Appendix L.3: Greenwood Utilities - Henderson 

Appendix L.3 contents: 

L.3.1 Appendix summary 

L.3.2 BART information request letter 

L.3.3 BART eligibility letter 

L.3.4 BART modeling report 

L.3.5 BART exemption letter 
Appendix L.3.1 

Greenwood Utilities - Henderson Station (1560-00048) BART Process Summary 

As a fossil fuel fired steam electric plant, Greenwood Utilities meets the initial BART 

eligibility requirement of source category code. The Henderson station is 281 km from 

Sipsey Wilderness Area, a Class I area, and has a possible visibility impact. Therefore, 

on February 28, 2002, Mississippi Department of Environmental Quality (MDEQ) sent 

them a letter requesting information to determine BART eligibility. Based on the 

information received from Greenwood Utilities, one unit was deemed BART eligible 

because it met the following criteria: 

operating or under construction between Aug.7, 1962 to Aug.7, 1977 

having potential emissions that exceed the limit of 250 tons per year for 

SO?, NO,, or PM 1 0. 

The following is the BART-eligible point source for Greenwood. 

260MMBtuhr Boiler (AA-003) 

o natural gas, no.6 fuel oil, coal 

o installed in 1967 

o potential SO2 emissions of 2030 tons per year 

o potential NO, emissions of 260 tons per year 

o potential PMlO emissions of 254 tons per year 

o currently particulate emissions are controlled by a cyclone 

As a result, Greenwood Utilities was required to perform CALPUFF modeling on this 

unit. Using the old IMPROVE equation, the modeling analysis demonstrated a 9sth 

percentile 24-hour average visibility impact of 0.22 dv for Breton. The threshold 

contribution for BART subjectivity is 0.5 dv; therefore, Greenwood Utilities - Henderson 

Station is not BART subject. 
Appendix L.3.2 

STATE OF MISSISSIPPI 

DAVID RONALD MUSCiROM.- 

MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY 

Quws H. CHISOLM, EXECUTIVE DIRRJIOR 

February 28,2002 

Mr. T. M. Flanagan 

Greenwood Utilities - Henderson 

P.O. Box 866 

Greenwood,MS 38930 

COPY 

Re: BART Information Request 

Dear Mr. Flanagan: 

In July 1999, The Environmental Protection Agency (EPA) issued ~gional haze 

regulations to improve visual air quality, or visibility, in specified national parks and 

wilderness areas across the country. These regulations require states to establish goals 

for improving visibility in these areas and to submit state implementation plans (SIPS) 

that contain enforceable measures and control strategies for reducing visibility-impairing 

pollution. 

One component of these regulations is to reduce emissions hm certain, existing, large 

emission units by installing the best available emission controls. This requirement, 

known as the Best Available Retrofit Technology (BART) requirement, applies to 

emission units that: 

wm built between August 7,1962 and August 7,1977; 

have the potential to emit 250 tons per year or more of ammonia, nitrogen oxides, 

particulate matter less that 10 microns (PMlo), suMbr dioxide, or volatile organic 

compounds, either individually or in combination with other such units; and 

faH into one of 26 listed source categories, including steam electric plants and 

industrial boilers, and large industrial plants such as pulp mills, nfincrits, and 

smeltas. See attached list. 

Thc final implementation plan should be submitted to EPA by December 3 1,2008, and 

must contain, among other things, the emission limits and compliance schedules for each 

BART subject source. The first step in this process is to identify all BART subject 

soufcts. 

Mississippi and other southeastern states and tribes have formed a Regional Planning 

Organization, known as VISTAS, to work on the regional haze issue and the required 
implementation plans. It is our goal to have all BART subject facilities and the specific 

emission units at the facilities identified by June 2002. 

An initial file review indicates that your facility is potentially subject to the BART 

requirement because it falls into one of the 26 source categories, was built prior to August 

7, 1977, and has potential emissions greater than 250 tons per year for at least one of the 

visibility-impairing pollutants. However, the information listed below is needed to 

make a determination. 

