C-1

APPENDIX C – SUMMARY OF ALM ANALYSES AND RECOMMENDATIONS 

Appendix L2 

Regional Haze SIP for Florida

Page 151 of 266
Summary of CMAQ 2002 Evaluation for 

Predictions with CALPUFF in 

VISTAS-BART

Christelle Escoffier-Czaja & Joseph S. Scire

Appendix L2 Regional Haze SIP for Florida
What sources of NH3 concentration 

with CALPUFF? 

z NH

3 = constant 

z Hourly or Monthly CMAQ NH

3(gas) alone = excess 

z Ammonia Limiting Method (ALM) using:

– Hourly CMAQ SO

4

– Hourly CMAQ totalNO

3=NO

3+HNO

3

– Hourly CMAQ totalNH

3=NH

3(gas)+NO

3+2SO

4

It creates a space- and time-varying environment of background pol

each receptor of Class I areas

It creates a space- and time-varying NH

3 background available for a 

source to use.

Appendix L2 Regional Haze SIP for Florida
CMAQ NH3(gas) ANNUAL AVERAGE

-2000 -1000 0 1000 2000 3000

-2000-1000

0

10002000

Ammonia Concentrations (ppb)

Annual Average (2002)

Appendix L2 Regional Haze SIP for Florida
CMAQ NH3(gas) MONTHLY AVERAGE

-2000 -1000 0 1000 2000 3000

-2000-1000

0

10002000

Ammonia Concentrations (ppb)

January Average (2002)

Ammonia

(ppb)

0.010.10.512345678910

-2000 -1000 0 1000 

-2000-1000

0

10002000

Ammonia Concentra

April Average (2

JANUARY 2002 APRIL 20

Appendix L2 Regional Haze SIP for Florida
CMAQ NH3(gas) COMPARED TO 

OBSERVATIONS – daily averaged

NH3 scatter plot - daily average - Jan to May 2002

012345678

012345678

NH3 observed (ppb)

NH3 CMAQ predicted (ppb)

NH3 Q-Q plot - daily average - Jan to M

012345678

012345

NH3 observed (ppb)

NH3 CMAQ prediction (ppb)

January to May 2002 – Daily average at St Louis SupersiteSCATTER PLOT Quantile-Quantile PL

Appendix L2 Regional Haze SIP for Florida
CMAQ NH3(gas) COMPARED TO SEAR

OBSERVATIONS – Monthly average

NH3 monthly average at each of the 8 SEARCH site.

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

1 13 25 37 49 61 73 85

Jan to Dec for each site

NH3 (ppb) 

Location of Shttp://www.atmolocations/index.h

Observations – year 2004CMAQ – year 2002

Appendix L2 Regional Haze SIP for Florida
CONCLUSION for NH

3 (gas phase)

z CMAQ NH

3(gas) shows a strong spatial and tempora

variability

– A constant NH

3 (i.e. 0.5ppb) is not consistent with this variab

z But at the sites where we have observations, CMAQ 

NH

3(gas) underpredicts NH

3(gas) observed

z So, CMAQ NH

3(gas) is not recommended to be used 

alone for a refined NO

3 prediction with CALPUFF be

it may underpredict NO

3 formation 

Appendix L2 Regional Haze SIP for Florida
Alternative to NH3(gas) alone: 

ALM application

z For ALM application, data needed: Background 

concentrations such as CMAQ dataset 

– concentrations necessary: NO3, HNO3, SO4 and 

TNH3=NH3(gas)+NO3+2SO4

z CMAQ NO3, SO4 and total NO3 (NO3+HNO3) are com

to observations from CASTNet and IMPROVE networevaluate CMAQ performance

– 52 CASTNet sites (23 in VISTAS states) – weekly average– 46 IMPROVE sites (16 in VISTAS states) – daily average

Appendix L2 Regional Haze SIP for Florida
-95 -90 -85 -80 -75 -70

Longitude (in Degrees)

2530354045

Latitude (in degrees) CAD150 SND152

ABT147

SUM156

IRL141

EVE419

GAS153

STK138

BVL130

ALH157

SAL133

VIN140

MCK131CKT136

MAC426

CDZ171

BEL116

BWR139

HOX148

UVL124

ANA115

CVL151

PNF126

CND125 COW137 BFT142

WSP144

HWF187

CTH110

CAT175

LYK123

QAK172 OXF122DCP114

CHE185

MKG113KEF112

PSU106

LRL117ARE128

SPD111

ESP127

GRS420

SHN418

VPI120 PED108

PAR107 CDR119

PRK134

CASTNet sites

Class I areas

Location of CASTNet sites Used 

and Class I areas in the SouthEast

Appendix L2 Regional Haze SIP for Florida
-95 -90 -85 -80 -75 -70

Longitude (in Degrees)

2530354045

Latitude (in degrees)

ADPI1

AREN1

BLMO1

BOND1

BOWA1

BRET1

BRIG1

CACR1

CADI1

CHAS1

COHI1

COHU1

DOSO1

ELDO1

EVER1

GRRI1

GRSM1

HEGL1

ISLE1

JARI1

LASU1

LIGO1

LIVO1

MING1 MACA1

MKGO1 MOMO1

OKEF1

QUCI1

ROMA1

SAFO1

SAMA1

SENE1

SHEN1

SHRO1

SIKE1

SIPS1

SWAN1

TALL1

UPBU1

VILA1

VOYA2

WASH1

IMPROVE sites

Class I areas

Location of IMPROVE sites Used 

and Class I areas in the SOuthEast

Appendix L2 Regional Haze SIP for Florida
CMAQ versus IMPROVE

daily averages comparison

NO3 daily average Q-Q plot - year 2002

02468

1012141618

0 2 4 6 8 10 12 14 16 18

NO3 IMPROVE (ug/m3)

NO3 CMAQ (ug/m3)

SO4 daily average Q-Q plot - 

05

1015202530

0 5 10 15 

SO4 IMPROVE (ug/

SO4 CMAQ (ug/m3)

Appendix L2 Regional Haze SIP for Florida
CMAQ versus CASTNet

weekly averages comparison

NO3 weekly average scatter plot - year 2002

02468

1012

0 2 4 6 8 10 12

NO3 CASTNET (ug/m3)

NO3 CMAQ (ug/m3)

SO4 weekly average Q-Q plot 

02468

101214161820

0 2 4 6 8 10 1

SO4 CASTNET (ug/m

SO4 CMAQ (ug/m3)

total NO3 weekly average Q-Q pl

02468

101214

0 2 4 6 8 

total NO3 CASTNET (ug

total NO3 CMAQ (ug/m3)

HNO3 weekly average Q-Q plot - year 2002

02468

1012

0 2 4 6 810 12

HNO3 CASTNET (ug/m3)

HNO3 CMAQ (ug/m3)

Appendix L2 Regional Haze SIP for Florida
CMAQ/Observation ratios as function of 

elevation and months

Appendix L2 Regional Haze SIP for Florida
CONCLUSION ON CMAQ EVALU

z SO

4 and total NO

3 from CMAQ are in very good a

with observations (from CASTNet and IMPROVE)

– CMAQ SO

4 slightly lower than observations

– CMAQ total NO

3 slightly larger than observations

– CMAQ NO

3 is larger than observations in winter and smaller in 

z Next Step to confirm CMAQ data suitable to be us

ALM application:

– Use of CMAQ hourly SO

4, totalNO

3=NO

3+HNO

3 and tota

2SO

4 + NH

3(gas) as input to POSTUTIL (as it would be 

ALM) and compare NO

3 output to NO

3 observed and CM

Appendix L2 Regional Haze SIP for Florida
CMAQ data INPUT in POSTUTIL for NO

predictions

NO3 weekly average - Q-Q plot - year 2002

02468

1012

0 2 4 6 810 12

NO3 CASTNET observations (ug/m3)

NO3 MODEL simulations (ug/m3) CHEMEQ 'CMAQ'

z CHEMEQ is POSTU

NO

3/HNO

3 equilibriu

parameterization

z Pink – CMAQ outpuz Dark blue – hourly C

input in CHEMEQ + TNH

3 = NH

3g+NO

3+

CONCLUSION: NO

3 output of 

closely tracks CMAQ NO

3. Hou

dataset can be used for ALM aPOSTUTIL.

