W RANCH COMP STA VA 53 13 pass 2C 65 JC0003K WESTVACO 103 236 pass 2B 
Page 32 

EPA Texas’ BART Analysis TSD 

66 JE0005H ATOFINA PETROCHEMICALS INC PORT ARTHUR REFINER 632 529 pass 2C 

THE GOODYEAR TIRE AND RUBBER CO 67 JE0039N 1528 33 pass 1A 

see 

note 

68 JE0042B PREMCOR REFINING GROUP PORT ARTHUR REFINER 135 3 pass 69 JE0052V HUNTSMAN CORPORATION PORT NECHES PLANT 304 58 pass 3 

see 

note 

70 JE0065M EXXON MOBIL CHEMICAL CO 104 2 pass 71 JE0067I EXXONMOBIL OIL CORP BEAUMONT REFINERY 462 574 pass 3 

see 

72 JE0091L SUN MARINE TERMINAL 40 0 pass note 73 JE0135Q HUNTSMAN PETROCHEMICAL CORP 520 68 pass 2B 74 JE0343H BMC HOLDINGS INC BMC HOLDINGS INC 24 63 pass 1A 75 JH0025O JOHNS MANVILLE INTERNATIONAL 75 141 pass 2AC 76 MB0123F LEHIGH CEMENT COMPANY LEHIGH PORTLAND CEM 10 225 pass 2B 

see 

note 

77 MC0002H ENBRIDGE PIPELINE TILDEN GAS PLANT 36 0 pass 78 MH0009H CELANESE LIMITED 127 496 pass 1B 79 MM0001T ALCOA INC ALCOA SANDOW PLANT 152 254 pass 1A 80 MR0008T DIAMOND SHAMROCK REFINING MCKEE PLANTS 818 128 pass 2C 81 NB0037F TXI OPERATIONS, L.P. STREETMAN PLANT 284 181 pass 3 82 NE0022I TICONA POLYMERS INC BISHOP FACILITY 309 31 pass 3 83 NE0027V CITGO REFINING & CHEMICALS CORPUS CHRISTI REFI 666 622 pass 1A 84 NE0043A VALERO REFINING COMPANY COMPLEX 6B 7 8 823 175 pass 3 85 NE0120H KOCH PETROLEUM GROUP LP CORPUS CHRISTI EAST 183 288 pass 3 86 NE0122D FLINT HILLS RESOURCES LP WEST REFINERY 240 13 pass 1A 

see 

87 OA0024I NORTHERN NATURAL GAS CO SPEARMAN PLANT 38 13 pass note 88 OC0007J EI DUPONT DENEMOURS & CO SABINE RIVER WORKS 1040 87 pass 2AC 

see 
Page 33 

EPA Texas’ BART Analysis TSD 

89 PE0024Q DUKE ENERGY FIELD SERVICES WAHA GAS PLANT 116 4 pass note 

see 

note 

90 TH0010I AUSTIN WHITE LIME CO 4 367 pass 91 VC0008Q EI DU PONT DE NEMOURS & CO EI DU PONT DE NEMOU 230 187 pass 2B 92 WH0014S WICHITA FALLS PLANT 191 81 pass 2C 

see 

note 

93 WN0021G DEVON GAS SERVICES, L.P. BRIDGEPORT 226 28 pass 

see 

note 

94 WN0042V DYNEGY MIDSTREAM SERVICES 3 0 pass 
Page 34 

EPA Texas’ BART Analysis TSD 

VOC SCREENING ANALYSIS 

Figure C-1 (App. C –ENVIRON Report Figure 3-1.) The visibility impacts (del-dv) at 

Class I areas from all eligible Texas BART sources’ VOC emissions. 

The visibility impacts due to all Texas BART sources’ VOC emissions were not significant because 

they were well below 0.5 del-dv threshold, both for the 98th percentile value and the maximum impact at 

all Class I areas. Therefore, each Texas BART source’s VOC emissions are < 0.5 del-dv and screened 

out from further BART considerations for VOC emissions.

 
Page 35 

EPA Texas’ BART Analysis TSD 

Figure C-2 (App. C –ENVIRON Report Figure 3-2.) The visibility impacts (del-dv) at Class I 

areas from all eligible Texas BART sources’ PM (PM2.5/PM10) emissions. 

The preliminary zero-out modeling indicated that the visibility impacts at one or more Class I areas 

due to PM emissions from all potential BART-eligible sources in Texas exceeded the 0.5 del-dv 

threshold (using the 98th percentile), therefore the group of all Texas BART PM sources were 

analyzed further. 

Inert Primary PM Screening Analysis 

Because only primary PM emissions were being considered in these runs, chemistry was not 

needed. The procedures for evaluating the visibility impacts from the inert CAMx 

simulations are the same as described for the PM impacts from the zero-out runs. However, 

instead of using concentrations differences from the 2002 BART base case and 2002 zeroout case, the total concentrations due to all BART sources in each BART group from the 

CAMx inert simulation were used. 

The larger visibility impacts from the group of all PM BART eligible emission sources 

occurred at the Class I areas near sources in northeast Texas (Caney Creek/CACR, HerculesGlade/HEGL, and Upper Buffalo/UPBU), while smaller impacts appeared near sources in 

west Texas (Big Bend/BIBE and Guadalupe Mountains/GUMO) and north Texas (Wichita 

Mountains/WIMO). Given this information, TCEQ had further analyses carried out by 

dividing the BART PM sources into subgroups, with consideration of their proximity to 

Class I areas and the magnitude of their PM emissions.

Prior to conducting this further PM modeling analyses though, some BART sources were 

removed from the screening process. Six non-EGU accounts (WN0021G, EB0197H, 

OA0024I, TH0010I, HX2897U, and AC0019U) were dropped from the potential BARTeligible list based on information supplied by the sources to the TCEQ (see note – ‘No 
Page 36 

EPA Texas’ BART Analysis TSD 

longer BART – eligible’ in Table C-3). Additionally, TCEQ eliminated 15 sources with PM 

emissions under 10 tons per year (tpy) based on the establishment of a de minimis threshold 

using 375 tpy and 50 km or 750 tpy and 100 km (based on 2002 actuals) as suggested in 

EPA’s BART Guidance (EPA, 2005). TCEQ then divided the remaining sources were into 

EGU and non-EGU categories. These source groups were then further divided into 

subgroups. Inert model runs were conducted with these groups, and if any source groups 

failed the 0.5 del-dv threshold, the sources in that group were broken down even further and 

re-analyzed. A list of BART-eligible EGU and non-EGU sources’ PM10 emissions and their 

associated groups are shown in Tables C-2 and C-3, respectively. 

The subgroup analyses for primary PM emissions were made for each of these BART source 

groups using CAMx inert simulations. The results for potential BART EGU sources are 

shown in Figures C-3a-e. The potential BART-eligible EGU sources, except EGU source 

group #1B and 3B (account TF0013B and TF0012D, respectively), passed the BART PM 

group screening test. Accounts TF0013B and TF0012D impacted visibility impairment at 

CACR by approximately 0.61 del-dv and 0.72 del-dv, respectively. Further modeling 

analyses using better estimates of the highest actual 24-hour emissions may produce values < 

0.5 del-dv for these two sources

Figure C3a (App. C –ENVIRON Report Figure 3-3a.) Visibility impacts (del-dv) at Class I areas 

due to PM emissions from EGU Source Group 1A

 
Page 37 

EPA Texas’ BART Analysis TSD 

Figure C-3b. (App. C –ENVIRON Report Figure 3-3b.)Visibility impacts (del-dv) at Class I areas 

due to PM emissions from EGU Source Group 1B, account TF0013B. Del-dv > 0.5 at CACR for all 

metrics and HEGL/UPBU for 2 of 4 metrics 

Figure C-3c. (App. C –ENVIRON Report Figure 3-3c.) Visibility impacts (del-dv) at Class I areas 

due to PM emissions from EGU Source Group 2.

 
Page 38 

EPA Texas’ BART Analysis TSD 

Figure C-3d. (App. C –ENVIRON Report Figure 3-3d.)Visibility impacts (del-dv) at Class I areas 

due to PM emissions from EGU Source 

Group 3A 

Figure C-3e. (App. C –ENVIRON Report Figure 3-3e.) Visibility impacts (del-dv) at 

Class I areas due to PM emissions from EGU Source Group 3B, account TF0012D. Del-dv > 

0.5 at CACR for all metrics and HEGL/UPBU for 3 of 4 metrics. 
Page 39 

EPA Texas’ BART Analysis TSD 

EPA Review Summary 

EGU Group 1A includes TXU Martin Lake, TXU Sandow, and CPS Sommers Deely which 

had 881 tpy, 735 tpy, and 1473 tpy of PM respectively and 8 other smaller PM sources spread 

over Texas. The results for all the PM Max Avg and 98th percentile were below 0.5 deciview 

for all Class I areas. EGU Group 1B (Account TF0013B- TXU Monticello) had 3297 tpy of 

PM and did not screen out for this modeling. EGU Group #2 (13 units – 2 large and 11 

smaller PM emissions) was below 0.5 deciview for all Class I areas for all metrics with the 

exception of being slightly over at GUMO for the PM Max B20% metric. EGU Group #3A 

was approximately 0.4 deciviews for all metrics at all Class I areas. EGU Group 3B (Account 

TF0012D- SWEPCO Welsh) had 1755 tpy of PM and did not screen out for this modeling as 

several metrics were above 0.5 del-dv including the PM 98th Percentile value at CACR. 

Therefore of the 37 EGU facilities screened for PM emissions, 35 screened out and do not 

have to be further analyzed for PM BART.

As discussed above, each Texas BART eligible source’s VOC emissions are < 0.5 del-dv and 

screened out from further BART considerations for VOC emissions. 

Non-EGU PM screening analysis 

The results for potential BART-eligible non-EGU sources are shown in Figure 3-4a-f. The 

potential BART eligible non-EGU sources, except non-EGU group 2AA (account CG0010G), 

are under the 0.5 del-dv threshold and therefore may require no further BART analyses. 

Account CG0010G estimated 98th percentile visibility impairment at CACR was 0.92 del-dv 

and therefore must perform further analyses. 

 
Page 40 

EPA Texas’ BART Analysis TSD 

Figure C-4a. (App. C –ENVIRON Report Figure 3-4a.) Visibility impacts (del-dv) at 

Class I areas due to PM emissions from non-EGU Source Group 1A. 

Figure C-4b. (App. C –ENVIRON Report Figure 3-4b.) Visibility impacts (del-dv) at Class 

I areas due to PM emissions from non-EGU Source Group 1B 

 
Page 41 

EPA Texas’ BART Analysis TSD 

Figure C-4c. (App. C –ENVIRON Report Figure 3-4c.) Visibility impacts (deldv) at Class I areas due to PM emissions from non-EGU Group Source 2AA, account 

CG0010G. Del-dv > 0.5 at CACR for all metrics and HEGL/UPBU for 2 and 3 of 4 

metrics, respectively. 

Figure C-4d. (App. C –ENVIRON Report Figure 3-4d.) Visibility impacts (del-dv) at Class I areas 

due to PM emissions from non-EGU Source Group 2AB 

 
Page 42 

EPA Texas’ BART Analysis TSD 

Figure C-4e. (App. C –ENVIRON Report Figure 3-4e.) Visibility impacts (del-dv) at Class I areas 

due to PM emissions from non-EGU Source Group 2AC 

Figure C-4f. (App. C –ENVIRON Report Figure 3-4f.) Visibility impacts (del-dv) at Class I areas 

due to PM emissions from non-EGU Source Group 3 

 
Page 43 

EPA Texas’ BART Analysis TSD 

EPA Review Summary Non-EGU PM CAMx screening 

In evaluating the Figures above and Table C-3 for the source groupings several conclusions 

can be made. Source Groups 1A, 2AB, and 2AC all screen out using the PM 98th Percentile 

and Maximum for the Average approach. Source Group 2AA did not screen out because all 

four metrics, including the 98th Percentile for the Average approach, were above 0.5 delta dv 

at CACR. Therefore Source Group 2AA (International Paper - Account CG0010G) did not 

screen out in source grouping approach with CAMx and was further evaluated using 

CALPUFF. 

Source Group 1B was below 0.5 delta-dv for the 98th percentile Max Avg, but was 

approximately 0.65 delta-dv for CACR for the Maximum Max. Average. Using the initial 

methodology of the 98th percentile, the group screens out and TCEQ and EPA agreed there 

were reasonable arguments for not looking back on the initial work with the tougher threshold 

of Maximum Max Average. At the time EPA looked at the sources in each of the groups that 

passed and that did not pass. Group 1B included 5 facilities: 1. North Texas Cement near 

Midlothian with 448/898 PM tpy 2002 actual/modeled (approx. 370 km to CACR) ; 2. Crown 

Refinery near Pasadena with 687/1374 PM tpy 2002 actual/modeled (approx. 530 km to 

CACR); 3. ExxonMobil Ref and SU near with 761/1522 PM tpy 2002 actual/modeled 

(approx. 520 km to CACR); 4. Eastman Chemical near Longview with 273/546 PM tpy 2002 

actual/modeled (234 km to CACR); and 5. Celanese Limited near Pasadena with 496/992 PM 

tpy 2002 actual/modeled (approx. 530 km to CACR). Being the closest, Eastman is the most 

likely contributor to the highest values at CACR. Overall there are three other facilities in the 

Houston area that also likely transport towards CACR when Eastman does. Eastman had 

much lower emissions than the three Houston area facilities 546 tpy vs. 3888 tpy of PM 

modeled. Weighting the emissions and the proximity difference that Eastman is approximately 

50% of the distance of the Houston area sources, we think it is reasonable to determine that 

the contribution due to Eastman on the Maximum Max Avg. value is likely less than 0.5 delta 

dv. We think it is reasonable to determine that the contribution of Eastman to CACR is such 

that a determination can be made that the facility would screen out if individual source impact 

modeling were done with even the Maximum Max Avg. impact value. Therefore EPA does 

not have a concern with screening out Eastman. 

The other Source Group that had this same conundrum was Source Group 3 which was below 

0.5 delta-dv for the 98th percentile Max Avg, but was approximately 0.65 delta-dv for CACR 

for the Maximum Max. Average. Source Group 3 included 23 sources with no specific 

sources overly dominating the group and potential impacts at CACR. Norit was the closest to 

CACR at a distance of 209 km (near Marshall). There were about 6 facilities SW, S, or SE of 

Dallas (on the order of 350-500 km from CACR), a number of facilities in the Houston area 

(on the order of 500 km from CACR), a few in the Beaumont area, a couple in the 

Corpus/Victoria area, and about 3 facilities in the panhandle. Comparing emissions, Norit had 

336 tpy vs. 8368 tpy of PM for the rest of the group with the lion’s share being from sources 

in the Houston and Beaumont areas. We think it is reasonable to determine that the 

contribution of Norit to CACR is such that a determination can be made that the facilities 

would screen out if individual source impact modeling were done with even the Maximum 

Max Avg. impact value. Therefore EPA does not have a concern with screening out Norit. 