The initial startup date for facility. 

The initial starnrp date for individual emission units. 

The dates of any modification or reconstruction for individual units. 

The BART source category of the emission units. 

A list of emission units obtained hm our files is enclosed. Pkase enter thc dates of 

initial start-up and any modification or reconslmction, review and make any corrections 

to the listed source category, and review and make any concctions to the potential 

emissions. This information is also available in excel spreadshtct format which can be 

completed and submitted electronically. 

Please qmnd by April 19,2002. If this information is not received, the fwility and all 

emission units at the facility will be considered subject to the BART requirements. 

However, the final damnhations will not be made until the SIP development process. 

Thank you for your help witb this project. If you have any questions, please contact me 

at (601)961-5176 or Deborah Boleware at (601)961-5768, If you would like the 

electronic copy of the &ion unit list, please send an e-mail to 

deborahrahbolcwara@dtq.state-ms.us and elliott-bick-q.state.ms.us. 

c&ae;S-.--w-p 

Elliott Bickerstaff, P.E. 

Chief, Air Support Branch 
Appendix L.3.3 

STATE OF MISSISSIPPI 

DAVID RONALD MVSGRM. GOMRNDR 

MISSISSIPPI DEPARTMENT OFENVIRONMENTAL QuALIIY 

CHARLES H. CHISOLM. U(ECVM DlSeptember 9,2002 

Mr. William J. Gamd 

Greenwood Utilities - Henderson 

P.O. Box 866 

Greenwood, MS 38930 

Re: BART Information Response 

Greenwood Utilities, Henderson 

Leflorc County, Mississippi 

Dear Mr. Gammill: 

This letter is to acknowledge receipt of your April 19, 2002 response to our Best 

Available Retrofit Technology (BART) information request. After reviewing the 

information you submitted, it appears your facility is BART eligible for the following 

reasons: 

1. Unit AA-003 falls into the category for fossil fuel-fired stcam ekctric plants 

(250 MMBTU heat input per hour). 

2. This unit began operation during the August 7, 1%2 to August 7, 1977 date 

range. 

3. The emissions from this unit exceed the 250 tons per year limit. 

On May 24, 2002, the D.C. circuit court vacated the BART provisions of the Regional 

Haze Rule (RHR). At issue is the metbod of determining the cost and bentfits of 

installing BART at a particular source. The RHR requires this determination to be 

made on a group or collenive basis; however, it was argued that the Ckan Air Act 

requires this determination to be made on a source by source basis. In a 2-1 decision, a 

three-judge panel agreed with the petitioners and vacated the BART provisions, 

requiring EPA to revise the BART requirements to incorporate a source by soum 

approach. EPA has filed a petition seeking rebearing of the case by the full court. 

Depending on the outcome of the appeals process, this ruling may affect what controls 

a BART applicable source will be required to install, but the ruling did not addrcss and 

therefore will not impact the methods in determining the BART applicabk sources. We 

have identified emission unit AA-003 at the facility to be subjcct to this rcquiremmt. 

Please note tbat a BART applicable source is one that will be considered for retrofit 
Appendix L.3.3 

technology controls. It does not necessarily mean that additional controls will be 

required for the source. Those determinations will be made over the next several years 

during the Regional Haze planning and our State Implementation Plan develapmcnt 

process. 