NO3 daily averaged - Q-Q plots - year 2002

02468

10121416

0 2 4 6 8 10 12 14 16

NO3 IMPROVE observations (ug/m3)

NO3 MODEL simulations (ug/m3) CHEMEQ CMAQ

Appendix L2 Regional Haze SIP for Florida
NO3 Predictions using CMAQ monthly avera

z TEST IF MONTHLY 2002 CM

USED TO CREATE 2001 anBACKGROUND

z Dark blue – hourly CMAQ inp

+ hourly CMAQ TNH3 = NH3g

z Red – Year 2002 using mont

input in CHEMEQ + monthly 

z Yellow – Year 2001 using mo

CMAQ input in CHEMEQ + mTNH3

z Light Blue – Year 2003 using 

CMAQ input in CHEMEQ + m

NO3 daily average - Q-Q plot

02468

101214

0 2 4 6 8 10 12 14

NO3 IMPROVE observations (ug/m3)

NO3 predicted (ug/m3) PUFHR PUFMONALL2002 PUFMONALL2001 PUFMONALL2003

NO3 weekly averaged Q-Q plot

02468

101214

0 2 4 6 8 10 12 14

NO3 CASTNET observations (ug/m3)

NO3 predicted (ug/m3) PUFHR PUFMONALL2002 PUFMONALL2001 PUFMONALL2003

Appendix L2 Regional Haze SIP for Florida
NO3 Predictions/Observations daily averaged time se

Smoky Mountains, NP, Tennessee - IMPRO

NO3 daily averaged at GRSM1 - 2001 - CASTNet T, RH

0123456

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3) IMPROVE PUFMON

NO3 daily averaged at GRSM1 - 2002 - CASTNet T, RH

0123456

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3) IMPROVE PUFMON PUFMONHR

Dark blue – ObservaPink – monthly Light blue – hourly B

Hourly BCKG = use oof SO4, NO3, HNO3 aTNH3 = NO3 +2 SO4 Monthly BCKG = use of SO4, NO3, HNO3 aTNH3 = NO3 +2 SO4 NH3g =CMAQNH3g

NO3 daily averaged at GRSM1 - 2003 - CASTNet T, RH

0123456

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3) IMPROVE PUFMON

Appendix L2 Regional Haze SIP for Florida
NO3 Predictions/Observations daily averaged tim

series at Dolly Sods Wilderness - IMPROVE

NO3 daily averaged at DOSO1 - 2001 - CASTNet T, RH

0123456

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3) IMPROVE PUFMON

NO3 daily averaged at DOSO1 - 2002 - CASTNet T, RH

0123456

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3) IMPROVE PUFMON PUFHR

Dark blue – ObservaPink – monthly Light blue – hourly B

Hourly BCKG = use of hof SO4, NO3, HNO3 and TNH3 = NO3 +2 SO4 +NMonthly BCKG = use of of SO4, NO3, HNO3 and TNH3 = NO3 +2 SO4 +NNH3g = CMAQNH3g

NO3 daily averaged at DOSO1 - 2003 - CASTNet T, RH

0123456

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3) IMPROVE PUFMON

Appendix L2 Regional Haze SIP for Florida
NO3 Predictions/Observations daily averaged tim

series at Everglades NP, Florida - IMPROVE

NO3 daily averaged at EVER1 - 2001 - CASTNet T, RH

0

0.20.40.60.8

1

1.21.41.6

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3) IMPROVE PUFMON

NO3 daily averaged at EVER1 - 2002 - CASTNet T, RH

0

0.20.40.60.8

1

1.21.41.6

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3) IMPROVE PUFMON PUFHR

Dark blue – ObservationPink – monthly BCLight blue – hourly BCK

Hourly BCKG = use of of SO4, NO3, HNO3 anTNH3 = NO3 +2 SO4 +Monthly BCKG = use oof SO4, NO3, HNO3 anTNH3 = NO3 +2 SO4 +NH3g =CMAQNH3g

NO3 daily averaged at EVER1 - 2003 - CASTNet T, RH

0

0.20.40.60.8

1

1.21.41.6

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3) IMPROVE PUFMON

Appendix L2 Regional Haze SIP for Florida
NO3 Predictions/Observations daily averaged tim

series at Everglades NP, Florida - IMPROVE

Dark blue – ObservatLight blue – hourly Pink – monthly BYellow – monthlGreen – monthly B

Hourly BCKG = usof SO4, NO3, HNOTNH3 = NO3 +2 SMonthly BCKG = of SO4, NO3, HNOTNH3 = NO3 +2 SIn TNH3, CMAQNeither 0.5ppb, 1ppb in this exampleNH3g = 1ppb gives closer to observatioWhile NH3g=10pp

in winter

NO3 daily averaged at EVER1 - 2001 - CASTNet T, RH

0

0.20.40.60.8

1

1.21.41.6

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3) IMPROVE PUFMON0p5 PUFMON1ppb PUFMON10ppb

NO3 daily averaged at EVER1 - 2002 - CASTNet T, RH

0

0.20.40.60.8

1

1.21.41.6

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3)IMPROVE PUFMON0p5 PUFMON1ppb PUFHR PUFMON10ppb

NO3 daily averaged at EVER1 - 2003 - CASTNet T, RH

0

0.20.40.60.8

1

1.21.41.6

1 31 61 91 121 151 181 211 241 271 301 331 361

Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3) IMPROVE PUFMON0p5 PUFMON1ppb PUFMON10ppb

Appendix L2 Regional Haze SIP for Florida
CONCLUSION – use of 2002 CM

hourly dataset

z CMAQ NH

3(gas) is not recommended to be used alone 

CALPUFF for a refined analysis - too much underpredimost sites evaluated

z ALM application with POSTUTIL using hourly 2002 CMA

concentrations for background is recommended.

– For year 2002: hourly SO

4, hourly totalNO

3 and hourly 

totalNH

3=NH

3(gas)+NO

3+2SO

4 in POSTUTIL gives NO

3 concent

comparable to CMAQ NO

3 at all sites.

z For years 2001 and 2003: an hourly dataset similar to C

2002 would be recommended

Appendix L2 Regional Haze SIP for Florida
CONCLUSION – use of 2002 CMA

monthly averaged

z CMAQ 2002 monthly averages as input in POSTUTIL underestim

largest NO

3 concentrations observed for all three years.

z At some Class I areas, up to 5 days out of 104 days (5%) – 18 days in a year can be m

(observed for 2001 and 2003).

z As an alternative to hourly background data for ALM application, 2

CMAQ monthly averaged background can be a solution, knowing highest NO

3 concentrations will be missed and the averaged NO

3

concentrations may be overestimated.

z If 2002 CMAQ monthly average is considered to be used for 2001 

2003. It will also be used for 2002 for consistency over the 3 year

z For Everglades NP, it is suggested that monthly average 

TNH

3=NO

3+2SO

4+NH

3(g) be replaced by TNH

3=NO

3+2SO

4+1ppb 

application (may be for Breton Wilderness too).

Appendix L2 Regional Haze SIP for Florida
BART Exemption Modeling 

of Sources in Florida

January 2007 

Prepared For: 

VISTAS 

526 Forest Parkway, Suite F 

Forest Park, GA 30297 

Submitted By: 

TRC Environmental Corporation 

650 Suffolk Street, Wannalancit Mills 

Lowell, MA 01854 

Appendix L3 

Regional Haze SIP for Florida

Page 174 of 266
i

TABLE OF CONTENTS 

Page 

1. INTRODUCTION 1-1

2. SOURCE PARAMETERS 2-1

3. GEOPHYSICAL AND METEOROLOGICAL DATA 3-1

3.1 Modeling Domain, Terrain, and Class I Areas 3-1

3.2 Land Use 3-3

3.3 Meteorological Data Base 3-6

3.4 Air Quality Monitoring Data 3-6

4. RESULTS 4-1

5. REFERENCES 5-1

LIST OF TABLES 

Page 

Table 2-1a. CEMEX Brooksville: Source Parameters and Emissions 2-3

Table 2-1b. CEMEX Brooksville: Particle Speciation 2-4

Table 2-2a. FPL - Putnam Power Plant: Point Source Parameters and Emissions 2-5

Table 2-2b. FPL - Putnam Power Plant: Particel Speciation 2-5

Table 2-3a. Hopkins Tallahassee: Source Parameters and Emissions 2-6

Table 2-3b. Hopkins Tallahassee: Particle Speciation 2-6

Table 4-1a. Summary of Visibility Results for CEMEX Brooksville – Refined Run (4-km 

grid) 4-3

Table 4-1b. Visibility Results – 8 Highest Values for CEMEX Brooksville – Refined Run 

(4-km grid) 4-3

Table 4-2. Summary of Visibility Results for FPL - Putnam Power Plant – Screening Run 

(12-km grid) 4-3

Table 4-3a. Summary of Visibility Results for Hopkins Tallahassee – Refined Run (4-km 

grid) 4-4

Appendix L3 

Regional Haze SIP for Florida

Page 175 of 266
 ii 

Table 4-3b. Visibility Results – 8 Highest Values for Hopkins Tallahassee – Refined Run 

(4-km grid) 4-4

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

Method 6 Applications 4-5

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 Florida facilities 

are also shown. 3-2

Figure 3-2. Terrain elevations for the CALMET/CALPUFF Domain 2. The Class I areas and 

the sites of Florida facilities are also shown. 3-4

Figure 3-3. Land use for the CALMET/CALPUFF Domain 2. The Class I areas and the sites 

for the Florida facilities are also shown. 3-5

Figure 3-4. Plot of MM5 grid and surface, precipitation, buoy, and upper air stations for the 

CALMET/CALPUFF subregional Domain 2. 3-7

Figure 3-5. Plot of ozone stations used for the CALPUFF simulations. The Class I areas and 

the sites of the Florida facilities are also shown. 3-8

Appendix L3 

Regional Haze SIP for Florida

Page 176 of 266
Introduction 1-1 

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 31, 2006 

(VISTAS, 2006) for emissions from three BART-eligible facilities in Florida. 