We concur with TCEQ’s assessment that all but three BART eligible sources screened out of 

BART applicability for PM. The thee sources are two EGU facilities (TF0013B, TF0012D) 

and one non-EGU account (CG0010G) {Commonly known in the RH SIP as TXU Monticello 

and Southwestern Public Service’s Welsh facilities and International Paper Co. near 

Texarkana}. We also concur with TCEQ’s conclusions that all BART eligible sources 

screened out from further BART analysis. 
Page 44 

EPA Texas’ BART Analysis TSD 

Other Issues

TCEQ indicated that one of the BART-eligible EGU sources, account CI0012D, was not 

included in TCEQ’s PM zero-out modeling runs. This account has a relatively small PM Q/D 

of 0.25 tpy/km and the nearest Class I area is BIBE. Other accounts in the same area around 

Corpus Christi, which have PM Q/D ranging from 0.02 - 4.7, were all screened out in the 

analysis above. EPA concurs with TCEQ’s analysis that account CI0012D can be reasonably 

assumed to pass the screening analysis as well based on the PM Q/D comparison. 

 
Page 45 

EPA Texas’ BART Analysis TSD 

PROCEDURES FOR SCREENING MODELING OF BART SOURCES’ SO2 AND NOX

EMISSIONS 

PSAT Visibility Impacts

The sulfate and nitrate families of PSAT tracers were utilized for the PSAT BART screening 

analysis. The visibility impacts at each Class I area were calculated in a similar manner as 

described above for the zero-out modeling, only the PSO4 and PNO3 concentrations from each 

PSAT BART source group were used in the extinction equation. The IMPROVE reconstructed 

mass extinction equation for each potential BART-eligible source group included the sulfate 

and nitrate components 

bgroup = 

bSO4 + bNO3

bSO4 = 3 

[(NH4)2SO4]f(RH) 

bNO3 = 3 

[NH4NO3]f(RH)

The f(RH) are the monthly average relative humidity adjustment factors, as recommended 

by EPA’s guidance. The concentrations in the square brackets are in μg/m3 and are the 

sulfate and nitrate from the PSAT output for each potential BART-eligible PSAT source 

group (i). Sulfate and nitrate are assumed to be fully neutralized by ammonium: 

[(NH4)2SO4] = 1.375 x PS4i

[NH4NO3] = 1.290 x PN3i

The Haze Index (HI) for the source group is calculated in deciview from the source 

group’s extinction plus natural background using the following formula: 

HIgroup = 10 ln[(bgroup + bnatural)/10] 

The source’s HI is compared to natural conditions to assess the significance of the source’s 

visibility impact. EPA guidance lists natural conditions (bnatural) by Class I area in terms of 

Mm-1 and assumes clean conditions with no anthropogenic or weather interference. The 

visibility significance metric for evaluating BART sources is the change in deciview (del-dv) 

from the source’s and natural conditions haze indices: 

del-dv = HIgroup – HInatural = 10 ln[(bgroup + bnatural)/10] - 10 ln[bnatural/10] 

Modeling Policy and Procedures 

The non-EGU potential BART-eligible sources were initially divided up into 10 source groups 

for the PSAT screening analysis. CAMx/PSAT was run for the 2002 annual year on the 36/12 

km grid with each potential BART-eligible source flagged to use the new PSAT PiG feature. 
Page 46 

EPA Texas’ BART Analysis TSD 

The CENRAP average non-EGU BART SO2 and NOX emissions (Indicated in Table C-4) 

were doubled to provide a conservative estimate of maximum 24-hour actual emissions. 

As described for the zero-out run, if the del-dv due to all sources in a source group at every 

Class I area and for all days from 2002 is < 0.5 dv, then each potential BART-eligible source in 

the source group would be < 0.5 dv. Thus, each source would contribute insignificantly to 

visibility impairment. 

PSAT Modeling for SO2 and NOx emissions was performed for non-EGUs. The PM2.5 

provisions of the Clean Air Interstate Rule (CAIR) applied to Texas at the time of Texas’ 

submittal. The premise at the time was that CAIR satisfies the BART SO2 and NOx 

requirements for EGUs covered under CAIR PM2.5 requirements and no analysis was needed 

for these EGUs for BART for SO2 and NOX. 

Non-EGU Potential BART-Eligible Sources’ SO2 and NOx Emissions 

Table C-4 lists potential BART-eligible non-EGU sources’ SO2 and NOx emissions and their 

associated source groups that were used to perform screening modeling. Unlike the zero-out 

CAMx modeling for VOC and PM emissions and inert CAMx modeling for PM emissions, the 

group screening modeling for SO2 and NOx emissions used the CAMx PSAT to track the 

SO4 and NO3 contributions due to each BART source group. 

The PSAT screening analysis initially divided up the potential BART-eligible non-EGU 

sources into 10 source groups (referred to as the Round 1 groupings in Table C-4). The 

assignment of potential BART-eligible non-EGU sources to the Round 1 source groups was 

made by ranking each source in terms of their total SO2 and NOx emissions divided by 

distance to the closest Class I area (i.e., Q/D). The top ten percent of the sources with the 

highest Q/D values were assigned to Group 1 and so on, so that the lower the source group 

number the more likely the group would have a potential visibility impact at a Class I areas due 

to higher emissions and/or closeness to a Class I area. Each BART source group in the 

preliminary run consisted of approximately 9 to 11 separate accounts (i.e., potential BARTeligible non-EGU sources). 
Page 47 

EPA Texas’ BART Analysis TSD Table C-4 (EPA App. C Table 4-1) Classification of potential BART-eligible non-EGU sources into Source Groups for BART group  screening modeling using CAMx/PSAT/PiG. 

Round Round Needs

NOx* 

(tpy) 

SO2* (tpy) 1 2

Further 

Analysis 

for SOx 

and NOx

ID Account Company Plant Group Group Not

DUKE ENERGY FIELD 

1 AB0012W SERVICES FULLERTON GAS PLANT 1256 2374 1 X 

INTERNATIONAL PAPER 

2 CG0010G CO 1619 374 1 X 

NORTH TEXAS 

3 ED0034O CEMENT COMPANY NORTH TEXAS CEMENT 2572 4434 1 X 

BP PRODUCTS NORTH 

4 GB0004L AMERICA IN TEXAS TEXAS CITY REFINERY 6320 4084 1 X 

CHEMICAL 

5 GH0004O CELANESE CHEMICAL MANUFACTUR 2609 4015 1 X 6 HG0659W SHELL OIL CO DEER PARK PLANT 5811 6968 1 X 

DEGUSSA ENGINEERED BORGER CARBON 

7 HW0008S CARBONS BORGER BLACK 445 3604 1 X 

SID RICHARDSON BORGER CARBON 

8 HW0017R CARBON BLACK 638 3535 1 X 9 JE0067I EXXONMOBIL OIL CORP BEAUMONT REFINERY 3871 9747 1 X 

10 HD0029C A.N.R. PIPELINE COMPANY E.G. HILL COMPRESSO 4028 0.4 2 X 
Page 48 

EPA Texas’ BART Analysis TSD 

11 HG0232Q EXXONMOBIL CORP EXXONMOBIL REF & SU 4372 1301 2 X 

EASTMAN CHEMICAL 

12 HH0042M COMPANY TEXAS OPERATIONS 2612 105 2 X 13 HR0018T VALENCE MIDSTREAM LTD COMO PLT 247 2743 2 X 14 HT0011Q ALON USA LP BIG SPRING REFINERY 344 3311 2 X 

SID RICHARDSON 

15 HT0027B CARBON CO BIG SPRING CARBON B 185 3149 2 X 

DIAMOND SHAMROCK 

16 MR0008T REFINING MCKEE PLANTS 1549 2245 2 X 17 NB0037F TXI OPERATIONS, L.P. STREETMAN PLANT 691 3468 2 X 

CITGO REFINING & 

18 NE0027V CHEMICALS CORPUS CHRISTI REFI 1201 5103 2 X 19 ED0066B TXI OPERATIONS, L.P. MIDLOTHIAN PLANT 1388 893 3 X 

MARATHON ASHLAND 

20 GB0055R PETROLEUM TEXAS CITY REFINERY 1134 2329 3 X 21 GH0003Q CABOT CORPORATION PAMPA PLANT 1335 342 3 X 

LYONDELL CITGO 

22 HG0048L REFINING L P LYONDELL-CITGO REFI 2288 789 3 X 23 HG0697O RHODIA, INC. HOUSTON PLANT 6.8 5099 3 X 24 HH0019H NORIT AMERICAS INC NORIT AMERICAS INC 489 784 3 X 

VALERO REFINING 

25 NE0043A COMPANY COMPLEX 6B 7 8 1318 3233 3 X 
Page 49 

EPA Texas’ BART Analysis TSD 

EI DUPONT DENEMOURS 

26 OC0007J & CO SABINE RIVER WORKS 3125 7.3 3 X 

DUKE ENERGY FIELD 

27 PE0024Q SERVICES WAHA GAS PLANT 131 1571 3 X 

HOECHST CELANESE 

28 HG0126Q CHEMICAL CLEAR LAKE PLANT 946 1202 4 X 

VALERO REFINING 

29 HG0130C TEXAS LP HOUSTON REFINERY 461 2243 4 X 

CROWN CENTRAL 

30 HG0175D PETROLEUM PASADENA PLANT 566 1291 4 X 

TEXAS LEHIGH CEMENT 

31 HK0014M CO TEXAS LEHIGH CEMENT 1156 805 4 X 

ATOFINA 

32 JE0005H PETROCHEMICALS INC PORT ARTHUR REFINER 796 1007 4 X 33 MC0002H ENBRIDGE PIPELINE TILDEN GAS PLANT 1.9 2276 4 X 

EI DU PONT DE NEMOURS 

34 VC0008Q & CO EI DU PONT DE NEMOU 2723 18 4 X 

DUKE ENERGY FIELD No lon

BART

35 EB0197H SERVICES 709 0 4 see note eligible 

DEVON GAS SERVICES, L.P. 

No lonBARTeligible 36 WN0021G BRIDGEPORT 936 0.8 4 see note 

CAPITOL CEMENT DIV 
Page 50 

EPA Texas’ BART Analysis TSD 

37 BG0045E CAPITOL PORTLAND CEMENT 718 850 5 2 X 38 BJ0001T CHEMICAL LIME LTD CHEMICAL LIME-- CLIF 700 509 5 1 39 BL0002S AMOCO CHEMICAL CO CHOCOLATE BAYOU PLN 2006 12 5 1 40 BL0082R THE DOW CHEMICAL CO PLANT B 1895 1.7 5 2 X 41 HG0632T ROHM & HAAS TEXAS DEER PARK PLANT 748 1076 5 1 42 JC0003K WESTVACO 1489 72 5 2 X 

LEHIGH CEMENT 

43 MB0123F COMPANY LEHIGH PORTLAND CEM 531 576 5 3 X 44 MM0001T ALCOA INC ALCOA SANDOW PLANT 36 1458 5 3 X 

NORTHERN NATURAL GAS CO 

No lonBARTeligible 45 OA0024I SPEARMAN PLANT 868 0 5 see note see note 

PUEBLO MIDSTREAM GAS 

46 AG0024G CORP FASHING PLANT 20 1005 6 4 X 

J.L. DAVIS GAS 

47 CA0011B PROCESSING LULING GAS PLANT 90 1021 6 4 X 

DYNEGY MIDSTREAM 

48 CY0019H SERVICES WADDELL COMPRESSOR 537 0.7 6 3 X 

CHAPARRAL STEEL Exclud

(VOC 

49 ED0011D MIDLOTHIAN 490 122 6 see note model

out) 
Page 51 

EPA Texas’ BART Analysis TSD 

50 HG0310V CHEVRON PHILLIPS CHEMICAL CHEVRON CHEMICAL CO 1013 44 6 5 51 HW0018P PHILLIPS 66 CO BORGER REFINERY 590 59 6 4 X 

THE GOODYEAR TIRE AND 

52 JE0039N RUBBER CO 1137 3.8 6 4 X 

HUNTSMAN 

53 JE0052V CORPORATION PORT NECHES PLANT 942 8.8 6 5 54 JE0343H BMC HOLDINGS INC BMC HOLDINGS INC 1192 4.3 6 3 X 

Exclud(VOC 

55 EB0057B HUNTSMAN POLYMERS 432 2.1 7 see note model

out) 

VALERO REFINING CO 

56 GB0073P TEXAS TEXAS CITY REFINERY 637 264 7 6 X 57 HG0228H EXXON CHEMICAL CO BAYTOWN OLEFINS PLA 1005 5.7 7 5 

EXXONMOBIL CHEMICAL 

58 HG0229F CO BAYTOWN CHEMICAL PL 701 104 7 7 X 59 HG0558G ATOFINA CHEMICALS INC ATOFINA INC 18 920 7 6 X 

VINTAGE PETROLEUM, 

60 JB0016M INC. W RANCH COMP STA VA 1036 0 7 6 X 

HUNTSMAN Exclud

(VOC 

61 JE0135Q PETROCHEMICAL CORP 735 1.8 7 see note model

out) 
Page 52 

EPA Texas’ BART Analysis TSD 

62 NE0022I TICONA POLYMERS INC BISHOP FACILITY 1129 4.8 7 5 

KOCH PETROLEUM 

63 NE0120H GROUP LP CORPUS CHRISTI EAST 915 65 7 6 X 

Exclud(VOC 

64 BL0113I EQUISTAR 636 1.4 8 see note model

out) 

ALCOA ALUMINA & 

65 CB0003M CHEMICALS POINT COMFORT PLANT 951 20 8 7 X 66 ED0051O OWENS CORNING 329 26 8 8 X 67 FG0036G TXI OPERATION LP CLODINE EXPANDED SH 194 635 8 7 X 

BP AMOCO CHEMICAL 

68 GB0001R COMPANY BP AMOCO CHEMICAL T 813 5 8 7 X 

CHEVRON PHILLIPS Exclud

(VOC 

69 HW0013C CHEMICAL CO 48 280 8 see note model

out) 

70 MH0009H CELANESE LIMITED 612 43 8 8 X 71 WH0014S WICHITA FALLS PLANT 107 28 8 8 X 

No lonBART

72 TH0010I AUSTIN WHITE LIME CO 375 253 8 see note eligible 

Exclud(VOC 

73 BL0038U SOLUTIA INC 502 10 9 see note model

out) 

CHEVRON PHILLIPS 

74 BL0758C CHEMICAL SWEENY COMPLEX 356 15 9 9 X 
Page 53 

EPA Texas’ BART Analysis TSD 

UNION CARBIDE 

75 CB0028T CORPORATION SEADRIFT PLANT 463 0.1 9 8 X 76 CG0012C ENBRIDGE PIPELINES BRYANS MILL PLANT 84 0.3 9 9 X 

DYNEGY MIDSTREAM Exclud

(VOC 

77 CI0022A SERVICES 406 1.6 9 see note model

out) Exclud(VOC 

78 CR0020C COPANO PROCESSING LP 454 1.6 9 see note model

out) Exclud(VOC 

79 HG0218K EI DUPONT 160 175 9 see note model

out) 