Attached are the BART requirement text and the applicable definitions from the Code 

of Federal Regulations. If you have questions or commcnb regarding tbe BART 

requirements or this designation, please contact me at (601) 961-5176 or Deborah 

Boleware at (601) 961-5768, 

Sincerely, 

Chief, Air Support 
Appendix L.3.4 

BART Exemption Modeling 

of Sources in Mississippi 

January 2007 

Prepared For: 

VISTAS 

526 Forest Parkway, Suite F 

Forest Park, GA 30297 

Submitted By: 

TRC Environmental Corporation 

Wannalancit Mills 

650 Suffolk Street, Suite 200 

Lowell, MA 0 1854 
TABLE OF CONTENTS 

Page 

1. INTRODUCTION 

2. SOURCE PARAMETERS 

3. GEOPHYSICAL AND METEOROLOGICAL DATA 

3.1 Modeling Domain, Terrain, and Class I Areas 

3.2 Land Use 

3.3 Meteorological Data Base 

3.4 Air Quality Monitoring Data 

4. RESULTS 

5. REFERENCES 

LIST OF TABLES 

Page 

Table 2-la. International Paper Co., Vicksburg Mill: Source Parameters and Emissions 2-2 

Table 2-1 b. International Paper Co., Vicksburg Mill: Particle Speciation 2-2 

Table 2-2a. Greenwood Utilities, Henderson: Source Parameters and Emissions 2-3 

Table 2-2b. Greenwood Utilities, Henderson: Particle Speciation 2-3 

Table 4-1. Summary of Visibility Results for International Paper Co., Vicksburg Mill 4-2 

Table 4-2. Summary of Visibility Results for Greenwood Utilities, Henderson 4-2 

Table 4-3. Monthly f(RH) Values Based on the Centroid of the Area, for Visibility 

Method 6 Applications 
LIST OF FIGURES 

Page 

Figure 3-1. Terrain elevations for the CALMET 12-km regional domain. CALPUFF 

computational subdomain, the Class I areas and the locations of the Mississippi 

facilities are also shown. 3-2 

Figure 3-2. Terrain elevations for the CALPUFF computational subdomain. The Class I 

areas and the sites of the Mississippi facilities are also shown. 3-3 

Figure 3-3. Land Use for the CALPUFF computational subdomain. The Class I areas and the 

sites of the Mississippi facilities are also shown. 3-5 

Figure 3-4. Plot of ozone stations used for the CALPUFF simulations. The Class I areas and 

the sites of the Mississippi facilities are also shown. 3-6 

iri 
1. INTRODUCTION 

TRC Environmental Corporation, on behalf of VISTAS has been retained to conduct Best 

Available Retrofit Technology (BART) exemption modeling for a number of facilities in the 

southeastern United States. This report documents the results of the modeling simulations 

conducted in accordance with the VISTAS BART Protocol Revision 3.2 dated August 3 1, 2006 

(VISTAS, 2006) for emissions from two BART-eligible facilities in Mississippi. 

The VISTAS BART protocol is based on the use of the CALMET and CALPUFF models (Scire 

et al., 2000a, 2000b). The modeling approach uses 12-km VISTAS regional CALMET 

meteorological datasets for facilities located more than 50-km from the closest Class I area for 

screening simulations of predicted impacts. The highest impact during the three year simulation 

period is compared to a 0.5 deciview threshold. According to the VISTAS protocol, sources with 

impacts less than this threshold are not subject to BART control. 

The modeling uses the VISTAS version of the CALPUFF modeling system (CALMET Version 

5.723 and CALPUFF Version 5.754) available from the TRC Atmospheric Studies Group web 

site (http:/lw ww.src.corn). 
2. SOURCE PARAMETERS 

VISTAS BART exemption modeling was performed for two facilities in Mississippi. These 

sources are: (1) International Paper Co., Vicksburg Mill and (2) Greenwood Utilities, Henderson. 

These two facilities were modeled using the screening 12-km regional VISTAS CALMET 

domain with CALPUFF computational subdomain as shown in Figure 3-1. Locations of the 

Mississippi sources are shown in Figures 3-1 through 3-3. 