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. For sources failing the screen by 

a small margin, or those located within 50 km of the closest Class I area, TRC performed 

modeling using the refined 4-km subregional CALMET Domain 2 datasets. The impacts on the 

98th percentile day (i.e., 8th highest within a year) predicted by the refined simulations were 

compared to the 0.5 deciview threshold. Facilities with a maximum 98th percentile impact below 

0.5 deciview were determined to be exempt from BART controls. 

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://www.src.com). 

Appendix L3 

Regional Haze SIP for Florida

Page 177 of 266
Source Parameters 2-1 

2. SOURCE PARAMETERS 

VISTAS BART exemption modeling was performed for three facilities in Florida. These sources 

are: (1) CEMEX Brooksville; (2) FPL Putnam Power Plant and (3) Hopkins Tallahassee. FPL 

Putnam Power Plant was modeled using the screening 12-km regional VISTAS CALMET 

domain with CALPUFF computational subdomain as shown in Figure 3-1. CEMEX Brooksville 

and Hopkins Tallahassee were modeled using the 4-km subregional Domain 2 since their distance 

to the closest Class I Area (Chassahowitzka for CEMEX and St. Marks for Hopkins) is less than 

50 km. Locations of the three Florida facilities are shown in Figures 3-1 through 3-3. 

Source parameters and emissions rates as provided by the State of Florida for each of the facilities 

used in the CALPUFF simulations are shown in Tables 2-1a through 2-3a. Tables 2-1b through 

2-3b show the particle speciation used in the CALPUFF simulations. In the tables, the column 

heading PM10 includes all PM mass (condensable plus filterable) emitted as particulate matter less 

than 10 micrometers (μm) in diameter. The emissions labeled as PM2.5 are a subset of the PM10

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

in the PM2.5 size range. The PM10 and PM2.5 categories include H2SO4 emissions, which in the 

model are treated as primary sulfate (SO4). The emissions of H2SO4 are adjusted by the ratio of 

molecular weights (96/98) to obtain the emissions as SO4 which is entered into the model. 

The PM10 size distribution was represented in the modeling as six explicit size ranges. The 

particle sizes modeled were as 8.0 μm diameter size particles (PM800) reflecting the size bin 

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

(PM187) for the size bin 1.25-2.5 μm, 1.125 μm particles (PM112) for the size bin 1.00-1.25 μm, 

0.8125 μm particles (PM081) for the size bin 0.625-1.00 μm, and 0.5625 μm (PM056) for the size 

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

Emissions of particulate matter in the 2.5-10 μm diameter size range define “coarse particulate 

matter”. Fine particles (soil) were defined using the particle size categories of PM187, PM112, 

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

sources with no speciation (emissions given as PM10 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). 

For the CEMEX Brooksville, Tables 2-1a and 2-1b show source parameters, emissions and 

particle speciation data extracted from the “CEMEX Brooksville 0530010.xls” file. For six of the 

ten stacks, PM distribution was provided and used in the modeling (Table 2-1b). Appropriate 

adjustments to PM10 and PM2.5 emissions for these six stacks were made (Table 2-1a), as 

described in the footnote. For remaining four stacks (002, 009, 011 and 024), the PM distribution 

was not provided, so PM10-H2SO4 emissions were equally divided between the two size 

categories of OC for modeling purposes. 

Appendix L3 

Regional Haze SIP for Florida

Page 178 of 266
Source Parameters 2-2 

For the FPL Putnam Power Plant, Tables 2-2a and 2-2b show source parameters, emissions and 

particle speciation data extracted from the “FPL Putnam.xls” file. For all four stacks, PM 

speciation was partially provided by the state (71% of PM10 that was assigned to condensable 

and distributed among two OC size categories). For the purpose of modeling, all PM10-H2SO4

emissions were equally divided between the two size categories of OC. 

For the Hopkins Tallahassee, Tables 2-3a and 2-3b show source parameters, emissions and 

particle speciation data extracted from the “Hopkins Tallahassee.xls” file. The PM distribution 

was not provided, so PM10-H2SO4 emissions were equally divided between the two size 

categories of OC for modeling purposes. 

Appendix L3 

Regional Haze SIP for Florida

Page 179 of 266
Source Parameters 2-3 

Table 2-1a. CEMEX Brooksville: Source Parameters and Emissions1

Stack 

ID # 

Lambert Conformal 

Coordinates Stack 

Height 

Base 

Elevation Diameter Gas Exit Velocity 

Stack 

Gas 

Exit 

Temp. 

SO2

Emissions 

H2SO4

Emissions2

NOx

Emissions 

PM

Emis

LCC East LCC North 

 km km m m m m/s K g/s g/s g/s g

002 1426.5697 -1148.3464 22.86 45.72 0.91 7.19 302.59 - - - 0.1003 1426.5918 -1148.4144 45.72 45.72 3.96 10.52 374.82 0.2604 0.1275 22.2138 0.9004 1426.5588 -1148.2247 15.24 45.72 3.05 9.06 444.26 - - - 0.6005 1426.5022 -1148.1934 21.34 45.72 0.79 14.35 366.48 - - - 3.8006 1426.5618 -1148.1830 45.72 45.72 0.61 24.26 302.59 - - - 0.0008 1426.5548 -1148.3192 65.84 45.72 0.61 24.26 302.59 - - - 0.2009 1426.4750 -1148.0953 42.67 45.72 0.67 26.73 338.71 - - - 0.0011 1426.6376 -1148.3243 24.38 45.72 0.76 15.52 298.15 - - - 0.2024 1426.6376 -1148.3243 24.69 45.72 0.52 12.04 314.82 - - - 0.0025 1426.5419 -1148.1865 9.75 45.72 0.61 24.26 294.26 - - - 0.2

Appendix L3 Regional Haze SIP for Florida
Source Parameters 2-4 

Table 2-1b. CEMEX Brooksville: Particle Speciation1, 1a, 1b

Stack 

ID # 

Particle speciation Condensable Filterable 

condensable 

PM10

filterable 

PM10

organic 

condensable (OC) 

inorganic 

condensable H2SO4 COARSE Soil 

0.625-

1.0 

μm 

0.5-

0.625 

μm 

0.625

-1.0 

μm 

0.5-

0.625 

μm 

M4=0.48

SD4=2.0

μm 

6-10 

μm 

2.5-6 

μm 

1.25-

2.5 

μm 

1.0-

1.25 

μm 

0.625-

1.0 

μm 

0.5-

0.625 

μm 

% % g/s g/s g/s g/s g/s g/s g/s g/s g/s g/s g/s 

002 100.0 0.0 0.0540 0.0540 - - - 003 87.6 12.4 0.0812 - 0.5953 - 0.1275 0.0092 0.0437 0.0553 0004 85.6 14.4 0.0688 - 0.5042 - - 0.0078 0.0370 0.0469 0005 85.6 14.4 0.3968 - 2.9100 - - 0.0450 0.2138 0.2704 0006 85.5 14.5 0.0040 - 0.0295 - - 0.0005 0.0022 0.0027 0008 85.6 14.4 0.0269 - 0.1969 - - 0.0030 0.0145 0.0183 0009 85.3 14.7 0.0008 - 0.0056 - - 0.0001 0.0004 0.0005 0011 100.0 0.0 0.1138 0.1138 - - - 024 100.0 0.0 0.0318 0.0318 - - - 025 100.0 0.0 0.1360 0.1360 - - - 

1 Emission and speciation data extracted and obtained from the “CEMEX Brooksville 0530010.xls” file. 1a PM10 emission provided by the state for stack 003 is 0.7903 g/s. The adjustment was made in Table 1 (in blue) to match the PM speciation provided 

OC + IOC + Coarse + Soil + EC +H2SO4 = PM10

PM2.5 emissions (in g/s) provided by the state for stacks 003, 004, 005, 006, 008, 009 are: 0.3556, 0.3523, 2.0696, 0.0210, 0.1400, 0.0040. The adju

to match the PM speciation provided by the state in Table 2, such that: Coarse = PM10 - PM2.5

1b The PM speciation was not provided by the state for stacks 002, 011, 024 and 025. All PM10 - H2SO4 emissions were equally divided between t

conservative approach since organic condensables have an extinction efficiency of 4 m2/g. 