TEXAS PETROCHEMICALS 

80 HG0562P LP 

TX PETROCHEMICALS L 

334 1.9 9 9 X 

FLINT HILLS 

81 NE0122D RESOURCES LP WEST REFINERY 284 27 9 9 X 

ABITIBI CONSOLIDATED 

82 AC0017B CORP 28 0.3 10 10 X 83 BL0021O BASF CORPORATION FREEPORT SITE 323 0.1 10 10 X 

Exclud(VOC 

84 BL0268B EQUISTAR CHEMICALS LP 6.2 0.8 10 see note model

out) 

CHANNELVIEW Exclud

(VOC 

85 HG0033B EQUISTAR CHEMICALS LP COMPLEX 11 0 10 see note model

out) 
Page 54 

EPA Texas’ BART Analysis TSD 

Exclud(VOC 

86 HG1451S OSYVINYLSLP 89 0.7 10 see note model

out) 

PREMCOR REFINING 

87 JE0042B GROUP PORT ARTHUR REFINER 96 0.4 10 10 X 

EXXON MOBIL CHEMICAL 

Exclud(VOC 

88 JE0065M CO 29 0 10 see note model

out) Exclud(VOC 

89 JE0091L SUN MARINE TERMINAL 0.9 0.1 10 see note model

out) 

JOHNS MANVILLE INTERNATIONALJOHNS MANVILLE 

90 JH0025O 97 19 10 10 X 

No lonBART

91 AC0019U TEXAS FOUNDRIES 3 2 10 see note eligible 

BP AMOCO POLYMERS No lon

BART

92 HX2897U INC 31 0.3 10 see note eligible 

Exclud(NOx<20tpy and 

93 GB0076J UNION CARBIDE CORP VINYL ACETATE FACIL 0 0 see note see note Sox<2

y) Exclud(NOx

DYNEGY MIDSTREAM SERVICES 

<20tpy and 
Page 55 

EPA Texas’ BART Analysis TSD 

* SO2 and NOX average actual emissions from 2002 CENRAP database, modeling used doubled values as an estimate of 24-hour maximum emissi

94 WN0042V 0 0 see note see note SOx<2

y) 
Page 56 

EPA Texas’ BART Analysis TSD 

Figure C-5 (EPA App. C. Figure 4-1.) Preliminary Round 1 visibility impacts (del-dv) at Class I areas 

from potential BART- eligible non-EGU source groups 1 to 4 (highest Q/D). 

SO2 and NOX Visibility Impacts from PSAT From Round 1 of Grouping

The preliminary Round 1 PSAT results indicated that all 10 BART source groups exceeded the 

0.5 del-dv threshold of the key significance metric (98th percentile change in deciview over 

annual average natural conditions) in at least one Class I area as shown. Therefore, the Round 1 

BART grouping failed the screening test. As shown in Figure C-5, the first four BART source 

groups (i.e., ones with the highest Q/D values) contributed 2 to 3.5 del-dv at a Class I area using 

the key metric (98th percentile/annual average, unfilled triangle in Figure C-5), whereas source 

groups 5 through 10 contributed < 2 del-dv. The largest estimated visibility impairments 

occurred at the Class I areas near northeast Texas, in Arkansas and southern Missouri (CACR, 

HEGL, and UPBU), while the next highest estimated visibility impacts occurred northern Texas 

(WIMO in Texas) and near western Texas (BIBE and GUMO). 

TCEQ decided that SO2 and NOx emissions for sources in the first four groups from Round 1 

would be unlikely to screen out even with further reducing the group sizes based on the size of 

impacts predicted. TCEQ concentrated the next Round (Round 2) grouping analysis of the SO2/ 

NOx BART screening modeling effort on lower contributing BART source groups (source 

groups 5 to 10 From Round 1), which are composed of 56 accounts. Some of these accounts 

were removed from Round 2 PSAT analyses for two reasons: based on continuing analysis by 
Page 57 

EPA Texas’ BART Analysis TSD 

the TCEQ on BART eligibility, some of the non-EGU accounts were found to not be BARTeligible as mentioned in the zero-out modeling; and 13 sources that were classified as potential 

BART-eligible sources because their VOC emissions exceeded the emissions thresholds and had 

to be assessed for VOC impairment at any Class I area discussed above. Once VOCs for all 

BART eligible sources screened out all the VOC sources, there were 13 facilities where the 

actual SO2 and/or NOX emissions from these sources are typically under 20 tpy. The TCEQ 

determined that the emissions from these 13 sources were not significant so they removed them 

from the PSAT list. The remaining sources from the preliminary Round 1 modeling source 

groups 5 through 10 were then divided into 10 source groups for Round 2 screening modeling by 

TCEQ using a significance threshold > 250 tpy. Because VOC emissions from all BART sources 

were shown to contribute insignificantly to visibility. 

TCEQ’s Round 2 of PSAT modeling indicated that only BART source Group 1 and Group 5 did 

not exceed the 0.5 dv threshold for the key visibility metric, as shown in Figure 4-2 (unfilled 

triangle); therefore, sources in these two groups may be determined to need no further BART 

analysis. The other Round 2 BART source groups estimated changes in deciview ranging from 

0.7-1.2 del-dv, and therefore failed the group screening test. The largest visibility impairments 

occurred at the Class I areas near northeast Texas (CACR, HEGL, and UPBU), while second 

highest visibility impairments were estimated near north Texas (WIMO). 

Figure C-6 (EPA App. C Figure 4-2.) Round 2 visibility impacts (del-dv) at Class I areas from potential 

BART-eligible non-EGU Source Groups 1 to 10 SO2 and NOX emissions. 
Page 58 

EPA Texas’ BART Analysis TSD 

As discussed above, using the initial methodology of the 98th percentile and Max Average, the 

Round 2 Groups 1 and 5 screened out, and TCEQ and EPA agreed that there were reasonable 

arguments for not looking back on the initial work with the tougher threshold of Maximum Max 

Average. At the time EPA looked at the sources (and each groups modeled impacts) in each of 

the groups that passed and would not pass using the Maximum Max Average. Round 2 Group 1 

passes with using both metrics, so EPA has no concern with the sources in this Group being 

screened out of BART analysis. Round 2 Group 5 has a value of approximately 0.75 delta-dv for 

the Maximum Max Avg. value, therefore further examination of the group is needed to 

determine if using the different threshold is truly a concern to whether the sources of Group 5 

would screen out using this alternate test approach that was used in later analyses. Group 5 

included 4 facilities: 1. Huntsman Corporation Port Neches Plant near Beaumont with 951/1902 

NOX+SO2 tpy 2002 actual/modeled (approx. 471 km to BRET and 500 km to CACR); 2. Exxon 

Chemical Co. Baytown Olefins near Baytown with 1011/2022 NOX+SO2 tpy 2002 

actual/modeled (approx. 530 km to CACR); 3. Phillips Chemical Chevron Chemical near 

Houston with 1057/2114 NOX+SO2 tpy 2002 actual/modeled (approx. 520 km to CACR); 4. 

Ticona Polymers Bishop Facility southwest of Corpus Christi with 1134/2268 NOX+SO2 tpy 

2002 actual/modeled (564 km to BIBE and approx. 900 km to CACR. Given that the three 

facilities (Huntsman, Exxon, and Phillips) are all similarly sized, in the modeling they probably 

have approximately the same impact at CACR and BRET and the fourth facility is much further 

away so its impacts would be smaller. Therefore the approximate 0.75 del-dv could be 

conservatively split 3 ways for the three facilities and each facility likely has Maximum Max 

Average impacts on the order of 0.25-0.3 del-dv at most. Therefore refined modeling of each of 

the facilities would show that they would screen out even using the more stringent test of 

Maximum Max Average that was used in later refined screening. The Q/D for all four facilities 

in this group to the Closest Class I area to the facility are very close with values of 1.91 for 

Exxon, 2.02 for Huntsman, 2.03 for Phillips, and 2.01 for Ticona. The closesness of the Q/D 

ratio further highlights that impacts at respective Class I areas of similar distance would have 

very similar impacts. We think it is reasonable to determine that the contributions of the three 

facilities to the CACR are similar with similar emissions and distances such that a determination 

can be made that each of the four facilities would screen out if individual source impact 

modeling were done with even the Maximum Max Avg. impact value. Therefore EPA does not 

have a concern with screening out all the sources in Round 2 Group 5 and using the individual 

sources for the model plant evaluation.

We have included a Table from the TX RH SIP (Table 9-3), that lists all the BART eligible sources that 

were screened out based on the cumulative CAMx modeling in Table C-5. We note that Sic code ‘49xx’ 

represents the EGUs. 

C-2 Model Plant Screening Approach 

In EPA’s BART Guidelines EPA outlined that states could develop model plants based on 

existing modeling that screened out certain facilities that had similar characteristics. The model 

plant approach is basically to use specific modeling (Model Plant) of a source 50/100 km away 
Page 59 

EPA Texas’ BART Analysis TSD 

from a Class I area and with a potential emissions of 500/1000 tpy of SO2 and NOX that results 

in an insignificant del-dv (< 0.5 del-dv) and then evaluate other facilities that are further away 

and compare their emissions levels and determine if the other facilities can be screened out. 

NOX and SO2 Model Plant Approach and Screening 

After conducting the CAMx source group modeling, the TCEQ developed Texas model plants 

based on the CAMx modeling results. The model plants are discussed in the addendums to the 

CAMx modeling report, Addendum I, BART Exemption Screening Analysis, and Addendum II, 

BART Exemption Screening Analysis. Both addendums are contained in TX RH SIP Appendix 

9-5. 

From EPA’s BART Guidelines, a model plant analysis may illustrate that facilities/sources with 

certain characteristics do not contribute to visibility impairment in the Class I areas. For this 

analysis, TCEQ used the modeling results for sources that successfully passed the threshold test 

in the CAMx modeling and used these Texas Model Plants (TMPs) to establish distance and 

emission rate thresholds that would indicate that a source would not have a significant impact on 

a given Class I area. Based on the modeling results, BART sources that emit less than a certain 

amount per year and are located a certain distance from the nearest Class I area can be exempted. 

In carrying out this approach, first TCEQ identified the TMPs. In the PSAT screening analysis 

for non-EGU sources, 7 potential BART-eligible sources (From SO2+NOX Round 2 Groups 1 

and 5) were shown to not contribute significantly to visibility impairment and therefore were 

declared exempt from BART. These seven sources (listed in Table C-5) were then used as model 

plants to exempt certain other potential BART-eligible sources that share specific characteristics. 

To account for regional factors, potential BART-eligible sources were only compared to the 

TMP that shares the same nearest Class I area. BART sources that emit combined SO2 and NOX

emissions less than the TMPs and are located further from the nearest Class I area than the TMPs 

may be declared exempt from BART. 

Table C-5. List of TMPs that passed the SO2 and NOX emissions exemption screening analysis 

in the Group runs. 

Model 

Plant Account Company Site

NOx + 

SO2 

(tpy) 

Closest 

Class I 

Area

Closest 

Distance 

to Class I

Area (km)

Q/D 

(tpy 

/km) 

1

2

3

4

5

6

7

BL0002S 

JE0052V 

BJ0001T 

NE0022I 

HG0228H 

HG0310V 

HG0632T 

AMOCO 

CHEMICAL CO 

HUNTSMAN 

CORPORATION 

CHEMICAL LIME 

LTD 

TICONA 

POLYMERS INC 

EXXON 

CHEMICAL CO 

CHEVRON 

PHILLIPS 

CHEMICAL 

ROHM & HAAS 

TEXAS 

CHOCOLATE BAYOU PLN 

PORT NECHES PLANT 

CHEMICAL LIME—CLIF 

BISHOP FACILITY 

BAYTOWN OLEFINS PLA 

CHEVRON CHEMICAL CO 

DEER PARK PLANT 

2018 

951 

1209 

1134 

1011 

1057 

1824 

BRET 

BRET 

WIMO 

BIBE 

CACR

CACR 

CACR

587

471

352

564

530

521

534

3.44 

2.02 

3.43 

2.01 

1.91 

2.03 

3.41 
Page 60 

EPA Texas’ BART Analysis TSD 

Note: Model Plants 1, 3, and 7 were in Round 2 Group 1 and Model Plants 2, 4, 5, and 6 were in Round 2 Group 5. 

TCEQ initially evaluated all of the potential BART-eligible sources in the PSAT Round 1 groups 

that have Q/D values higher than the TMPs. None of the sources from Round 1 passed this TMP 

analysis. TCEQ appropriately limited the comparison of BART-eligible sources with TMPs that 

share the same nearest Class I area. Therefore, the seven TMPs limit the potential analysis to the 

BART eligible sources that are closest to Class I areas BIBE, BRET, CACR and WIMO. 

Account CY0019H, which is nearest to GUMO, was not compared in this analysis because there 

were no model plants for GUMO. 

The potential BART-eligible sources that were in the groups that did not pass in the PSAT 

Round 2 modeling are grouped by nearest Class I area in Table C-6. Sources in each group were 

compared to the TMP that shares the same nearest Class I area. If the source passed the two 

criteria, of: for a specific TMP, the emissions have to be less than the TMP; and, the source must 

be further away from the closest Class I area than the same TMP that passed the emissions test. 

If a facility passes both tests for one of the TMPs, then it may be exempt from BART. For 

example, Account NE0120H is closest to BIBE and so was compared to the TMP 4 in Table C-5. 

The combined SO2 and NOX emissions of this account (979 TPY) are less than the emissions 

from TMP 4 (1134 TPY) and the source is located further from the nearest Class I area (592 km) 

than the TMP 4 (564 km). For these reasons, Account NE0120H is exempt from BART using the 

TMP criteria. If there are more than one representative TMP in a group, potential BART-eligible 

sources are only required to pass the criteria of one of the TMPs in that group. For instance, 

there are two TMPs representing BRET, TMP 1 and 2, Account JE0042B passed the criteria 

(less emissions and greater distance) of TMP 2 and therefore can be exempt from BART. 

Seventeen (17) sources passed the TMP analysis. Note by using the closest Class I area in 

general the sources have similar source-receptor relationships between the facilities being 

evaluated and the TMPs. TCEQ provided several Figures with the sources and model plants in 

relation to the respective Class I area to support the similar source receptor relationship. 

Furthermore, the TMP’s have a mix of low and mid-height emissions and the facilities that were 

screened out have similar enough dispersion profile in comparison to the TMPs. 

 
Page 61 

EPA Texas’ BART Analysis TSD 

Table C-6. List of potential BART-eligible non-EGU sources included in the NOX and SO2 

TMP analysis in TCEQ’s Addendum I.