Source parameters and emissions rates as provided by the State of Mississippi for two facilities 

used in the CALPUFF simulations are shown in Tables 2-la through 2-2a. Tables 2-1 b through 

2-2b show the particle speciation used in the CALPUFF simulations. In the tables, the column 

heading PMlo includes all PM mass (condensable plus filterable) emitted as particulate matter less 

than 10 micrometers (ym) in diameter. The emissions labeled as PMz5 are a subset of the PMlo 

composed of particles less than 2.5 ym in diameter. All condensable emissions are assumed to be 

in the PMz,5 size range. The PMIo and PM2.5 categories include emissions, which in the 

model are treated as primary sulfate (S04). The emissions of H2S04 are adjusted by the ratio of 

molecular weights (96198) to obtain the emissions as SO4 which is entered into the model. 

The PMlo size distribution was represented in the modeling as six explicit size ranges. The 

partide sizes modeled were as 8.0 ym diameter size particles (PM800) reflecting the size bin 

6-10 pm, 4.25 pm diameter particles (PM425) for the size bin 2.5-6 pm, 1.875 pm particles 

(PM 187) for the size bin 1.25-2.5 pm, 1.125 pm particles (PMI 12) for the size bin 1.00-1 .25 pm, 

0.8 125 pm particles (PM08 1) for the size bin 0.625- 1 .OO pm, and 0.5625 pm (PM056) for the size 

range 0.500-0.625 pm. PM056 was also used for all particles less than 0.5 pm diameter. 

Emissions of particulate matter in the 2.5-10 pm diameter size range define "coarse particulate 

matter". Fine particles (soil) were defined using the particle size categories of PM187, PMI 12, 

PM081, and PM056 which is particulate matter with a size of 2.5 ym diameters or less. For 

sources with no speciation (emissions given as PMlo only) it was conservatively assumed that all 

the particulate emissions were condensable which have higher extinction efficiency than either 

soil or coarse particulate matter. Condensable emissions were assumed to be evenly distributed 

across the smallest two size categories modeled (i.e. 50 percent in PM081 and 50 percent in 

PM056). 

Sotrrce Parameters 2-1 
z-z slalaurmad Jarnos 

sP s13 sP sP s10 sfi SF ~1% SF 

md md md md lud mrl md md m li 

SZYO 0'1 ST1 S'Z SZYO 0.1 SZ'I F'Z 9-S'Z -S'O -SZYO -0'1 -ST1 -S'O -SZ9'0 -0'1 -ST1 
Table 2-2a. Greenwood Utilities. Henderson: Source Parameters and ~missions' 

Table 2-2b. Greenwood Utilities. Henderson: Particle ~~eciation' 

ftYPk Particle speciation Condensable Filterable 

NO, 

Emissions 

gls 

7.483 1 

Stack 

ID # 

002 

Emissions obtained the "BART-template-Greenwood Utilities-Henderson.xls" document. The PM speciation partially provided - only condensables were speciated. Remaining PMI 0 was 

subsequently speciated into filterables for the modeling purposes. 

H2S04 emissions are entered in CALPUFF as SO., i.e., weighted by ratio of molecular weights (96198). 

PM,, emission rate includes filterable and condensable emissions. The condensable component includes H2S0, emissions. 

M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO,) particle size distribution in CALPUFF. 

NH3 

Emissions 

gls 

PMIO 

~missions~ 

gls 

7.2967 

----.. 

ID # 

002 

Source Parameters 2-3 

PM2.s 

Emissions 

gls 

5.9209 

Lambert Conformal 

Coordinates 

condensable 

PMIo 

Yo 

55.5 

Stack 

Height 

m 

53.04 

LCC East 

km 

628.382 

LCC North 

km 

-694.365 

filterable 

PMlo 

Yo 

44.5 

Base 

Elevation 

m 

51.51 

~i~~~t~~ 

m 

2.74 

organic 

condensable (OC) 

0.625- 

1.0 

pm 

gls 

1.0485 

Gas Exit 

Velocity 

mls 

4.57 

0.5- 

0.625 

pm 

gls 

1.0485 

inorganic 

condensable H2S04 

~~=0.48 

SD4=2.0 

pm 

g/s 

0.625 

-1.0 

pm 

gls 

0.2621 

Stack 

Gas 

Exit 

Temp. 