2 H2SO4 emissions are entered in CALPUFF as SO4 i.e., weighted by ratio of molecular weights (96/98). 3 PM10 emission rate includes filterable and condensable emissions. The condensable component includes H2SO4 emissions. 4 M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO4) particAppendix L3 Regional Haze SIP for Florida
Source Parameters 2-5 

Table 2-2a. FPL - Putnam Power Plant: Point Source Parameters and Emissions1

Stack 

ID # 

Lambert Conformal 

Coordinates Stack 

Height 

Base 

Elevation Diameter Gas Exit Velocity 

Stack 

Gas 

Exit 

Temp. 

SO2

Emissions 

H2SO4

Emissions2

NOx

Emissions 

PM

Emis

LCC East LCC North 

 km km m m m m/s K g/s g/s g/s g

EU003 1493.905 -1024.347 22.25 7.01 3.15 29.29 437.37 - 0.0896 - 1.0EU004 1493.909 -1024.373 22.25 7.01 3.15 29.29 437.37 - 0.1134 - 1.0EU005 1494.027 -1025.041 22.25 7.01 3.15 29.29 437.37 - 0.1187 - 1.0EU006 1493.927 -1024.472 22.25 7.01 3.15 29.29 437.37 - 0.0983 - 1.0

Table 2-2b. FPL - Putnam Power Plant: Particle Speciation1, 1a

Stack 

ID # 

Particle speciation Condensable Filterable 

condensable 

PM10

filterable 

PM10

organic 

condensable (OC) 

inorganic 

condensable H2SO4 COARSE Soil 

0.625-

1.0 

μm 

0.5-

0.625 

μm 

0.625

-1.0 

μm 

0.5-

0.625 

μm 

M4=0.48

SD4=2.0

μm 

6-10 

μm 

2.5-6 

μm 

1.25-

2.5 

μm 

1.0-

1.25 

μm 

0.625-

1.0 

μm 

0.5-

0.625 

μm 

% % g/s g/s g/s g/s g/s g/s g/s g/s g/s g/s g/s 

EU003 100.0 0.0 0.46173 0.46173 - - 0.0896 - - - - - - EU004 100.0 0.0 0.44982 0.44982 - - 0.1134 - - - - - - EU005 100.0 0.0 0.44717 0.44717 - - 0.1187 - - - - - - EU006 100.0 0.0 0.45738 0.45738 - - 0.0983 - - - - - - 

1 Emission and speciation data extracted and obtained from the “FPL Putnam.xls” file. 1a The PM speciation was partially provided by the state – 71% of PM10 that is condensable is assigned to two OC size categories. For the purpose o

emissions were equally divided between the two size categories of OC. This is a conservative approach since, Organic condensable have extinction 

2 H2SO4 emissions are entered in CALPUFF as SO4 i.e., weighted by ratio of molecular weights (96/98). 3 PM10 emission rate includes filterable and condensable emissions. The condensable component includes H2SO4 emissions. 4 M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO4) particAppendix L3 Regional Haze SIP for Florida
Source Parameters 2-6 

Table 2-3a. Hopkins Tallahassee: Source Parameters and Emissions1

Stack 

ID # 

Lambert Conformal 

Coordinates Stack 

Height 

Base 

Elevation Diameter Gas Exit Velocity 

Stack 

Gas 

Exit 

Temp. 

SO2

Emissions 

H2SO4

Emissions2

NOx

Emissions 

PM

Emis

LCC East LCC North 

 km km m m m m/s K g/s g/s g/s g

EU-001 1210.330 -975.170 60.96 41.45 3.35 11.97 423.15 - 1.2978 - 4.7EU-004 1210.310 -975.142 76.20 41.45 4.27 22.98 415.15 - 4.7754 - 22.0

Table 2-3b. Hopkins Tallahassee: Particle Speciation1, 1a

Stack 

ID # 

Particle speciation Condensable Filterable 

condensable 

PM10

filterable 

PM10

organic 

condensable (OC) 

inorganic 

condensable H2SO4 COARSE Soil 

0.625-

1.0 

μm 

0.5-

0.625 

μm 

0.625

-1.0 

μm 

0.5-

0.625 

μm 

M4=0.48

SD4=2.0

μm 

6-10 

μm 

2.5-6 

μm 

1.25-

2.5 

μm 

1.0-

1.25 

μm 

0.625-

1.0 

μm 

0.5-

0.625 

μm 

% % g/s g/s g/s g/s g/s g/s g/s g/s g/s g/s g/s 

EU-001 100.0 0.0 1.7086 1.7086 - - 1.2978 - - - - - - EU-004 100.0 0.0 8.6279 8.6279 - - 4.7754 - - - - - - 

1 Emission and speciation data extracted and obtained from the “Hopkins Tallahassee.xls” file. 1a The PM speciation was not provided by the state for stacks EU-001 and EU-004. All PM10 - H2SO4 emissions were equally divided between the tw

is a conservative approach since, Organic condensable have extinction efficiency of 4 m2/g. 

2 H2SO4 emissions are entered in CALPUFF as SO4 i.e., weighted by ratio of molecular weights (96/98). 3 PM10 emission rate includes filterable and condensable emissions. The condensable component includes H2SO4 emissions. 4 M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO4) particAppendix L3 Regional Haze SIP for Florida
Geophysical and Meteorological Data 3-1 

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 

GTOPO30, a global digital elevation model (DEM) with a horizontal grid spacing of 30 arc 

seconds (approximately 1 kilometer). GTOPO30 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 21,600 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. GTOPO30 has been divided into 33 smaller pieces, or tiles. Two of these tiles cover 

regional VISTAS domain: W100N40 and W100N90. 

Gridded terrain elevations for the 4-km modeling VISTAS Domain 2 are derived from 

3 arc-second DEMs produced by the USGS. Data are provided in files covering 1-degree by 

1-degree blocks of latitude and longitude. The 1-degree DEMs are produced by the Defense 

Mapping Agency using cartographic and photographic sources. USGS 1:250,000 scale 

topographic maps are the primary source of 1-degree DEMs. One-degree DEM data consists of 

an array of 1201 by 1201 elevations referenced on the geographic (latitude/ longitude) coordinate 

system of the World Geodetic System 1972 Datum. Elevations are in meters relative to mean sea 

level, and the spacing of the elevations along each profile is 3 arc-seconds, which corresponds to 

a spacing of approximately 90 meters. 

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

visibility analysis for the Putnam facility. The CALPUFF computational subdomain was chosen 

to cover all Class I areas that fall into the 300 km circle around the FL sources, as well as a 50 km 

buffer zone from these Class I areas and Florida 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 1068 km by 8648 km or 89x72 grid cells. This subdomain was used for modeling 

Putnam facility. A Lambert Conformal Projection is used with an origin of 40.0N, 97.0W and 

standard parallels at 33N and 45N. The datum used is NWS-84. 

The subregional VISTAS 4-km CALMET Domain 2 was used in CALPUFF modeling and 

BART visibility analysis for CEMEX and Hopkins facilities. VISTAS Domain 2 was designed 

for modeling the Florida sources. It covers entire states of Florida, all Class I areas that are within 

300 km from any of the sources in FL, as well as a 50 km buffer zone from these Class I areas 

and FL facilities. Domain 2 covers an area of 1052 km by 824 km. The CALMET simulations use 

Appendix L3 

Regional Haze SIP for Florida

Page 184 of 266
Geophysical and Meteorological Data 3-2 

200 400 600 800 1000 1200 1400 1600 1800 2000

LCC East (km)

-1600

-1400

-1200

-1000

-800

-600

-400

-200

0

200

400

LCC North (km)

LCC Origin: 40.0 N, 97.0 W

Standard Parallels: 33.0 N, 45.0 N

Datum: NWS-84

Elevation

(meters)

AL GA

FL

Everglades

Chassahowitzka

Okefenokee

St Marks

Wolf Island

-25

0.1

50

100

150

200

300

400

500

600

700

800

900

1000

1100

1200

1300

1400

FL facility

CALPUFF 

computational domain

Breton

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

subdomain, the Class I areas and the locations of Florida facilities are also shown. 

Appendix L3 

Regional Haze SIP for Florida

Page 185 of 266
Geophysical and Meteorological Data 3-3 

a resolution of 4 km in the horizontal resulting in 263x206 grid cells. Figure 3-2 shows terrain 

contours for Domain 2 averaged to 4 km grid cells, three Florida sources modeled, and Class I 

areas within the Domain 2. The CALPUFF computational domain is the same as the CALMET 

Domain 2. 

Class I areas in the Domain 2 as well as in the computational subdomain for the 12 km runs are: 

Everglades, Chassahowitzka, St. Marks, Okefenokee, Wolf Island and Breton. 