Nearest 

Class I 

Area Account Company Site 

NOx

+ SO2

(tpy) 

Closest 

Distance 

from 

Class I 

Area 

(km) TMP Passed 

Distance 

further 

from a 

Class I 

Area 

than 

TMP km 

BIBE 

AG0024G PUEBLO MIDSTREAM GAS

CORP 

FASHING PLANT 1025 494 

4 143 

BG0045E CAPITOL CEMENT DIV

CAPITOL 

PORTLAND CEMENT 1568 482 

4 230 

CA0011B J.L. DAVIS GAS PROCESSING LULING GAS PLANT 1111 534 4 243 

CB0003M ALCOA ALUMINA &

CHEMICALS 

POINT COMFORT

PLANT 

971 654 

4 YES 175 

CB0028T UNION CARBIDE 

CORPORATION 

SEADRIFT PLANT 464 636 

4 YES 149 

JB0016M VINTAGE PETROLEUM, INC. W RANCH COMP

STA VA 

1036 646 

4 YES 182 

NE0120H KOCH PETROLEUM GROUP

LP 

CORPUS CHRISTI

EAST 

979 592 

4 YES 49 

NE0122D FLINT HILLS RESOURCES LP WEST REFINERY 311 582 4 YES 42 

BRET BL0021O BASF CORPORATION FREEPORT SITE 323 607 1 YES 32 

2 YES 179 

BL0082R THE DOW CHEMICAL CO PLANT B 1897 605 1 YES 33 

2 179 

GB0001R BP AMOCO CHEMICAL

COMPANY 

BP AMOCO

CHEMICAL T 

818 560 1 31 

2 YES 118 

GB0073P VALERO REFINING CO

TEXAS 

TEXAS CITY

REFINERY 

901 559 1 33 

2 YES 116 

JE0039N THE GOODYEAR TIRE AND

RUBBER CO 

1141 497 

1 127 

2 27 

JE0042B PREMCOR REFINING GROUP PORT ARTHUR

REFINER 

97 472 

1 139 

2 YES 13 

JE0343H BMC HOLDINGS INC BMC HOLDINGS INC 1196 481 1 144 

2 11 

CACR AC0017B ABITIBI CONSOLIDATED

CORP 

28 348 5 182 

6 173 

7 186 

BL0758C CHEVRON PHILLIPS

CHEMICAL 

SWEENY COMPLEX 370 619 5 YES 105 

6 YES 117 

7 YES 97 

CG0012C ENBRIDGE PIPELINES BRYANS MILL

PLANT 

84 140 5 391 

6 382 

7 395 

FG0036G TXI OPERATION LP CLODINE

EXPANDED SH 

829 551 5 YES 68 

6 YES 78 

7 YES 59 
Page 62 

EPA Texas’ BART Analysis TSD 

Nearest 

Class I 

Area Account Company Site 

NOx

+ 

SO2

(tpy) 

Closest 

Distance 

from 

Class I 

Area 

(km) TMP Passed 

Distance 

further 

from a 

Class I 

Area 

than 

TMP km 

HG0229F EXXONMOBIL CHEMICAL 

CO 

BAYTOWN 

CHEMICAL PL 

805 531 5 YES 1 

6 YES 13 

7 8 

HG0558G ATOFINA CHEMICALS INC ATOFINA INC 939 532 5 YES 16 

6 YES 26 

7 8 

HG0562P TEXAS PETROCHEMICALS 

LP 

TX 

PETROCHEMICALS 

L 

336 540 5 YES 24 

6 YES 35 

7 YES 15 

JC0003K WESTVACO 1560 458 5 113 

6 101 

7 122 

MH0009H CELANESE LIMITED 655 649 5 YES 141 

6 YES 152 

7 YES 132 

WIMO ED0051O OWENS CORNING 356 308 3 107 

HW0018P PHILLIPS 66 CO BORGER REFINERY 649 263 3 564 

JH0025O JOHNS MANVILLE 

INTERNATIONALJOHNS 

MANVILLE 

116 293 

3 75 

MB0123F LEHIGH CEMENT COMPANY LEHIGH PORTLAND 

CEM 

1107 387 

3 YES 42 

MM0001T ALCOA INC ALCOA SANDOW 

PLANT 

1493 488 

3 137 

WH0014S WICHITA FALLS PLANT 135 97 3 257 

As part of this Addendum TCEQ also addressed an error in the CAMx PM source group 

modeling of Account BG0057U (CPS – Sommer Deely Spruce Power Plant). The previous 

modeling included the stack diameter as 1 foot for two units and TCEQ had an analysis redone 

using the correct diameters (26 ft). The new modeling (using the same doubling of 2002 typical 

emissions had a PM Maximum Max Avg. impact of approximately 0.14 del-dv at WIMO and 

0.13 at BIBE. Therefore Account #BG0057U still screened for PM impacts and because it is an 

EGU it was screened out for BART (based on CAIR coverage for BART for NOX and SO2).
Page 63 

EPA Texas’ BART Analysis TSD 

PM Model Plant Approach and Screening 

TCEQ also had a second Addendum they developed that is being included as Appendix E 

(“Addendum II Bart Exemption Screening Analysis – Primary Particulate Plant Methodology: 

Texas PM Model Plants (TPMMP)”). In the PM source group analysis, 104 plants screened out. 

TCEQ used the results of modeling for these sources to crate TPMMPs that could be used for 

evaluating a few facilities that were not included in the original analysis. 

TCEQ developed EGU TPMMPs and non-EGU TPMMPs and evaluated like source/emissions 

against similar model plants (e.g., an EGU would only be compared with an EGU, and a nonEGU with a non-EGU). TCEQ developed analysis of these 104 sources based on comparing the 

emissions of the model plants, concentrations at Class I areas estimated with CAMx, the old 

IMPROVE equation and the effective extinction efficiency coefficient. They also used a 

dispersion principals to come up with a transport coefficient for comparison of different 

distances between the model plant and the plant to be tested. 

In essence, the test boils down to two tests. Both are a scalar test approach so the typical 2002 

emissions are used in the calculations instead of the CAMx modeled emissions. 

Test One - If the plant being accessed (target plant) has a coarse mass component less 

than the model plant’s coarse mass (using 0.6 * Coarse Mass typical 2002 emissions), 

then fine mass component Q’ F (using the fine mass calculations of the IMPROVE 

equation) of the target source (noted by the apostrophe) must be less than Q F of the 

model plant (lack of apostrophe denotes model plant from CAMx screening). 

Test Two - If the target plant’s coarse mass is greater than the model plant, then the 

addition of fine mass and coarse mass for the target plant must be less than the 

combination of fine mass and coarse mass components for the model plant. 

Q’ F + Q’ C ≤ Q F + Q C 

Overall we have reviewed this methodology and approve this analysis for these limited sources 

(only two sources that were not modeled otherwise relied solely on the TPMMP comparison to 

screen out). 

The two additional facilities that TCEQ evaluated were Account CI0012D – Texas Genco LP 

and Account HW0004D – Agrium. 

Table B-1 in Appendix E lists the 104 TPMMPs with Q’ F , Q’ C , e, and relevant information 

about the date utilized for the TPMMP. Table B-3 in Appendix E compares the calculated 

metrics for Account CI0012D with the metrics for a number of model plants. The Account 

CI0012D passed for several TPMMPs including TPMMP #10 for impacts at CACR and BRET, 

therefore screening out from further BART consideration. 

Table B-2 in Appendix E includes screening analysis for Account HG0659 –Shell Oil Co. that 

also screened out with CALPUFF modeling. Evaluating the table indicates the facility also 

screened out when compared to TPMMPs #58 and #73 for impacts at CACR and TPMMP #52, 

#58, and #73 for impacts at BRET. 
Page 64 

EPA Texas’ BART Analysis TSD 

Table B-4 in Appendix E compares the calculated metrics for Account HW0004D – Agrium with 

the metrics for a number of model plants. Evaluating the table indicates the facility screened out 

when compared to TPMMP #94 for impacts at WIMO and TPMMP #103 for impacts at SACR. 

It passed for some of the other model plants that Texas evaluated, but the model plants were not 

in the same general alignment as the Agrium facility to the Class I Area. 

EPA SUMMARY 

Using these different modeling approaches, TCEQ was able to screen out a large number of the 

sources from additional BART consideration. We have reviewed the different techniques as 

discussed above and concur with TCEQ’s screening analysis results as discussed above. We have 

included a Table that is similar to the Table 9-3 in the TX RH SIP, that lists all the BART 

eligible sources that were screened out based on the cumulative CAMx modeling - Table C-7. 

We note that Sic code ‘49xx’ represents the EGUs.
Page 65 

EPA Texas’ BART Analysis TSD 

Table C-7 (TX RH SIP Table 9-3): BART-Eligible Sources Screened Out Using Cumulative CAMx 

Modeling and Model Plant Tests

No. Account Source Regulated Entity SIC

1 TG0044C AEP TEXAS RN101531226 4911 

2 CD0013K AEP TEXAS CENTRAL COMPANY RN102560687 4911 

3 NE0024E AEP TEXAS CENTRAL COMPANY RN100642040 4911 

4 NE0026A AEP TEXAS CENTRAL COMPANY RN100552181 4911 

5 JI0030K AEP TEXAS NORTH COMPANY RN100215557 4911 

6 CB0003M ALCOA ALUMINA & CHEMICALS RN100242577 2819 

7 HG0558G ATOFINA CHEMICALS INC RN100209444 2869 

8 BL0021O BASF CORPORATION RN100218049 2869 

9 GB0001R BP AMOCO CHEMICAL COMPANY RN102536307 2869 

10 MH0009H CELANESE LIMITED RN100258060 2869 

11 ED0011D CHAPARRAL STEEL MIDLOTHIAN RN100216472 3312 

12 BJ0001T CHEMICAL LIME LTD RN100219856 3274 

13 BL0758C CHEVRON PHILLIPS CHEMICAL RN100825249 2869 

14 HG0310V CHEVRON PHILLIPS CHEMICAL RN103919817 2869 

15 HW0013C CHEVRON PHILLIPS CHEMICAL RN102320850 2869 

16 BG0057U CITY PUBLIC SERVICE RN100217975 4911 

17 BG0186I CITY PUBLIC SERVICE RN100217835 4911 

18 CR0020C COPANO PROCESSING LP RN101271419 1321 

19 CI0022A DYNEGY MIDSTREAM SERVICES RN100222900 1321 

20 HG0218K EI DUPONT RN100225085 2869 

21 EE0029T EL PASO ELECTRIC CO RN100211309 4911 

22 TH0004D ELECTRIC UTILITY DEPT RN100219872 4911 

23 MQ0009F ENTERGY GULF STATES INC RN100226877 4911 

24 OC0013O ENTERGY GULF STATES INC RN102513041 4911 

25 BL0113I EQUISTAR RN100218601 2869 

26 BL0268B EQUISTAR CHEMICALS LP RN100237668 2821 

27 HG0228H EXXON CHEMICAL CO RN102212925 2869 

28 JE0065M EXXON MOBIL CHEMICAL CO RN100211903 2821 

29 HG0229F EXXONMOBIL CHEMICAL CO RN102574803 2869 

30 NE0120H Flint Hills Resources RN102534138 2911 

31 NE0122D FLINT HILLS RESOURCES LP RN100235266 2911 

32 JE0052V HUNTSMAN CORPORATION RN100219252 2869 

33 JE0135Q HUNTSMAN PETROCHEMICAL RN100217389 2869 

34 BL0002S Ineos Olefins & Polymers RN100238708 2869 

35 WE0005G LAREDO POWER RN100213909 4911 

36 MB0123F LEHIGH CEMENT COMPANY RN100218254 3241 

37 NE0025C LON C HILL POWER RN100215979 4911 

38 BC0015L Lower Colorado River Authority RN102038486 4911 

39 FC0018G Lower Colorado River Authority RN100226844 4911 
Page | 66 

EPA TX BART ANALYSIS TSD 

No. Account Source Regulated Entity SIC

40 HG1575W Lyondell Chemical RN100633650 2869 

41 HG1451S OXYVINYLSLP RN102518065 2821 

42 JE0042B PREMCOR REFINING GROUP RN102584026 2911 

43 HG0632T ROHM & HAAS TEXAS RN100223205 2869 

44 BL0038U SOLUTIA INC RN100238682 2869 

45 GJ0043K SOUTHWESTERN ELECTRIC POWER RN102156916 4911 

46 LN0081B 

SOUTHWESTERN PUBLIC SERVICE 

(FORMERLY XCEL) RN100224765 4911 

47 ME0006A SOUTHWESTERN ELECTRIC POWER RN100542596 4911 

48 PG0040T SOUTHWESTERN PUBLIC SERVICE RN100224641 4911 

49 PG0041R SOUTHWESTERN PUBLIC SERVICE RN100224849 4911 

50 JE0091L SUN MARINE TERMINAL RN100214626 4226 

51 WN0042V TARGA RN102552387 1311 

52 CI0012D TEXAS GENCO LP RN100825371 4911 

53 FG0020V TEXAS GENCO LP RN100888312 4911 

54 HG0562P TEXAS PETROCHEMICALS LP RN100219526 2869 

55 BL0082R THE DOW CHEMICAL CO RN100225945 2869 

56 NE0022I TICONA POLYMERS INC RN101625721 2869 

57 FI0020W TXU BIG BROWN COMPANY LP RN101198059 4911 

58 DB0251U TXU ELECTRIC COMPANY RN101559854 4911 

59 FB0025U TXU GENERATION COMPANY LP RN102285855 4911 

60 HQ0012T TXU GENERATION COMPANY LP RN100664812 4911 

61 MB0116C TXU GENERATION COMPANY LP RN102566494 4911 

62 MM0023J TXU GENERATION COMPANY LP RN102147881 4911 

63 MO0014L TXU GENERATION COMPANY LP RN102285848 4911 

64 RL0020K TXU GENERATION COMPANY LP RN102583093 4911 

65 TA0352I TXU GENERATION COMPANY LP RN100693308 4911 

66 WC0028Q TXU GENERATION COMPANY LP RN102183969 4911 

67 YB0017V TXU GENERATION COMPANY LP RN102563426 4911 

68 GB0076J UNION CARBIDE CORP RN100219351 2869 

69 CB0028T UNION CARBIDE CORPORATION RN102181526 2869 

70 GB0073P VALERO REFINING CO TEXAS RN100238385 2911 

71 VC0003D VICTORIA POWER RN100214980 4911 

72 JB0016M VINTAGE PETROLEUM INC RN100214592 1311 

 
Page | 67 

EPA TX BART ANALYSIS TSD 

D. Single Source Analysis 

One of the air quality modeling approaches suggested by the EPA in the BART Guidelines is an 

individual source attribution approach using CALPUFF or other models such as a photochemical model 

(CAMx). Specifically, this entails modeling source-specific BART- eligible units and comparing modeled 

impacts to a particular deciview threshold. From discussions with EPA, TCEQ proposed that sources 

within 300 km of a Class I area should be screened out using CALPUFF; sources beyond 300 km could 

be screened out with CALPUFF, or could conduct a more refined approach with CAMx. 

D-1 CALPUFF Modeling 

In this section we will discuss the CALPUFF modeling that was conducted in evaluating and screening 

BART eligible sources by facilities and by TCEQ. 

Initially CENRAP developed a CALPUFF modeling protocol to go with the CALMET data that 

CENRAP was having developed (Appendix A). TCEQ also developed a CALPUFF modeling protocol, 

Best Available Retrofit Technology (BART) Modeling Protocol to Determine Sources Subject to BART 

in the State of Texas (Appendix D), for further evaluating and screening which BART eligible sources. 