K 

424.82 

0.5- 

0.625 

pm 

g/s 

0.2621 , 

So2 

Emissions 

g/s 

58.3897 

H2S04 

~missions~ 

gls 

1.4307 

1.4307 10.5289 0.8469 

COARSE 

6-10 

pm 

gls 

0.7468 

2,5-6 

pm 

g/s 

Soil 

0.0287 

1.25- 

2.5 

pm 

g/s 

0.2031 

Elemental Carbon (EC) 

1.25- 

2.5 

pm 

.ds 

0.0078 

1.0- 

1.25 

pm 

g/s 

0.3750 0.4750 

1.0- 

1.25 

pm 

0.0144 

0.625- 

1.0 

pm 

gls 

0.0182 

0.5- 

0.625 

pm 

gls 

0.625- 

1.0 

pm 

g/s 

0.5- 

0.625 

pm 

g/s 
3. GEOPHYSICAL AND METEOROLOGICAL DATA 

3.1 Modeling Domain, Terrain, and Class I Areas 

Gridded terrain elevations for the 12-km regional VISTAS modeling domain are derived from 

GTOP030, a global digital elevation model (DEM) with a horizontal grid spacing of 30 arc 

seconds (approximately 1 kilometer). GTOPO3O is a global data set covering the full extent of 

latitude from 90 degrees south to 90 degrees north, and the full extent of longitude from 180 

degrees west to 180 degrees east, developed by the United States Geological Survey (USGS). The 

horizontal grid spacing is 30-arc seconds, resulting in a DEM having dimensions of 2 1,600 rows 

and 43,200 columns. The horizontal coordinate system is decimal degrees of latitude and 

longitude referenced to WGS84. The vertical units represent elevation in meters above mean sea 

level. GTOP030 has been divided into 33 smaller pieces, or tiles. Two of these tiles cover 

regional VISTAS domain: W 1 OON4O and W 1 OON9O. 

The VISTAS CALMET 12-km regional domain was used in CALPUFF modeling and BART 

visibility analysis for two facilities in Mississippi. The CALPUFF computational subdomain was 

chosen to cover all Class I areas that are within 300 km from the MS sources, as well as a 50 km 

buffer zone from these Class I areas and the Mississippi facilities. The subdomain extends at least 

50 km from the Class I areas and all of the facilities in order to provide an adequate buffer zone at 

the boundaries. and to allow the effects of flow curvature and possible small-scale recirculation to 

be evaluated. 

Figure 3-1 shows contours of the terrain averaged to 12 km grid cells on the VISTAS 12-km 

regional domain. Blue rectangle depicts the area of the CALPUFF computational subdomain 

covering 468 km by 732 km or 39x61 grid cells. A Lambert Conformal Projection is used with an 

origin of 4O.ON, 97.OW and standard parallels at 33N and 45N. The datum used is NWS-84. The 

Class I areas covered by the computational subdomain and that were included in the BART 

visibility analysis are Sipsey and Breton Island (Figure 3-2). 

3.2 Land Use 

The USGS Land Use data within the CALMET regional and subregional domains have been used 

to produce a gridded field of dominant land use categories. The land use data were obtained in 

Composite Theme Grid format (CTG) from the USGS, with a resolution of 200 m. For the 

portions of the domains where CTG data were missing, North America USGS land uselland cover 

data have been used. The North America land cover data base is one portion of a global land 

cover characteristics data base that was developed on a continent-by-continent basis with I -km 

nominal spatial resolution. 