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 use/land 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 1-km 

nominal spatial resolution. 

Land use data were processed to produce a 12 km and a 4 km resolution gridded field of 

fractional land use categories for the regional domain and the subregional Domain 2, respectively. 

The 37 USGS land use categories were then mapped into 14 CALMET land use categories. 

Surface properties such as albedo, Bowen ratio, roughness 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 4-km CALMET grid cell in modeling Domain 2. 

Appendix L3 

Regional Haze SIP for Florida

Page 186 of 266
Geophysical and Meteorological Data 3-4 

800 900 1000 1100 1200 1300 1400 1500 1600 1700

LCC East (km)

-1500

-1400

-1300

-1200

-1100

-1000

-900

-800

LCC North (km)

1

2

3

LCC Origin: 40.0 N, 97.0 W

Standard Parallels: 33.0 N, 45.0 N

Datum: NWS-84

Elevation

(meters)

FL

MS AL GA

-25

0.1

50

100

150

200

300

400

500

600

700

800

900

1000

1100

1200

1300

1400

Everglades

Chassahowitzka

St Marks

Okefenokee

Wolf Island

Breton

Figure 3-2. Terrain elevations for the CALMET/CALPUFF Domain 2. The Class I areas and the sites 

of Florida facilities are also shown. 

Appendix L3 

Regional Haze SIP for Florida

Page 187 of 266
Geophysical and Meteorological Data 3-5 

800 900 1000 1100 1200 1300 1400 1500 1600 1700

LCC East (km)

-1500

-1400

-1300

-1200

-1100

-1000

-900

-800

LCC North (km)

1

2

3

LCC Origin: 40.0 N, 97.0 W

Standard Parallels: 33.0 N, 45.0 N

Datum: NWS-84

FL

MS AL GA

Everglades

Chassahowitzka

St Marks

Okefenokee

Wolf Island

Breton

10

15

20

25

30

35

40

45

50

55

60

65

70

75

80

85

90

95

100

Urban/

built-up land

Agricultural

land

Rangeland

Forest land

Water

Wetland

Barren land

Tundra

Snow / Ice

Figure 3-3. Land Use for the CALMET/ CALPUFF Domain 2. The Class I areas and the sites for the 

Florida facilities are also shown. . 

Appendix L3 

Regional Haze SIP for Florida

Page 188 of 266
Geophysical and Meteorological Data 3-6 

3.3 Meteorological Data Base 

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

Generation Penn State/NCAR 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 and VISTAS subregional 4-km CALMET Domain 2. The MM5 data 

was run at a horizontal spatial resolution of 12 km for 2001 and 2002 and 36-km for 2003. 

For the regional 12-km domain, CALMET runs have been made in the no-observational mode. 

For the subregional 4-km Domain 2, available surface, upper air and precipitation stations were 

also included in the CALMET simulations along with the gridded MM5 data. Figure 3-4 shows a 

plot of the MM5 grid along with the surface, precipitation, buoys and upper air stations used in 

the CALMET simulations for Domain 2. 

3.4 Air Quality Monitoring Data 

CALPUFF uses hourly ozone concentration measurements in the chemical transformation rates 

(SO2 to SO4, NOx to HNO3/NO3). The ambient ozone measurements are used in determining SO2

loss rates due to chemical transformation to sulfate and in determining NOx 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 (OZONE.DAT). Figure 3-5 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. 

Appendix L3 

Regional Haze SIP for Florida

Page 189 of 266
Geophysical and Meteorological Data 3-7 

700 800 900 1000 1100 1200 1300 1400 1500 1600 1700 1800

LCC East (km)

-1600

-1500

-1400

-1300

-1200

-1100

-1000

-900

-800

-700

LCC North (km)

722010

722011

722012

722014

722015

722016

722017

722018

722020

722021

722022

722024

722025

722026

722029

722030 722034

722037

722038

722039

722040

722045

722046

722049

722050

722053

722055

722056

722057

722060

722065

722066

722067

722068

722069

722070

722090

722100

722103

722104

722106 722108

722110

722115

722116

722119

722120

722123

722130

722134

722135

722136

722137

722140

722146

722160

722166

722200

722210

722212

722213

722215

722220 722223 722224

722225

722226

722230722235

722240

722245

722246

722250

722255

722260

722265

722267

722275 722269 722268 722276

722284

722309

722315

722316

722320

722330

722340

722345

722347

722348

722366

747685 747686

747688

747750

747760

747770

747804

747810

747880

747930

747946

747950

994010

994050

994170

994220

994290

994310

994360

994380

994390

994410

994420

994430

994440

994450

994560

994570

994620

994630

994640

994650

41008

42003

42007

42036 42039

42040

41008

41009

41012

42001

72201

72202

72206

72210

72214

72230

72233

74794

LCC Origin: 40.0 N, 97.0 W

Standard Parallels: 33.0 N, 45.0 N

Datum: NWS-84

Elevation

(meters)

FL

GA AL MS

SC

-25

0.1

50

100

150

200

300

400

500

600

700

800

900

1000

1100

1200

1300

1400

Everglades

Chassahowitzka

St Marks

Okefenokee

Wolf Island

Breton

MM5 grid point

Upper Air data

Surface Met data

Precipitation data

Buoy data

Figure 3-4. Plot of MM5 grid and surface, precipitation, buoy, and upper air stations for the 

CALMET/CALPUFF Subregional Domain 2. 2. 

Appendix L3 

Regional Haze SIP for Florida

Page 190 of 266
Geophysical and Meteorological Data 3-8 

700 800 900 1000 1100 1200 1300 1400 1500 1600 1700 1800

LCC East (km)

-1600

-1500

-1400

-1300

-1200

-1100

-1000

-900

-800

LCC North (km)

1

2

3

LCC Origin: 40.0 N, 97.0 W

Standard Parallels: 33.0 N, 45.0 N

Datum: NWS-84

Elevation

(meters)

FL

MS AL GA

-25

0.1

50

100

150

200

300

400

500

600

700

800

900

1000

1100

1200

1300

1400

Everglades

Chassahowitzka

St Marks

Okefenokee

Wolf Island

Breton

Ozone data

FL facility

Figure 3-5. Plot of ozone stations used for the CALPUFF simulations. The Class I areas and the sites 

of the Florida facilities are also shown. 

Appendix L3 

Regional Haze SIP for Florida

Page 191 of 266
Results 4-1 

4. RESULTS 

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

Florida 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 or 4-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 SO2, SO4, and 

NOX were input directly to the CALPUFF model while the six particulate species defining 

specific size categories were modeled as a unit emission rate (1 g/s) 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 4-4 provides the monthly f(RH) values based on the centroid of the Class I area as required 

for the application of Method 6. The last column in Tables 4-1 through 4-3 provides the annual 

average background bext values for each Class I Area included in the analysis. For each Class I 

area, the Rayleigh scattering coefficient of 10 Mm-1 was subtracted from the annual average 

background bext and resulting values were entered in CALPOST as BKSOIL. 

Tables 4-1 through 4-3 summarize the maximum predicted extinction changes for 2001, 2002, 

and 2003 for the Class I areas situated within a 300 km radius of each of the three facilities. The 

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

value are presented in the 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 I 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. 

Tables 4-1a and 4-1b show results for CEMEX Brooksville. This facility was modeled on the 

VISTAS 4-km CALMET Domain 2 refined grid. Table 4-1a shows that in the Okefenokee and 

St Marks Class I areas, maximum predicted extinction change is below the 0.5 dv threshold value 

for all three years. Maximum predicted extinction change exceeds 0.5 dv in Chassahowitzka. The 

8th highest predicted extinction changes for Chassahowitzka for 2001-2003 are shown in Table 

4-1b. 

Table 4-2 shows that for FPL Putnam Power Plant, modeled with 12-km CALMET domain, the 

maximum predicted extinction change for each of the Class I areas are all below the 0.5 dv 

threshold value. 

Appendix L3 

Regional Haze SIP for Florida

Page 192 of 266
Results 4-2 

Hopkins Tallahassee was modeled on the VISTAS 4-km CALMET Domain 2 refined gird. 

Visibility analyses showed that predicted maximum extinction changes in the Chassahowitzka 

and Okefenokee Class I areas were below 0.5 dv for all three years (Table 4-3a). In St. Marks, 

maximum extinction change was predicted to exceed 0.5 dv. Table 4-3b shows eight highest 

predicted values of extinction change for all three years for St. Marks. 