The TCEQ protocol provided the option of a more refined modeling analysis if the facility did not screen 

out using the potentially more conservative CENRAP modeling databases and protocol. The TCEQ 

modeling protocol provided the approach for several facilities without having to have a refined modeling 

protocol for each facility. TCEQ included their modeling protocol as Appendix 9-7: CALPUFF 

Modeling Guidelines in the TX RH SIP. Appendix 9-7 also contains a summary report from TCEQ for 

each modeling demonstration. 

CALPUFF Modeling Using CENRAP with No-OBS CALMET data 

A CALPUFF modeling demonstration was conducted using three years of CENRAP developed 

CALMET data. 

The CENRAP developed a set of three overlapping CALMET/CALPUFF modeling domains in 

the central United States covering the southern, central and northern portion of the CENRAP 

region (Fig. D-1). The dimensions of the domain were selected to include the State of interest, 

plus Class I areas in nearby states, and to provide a sufficient buffer between the Class I areas 

and the domain boundaries (e.g., 50 km) to assure that CALPUFF’s intermediate calculations, 

called “puffs”, are not eliminated that may temporarily leave the domain and later reemerge 

and cause visibility impacts at a Class I area. The operator/owner may elect to restrict the 

computational CALPUFF domain to a subset of the CALMET domain to include the facilities 

of interest and only areas where significant impacts are feasible, extending at least 50 km in all 

directions beyond the class I areas within 300km of a source. 

   
Page | 68 

EPA TX BART ANALYSIS TSD 

Figure D-1. CENRAP CALMET 6km meteorological modeling domains 

CENRAP used MM5 meteorology data for the years 20012

, 20023 and 20034 (at 36 km 

resolution to create 6-km resolution CALMET 

The three-year CALMET dataset was developed under CENRAP contract using only prognostic 

modeling data from MM5 (“No Obs” mode). Modeling was conducted for SO2, NOX, and PM. 

Because this was a deviation from the 40 CFR Part 51 Appendix W 8.3.1.2.(d) that observations 

                                                            

2 “Annual Application of MM5 for Calendar Year 2001”. McNally, D. E., Alpine Geophysics, LLC, Arvada, CO. 

178 pp., 2003 (http://www.epa.gov/scram001/reports/2001_36_mm5_summary_final.pdf); “Annual Meteorological 

Modeling Protocol: Annual Application of the MM5 to the Continental United States”, McNally, D. E., and T. W. 

Tesche, 2002. (http://www.epa.gov/scram001/meteorology/metgridmodeling/annual_prot_1.1.pdf). 3

 “Meteorological modeling protocol: IDNR 2002 annual MM5 application, Johnson, M.T., Iowa Department of 

Natural Resources, Air Quality Bureau, Des Moines, IA, 2003; Iowa DNR 2002 Annual MM5 Modeling Project 

Johnson, M.T., Presented at the August 11th 2003 CENRAP Workgroup Meeting in Bloomington, Minnesota, 2003. 

(http://www.epa.gov/scram001/adhoc/johnson_2003.pdf)

4 Baker, K., 2005. MM5 Model Performance: Great Lakes Region: 2002-04. Ad-Hoc Meteorological Modelers 

Group Meeting, Lakewood, Colorado. 11 June. (http://www.epa.gov/scram001/adhoc/baker_2005.pdf); Baker, K., 

M. Johnson, et al. 2005. Meteorological modeling performance summary for application to PM2.5/haze/ozone 

modeling projects, Prepared by the Lake Michigan Air Directors Consortium and the Midwest Regional Planning 

Organization, Des Plaines, IL 

(http://www.deq.state.va.us/export/sites/default/info/pdf/vchec/BoardBook/attachments/Attachment_8.pdf) 
Page | 69 

EPA TX BART ANALYSIS TSD 

should be included in the meteorological data generation with CALMET, it raised into question 

the appropriate metric to use. EPA Region 6 and 7 representatives reviewed the issue with 

consultation within EPA’s Office of Air Quality Planning and Standards (OAQPS) and decided 

the no-obs CALMET data could still be used but the 1st High or Maximum should be used for 

comparing to the 0.5 deciview threshold (or other threshold less than 0.5 deciview if a state was 

using a different value). We also indicated that if facilities did not pass using the No-Obs 

CENRAP CALMET data that they could submit a refined CALPUFF modeling protocol that 

would include running CALMET with observations included and then the normal 98th percentile 

(H8H) could be used to compare with the deciview threshold for screening out from further 

BART analysis. 

Some facilities were able to just use the CENRAP CALMET with No-OBS and screen out. In 

these cases PM was assumed to be PM2.5 because the applicant did not have particle size or 

speciation data available. The modeled source parameters and emission rates have been reviewed 

by TCEQ and EPA and are consistent with data in the modeling reports provided by the facility. 

CALPUFF and CALPOST model option selections are consistent with representations made in 

the modeling report and the TCEQ BART Modeling Protocol. 

The maximum visibility impacts for all Class I areas evaluated (Class I areas based on TCEQ 

CAMx model runs) were less than 0.5 dv for the following facilities: 

1. Alcoa, Inc. – Rockdale Operations; Account Number: MM-0001-T; Regulated Entity 

Number: RN100221472; Customer Reference Number: CN600130884; Nearest 

City, County: Rockdale, Milam 

2. Alon USA, L.P; Account Number: HT-0011-Q; Regulated Entity Number: 

RN100250869; Customer Reference Number: CN600881783 ;Nearest City, County: 

Big Spring, Howard 

3. TOTAL Petrochemicals USA Inc.; Account Number: JE-0005-H; Regulated Entity 

Number: RN102457520; Customer Reference Number: CN600582399; Nearest 

City, County: Port Arthur, Jefferson 

4. Cabot Corporation; Account Number: GH-0003-Q; Regulated Entity Number: 

RN100221761; Customer Reference Number: CN600124911; Nearest City, County: 

Pampa, Gray 

5. DCP Midstream Fullerton Gas Plant; Account Number: AB-0012-W; Regulated 

Entity Number: RN100218684; Customer Reference Number: CN601229917; 

Nearest City, County: Andrews, Andrews 

6. Huntsman Polymers Corporation; Account Number: EB-0057-B; Regulated Entity 

Number: RN101867554; Customer Reference Number: CN600132104; Nearest 

City, County: Odessa, Ector 

7. Owens Corning Insulating System, LLC; Account Number: ED-0051-O; Regulated 

Entity Number: RN100223585; Customer Reference Number: CN600124838; 

Nearest City, County: Waxahachie, Ellis 

8. ConocoPhillips – Borger Refinery; Account Number: HW-0018-P; Regulated Entity 

Number: RN102495884; Customer Reference Number: CN601674351; Nearest 

City, County: Borger, Hutchinson; 
Page | 70 

EPA TX BART ANALYSIS TSD 

9. Rhodia, Inc. – Houston Plant; Account Number: HG-0697-O; Regulated Entity 

Number: RN100220581; Customer Reference Number: CN600125330; Nearest 

City, County: Houston, Harris 

10. Sid Richardson Carbon, Ltd.; Account Number: HT-0027-B; Regulated Entity 

Number: RN100226026; Customer Reference Number: CN600131171; Nearest 

City, County: Big Spring, Howard 

11. American Electric Power (AEP) - Southwestern Electric Power Company; Account 

Number: TF-0012-D; Regulated Entity Number: RN100213370; Customer 

Reference Number: CN600126767; Nearest City, County: Pittsburgh, Titus (NOTE: 

Only modeled PM because of CAIR coverage for SO2 and NOX). 

12. Temple-Inland; Account Number: OC-0019-C; Regulated Entity Number: 

RN100214428; Customer Reference Number: CN602787053; Nearest City, County: 

Orange, Orange 

13. Texas Lehigh Cement Company, L.P.; Account Number: HK-0014-M; Regulated 

Entity Number: RN102597846; Customer Reference Number: CN600127666; 

Nearest City, County: Buda, Hays 

14. NRG Texas, L.P. (P.H. Robinson Electric Generating Station); Account Number: 

GB-0037-T; Regulated Entity Number: RN101062826; Customer Reference 

Number: CN602755415; Nearest City, County: Bacliff, Galveston; (NOTE: Only 

modeled PM because of CAIR coverage for SO2 and NOX). 

15. TXU Energy (Monticello Facility); Account Number: TF-0013-B; Regulated Entity 

Number: RN102285921; Customer Reference Number: CN600135511; Nearest 

City, County: Mount Pleasant, Titus; (NOTE: Only modeled PM because of CAIR 

coverage for SO2 and NOX). 

16. MeadWestvaco Texas, L.P.; Account Number: JC-0003-K; Regulated Entity 

Number: RN102157609; Customer Reference Number: CN601549496; Nearest 

City, County: Evadale, Jasper 

For Rhodia, Inc. – Houston Plant there were some BART-eligible units not included in the 

modeling demonstration. Given the distance to the nearest Class I area (520 km to CACR), the 

relatively small total emission rate (PM10 – 8.64 lb/hr), and the maximum visibility impact (0.24 

dv), the applicant contended that the visibility impacts should not be significantly affected by not 

having these BART-eligible units included in the modeling demonstration. Given that there is 

some headroom in the model values vs. threshold and that this is based on the maximum value 

because of the No-Obs issue, this seems to be a reasonable conclusion. 

CALPUFF Modeling Using Refined CALMET with OBS (pursuant to 

TCEQ refined CALPUFF modeling protocol)

The BART exemption modeling demonstration was conducted in two parts for many of the 

facilities and some facilities just conducted the second part (Refined CALPUFF). The first part 

consisted of a CALPUFF modeling demonstration using three years of CENRAP- developed 

CALMET data. The three-year CALMET dataset was developed using only prognostic 

modeling data from MM5 (“No Obs” mode). 
Page | 71 

EPA TX BART ANALYSIS TSD 

The second part consisted of a refined CALPUFF modeling demonstration using three years of 

CALMET data. The three-year CALMET dataset was developed using observational 

meteorological data along with prognostic modeling data from MM5. CALMET model option 

selections are consistent with representations made in the modeling report. 

For both modeling demonstrations, modeling was conducted for SO2, NOX, and PM. All PM 

was assumed to be PM2.5 because the applicant did not have particle size or speciation data 

available. 

Relevant guidance5 states that the CALPUFF model is generally applicable at distances from 50 

km to at least 200-300 km downwind of a source. BART screening analyses were performed 

with the latest versions of CALMET/CALPUFF. The BART modeling conducted by consultants 

and the State extended beyond 300km for many of the analyses. EPA, FLM representatives and 

TCEQ agreed with using CALPUFF for distances beyond 300km, and we note that EPA and 

FLM representatives have previously allowed modeling at greater than 300km. Some 

information indicates that CALPUFF may yield a more conservative result at these greater 

distances. EPA concurred with the use of CALPUFF in the context of conducting these BART 

analyses. 

According to the EPA BART Guidelines: “The emissions estimates used in the models are 

intended to reflect steady-state operating conditions during periods of high capacity 

utilization. We do not generally recommend that emissions reflecting periods of start-up, 

shutdown, and malfunction be used, as such emission rates could produce higher than normal 

effects than would be typical of most facilities. We recommend that States use the 24 hour 

average actual emission rate from the highest emitting day of the meteorological period 

modeled, unless this rate reflects periods start-up, shutdown, or malfunction.”6

The modeled source parameters and emission rates are consistent with data in the modeling 

report. CALPUFF and CALPOST model option selections are consistent with representations 

made in the modeling report and the TCEQ BART Modeling Protocol. 

The results from the initial modeling demonstration were used to determine the Class I areas to 

be considered in the refined modeling demonstration (second part). Class I areas with maximum 

                                                            

5 Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for 

Modeling Long-Range Transport and Impacts on Regional Visibility, EPA- 454/R-98-019, IWAQM, 1998; 

“Federal Land Managers’ Air Quality Related Values Workgroup (FLAG)”: Phase I Report, FLAG, USDI – 

National Park Service, Air Resources Division, Denver, CO., 2000. 

http://www.nature.nps.gov/air/Pubs/pdf/flag/FlagFinal.pdf;. EPA, 2003. “Revisions to the Guideline on Air Quality 

Models: Adoption of a Preferred Long Range Transport Model and Other Resources”; Final Rule. Fed. Reg./Vol. 

68, No. 72/Tuesday April 15, 2003/Rules and Regulations. 40 CFR51. 

6 EPA. 2005. “Regional Haze Regulations and Guidelines for Best Available Technology (BART) Determinations”. 

Fed. Reg./Vol. 70, No. 128/Wed. July 6, 2005, Rules and Regulations, pp. 39104-39172. 40 CFR Part 51, FRL7925-9, RIN AJ31.
Page | 72 

EPA TX BART ANALYSIS TSD 

visibility impacts greater than 0.5 dv were considered further in the refined modeling 

demonstration. 

For the refined modeling demonstration, the maximum 98th percentile visibility impacts for all 

Class I areas evaluated (based on initial model runs) are less than 0.5 dv. 

For Celanese Ltd. and Degussa Engineered Carbons L.P. there were some BART-eligible units 

not included in the modeling demonstration. Given that the total emissions from the units 

considered in the modeling demonstration make up approximately 98% of the PTE, the applicant 

contended that the conclusions based on the visibility impacts should not be significantly 

affected by not having these BART-eligible units included in the modeling demonstration. Given 

that there is some headroom in the model values vs. threshold, this seems to be a reasonable 

conclusion. 

These facilities did the refined CALMET modeling so they were allowed to use the 98th

percentile of the value instead of the maximum value to screen out. The following facilities did 

refined CALMET/CALPUFF modeling and screened out: 

1. Celanese Ltd; Account Number: GH-0004-O; Regulated Entity Number: 

RN101996395; Customer Reference Number: CN600130850; Nearest City, County: 

Pampa, Gray 

2. Degussa Engineered Carbons L.P.; Account Number: HW-0008-S; Regulated Entity 

Number: RN100209659; Customer Reference Number: CN600123988; Nearest 

City, County: Borger, Hutchinson 

3. Invista S.AR.L; Account Number: VC-0008-Q; Regulated Entity Number: 

RN102663671; Customer Reference Number: CN602582231; Nearest City, County: 

Victoria, Victoria 

4. Equistar Chemicals; Account Number: HG-0033-B; Regulated Entity Number: 

RN100542281; Customer Reference Number: CN600124705; Nearest City, County: 

Channelview, Harris (0.214 dv CACR and 0.212 dv at WIMO) 

5. ExxonMobil Baytown Refinery; Account Number: HG-0232-Q; Regulated Entity 

Number: RN102579307; Customer Reference Number: CN600123939; Nearest 

City, County: Baytown, Harris 

6. ExxonMobil Beaumont Refinery; Account Number: JE-0067-I; Regulated Entity 

Number: RN102450756; Customer Reference Number: CN600920748; Nearest 

City, County: Beaumont, Jefferson 

7. International Paper Co; Account Number: CG-0010-G; Regulated Entity Number: 

RN100543115; Customer Reference Number: CN601047830; Nearest City, County: 

Queen City, Cass 

8. Invista S.AR.L; Account Number: No account number; Regulated Entity Number: 

RN104392626; Customer Reference Number: CN602582231; Nearest City, County: 

Orange, Orange 

9. Ash Grove Texas, L.P.; Account Number: ED-0034-O; Regulated Entity Number: 

RN100225978; Customer Reference Number: CN600132161; Nearest City, County: 

Midlothian, Ellis 
Page | 73 

EPA TX BART ANALYSIS TSD 

10. Shell Chemical; Account Number: HG-0659-W; Regulated Entity Number: 

RN100211879; Customer Reference Number: CN601542012; Nearest City, County: 

Deer Park, Harris 

11. Eastman Chemical Company; Account Number: HH-0042-M; Regulated Entity 

Number: RN100219815; Customer Reference Number: CN601214406; Nearest 

City, County: Longview, Harrison 

12. Sid Richardson Carbon Company; Account Number: HW-0017-R; Regulated Entity 

Number: RN100222413; Customer Reference Number: CN600131171; Nearest 

City, County: Borger, Hutchinson 

13. TXI Operations, L.P.; Account Number: ED-0066-B; Regulated Entity Number: 

RN100217199; Customer Reference Number: CN600125157; Nearest City, County: 

Midlothian, Ellis 

SUMMARY 

EPA has reviewed the modeling reports and files provided for these 29 modeling efforts. 