Land use data were processed to produce a 12 km resolution gridded field of fractional land use 

categories for the regional domain. The 37 USGS land use categories were then mapped into 

14 CALMET land use categories. Surface properties such as albedo, Bowen ratio, roughness 

Geophysical and Me/eorological Data 3- 1 
Elevation 

(meters) 

CALPUFF / I computatatlonal domaln 

LCC Or~g~n 40 0 N, 97 0 W 

Standard Parallels 33 0 N, 45 0 N 

Datum NWS-84 

LCC East (km) 

Figure 3- 1. Terrain elevations for the CALMET 12-km regional domain. CALPUFF computational 

subdomain, the Class 1 areas and the locations of the Mississippi facilities are also shown. 

Geophysical and Meteorological Data 3-2 
500 600 700 800 900 

LCC East (km) 

Figure 3-2. Terrain elevations for the CALPUFF computational subdomain. The Class I areas and the 

sites of the Mississippi facilities are also shown. 

Elevation 

(meters) 

-k MS facility 

LCC Origin: 40.0 N, 97.0 W 

Standard Parallels: 33.0 N, 45.0 N 

Datum: NWS-84 

Crophvsrcal and Me~eorological Data 3-3 
length, and leaf area index were computed proportionally to the fractional land use. The USGS 

land use categories and their associated geophysical parameters are described in Scire et al. 

(2000a). Figure 3-3 shows the dominant land use categories for each CALMET grid cell in the 

modeling subdomain. 

3.3 Meteorological Data Base 

The meteorological data used include the three dimensional gridded model output from the Fifth 

Generation Penn StateINCAR MM5 (Grell 1995) provided by VISTAS. VISTAS has assembled 

three years of MM5 meteorological data for the regional CALPUFF modeling. These MM5 

datasets have been developed by EPA for 2001, VISTAS for 2002 and Midwest Regional 

Planning Organization (RPO) for 2003. The MM5 gridded data set consists of hourly values of 

wind speed, wind direction, temperature and pressure on a grid covering the VISTAS regional 

12-km CALMET domain. The MM5 data was run at a horizontal spatial resolution of 12-km for 

years 2001 and 2002 and 36-km for year 2003. For the VISTAS regional 12-km domain, 

CALMET runs have been made in the no-observational mode. 

3.4 Air Quality Monitoring Data 

CALPUFF uses hourly ozone concentration measurements in the chemical transformation rates 

(SO2 to SO4, NO, to HN03/NO?). The ambient ozone measurements are used in determining SO2 

loss rates due to chemical transformation to sulfate and in determining NO, loss rates to nitrate. 

Ambient ozone monitoring data from the U.S. EPA AIRS and CASTNET networks were used to 

develop the hourly ozone monitoring data file (0ZONE.DAT). Figure 3-4 provides a plot of 

available ozone monitoring stations that were used for the CALPUFF modeling. 

For the base case simulations, a constant ammonia concentration of 0.5 parts per billion (ppb) 

was assumed as recommended by the Interagency Workgroup on Air Quality Modeling 

(IWAQM, 1998) for forested Class I areas. In this application of the model, the Ammonia 

Limiting Method (ALM) was not used. 

tieophysrcal and Meteorologrcal Data 3- J 
Snow 1 Ice 

Tundra 

Barren land 

Wetland 

Water 

Forest land 

Rangeland 

Agricultural 

land 

Urban/ 

built-up land 

+ MS facility 

LCC Origin: 40.0 N. ' 

Standard Parallels: 33 

Datum: NWS-84 

500 600 700 800 960 

LCC East (krn) 

Figure 3-3. Land Use for the CALPUFF computational subdomain. The Class I areas and the sites of 

the Mississippi facilities are also shown. . 