Appendix L3 

Regional Haze SIP for Florida

Page 193 of 266
Results 4-3 

Table 4-1a. Summary of Visibility Results for CEMEX Brooksville – Refined Run (4-km grid)

Class I Area 2001 2002 2003 

Annual 

average 

background 

bext

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

Chassahowitzka 1.084 (49 1) 0.967 (52 0) 1.348 (46 3) 21.46 

Okefenokee 0.039 (0 0) 0.050 (0 0) 0.044 (1 0) 21.41 

St Marks 0.130 (0 0) 0.084 (0 0) 0.065 (0 0) 21.54 

Table 4-1b. Visibility Results – 8 Highest Values for CEMEX Brooksville – Refined Run (4-km 

grid) 

2001 2002 2003 

Change in 

Deciview 

(dv)

Day 

Change in 

Deciview 

(dv)

Day 

Change in 

Deciview 

(dv)

Day Rank 

Chassahowitzka

1.084 

0.992 

0.947 

0.936 

0.933 

0.901 

0.898 

0.889 

Sep 7 

Sep 22 

May 11 

Oct 12 

Sep 19 

Sep 3 

Apr 19 

Jun 19 

0.967 

0.951 

0.932 

0.901 

0.833 

0.813 

0.795 

0.793 

Jul 9 

Oct 8 

Aug 16 

Apr 15 

Aug 20 

Apr 16 

Aug 14 

Jun 1 

1.348 

1.338 

1.010 

0.905 

0.866 

0.833 

0.825 

0.799 

Aug 20 

Aug 16 

Aug 26 

Jul 28 

Nov 22 

Feb 14 

Apr 2 

Jul 25 

1 

2 

3 

4 

5 

6 

7 

8 

Table 4-2. Summary of Visibility Results for FPL - Putnam Power Plant– Screening Run 

(12-km grid) 

Class I Area 2001 2002 2003 

Annual 

average 

background 

bext

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

Chassahowitzka 0.075 (0 0) 0.083 (0 0) 0.045 (0 0) 21.46 

Okefenokee 0.099 (0 0) 0.058 (0 0) 0.054 (0 0) 21.41 

St Marks 0.033 (0 0) 0.027 (0 0) 0.030 (0 0) 21.54 

Wolf Island 0.026 (0 0) 0.031 (0 0) 0.024 (0 0) 21.33 

Appendix L3 

Regional Haze SIP for Florida

Page 194 of 266
Results 4-4 

Table 4-3a. Summary of Visibility Results for Hopkins Tallahassee – Refined Run (4-km grid)

Class I Area 2001 2002 2003 

Annual 

average 

background 

bext

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

Chassahowitzka 0.232 (0 0) 0.279 (0 0) 0.207 (0 0) 21.46 

Okefenokee 0.212 (0 0) 0.251 (0 0) 0.269 (0 0) 21.41 

St Marks 1.581 (40 5) 1.279 (44 7) 1.223 (38 3) 21.54 

Table 4-3b. Visibility Results – 8 Highest Values for Hopkins Tallahassee – Refined Run (4-km 

grid) 

2001 2002 2003 

Change in 

Deciview 

(dv)

Day 

Change in 

Deciview 

(dv)

Day 

Change in 

Deciview 

(dv)

Day Rank 

St Marks 

1.581 

1.534 

1.361 

1.117 

1.06 

0.965 

0.942 

0.941 

Nov 7 

Nov 20 

Nov 8 

Sep 21 

Sep 18 

Aug 15 

Oct 2 

Sep 5 

1.279 

1.274 

1.254 

1.11 

1.039 

1.014 

1.007 

0.953 

Jan 1 

Mar 4 

Dec 15 

Oct 16 

Oct 31 

Feb 27 

Feb 10 

Feb 4 

1.223 

1.162 

1.045 

0.981 

0.905 

0.894 

0.851 

0.818 

Jan 26 

Jan 4 

Jan 17 

Jan 15 

Feb 12 

Dec 17 

Mar 10 

Dec 19 

1 

2 

3 

4 

5 

6 

7 

8 

Appendix L3 

Regional Haze SIP for Florida

Page 195 of 266
Results 4-5 

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

Applications 

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

Chassahowitzka 3.8 3.5 3.4 3.2 3.3 3.9 3.9 4.2 4.1 3.9 3.7 3.9 

Okefenokee 3.5 3.2 3.1 3.0 3.6 3.7 3.7 4.1 4.0 3.8 3.5 3.6 

St. Marks 3.7 3.4 3.4 3.4 3.5 4.0 4.1 4.4 4.2 3.8 3.7 3.8 

Wolf Island 3.4 3.1 3.1 3.0 3.3 3.7 3.7 4.1 4.0 3.7 3.5 3.5 

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

Appendix L3 

Regional Haze SIP for Florida

Page 196 of 266
References 5-1 

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-454/R-98-019. 

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 (MM5)”, 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 

http://www.src.com. 

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

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

from http://www.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 

http://www.vistas-sesarm.org. 

Appendix L3 

Regional Haze SIP for Florida

Page 197 of 266
APPENDIX L4 

Florida BART Exemption Contribution Threshold 

and 

VOC/NH3 Exclusion Analysis 

Appendix L4 

Regional Haze SIP for Florida

Page 198 of 266
BART Exemption Contribution Threshold 

Determining whether a source causes or contributes to visibility impairment is one step in the 

BART review process. The Guidelines for BART Determinations Under the Regional Haze Rule1

state that “A single source that is responsible for a 1.0 deciview change or more should be 

considered to „cause‟ visibility impairment.” The guideline document also states that “the 

appropriate threshold for determining whether a source „contributes to visibility impairment‟ 

may reasonably differ across states,” but, “As a general matter, any threshold that you use for 

determining whether a source „contributes‟ to visibility impairment should not be higher than 0.5 

deciviews.” The rationale for these instructions is provided in the preamble to the BART 

guidance, in the statement, “If „causing‟ visibility impairment means causing a humanly 

perceptible change in visibility in virtually all situations (i.e. a 1.0 deciview change), then 

„contributing‟ to visibility impairment must mean having some lesser impact on the conditions 

affecting visibility that need not rise to the level of human perception.”2

The guidance document 

itself also states that, “States remain free to use a threshold lower than 0.5 deciviews if they 

conclude that the location of a large number of BART-eligible sources within the State and in 

proximity to a Class I area justify this approach.” 

The EPA‟s documents strive to set these thresholds in the context of the human perception of 

visibility change. As noted above, the EPA considers a 1.0-deciview change in visibility to be 

humanly perceptible “in virtually all situations.” Also, the preamble to the BART guidance3

cites 

an analysis in an appendix of a NAPAP (National Acid Precipitation Assessment Program) 

report, which asserts that “changes in light extinction of 5 percent will evoke just noticeable 

changes in most landscapes.” 4(A 5% change is approximately 0.5 dv.) But, as noted above, the 

preamble also states that perceptibility is not a prerequisite for choosing a contribution threshold. 

Putting all this together, it appears that “causing” visibility impairment means having a humanly 

perceptible impact (for which EPA considers the practical threshold to be 1.0 dv) while 

“contributing” to visibility impairment means having a smaller impact (for which EPA considers 

the threshold to be 0.5 dv or some smaller value) that may or may not be perceptible.The EPA 

argues that a contribution threshold of less than 0.5 dv impact per source is appropriate when 

multiple sources contribute, in order to limit the combined effect of these sources. As an 

example, EPA asserts that if there were 100 sources, each affecting visibility by 0.1 dv 

(presumably an imperceptible amount), their total impact would be 10 dv (which can be expected 

to be quite perceptible).5

The point remains that multiple sources can cause a larger impact than a 

single one. For BART purposes, visibility impacts are calculated as 24-hr averages of 1-hr plume 

impacts, so if the plumes from the various sources each impact the point of interest at some time 

during a 24-hr period (not necessarily all at the same hour) then the 24-hr average will reflect 

their combined impact. 

 

1

40 CFR 51, Appendix Y, Section III.A.1 

2

70 FR 39120. Footnote 31 

3

70 FR 39119. Footnote 28 

4

“The Quadratic Detection Model” by W. Malm. Appendix D in Acidic Deposition: State of Science and 

Technology, Report 24, Visibility: Existing and Historical Conditions -- Causes and Effects. National 

Acid Precipitation Assessment Program, Washington, DC. 1990. 

5

70 FR 39121. 1st column 

Appendix L4 

Regional Haze SIP for Florida

Page 199 of 266
Florida DEP has concluded that the EPA suggested contribution threshold of 0.5 dv is

appropriate in Florida. While Florida has 47 BART-eligible sources, they are scattered about the 

state and, in our judgment, are not clustered in sufficient quantity to warrant a change to the EPA 

suggested value of 0.5 dv. 

Map of BART-eligible Sources 

Appendix L4 

Regional Haze SIP for Florida

Page 200 of 266
Exemption of Point Source Volatile Organic Compounds for BART 

Purposes 

The State of Florida has determined through modeling that Volatile Organic Compounds (VOC) 

from point sources are not anticipated to cause or contribute significantly to any impairment of 

visibility in Class I areas and should be exempt for BART purposes. 