These17 facilities that screened out using the CENRAP No-Obs data set and followed the 

approved CENRAP protocol, including model setup/flags, post processing procedures, and 

accepted versions of the CALPUFF modeling suite at the time. The12 facilities that screened out 

using the refined CALMET data set using the CENSARA MM5 data and incorporating land and 

upper air meteorological data. These 12 facilities also followed the TCEQ refined CALPUFF 

protocol and supplemented TCEQ’s protocol with any changes in a source specific modeling 

protocol and subsequent modeling report. The modeling protocol and report include details such 

as model setup/flags (CALMET and CALPUFF), post processing procedures, versions of the 

CALPUFF modeling suite at the time. Overall EPA did not find any issues/concerns with the 

modeling evaluations because they followed modeling protocols established in consultation with 

EPA and FLM representatives. We include Table D-1 below that summarizes the modeling 

results and some of the key parameters of the CALPUFF modeling and Table D-1 that 

summarizes some of the key CALMET parameters for the refined modeling sources. 

The CALPUFF modeling reports that were reviewed are in the Docket for this action. The 

CALPUFF modeling files are voluminous and being made available from EPA or TCEQ upon 

request. 

 
Page | 74 

EPA TX BART ANALYSIS TSD 

TABLE D-1 Summary of CALPUFF screening results 

Regulated          

Entity Account Source SIC 

CENRAP 

or 

Refined 

Modeling 

Del-dev Class I Area 

RN100221472 MM0001T ALCOA INC 3334 CENRAP 0.397 CACR 

RN100250869 HT0011Q ALON USA LP 2911 CENRAP 0.272 BIBE 

      ASH GROVE (formerly 

NORTH TEXAS    CENRAP 0.562 

RN100225978 ED0034O CEMENT)** 3241 REFINED 0.469 WIMO 

RN100221761 GH0003Q CABOT CORPORATION 2895 CENRAP 0.447 WIMO 

RN101996395 GH0004O CELANESE CHEMICAL 2869 REFINED < 0.5 WIMO 

RN102495884 HW0018P 

CONOCO PHILLIPS 

(formerly PHILLIPS 66 

CO) 

2911

CENRAP 0.189 WIMO 

      DCP (formerly DUKE 

ENERGY FIELD    

RN100218684 AB0012W SERVICES) 1321 CENRAP 0.407 SACR 

            

RN100209659 HW0008S DEGUSSA ENGINEERED 

CARBONS 2869

REFINED < 0.5 WIMO 

RN100219815 HH0042M EASTMAN CHEMICAL 

COMPANY 2869

CENRAP 0.463 WIMO 

RN100542281 HG0033B EQUISTAR CHEMICALS 

LP 2869

REFINED .214/.212 CACR/WIMO

RN102579307 HG0232Q EXXONMOBIL CORP 2911 REFINED 0.395 CACR 

RN102450756 JE0067I EXXONMOBIL OIL 

CORP 2911 REFINED 0.49 CACR 

RN101867554 EB0057B HUNTSMAN POLYMERS 2869 CENRAP 0.067 SACR 

RN100543115 CG0010G INTERNATIONAL 

PAPER CO 2621

REFINED 0.317 CACR 

RN104392626 OCA002B INVISTA 2869 REFINED 0.319 CACR 

RN102663671 VC0008Q INVISTA (formerly DU 

PONT DE NEMOURS) 2869

REFINED 0.228 CACR 

RN101062826 GB0037T NRG TEXAS (formerly 

TEXAS GENCO LP) 4911

CENRAP 0.32 WIMO 

RN100223585 ED0051O OWENS CORNING 3296 CENRAP 0.101 WIMO 

RN100220581 HG0697O RHODIA INC 2819 CENRAP 0.24 WIMO 

RN100211879 HG0659W SHELL OIL CO 2911 REFINED 0.106 WIMO 
Page | 75 

EPA TX BART ANALYSIS TSD 

RN100222413 HW0017R SID RICHARDSON 

CARBON 2895

REFINED 0.281 WIMO 

RN100226026 HT0027B SID RICHARDSON 

CARBON CO 2895

CENRAP 0.409 BIBE 

RN100213370 TF0012D SOUTHWESTERN 

ELECTRIC POWER 4911

CENRAP 0.348 CACR 

RN100214428 OC0019C TEMPLE-INLAND 2621 CENRAP 0.468 CACR 

RN102597846 HK0014M TEXAS LEHIGH 

CEMENT CO 3241

CENRAP 0.223 WIMO 

     

TOTAL 

PETROCHEMICALS INC 

(formerly 

  

 

RN102457520 JE0005H ATOFINA 

PETROCHEMICALS INC) 2911

CENRAP 0.029 WIMO 

RN100217199 ED0066B TXI OPERATIONS LP 3241 REFINED 0.42 WIMO 

RN102285921 TF0013B TXU GENERATION 

COMPANY LP 4911

CENRAP 0.365 CACR 

RN102157609 JC0003K WESTVACO 2631 CENRAP 0.473 WIMO 

** We note that Ash Grove has received a permit to build a new kiln and retire some of the 

existing kilns. Ash Grove is installing controls on the new kiln that will result in a net decrease 

in emissions. Based on this information the above estimates can be considered to be an 

overestimate of the new Ash Grove facility’s impacts. We evaluated this new emissions scenario 

in our FIP RP analysis and decided impacts were small enough that the source did not need to be 

further controlled for RP at this time.(See Docket materials “Midlothian Kiln Reconstruction Prj 

Emis rev 4-13-12.xlsx”, “CND-1 Ash Grove Texas LP (amendment).doc”, “TRV – 1 Ash Grove 

Texas LP (amendment).doc”, and “MRT – 1 Ash Grove Texas LP (amendment).doc”. 
Page | 76 

EPA TX BART ANALYSIS TSD 

D-2 Source Specific CAMx Modeling 

TCEQ developed “The CAMx modeling guideline, Guidance for the Application of the CAMx Hybrid 

Photochemical Grid Model to Assess Visibility Impacts of Texas BART Sources at Class I Areas”, as a 

standard protocol for refined single facility assessment with CAMx using the platform used for earlier 

screening modeling. The only major difference in the set-up was using a more recent version of the 2002 

Emissions Inventory. These six CAMx runs utilized the Typical 2002 Base F instead of the Typical 2002 

Base B Version used in the group CAMx screening analysis. The other change was the facility conducting 

the evaluation used their short-term lb/hr allowable from either a permit or emission cap instead of the 

doubling of 2002 actuals as was done in the group screening modeling. TCEQ included these reports as 

Appendices in the RH SIP and we are including the reports in our docket. TX RH SIP Appendix 9-8 

contained both the Refined CAMx Modeling Protocol and the modeling summary reports for each modeling 

demonstration. TCEQ indicated that ENVIRON maintained the CAMx modeling files for these 6 reports 

and the files were available upon request. 

We have reviewed the modeling reports for these six facilities and do not have concerns with the 

methodology used in the CAMx modeling or the inputs as indicated. These analyses used the Maximum 

Max Average impact value to compare against the 0.5 del-dv threshold. Table 9-6 presents the BARTeligible sources that screened out on an individual basis using CAMx. These values are summarized for 

the Highest impact at any Class I area evaluated (not necessarily the closest). As can be seen in Table D2, all the highest impact values were below 0.5 del-dv. More details and modeling results are available in 

the reports, but this information is enough to concur with Texas that these six facilities screened out of a 

full BART evaluation. 

   
Page | 77 

EPA TX BART ANALYSIS TSD 

Table D-2 (TH RH SIP Table 9-6): BART-Eligible Sources Screened Out on Individual Basis Using 

CAMx

Reference

Number Reference Number

Nearest 

Class I 

Area

Distance

to Nearest 

Class I 

area (km)

Emission Rate

Data Source

Highest 

Impact 

(del-dv)

Class I 

Area 

with 

Highest

Impact

RN102535077 

BP Products North 

American BRET 562 Permit Allowables 0.28 CACR/ 

UPBU 

RN102555166 

CITGO Corpus Christi 

Refinery BIBE 557 Permit Allowables 0.16 BIBE 

RN104150123 

Dow Chemical 

Company CACR 536 Permit Allowables 0.21 BRET 

RN100218130 Houston Refining LP CACR 529 

PTE, Permit 

Allowables 0.10 

UPBU/ 

CACR 

RN100716661 

Pasadena Refining 

System Inc. CACR 528 Permit Allowables 0.42 CACR 

RN100211663 

Valero Corpus Christi 

East Plant BIBE 554 

Facility Wide 

Emission Cap 0.11 

BIBE/ 

CACR 
Page | 78 

EPA TX BART ANALYSIS TSD 

E. Post-BART Emissions Reductions/Removal of Facilities 

Subsequent to the 2002 base year inventory, some BART-eligible sources reduced their permitted 

emissions. Documentation of the emission reductions is in TX RH SIP Appendix 9-11: Documentation 

of Emission Reductions. The sources and the estimated reductions were also presented in TX RH SIP 

Table 9-9 and replicated in Table E-1 below. EPA agrees that the reduction estimates are conservative 

because they are from the 2002 actual emissions level to a new potential to emit level below the 2002 

actuals. Capitol Cement shut down their BART units. 

Table E-1 (TX RH SIP Table 9-9): Post-BART Emissions Reductions at Texas Sources

No. Regulated

Entity Source Account*

NOX 

Reduced 

from 

Baseline

2002 

(tpy)

SO2

Reduced

from

Baseline

2002 

(tpy)

PM 

Reduced

from

Baseline

2002 

(tpy)

1 RN100211507 CAPITOL CEMENT DIV BG0045E 1,328 1,193 100

2 RN100227016 DOW HG0126Q 694 0 0

3 RN102450756 EXXONMOBIL OIL*** JE0067I 2.7 290 0

4 RN102609724 NORIT AMERICAS INC HH0019H** 16.6 +5.4 0

5 RN100216621 

REGENCY TILDEN GAS 

(FORMERLY ENBRIDGE 

PIPELINE) MC0002H 2 2,276 0.2

6 RN102551785 

TARGA (FORMERLY 

DYNEGY MIDSTREAM 

SERVICES) CY0019H 336 0.3 0.5

7 RN102561925 

THE GOODYEAR TIRE 

AND RUBBER CO JE0039N 89.1 +11.3 2.9

8 RN100213685 

VALENCE MIDSTREAM 

LTD HR0018T 247.1 2,743.5 5.6

9 RN100218601 

VETROTEX AMERICA 

ST. GOBAIN WH0014S 62.6 16.4 59.0

Total estimated reductions in haze emissions

= 9,485.2 tpy 2,778.1 6,535.9 168.2

*The first two letters in account number are the abbreviation for the source’s county location. See 

Appendix 9-11 for the list of county abbreviations. 

**Company has permit limiting combined SO2 and NOX to 841 tpy on previously grandfathered BART 

sources. This limit is lower than actual emissions in previous years. For example, the facility emitted 

1,266 tpy of NOX and SO2 in 1990. 

***ExxonMobil numbers are preliminary and subject to change. These estimates are based on reductions 

from the 2002 EI and pre- and post-BART hourly emissions rates submitted. (Emission reductions as 

a result of the completion of permit 49138 (FCCU) will be updated when they become available.) 

   
Page | 79 

EPA TX BART ANALYSIS TSD 

Sites Removed From Further BART Consideration 

The TCEQ BART rule was published January 10, 2007, which included exemption provisions for 

being removed/screened out from further BART Consideration. A number of companies requested 

removal from further BART consideration per the exemptions in the rule or based on updated 

information on the site. To be removed from the list, a site had to be exempted for all potential haze 

causing pollutants, NOX, SO2, and fine particulate matter. VOC was not required because VOC was 

screened out for all the BART eligible sources in the group CAMx modeling. TCEQ’s BART rule that 

a site may be exempted if the combined NOX and SO2 potential to emit are less than 1,000 tpy, and the 

site is greater than 100 km from a Class I area. Some sites may be exempted if the combined NOX and 

SO2 potential to emit are less than 500 tpy, and the site is greater than 50 km from a Class I area. These 

exemption levels are the same as exemptions identified in EPA’s BART Guidelines. Several sites 

requested exemption for combined SOX and NOX limits and certified that the TCEQ-sponsored 

modeling adequately represented particulate emissions. One site requested PM2.5 exemption due to de 

minimis levels of emissions. 

Some facilities provided updated site information included construction dates and potential emission 

rates of equipment. Two sites requested removal because the operating equipment did not meet a BART 

category. 