Geophysrcal and Meteorological Data 3-5 
Elevation 

(meters) 

CALPUFF 1 romputat~onal domam 

.* MS facility 

Ozonedata 

LCC Origin. 40.0 N, 97.0 W 

Standard Parallels. 33.0 N, 45.0 N 

Datum: NWS-84 

400 500 600 700 800 900 1000 

LCC East (km) 

Figure 3-4. Plot of ozone stations used for the CALPUFF simulations. The Class I areas and the sites 

of the Mississippi facilities are also shown. 
4. RESULTS 

The results of the CALMET and CALPUFF modeling for two BART-eligible facilities in 

Mississippi are presented in this section. The simulations were conducted over the three year 

period of 2001-2003. Modeling was conducted using the VISTAS 12-km gridded CALMET 

meteorological data files. The POSTUTIL program was used to scale and sum the various 

CALPUFF concentration files to obtain total concentrations. Emission rates of SOz, SO4, and 

NO, were input directly to the CALPUFF model while the six particulate species defining 

specific size categories were modeled as a unit emission rate (1 gls) and then scaled source by 

source using the POSTUTIL program. CALPOST Method 6 was used to compute the extinction 

change in deciviews (dv) consistent with the procedures outlined in the VISTAS modeling 

protocol using the IMPROVE method (CSU, 1996) as recommended by FLAG (2000). 

Table 4-3 provides the monthly f(RH) values based on the centroid of the Class 1 area as required 

for the application of Method 6. The last column in Tables 4-1 through 4-2 provides the annual 

average background be, values for each Class I area included in the analysis. For each Class 1 

area, the Rayleigh scattering coefficient of 10 ~m-' was subtracted from the annual average 

background be,, and resulting values were entered in CALPOST as BKSOIL. 

Tables 4- 1 through 4-2 summarize the maximum predicted extinction changes for 2001, 2002, 

and 2003 for the Class 1 Areas situated within a 300 km radius of the two modeled sources. The 

highest values of the extinction change along with number of exceedances of the 0.5 dv threshold 

value are presented in these tables. For screening simulations using the 12-km CALMET 

meteorological grid, the highest predicted change in extinction is compared to the 0.5 dv 

threshold. According to the VISTAS protocol, screening simulation results below 0.5 dv for all 

three years indicates that facility is not subject to BART controls. For facilities failing the screen, 

or those located relatively close to one or more Class 1 areas (usually within 50 km) the state has 

recommended immediately using the more refined 4-km CALMET meteorological grid. In the 

refined simulations, the 98th percentile value of prediction change in extinction (i.e., the 8th 

highest day) is compared to the 0.5 dv threshold. If the highest 98th percentile value during the 

three year simulation period is below the 0.5 dv threshold, the source is considered not subject to 

BART controls. 

Visibility results in Tables 4-1 and 4-2 show that the maximum predicted extinction change for 

each of the Class I areas are all below the 0.5 dv threshold value for both modeled facilities. 

Breton Island is within 300 km from the International Paper Co., Vicksburg Mill. Maximum 

predicted extinction change due to the BART emissions from this facility is 0.3 15 dv in 2001. 

The Class I area that is less than 300 km away from the Greenwood Utilities, Henderson is 

Sipsey. Maximum predicted extinction change due to the BART emissions from this facility is 

0.216 dv, also in 2001. 
Table 4-1. Summary of Visibility Results for International Paper Co., Vicksburg Mill 

Annual 

Class I Area 2001 1 2002 1 2003 average background 

Table 4-2. Summarv of Visibilitv Results for Greenwood Utilities. Henderson 

Maximum delta-deciview, (# days>0.5 dv, # days > 1 dv) 

Class I Area 

(~m-I) 

Maximum delta-deciview, (# days>0.5 dv, # days >I dv) 

0.216 (0 0) ( 0.198 (0 0) 1 0.122 (0 0) 

Annual 

Breton 

average 

background 

be,, 

0.3 I5 (0. 0) 1 0.205 (0,O) 1 0.222 (0,O) I 21.57 

Table 4-3. Monthly f(RH) Values Based on the Centroid of the Area, for Visibility Method 6 