Method 

The State of Florida determined through modeling that VOCs from point sources are not 

anticipated to cause or contribute significantly to any impairment of visibility in Class I areas. 

Modeling was conducted through The Visibility Improvement State and Tribal Association of 

the Southeast (VISTAS). VISTAS is a collaborative effort of state governments, tribal 

governments, and various federal agencies established to initiate and coordinate activities 

associated with the management of regional haze, visibility and other air quality issues in the 

Southeastern United States. VISTAS contracted with Georgia Institute of Technology to 

perform model sensitivity runs to determine the impact of point source VOCs on visibility in 

Class I areas. 

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on 

regional haze, annual PM2.5, and 8-hour ozone concentrations using CMAQv4.4_SOAmods on 

the VISTAS 12 km modeling domain, using the 2009 OTW (on the way) BaseD emissions. One 

such sensitivity run reduced anthropogenic, point source VOCs by 100%. The purpose was to 

quantify the impact of VOC emissions from VISTAS BART sources on Class I areas. Two 

periods were examined representing a summer and winter (annual) timeframe : June 1-July 10, 

2002 and November 19 – December 19, 2002. The approach included calculating the extinction 

coefficient in dv (deciviews), then determining the maximum impact of point source VOCs. The 

chart below shows the impact on the following twenty-two Class I areas within the VISTAS 

domain. 2 

BRET = Breton, LA 

BRIG = Brigantine NWR, NJ 

CACR = Caney Creek, AR 

CHAS = Chassahowitzka, FL 

COHU = Cohutta, GA 

DOSO = Dolly Sods, WV 

EVER = Everglades, FL 

GRSM = Great Smoky Mountains National Park 

HEGL = Hercules Glade, MO 

JARI = James River Face, VA 

LIGO = Linville Gorge, NC 

MACA = Mammoth Cave, KY 

MING = Mingo, MO 

OKEF = Okefenokee, GA 

Appendix L4 

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Page 201 of 266
ROMA = Cape Romain, SC 

SAMA = Saint Marks, FL 

SHEN = Shenandoah, VA 

SHRO = Shining Rock, NC 

SIPS = Sipsey Wilderness, AL 

SWAN = Swanquarter, NC 

UPBU = Upper Buffalo Wilderness, AR 

WOLF = Wolf Island, GA 

Appendix L4 

Regional Haze SIP for Florida

Page 202 of 266
 Maximum Point VOC Impact 

Conclusions 

The results show that the maximum impact from eliminating all point source VOC emissions in 

the VISTAS 12 km domain is less than a 0.5 dv for all Class I areas in the VISTAS domain. 

Given that the fraction of the total point source VOC emissions that are also BART-eligible in 

the state of Florida is small, the expected impact of controlling VOCs from a BART source 

would be much less than the 0.5 dv threshold. VISTAS and the State of Florida conclude that 

VOCs from point sources are not a visibility impairing pollutant for BART purposes and that 

BART-eligible sources do not need to consider VOC emissions. 

Treatment of Ammonia Emissions for BART Purposes 

Similar to its treatment of VOCs, EPA guidance allows States the discretion to decide whether or 

not ammonia emissions are to be considered for BART purposes based on evaluations of the 

contributions of the emissions to haze at Class I areas in their areas of influence. One approach a 

State can use to determine whether applying BART will be needed is to evaluate the haze 

impacts of all current emissions from all BART-eligible sources in the State. If the impact from 

all sources in the state is less than the contribution threshold established by the State, 0.5 dv for 

Florida, then source by source analysis for BART is not needed. 

The State of Florida has determined through modeling that ammonia (NH3) emissions from 

point sources are not anticipated to cause or contribute significantly to any impairment of 

visibility in Class I areas and should be exempt for BART purposes. 

Maximum Point VOC Impact

Maximum VOC Impact

0.0

0.1

0.2

0.3

0.4

0.5

0.6

BRET

BRIG

CACRCHAS

COHU

DOSO

EVER

GRSM

HEGL

JARI

LIGO

MACA

MING

OKEF

ROMA

SAMA

SHEN

SHRO

SIPS

SWAN

UPBU

WOLF

dV

Appendix L4 

Regional Haze SIP for Florida

Page 203 of 266
Method 

The State of Florida determined through modeling that ammonia emissions from point sources 

are not anticipated to cause or contribute significantly to any impairment of visibility in Class I 

areas in or near Florida. 

VISTAS contracted with Georgia Institute of Technology to perform model sensitivity runs to 

determine the impact of point source ammonia on visibility in Class I areas. 

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on 

regional haze using CMAQv4.5 with SOA mods on the VISTAS 12 km modeling domain, using 

the VISTAS 2009 OTW (on the way) Base F4 emissions. One such sensitivity run reduced, 

BART-eligible source ammonia by 100%. The purpose was to quantify the impact of ammonia 

emissions from VISTAS BART sources on Class I areas. Two periods were examined: June 1-

July 10, 2002 and November 19 – December 19, 2002. The approach included calculating the 

extinction coefficient in dv (deciviews), then determining the maximum impact of BARTeligible source ammonia. The chart below, taken from the VISTAS analysis, shows the impact 

on the following twenty-two Class I areas within the VISTAS domain. 2 

Maximum NH3 Impact - Maximum contributions of all BART-eligible NH3 point sources in 

the VISTAS region to haze in Class I areas during the CMAQ-modeled periods. 

The chart shows the largest haze impact in delta dv over the two timeframes at each Class I area. 

These delta dv changes represent the haze contribution of all BART source ammonia emissions 

relative to assumed natural haze levels. The natural haze levels are based on EPA-default annual 

average natural concentrations for the East and monthly-varying “climatologically 

representative” relative humidity at each Class I area. 

Maximum NH3Impact

0.0

0.5

1.0

1.5 BRET BRIG CACR CHAS COHU DOSO EVER GRSM HEGL JARI LIGO MACA MING OKEF ROMA SAMA SHEN SHRO SIPS SWAN UPBU WOLF

dV

Appendix L4 

Regional Haze SIP for Florida

Page 204 of 266
During the periods modeled the ammonia emissions from all BART-eligible sources contributed 

more than 0.5 dv to haze at Mammoth Cave National Park (MACA), Kentucky; Mingo 

Wilderness (MING), Missouri, Cape Romain National Wildlife Refuge Area (ROMA) South 

Carolina, and Swanquarter National Wildlife Refuge (SWAN), North Carolina. All of these 

Class 1 areas are located more than 300 km from Florida BART-eligible sources. 

Conclusions 

The BART requirements of the regional haze rule allow states to determine whether or not 

ammonia is to be considered a visibility impairing pollutant to be addressed for BART purposes. 

NH3 emissions from BART sources may impair visibility; however the majority of NH3 

emissions in the VISTAS region are from a few BART sources. Removal of the large NH3 

emission sources results in minimal impact on visibility at Class I areas in the VISTAS region. 

At their discretion states may ask those few large sources to evaluate NH3 impacts and potential 

controls for NH3. 

Appendix L4 

Regional Haze SIP for Florida

Page 205 of 266
Appendix L5 

Regional Haze SIP

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L5 

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Appendix L6 

Summary of BART Modeling Exemptions

Appendix L6 

Regional Haze SIP for Florida

Page 228 of 266
FACILITY 

ID OWNER COMPANY NAME SITE NAME

Meets 

Modeling 

Exemption

Meets 

Model Rule 

Exemption

Max Visibility 

Impact 

(deciviews)