The results of granted exclusions are also shown in Table E-2 which is based on info in TX RH SIP 

Table 9.7: Sites Removed From BART Due to Exemption Requests. 
Page | 80 

EPA TX BART ANALYSIS TSD 

Table E-2 (TX RH SIP Table 9-7): Sites Removed From BART Due to Exemption Requests 

No. Regulated

Entity Company Reason Account SIC

1 RN100220110 

ABITIBI CONSOLIDATED 

CORP 

PTE*<1,000, 

de minimis PM AC0017B 2621 

2 RN102559291 BMC HOLDINGS INC 

PTE<1,000, 

PM certification JE0343H 2869 

3 RN100211507 CAPITOL CEMENT Shut down kiln BG0045E 3241 

4 RN100227016 CELANESE PTE<250 HG0126Q 2869 

5 RN100825249 

CHEVRON PHILLIPS 

CHEMICAL 

met TCEQ model 

plant BL0758C 2869 

6 RN100542711 

EI DUPONT DENEMOURS & 

CO 

PTE<1,000, 

PM certification OC0007J 2869 

7 RN102166964 ENBRIDGE PIPELINES PTE<250 CG0012C 1321 

8 RN104579487 INEOS USA PTE<250 GBA007G 2869 

9 RN100212018 J.L. DAVIS GAS PROCESSING No BART sources CA0011B 1321 

10 RN100213719 

JOHNS MANVILLE 

INTERNATIONAL PTE<250 JH0025O 3296 

11 RN100633650 LYONDELL PETROCHEMICAL 

PTE<1,000, 

PM certification HG1575W 2869 

12 RN100210608 

MARATHON ASHLAND 

PETROLEUM PTE<250 GB0055R 2911 

13 RN102609724 NORIT AMERICAS INC 

PTE<1,000, 

PM certification HH0019H 2819 

14 RN102643327 

PUEBLO MIDSTREAM GAS 

CORP 

recheck dates, 

not BART AG0024G 1321 

15 RN100211408 REGENCY GAS SERVICES No BART equip PE0024Q 1321 

16 RN100216621 REGENCY TILDEN GAS 

PTE<1,000, 

PM certification MC0002H 2819 

17 RN102551785 TARGA Shut down CY0019H 1311 

18 RN102561925 

THE GOODYEAR TIRE AND 

RUBBER CO PTE<250 JE0039N 2822 

19 RN100213685 VALENCE MIDSTREAM LTD plant shut down HR0018T 1321 

20 RN100210517 VALERO MCKEE REFINERY 

PTE<1,000, 

PM certification MR0008T 2911 

21 RN100219310 VALERO REFINING TEXAS LP 

PTE<1,000, 

PM certification HG0130C 2911 

22 RN100218601 

VETROTEX AMERICA ST. 

GOBAIN 

PTE<500,

PM certification WH0014S 3229 
Page | 81 

EPA TX BART ANALYSIS TSD 

F. Summary

Overall TCEQ analyzed over 120 facilities that were potentially BART eligible or needed additional 

information to rule out their BART eligibility. EPA has reviewed the different modeling techniques that 

TCEQ utilized in evaluating and screening out these sources and concurs with the analysis. TCEQ’s analysis 

was done in accordance with EPA’s 2005 BART Guidelines, EPA’s modeling Guidelines on Air Quality 

Models (40 CFR Part 51 App. W), EPA and IWAQM’s modeling guidance for CALPUFF and visibility 

analysis (several documents) and other pertinent modeling guidance. CALPUFF modeling was conducted 

pursuant to modeling protocols that were shared and reviewed by EPA and Federal Land Manager 

representatives and included the initial CENRAP modeling protocol, TCEQ’s refined modeling protocol, and 

Source specific modeling protocols. TCEQ and six sources also performed modeling analyses with CAMx 

based on the TCEQ’s modeling protocols (Initial group modeling and Refined single source protocols {TCEQ 

and the 6 different facilities}). There was some concern that the initial CAMx group modeling and Model 

Plant source screening may have been based on using the 98th percentile threshold and that the threshold that 

was agreed to in February 2007 of using the Maximum Max. Average (High 1st High vs. 8th High) for 

subsequent analysis with CAMx would cause some concern that earlier sources may have gotten out of a 

BART analysis with the less conservative metric initially used. As discussed at the time and detailed above, 

the sources that screened out were analyzed in groups, and it is reasonable to believe no one source would 

have been above either threshold if refined modeling had been conducted. Subsequent screening using these 

sources and the model plant approach are also valid because each source would be below 0.5 del-dv based on 

the analysis above. Therefore we concur with the sources that were screened out using the model plant 

approaches discussed in Section C-2. 

We also reviewed the results of the CALPUFF and CAMx single-source modeling and concur with the 

screening of those facilities. We do not think any of the individual sources of NOx, SOx and PM that 

screened out would have had a different outcome using a different modeling approach. The final list of all 

BART-eligible sources is in Appendix 9-13: BART-Eligible List. 

As discussed in the Federal Register Notice for this proposed rulemaking, we are proposing a FIP to replace 

Texas’s reliance on CAIR in 30 TAC 116.1510(d) with reliance on the trading programs of CSAPR as an 

alternative to BART for SO2 and NOX emissions from EGUs in the regional haze plan for Texas. 

Specifically30 TAC 116.1510(d) states “BART-eligible electric generating units participating in the Clean 

Air Interstate Rule Trading Program are not subject to the requirements of Section 116.1520 or 

Section116.1530 of this title for NOX and SO2.”7

 We have already issued a limited disapproval of the Texas 

regional haze SIP for its reliance on CAIR. However, we determined that CSAPR provides for greater 

reasonable progress towards the national goal than would BART and Texas is included in CSAPR for NOX

and SO2. Therefore, our proposed FIP to replace reliance on CAIR with reliance on the trading programs of 

CSAPR as an alternative to BART includes a FIP to replace Texas’s reliance on CAIR in 30 TAC 

116.1510(d) with reliance on CSAPR.

                                                            

7

 30 TAC 116.1510(d). 
Page | 82 

EPA TX BART ANALYSIS TSD 

Our proposed regional haze FIP relies on the already promulgated CSAPR FIP for Texas at 40 CFR 52.2283-

84 to satisfy the BART requirement for SO2 and NOx emissions from EGUs. We more fully explained the 

basis for our limited disapproval in that rulemaking and are not taking comment on our limited disapproval of 

Texas’ regional haze SIP in this action. 

We concur with TCEQ’s conclusion that no Texas sources remained subject to BART. Based on TX RH SIP 

Table 9-8 with some additional information we are providing Table F-1 to summarize the analysis that 

supports screening out each facility. Several sources were added to the process after the BART survey, either 

at the site’s request or as a result of recent activity at the site. Their status is reflected in this table. Site 

activity also included transfer of equipment or corporate reorganization resulting in site splits or name 

changes. 

Therefore, in reference to 40 CFR 51.308(e)(1)(ii)(C), no five Factor BART determinations are required 

because all the BART eligible sources in Texas were determined to not emit any air pollutant which may 

reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I 

Federal area. 

TCEQ included a Table in the TX RH Appendix 9-13 that gives a tracking of how each facility either 

screened out or was dropped from the BART eligible list. We have made some edits and replicated it below 

to summarize the results of all the different analyses of BART eligible facilities. 

   
Page | 83 

EPA TX BART ANALYSIS TSD 

Table F‐1 Summary of Screening Analysis for each BART‐eligible facility that was evaluated for impacts at Class I

areas and Removed (Screened Out) 1

  

Account Company

BART‐ eligible

Reason for Removal

Cum.

Model

CAMx

CAL‐ 

PUFF

Single

Source

CAMx

Exemp‐ tion

Requested

1 TG0044C AEP TEXAS y y

2 CD0013K AEP TEXAS CENTRAL COMPANY ‐ La Palma y y

3 NE0024E

AEP TEXAS CENTRAL COMPANY ‐Barney M

Davis y y

4 NE0026A

AEP TEXAS CENTRAL COMPANY ‐ Nueces

Bay y y

5 JI0030K

AEP TEXAS NORTH COMPANY ‐ W.T.U.‐FT.

PHANTOM y y

6 CB0003M ALCOA ALUMINA & CHEMICALS y y

7 BL0002S INEOS OLEFINS & POLYMERS y y

8 HG0558G ATOFINA CHEMICALS INC y y

9 BL0021O BASF CORPORATION y y

10 GB0001R BP AMOCO CHEMICAL COMPANY y y

11 MH0009H CELANESE LIMITED y y

12 ED0011D CHAPARRAL STEEL MIDLOTHIAN y y

13 BJ0001T CHEMICAL LIME LTD y y

14 HG0310V CHEVRON PHILLIPS CHEMICAL y y

15 HW0013C CHEVRON PHILLIPS CHEMICAL CO y y

16 BG0057U

CITY PUBLIC SERVICE ‐Sommers Deely

Spruce y y

17 BG0186I CITY PUBLIC SERVICE ‐ V.H Brauning y y
Page | 84 

EPA TX BART ANALYSIS TSD 

18 CR0020C COPANO PROCESSING LP y y

19 CI0022A DYNEGY MIDSTREAM SERVICES y y

20 WN0042V TARGA y y

21 HG0218K EI DUPONT y y

22 EE0029T EL PASO ELECTRIC CO y y

23 TH0004D ELECTRIC UTILITY DEPT y y

24 MQ0009F ENTERGY GULF STATES INC ‐ Lewis Creek y y

25 OC0013O ENTERGY GULF STATES INC – Sabine y y

26 BL0113I EQUISTAR y y

27 BL0268B EQUISTAR CHEMICALS LP y y

28 HG0033B EQUISTAR CHEMICALS LP y y y

29 HG0228H EXXON CHEMICAL CO y y

30 JE0065M EXXON MOBIL CHEMICAL CO y y

31 HG0229F EXXONMOBIL CHEMICAL CO y y

32 NE0122D FLINT HILLS RESOURCES LP y y

33 JE0052V HUNTSMAN CORPORATION y y

34 JE0135Q HUNTSMAN PETROCHEMICAL CORP y y

35 EB0057B HUNTSMAN POLYMERS y y

36 GBA007G INEOS y

37 NE0120H FLINT HILLS RESOURCES LP y y

38 WE0005G LAREDO POWER y y

39 MB0123F LEHIGH CEMENT COMPANY y y

40 NE0025C LON C HILL POWER y y

41 BC0015L

LOWER COLORADO RIVER Authority ‐ Lower

Colorado River y y

42 FC0018G

LOWER COLORADO RIVER AUTHORITY ‐ 

Fayette y y

43 HG1575W LYONDELL CITGO REFINING y y y

44 HG1451S OXYVINYLS LP y y

45 JE0042B PREMCOR REFINING GROUP y y
Page | 85 

EPA TX BART ANALYSIS TSD 

46 HG0632T ROHM & HAAS TEXAS y y

47 BL0038U SOLUTIA INC y y

48 GJ0043K SOUTHWESTERN ELECTRIC POWER y y

49 ME0006A SOUTHWESTERN ELECTRIC POWER –Wilkes y y

50 PG0040T SOUTHWESTERN PUBLIC SERVICE –Nichols y y

51 PG0041R

SOUTHWESTERN PUBLIC SERVICE ‐ 

Harrington y y

52 TF0012D SOUTHWESTERN ELECTRIC POWER – Welsh y y

53 JE0091L SUN MARINE TERMINAL y y

54 CI0012D TEXAS GENCO LP ‐Cedar Bayou y y

55 FG0020V TEXAS GENCO LP ‐ W A Parrish y y

56 GB0037T NRG Texas ‐ PH Robinson y y

57 HG0562P TEXAS PETROCHEMICALS LP y y

58 BL0082R THE DOW CHEMICAL CO y y

59 NE0022I TICONA POLYMERS INC y y

60 ED0066B TXI OPERATIONS, L.P. y y

61 FI0020W TXU BIG BROWN COMPANY LP y y

62 DB0251U

TXU ELECTRIC COMPANY ‐ North Lake

Steam y y

63 FB0025U

TXU GENERATION COMPANY LP ‐ Valley

Steam y y

64 HQ0012T

TXU GENERATION COMPANY LP –

Decordova y y

65 MB0116C

TXU GENERATION COMPANY LP –

Tradinghouse y y

66 MM0023J TXU GENERATION COMPANY LP – Sandow y y

67 MO0014L

TXU GENERATION COMPANY LP ‐ Morgan

Creek y y

68 RL0020K

TXU GENERATION COMPANY LP ‐ Martin

Lake y y

69 TA0352I

TXU GENERATION COMPANY LP ‐ Eagle

Mtn. y y
Page | 86 

EPA TX BART ANALYSIS TSD 

70 WC0028Q

TXU GENERATION COMPANY LP ‐ Permian

Bsn y y

71 YB0017V TXU GENERATION COMPANY LP – Graham y y

72 TF0013B

TXU GENERATION COMPANY LP –

Monticello y y

73 GB0076J UNION CARBIDE CORP y y

74 CB0028T UNION CARBIDE CORPORATION y y

75 GB0073P VALERO REFINING CO TEXAS y y

76 VC0003D VICTORIA POWER y y

77 JB0016M VINTAGE PETROLEUM, INC. y y

78 LN0081B SOUTHWESTERN PUBLIC SERVICE y y

79 AC0017B ABITIBI CONSOLIDATED CORP y y

80 MM0001T ALCOA INC y y

81 HT0011Q ALON USA LP y y

82 ED0034O ASH GROVE y y

83 JE0343H BMC HOLDINGS INC y

84

   BP PRODUCTS NORTH AMERICA IN

GB0004L TEXAS y y

85 GH0003Q CABOT CORPORATION y y

86 BG0045E CAPITOL CEMENT DIV CAPITOL y y

87 GH0004O CELANESE CHEMICAL y y

88 BL0758C CHEVRON PHILLIPS CHEMICAL y y

89 NE0027V CITGO REFINING & CHEMICALS y y

90 HW0018P CONOCOPHILLIPS y y

91 AB0012W DCP y y

92 HW0008S DEGUSSA ENGINEERED CARBONS y y

93 MR0008T DIAMOND SHAMROCK REFINING y y

94 HGA005E DOW y y

95 HG0126Q DOW y y

96 HH0042M EASTMAN CHEMICAL COMPANY y y
Page | 87 

EPA TX BART ANALYSIS TSD 

97 OC0007J EI DUPONT DENEMOURS & CO y y

98 MC0002H ENBRIDGE PIPELINE y

99 CG0012C ENBRIDGE PIPELINES y y

100 HG0232Q EXXONMOBIL CORP ‐ Baytown y y

101 JE0067I EXXONMOBIL OIL CORP – Beaumont y y

102 CG0010G INTERNATIONAL PAPER CO y y

103 OCA002B INVISTA y y

104 VC0008Q INVISTA y y

105 JH0025O JOHNS MANVILLE INTERNATIONAL y

106 HG0048L LYONDELL CITGO REFINING y y

107 GB0055R MARATHON ASHLAND

PETROLEUM y       y

108 HH0019H NORIT AMERICAS INC y y y

109 ED0051O OWENS CORNING y

110 HG0175D PASADENA REFINING y y

111 AG0024G PUEBLO MIDSTREAM GAS CORP y

112 PE0024Q REGENCY GAS SERVICES y

113 HG0697O RHODIA, INC. y y

114 HG0659W SHELL OIL CO y y

115 HW0017R SID RICHARDSON CARBON y y

116 HT0027B SID RICHARDSON CARBON y y

117 CY0019H TARGA y y

118 OC0019C TEMPLE‐INLAND y y

119 HK0014M TEXAS LEHIGH CEMENT CO y y

120 JE0039N THE GOODYEAR TIRE AND RUBBER CO y y y

121 JE0005H TOTAL PETROCHEMICALS y y

122 HR0018T VALENCE MIDSTREAM LTD y y y y

123 NE0043A VALERO REFINING COMPANY y

124 HG0130C VALERO REFINING TEXAS LP y
Page | 88 

EPA TX BART ANALYSIS TSD 

125 WH0014S VETROTEX WICHITA FALLS PLANT y y

126 JC0003K WESTVACO y y

1. Some sources were added to the determination process after the BART survey, either by their request or as a result of 

equipment transfers. These are indicated with a blank. 
Page | 89 

EPA TX BART ANALYSIS TSD 

In the Table below (F-2) there are several footnotes and color coding of facilities that we are 

explaining prior to the Table below that covers several pages. 