ADDlica tions 

Class 1 area Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Breton 3.7 3.5 3.7 3.6 3.8 4.0 4.3 4.3 4.2 3.7 3.7 3.7 

Sipsey 3.4 3.1 2.9 2.8 3.3 3.7 3.9 3.9 3.9 3.6 3.3 3.4 

Source: Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule (2003); Appendix A, Table A-3 

Results 4-2 
5. REFERENCES 

CSU, 1996: IMPROVE (Interagency Monitoring of Protected Environments). Spatial and 

Seasonal patterns and Long Term Variability of the Composition of the Haze in the 

United States: An Analysis of Data from the IMPROVE Network. ISSN: 0737-5352-32. 

Environmental Protection Agency (EPA), 1998: Interagency Workgroup on Air Quality 

Modeling (IWAQM), Phase 2 Report: Summary Report and Recommendation for 

Modeling Long Range Transport and Impacts on Regional Visibility. U.S. EPA, 

Research Triangle Park, NC. EPA-454lR-98-0 19. 

Environmental Protection Agency (EPA), 2003: Guidance for Estimating Natural Visibility 

Conditions under the Regional Haze Program. U.S. EPA, Research Triangle Park, NC, 

EPA-454/B-03-005. 

FLAG, 2000: Federal Land Managers' Air Quality Related Values Workgroup (FLAG). Phase I 

report. 

Grell, G.A., J.Dudhia, and D.R. Stauffer, 1995: "A Description of the Fifth Generation Penn 

State/NCAR Mesoscale Model (MMj)", NCAR TN-398-STR, NCAR Technical Note. 

Scire, J.S., D.G. Strimaitis, and R.J. Yamartino, 2000a: A User's Guide for the CALPUFF 

Dispersion Model (Version 5). Earth Tech, Inc., Concord, MA. Available from 

littp:i~~vwu~.src.c01n. 

Scire, J.S., F.R. Robe, M.E. Femau, and R.J. Yamartino, 2000b: A User's Guide for the 

CALMET Meteorological Model (Version 5). Earth Tech, Inc., Concord, MA. Available 

from htt~:ii\vww.src.com. 

VISTAS, 2006: Protocol for the Application of the CALPUFF Model for Analyses of Best 

Available Retrofit Technology (BART). Revision 3.2, August 2006. Available from 

ht.t.p:iiwww.vistas-sesar1n.org. 

References 5- 1 
Appendix L.3.5 

STATE OF MISSISSIPPI 

Hum&urnn 

Covamm 

MISSiSSIPPl DEPARTMENT OF ENVIRONMENTAL QUALITY 

. - mD.F-Exllamnm 

October 2,2007 

Dudley McBee 

Greenwood Utilities - Henderson 

P.O. BOX 866 

Greenwood, MS 38935 

Subject: Exemption fiom Best Available Retrofit Technology (BART) Determination Requirements 

Henderson, (1 560)083-00048 

Leflore, Mississippi 

Dear Mr. McBee: 

Due to the Greenwood Utilities - Henderson facility being BART eligible, you were required to 

perform and submit exemption modeling analysis for your eligible units. We have received the 

exemption modeling performed by TRC Environmental Corporation. The modeling finds a 

visibility impact of0.22 deciviews (dv) which is below the 0.5 dv subjectivity threshold. Based 

on these results, we are proposing that the BART eligible units be exempt from further 

determination requirements. Mississippi Department of Environmental Quality (MDEQ) will 

include documentation of the proposed exemptions in our Regional Haze State Implementation 

Plan (SIP) submittal. The SP is reviewed and commented on by the Environmental Protection 

Agency (EPA) and other parties with Greenwood Utilities - Henderson's exemption contingent 

on EPA's approval. 

If you have any questions regarding this matter, please feel free to contact Elliott Bickerstaff 

(60 1-96 1-5 176) or Deborah Boleware (601 -96 1-5768) of my staff. 

Sincerely, 

Maya ~aof/P.~.. BCEE