The non-highlighted facilities are the facilities that either screened out using the group CAMx 

modeling results, or via the Model Plant analyses. 

The facilities highlighted in Olive Green are facilities that screened out based on refined single 

source analysis with either CALPUFF or CAMx. 

The facilities highlighted in Blue are the facilities/sources that were dropped from the BART 

eligible list based either on PTE and PM emissions, shut downs, verification of PTE less than 1000 

tpy or 500 tpy, clarifications on sources and applicable dates. 

‘*’ = This source was screened out using the group CAMx modeling analysis with certification of 

emissions and other modeling parameters by a representative of the source. 

‘**’ = This source was removed due to additional information. 

‘***’ = For EGU’s, TX did not evaluate NOx and SOx for BART as the facilities were applicable 

to CAIR requirements at the time that gave BART coverage for these two pollutants. 

Table F‐2 Summary of Results for each facility that was evaluated for BART eligibility and source impacts

at Class I areas as needed.
Page | 90 

EPA TX BART ANALYSIS TSD 

Account Company

Needs to do Further PM Analyses?

Needs to do 

Further SOx 

and NOx 

Analyses?

Passed Using 

Model Plant 

(NEW 

12-6-06)

Certification 

Recieved

Company Ok Emissions Data

Co. notes any data changes 

HD0029C A.N.R. PIPELINE COMPANY NO NO NA TG0044C AEP TEXAS NO* NO*** 1/18/2007 yes no CD0013K AEP TEXAS CENTRAL COMPANY NO* NO*** 1/28/2007 yes yes NE0024E AEP TEXAS CENTRAL COMPANY NO* NO*** 1/28/2007 yes no NE0026A AEP TEXAS CENTRAL COMPANY NO* NO*** 2/28/2007 yes yes JI0030K AEP TEXAS NORTH COMPANY NO* NO*** 1/18/2007 yes no CB0003M ALCOA ALUMINA & CHEMICALS NO* No* X 3/5/2007 yes yes HG0558G ATOFINA CHEMICALS INC NO* No* X 2/16/2007 yes no BL0021O BASF CORPORATION NO* No* X 3/5/2007 yes yes GB0001R BP AMOCO CHEMICAL COMPANY NO* No* X 5/1/2005 yes no MH0009H CELANESE LIMITED NO* No* X 3/5/2007 yes no ED0011D CHAPARRAL STEEL MIDLOTHIAN NO* NO* 3/1/2007 yes yes BJ0001T CHEMICAL LIME LTD (added to 

certification)

NO* NO* 5/3/2007 yes no 

HG0310V CHEVRON PHILLIPS CHEMICAL NO* NO* 1/8/2007 yes no HW0013C CHEVRON PHILLIPS CHEMICAL CO NO* NO* 2/7/2007 yes yes BG0057U CITY PUBLIC SERVICE NO* NO*** 2/8/2007 yes yes BG0186I CITY PUBLIC SERVICE NO* NO*** 2/8/2007 yes yes CR0020C COPANO PROCESSING LP NO* NO* 1/8/2007 yes no CI0022A DYNEGY MIDSTREAM SERVICES NO* NO* NA HG0218K EI DUPONT NO* NO* 3/5/2007 yes yes EE0029T EL PASO ELECTRIC CO NO* NO*** 3/27/2007 yes no TH0004D ELECTRIC UTILITY DEPT NO* NO*** 1/4/2007 yes yes MQ0009F ENTERGY GULF STATES INC NO* NO*** 1/5/2007 yes yes OC0013O ENTERGY GULF STATES INC NO* NO*** 1/5/2007 yes yes BL0113I EQUISTAR NO* NO* 3/5/2007 yes yes BL0268B EQUISTAR CHEMICALS LP NO* NO* 3/5/2007 yes yes HG0228H EXXON CHEMICAL CO NO* NO* 2/5/2007 yes yes JE0065M EXXON MOBIL CHEMICAL CO NO* NO* 3/5/2007 yes yes HG0229F EXXONMOBIL CHEMICAL CO NO* No* X 3/5/2007 yes yes NE0120H Flint Hills Resources NO* No* X 3/5/2007 yes no NE0122D FLINT HILLS RESOURCES LP NO* No* X 2/20/2007 yes yes JE0052V HUNTSMAN CORPORATION NO* NO* 3/1/2007 yes yes JE0135Q HUNTSMAN PETROCHEMICAL CORP NO* NO* 3/5/2007 yes yes BL0002S Ineos (formerly AMOCO) Olefins & 

Polymers

NO* NO* 4/27/2007 yes yes 

GBA007G INEOS (formerly part of GB0001R) NO NO 5/1/2007 PTE<250 WE0005G LAREDO POWER NO* NO*** 2/28/2007 yes yes MB0123F LEHIGH CEMENT COMPANY NO* No* X 1/12/2007 yes no NE0025C LON C HILL POWER NO* NO*** 2/28/2007 yes yes BC0015L LOWER COLORADO RIVER AUTHORITY NO* NO*** 2/22/2007 yes no FC0018G LOWER COLORADO RIVER AUTHORITY NO* NO*** 2/22/2007 yes no 
Page | 91 

EPA TX BART ANALYSIS TSD 

Account Company

Needs to do Further PM Analyses?

Needs to do 

Further SOx 

and NOx 

Analyses?

Passed Using 

Model Plant 

(NEW 

12-6-06)

Certification 

Recieved

Company Ok Emissions Data

Co. notes any data changes Reg

Ent

HG1575W Lyondell Chemical (added to certification) NO NO X 6/5/2007 yes RNHG1451S OXYVINYLSLP NO* NO* 2/26/2007 yes yes RNJE0042B PREMCOR REFINING GROUP NO* No* X 3/9/2007 yes no RNHG0632T ROHM & HAAS TEXAS NO* NO* 1/24/2009 yes no RNBL0038U SOLUTIA INC NO* NO* 3/5/2007 yes yes RNGJ0043K SOUTHWESTERN ELECTRIC POWER NO* NO*** 1/22/2007 yes no RNME0006A SOUTHWESTERN ELECTRIC POWER NO* NO*** 1/18/2007 yes no RNPG0040T SOUTHWESTERN PUBLIC SERVICE NO* NO*** 1/8/2007 yes no RNPG0041R SOUTHWESTERN PUBLIC SERVICE NO* NO*** 1/8/2007 yes no RNLN0081B Southwestern Public Service (formerly 

XCEL ENERGY)

NO* NO*** 1/8/2007 yes no RN

JE0091L SUN MARINE TERMINAL NO* NO* 5/4/2007 yes no RNWN0042V TARGA (formerly Dynegy Midstream Services) NO* NO* NA <250 MMBTU/hr RNCI0012D TEXAS GENCO LP NO* NO*** 3/5/2007 yes yes RNFG0020V TEXAS GENCO LP NO* NO*** 3/5/2007 yes yes RNHG0562P TEXAS PETROCHEMICALS LP NO* No* X 3/5/207 yes no RNBL0082R THE DOW CHEMICAL CO NO* No* X 3/5/2007 yes yes RNNE0022I TICONA POLYMERS INC NO* NO* 2/12/2007 yes yes RNFG0036G TXI OPERATION LP NO* No* X NA removed not in the 26 source categories RNNB0037F TXI OPERATIONS, L.P. NO NO NA removed not in the 26 source categories RNFI0020W TXU BIG BROWN COMPANY LP NO* NO*** 2/28/2007 yes yes RNDB0251U TXU ELECTRIC COMPANY NO* NO*** 2/28/2007 yes yes RNFB0025U TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNHQ0012T TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNMB0116C TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNMM0023J TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNMO0014L TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNRL0020K TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNTA0352I TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNWC0028Q TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes yes RNYB0017V TXU GENERATION COMPANY LP NO* NO*** 2/28/2007 yes no RNGB0076J UNION CARBIDE CORP NO* NO* 5/3/2007 yes no RNCB0028T UNION CARBIDE CORPORATION NO* No* X 1/10/2007 yes no RNGB0073P VALERO REFINING CO TEXAS NO* No* X 3/5/2007 yes yes RNVC0003D VICTORIA POWER NO* NO*** 2/28/2007 yes yes RNJB0016M VINTAGE PETROLEUM, INC. NO* No* X 5/10/2007 yes no RN
Page | 92 

EPA TX BART ANALYSIS TSD 

Account Company

Needs to do Further PM Analyses?

Needs to do 

Further SOx 

and NOx 

Analyses?

Passed Using 

Model Plant 

(NEW 

12-6-06)

Protocol Recieved

Modeling Received EA Receive

MM0001T ALCOA INC NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

HT0011Q ALON USA LP NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

ED0034O Ash Grove (formerly N TEXAS CEMENT) NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

GB0004L BP PRODUCTS NORTH AMERICA IN TEXAS NO* YES CAMx CAMx, passed (threshold <0.5dv) NA GH0003Q CABOT CORPORATION NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

GH0004O CELANESE CHEMICAL NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

NE0027V CITGO REFINING & CHEMICALS NO* YES CAMx

CAMx, passed 

(threshold 

<0.5dv)

NA 

HW0018P ConocoPHILLIPS (formerly Phillips 66 CO) NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

AB0012W DCP (aka DUKE ENERGY FIELD SERVICES) NO* YES Calpuff Calpuff, passed (threshold <0.5dv) NA HW0008S DEGUSSA ENGINEERED CARBONS NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

HGA005E DOW YES YES CAMx

CAMx, passed 

(threshold 

<0.5dv)

NA 

HH0042M EASTMAN CHEMICAL COMPANY NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

HG0033B EQUISTAR CHEMICALS LP (added to modeling) Calpuff Calpuff, passed (threshold <0.5dv) NA HG0232Q EXXONMOBIL CORP - Baytown NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

JE0067I EXXONMOBIL OIL CORP - Beaumont NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

EB0057B HUNTSMAN POLYMERS (added to modeling) Calpuff Calpuff, passed (threshold <0.5dv) NA CG0010G INTERNATIONAL PAPER CO YES YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 
Page | 93 

EPA TX BART ANALYSIS TSD 

Account Company 

Needs to do 

Further PM 

Analyses? 

Needs to do 

Further SOx 

and NOx 

Analyses? 

Passed Using Model Plant (NEW 12-6-06) 

Protocol Recieved 

Modeling 

Received 

EA Receiv

OCA002B INVISTA (formerly part of DUPONT OC0007J) NO* YES Calpuff Calpuff, passed (threshold <0.5dv) NA VC0008Q INVISTA Victoria (formerly DU PONT) NO* YES Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

HG0048L LYONDELL CITGO REFINING (aka Houston Refinery) NO* YES CAMx CAMx, passed (threshold <0.5dv) NA GB0037T NRG Texas (formerly Texas Genco) add to modeling Calpuff Calpuff, passed (threshold <0.5dv) NA ED0051O OWENS CORNING NO* YES Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

HG0175D 

Pasadena Refining Systems (formerly Crown Central Petroleum) 

NO* YES CAMx 

CAMx, passed 

(threshold 

<0.5dv) 

NA 

HG0697O RHODIA, INC. NO* YES Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

HG0659W SHELL OIL CO NO* YES Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

HW0017R SID RICHARDSON CARBON NO* YES Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

HT0027B SID RICHARDSON CARBON CO NO* YES Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

TF0012D SOUTHWESTERN ELECTRIC POWER (AEP) YES NO*** Calpuff Calpuff, passed (threshold <0.5dv) NA OC0019C Temple-Inland (added to modeling) Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 

HK0014M TEXAS LEHIGH CEMENT CO NO* YES 

requested exemption, denied 

Calpuff 

Calpuff, passed

(threshold 

<0.5dv) NA 

JE0005H Total Petrochemicals (formerly ATOFINA PETR.) NO* YES Calpuff Calpuff, passed (threshold <0.5dv) NA ED0066B TXI OPERATIONS, L.P. (added to modeling) Calpuff Calpuff, passed (threshold <0.5dv) NA TF0013B TXU GENERATION COMPANY LP YES NO*** Calpuff 

Calpuff, passed

(threshold 

<0.5dv) 

NA 
Page | 94 

EPA TX BART ANALYSIS TSD 

Account Company

Needs to do Further PM Analyses?

Needs to do 

Further SOx 

and NOx 

Analyses?

Passed Using 

Model Plant 

(NEW 

12-6-06)

Protocol Recieved

Modeling Received EA Recei

NE0043A VALERO REFINING COMPANY NO* YES CAMx

CAMx, passed 

(threshold 

<0.5dv)

NA 

JC0003K WESTVACO NO* YES Calpuff

Calpuff, passed

(threshold 

<0.5dv)

NA 

AC0017B ABITIBI CONSOLIDATED CORP NO* YES requested exemption PTE <1000: demin PM Off list JE0343H BMC HOLDINGS INC NO* YES requested exemption PTE <1000: PM cert Off list BG0045E CAPITOL CEMENT DIV CAPITOL NO* YES Wet kiln permanent shut down EA submitted HG0126Q CELANESE NO* YES PTE<250 Off list BL0758C CHEVRON PHILLIPS CHEMICAL (added to modeling) requested exemption Met TCEQ model Plant Off list OC0007J EI DUPONT DENEMOURS & CO NO* YES requested exemption PTE <1000: PM cert Off list CG0012C ENBRIDGE PIPELINES NO* YES PTE<250 Off list GBA007G Ineos USA no no PTE<250 Off list CA0011B J.L. DAVIS GAS PROCESSING NO* YES site rechecked equipment No BART Sources Off list JH0025O JOHNS MANVILLE INTERNATIONAL NO* YES Exempt PTE<250 Off list HG1575W LYONDELL PETROCHEMICAL Exempt PTE <1000: PM cert Off list GB0055R MARATHON ASHLAND PETROLEUM NO* YES req ex PTE<250 Off list HH0019H NORIT AMERICAS INC NO* YES requested exemption PTE <1000: PM cert Off list AG0024G PUEBLO MIDSTREAM GAS CORP NO* YES

site rechecked

construction 

dates

outside applicable dates

Off list 

PE0024Q REGENCY GAS SERVICES (formerly DUKE) NO* YES site rechecked equipment No BART Sources Off list MC0002H Regency Tilden Gas (formerly Enbridge Pipeline) NO* YES requested exemption PTE <1000: PM cert Off list CY0019H TARGA (formerly Dynegy Midstream Services) NO* YES shutdown equip exempt- shutdown Off list with permJE0039N THE GOODYEAR TIRE AND RUBBER CO NO* YES PTE<250 Off list HR0018T VALENCE MIDSTREAM LTD NO* YES plant shutdown shutdown Off list MR0008T

Valero (formerly DIAMOND SHAMROCK REFINING) McKee Refinery

NO* YES

requested exemption

PTE <1000: PM 

cert

permit update; 

off 

list

HG0130C VALERO REFINING TEXAS LP NO* YES requested exemption PTE <1000: PM cert Off list WH0014S Vetrotex WICHITA FALLS PLANT NO* YES requested exemption PTE <500: PM cert Off list