0990016 ATLANTIC SUGAR ASSOCIATION ATLANTIC SUGAR MILL x 0.490

1230001 BUCKEYE FLORIDA, LIMITED PARTNERSHIP BUCKEYE FLORIDA, LIMITED PARTNERSHIP x 0.388

0570005 CF INDUSTRIES, INC., PLANT CITY PHOS CF INDUSTRIES, INC., PLANT CITY PHOSP xx 0.498

0010006 CITY OF GAINESVILLE, GRU DEERHAVEN GENERATING STATION x 0.018

0730003 CITY OF TALLAHASSEE ARVAH B.HOPKINS GENERATING STATION x 0.444

0610029 CITY OF VERO BEACH CITY OF VERO BEACH MUNICIPAL UTILITIES x 0.052

1130005 EXXONMOBIL PRODUCTION COMPANY ST REGIS TREATING FAC AND JAY GAS PLANT x 0.390

0090006 FLORIDA POWER & LIGHT (PCC) CAPE CANAVERAL POWER PLANT x 0.206

0850001 FLORIDA POWER & LIGHT (PMR) FPL / MARTIN POWER PLANT x 0.449

0810010 FLORIDA POWER & LIGHT (PMT) MANATEE POWER PLANT x 0.458

0110036 FLORIDA POWER & LIGHT (PPE) PORT EVERGLADES POWER PLANT x 0.462

1070014 FLORIDA POWER & LIGHT (PPN) PUTNAM POWER PLANT x 0.099

0990042 FLORIDA POWER & LIGHT (PRV) RIVIERA POWER PLANT x 0.194

1010017 FLORIDA POWER CORP. ANCLOTE POWER PLANT x 0.488

1030011 FLORIDA POWER CORPORATION FPC-BARTOW PLANT x 0.182

1110003 FT PIERCE UTILITIES AUTHORITY FT PIERCE UTIL/H D KING PWR PLNT x

1070005 GEORGIA-PACIFIC CORP. PULP/PAPER MILL GEORGIA-PACIFIC CORP. PULP/PAPER MILL xx 0.480

0050014 GULF POWER COMPANY LANSING SMITH PLANT x 0.060

0330045 GULF POWER COMPANY CRIST ELECTRIC GENERATING PLANT x 0.210

0310071 IFF CHEMICAL HOLDINGS, INC. IFF CHEMICAL HOLDINGS, INC. x 0.269

1050055 IMC PHOSPHATES COMPANY SOUTH PIERCE x 0.494

0330042 INTERNATIONAL PAPER COMPANY PENSACOLA MILL x 0.057

0310045 JEA NORTHSIDE/SJRPP x 0.402

0990045 LAKE WORTH UTIL. TOM G. SMITH PLANT x

1050003 LAKELAND ELECTRIC CHARLES LARSEN MEMORIAL POWER PLANT x 0.074

1050004 LAKELAND ELECTRIC C.D. MCINTOSH, JR. POWER PLANT x 0.215

0570008 MOSAIC RIVERVIEW xx 0.494

1050046 MOSAIC - BARTOW BARTOW x 0.144

1050053 MOSAIC - GREEN BAY GREEN BAY PLANT x 0.219

1050059 MOSAIC - NEW WALES NEW WALES xx 0.496

0990019 OSCEOLA FARMS OSCEOLA FARMS x 0.302

0090196 RELIANT ENERGY INDIAN RIVER, L.L.C. INDIAN RIVER PLANT - RELIANT x 0.178

0890003 SMURFIT STONE CORPORATION (US) JSC-FERNANDINA BEACH PAPERBOARD MILL xx 0.495

0330040 SOLUTIA INC. SOLUTIA INC. x

1130003 STERLING FIBERS, INC. STERLING FIBERS, INC. x

0050009 STONE CONTAINER CORPORATION PANAMA CITY MILL xx 0.498

0990026 SUGAR CANE GROWERS CO-OP SUGAR CANE GROWERS CO-OP x 0.467

0570039 TAMPA ELECTRIC COMPANY BIG BEND STATION x 0.466

0510003 U.S. SUGAR CORP. CLEWISTON MILL U.S. SUGAR CLEWISTON MILL AND REFINERY x 0.265

35 4

Appendix L6 

Regional Haze SIP for Florida

Page 229 of 266
BART Modeling Review 

Atlantic Sugar –units 1, 2, 3, and 4 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

based on maximum stack test data for NOx and PM (bagasse), and for SO2 

(bagasse) from industry test data; AP-42 was used for NOx and SO2 emissions 

when firing fuel oil; maximum allowable permitted PM for fuel oil; condensable 

emissions from AP-42 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.490 dv 

(Everglades NP) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 230 of 266
BART Modeling Review 

Buckeye –units 7, 11, 22, and 23 (No.’s 3 and 4 recovery boilers, and No.’s 3 and 4 smelt 

dissolving tanks) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

SO2 and NOx emissions based on maximum permitted process rate and NCASI 

emission factors developed for the industry; PM emissions based on maximum 

stack test data 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.284 dv (St. 

Marks NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 231 of 266
BART Modeling Review 

CF Industries –units 2,3,7,8,10,11,12,13,15, and 18 (A, B, C, and D sulfuric acid plants, 

A, Z, X, and Y DAP/MAP plants, and, A and B shipping baghouses. 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP 

Comments were appropriately responded to by the applicant 

Protocol includes the evaluation of three scenarios for emission reductions 

sufficient to meet the exemption criteria. Only scenarios A and B have been 

evaluated because scenario C was not deemed consistent with current permit 

conditions and was dismissed by the department. A federally enforceable permit 

requiring the implementation of either A or B scenarios is being issued. 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

Two emission reduction scenarios evaluated – CFI has the option of choosing 

either . 

Scenario A – SO2 emissions are reduced from the “A” SAP 250 lb/hr to 75.8 lb/hr 

(24-hr average), from the “B” SAP 233.3 lb/hr to 93.3 lb/hr, from the “C” SAP 

401.1 lb/hr to 303.3 lb/hr, and from “D” SAP 401.3 lb/hr to 303.3 lb/hr. 

Additional minor reductions in NOx and sulfuric acid mist are obtained from 

reductions in production. 

Scenario B – SO2 emissions are reduced from the “A” SAP 250 lb/hr to 81.3 

lb/hr, from the “B” SAP 233.3 lb/hr to 100 lb/hr, from the “C” SAP 401.1 lb/hr to 

241.7 lb/hr, and from “D” SAP 401.1 lb/hr to 241.7 lb/hr. Again, minor 

reductions from NOx and sulfuric acid mist will occur resulting from production 

decreases. 

All data input correctly and consistent with protocol 

Assumed all PM are fine particles and are organic compounds 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.498 dv 

(Chassahowitzka NWA) for scenario A, and 0.432 dv (Chassahowitzka NWA) for 

scenario B from modeling report 

based on new IMPROVE equation 

Appendix L6 

Regional Haze SIP for Florida

Page 232 of 266
Department recommendation: Either scenario meets BART exemption criteria, source 

exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 233 of 266
BART Modeling Review 

Gainesville Deerhaven –unit 1 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.022 dv 

(Okefenokee NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 234 of 266
BART Modeling Review 

City of Tallahassee Hopkins –units 1 and 4 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data, using maximum rated heat input 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.522 dv (St. 

Marks NWA), based on the old IMPROVE equation 

maximum 8th highest daily visibility value at any Class I area = 0.444 dv (St. 

Marks NWA), based on new IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 235 of 266
BART Modeling Review 

City of Vero Beach –units 2, 3, and 4 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum allowable permitted rates 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.052 dv 

(Everglades NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 236 of 266
BART Modeling Review 

Exxon Mobil –unit 34 (sulfur recovery plants) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

SO2 based on stack test data; PM and NOx based on annual operation reports; PM 

and NOx emissions are very small and variations of these values would not be 

expected to significantly change the results 

input correctly and consistent with protocol 

default speciation used correctly (all PM is fine and is organic carbon) 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

output for 2002 inconsistent with values listed in the report, other years are 

consistent; the model output takes precedence, and no further action is necessary 

maximum 8th highest daily visibility value at any Class I area = 0.390 dv (Breton 

NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 237 of 266
BART Modeling Review 

FPL Cape Canaveral –units 1 and 2 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data 

input correctly and consistent with the revised protocol. speciation correctly input 

and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with revised protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.206 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 238 of 266
BART Modeling Review 

FPL Martin –units 1 and 2 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data 

input correctly and consistent with the revised protocol. 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.449 dv 

(Everglades NP) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 239 of 266
BART Modeling Review 

FPL Manatee –units 1 and 2 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data 

input correctly and is consistent with the revised protocol. 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.458 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 240 of 266
BART Modeling Review 

FPL Port Everglades – units 3 and 4 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum permitted emission rates from the Title V permit and actual 

maximum heat input rates based on stack tests. 

input correctly and consistent with the protocol. 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.594 dv 

(Everglades NP), based on old IMPROVE equation 

new IMPROVE equation was used correctly, giving a maximum 8th highest daily 

visibility value of 0.462 dv 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 241 of 266
BART Modeling Review 

FPL Riviera –unit 4 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data 

input correctly and consistent with the revised protocol. 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.194 dv 

(Everglades NP) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 242 of 266
BART Modeling Review 

Progress Energy Anclote–units 1 and 2 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were considered in the final report 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test emission rates 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.576 dv 

(Chassahowitzka NWA), based on the old IMPROVE equation 

maximum 8th highest daily visibility value at any Class I area = 0.488 dv 

(Chassahowitzka NWA), based on the new IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 243 of 266
BART Modeling Review 

Progress Energy Bartow–unit 3 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were considered in the final report 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum allowable emission rates 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.182 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 244 of 266
BART Modeling Review 

Georgia Pacific –units 15, 16, 17, 18, and 19 (No. 5 power boiler, No. 4 combination 

boiler, No. 4 lime kiln, No. 4 recovery boiler, No. 4 smelt dissolving tank) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were not completely responded to by the applicant, additional 

information showing the data and calculations for the maximum 24-hour 

emissions is necessary 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

SO2, NOx, and PM emissions from units 17 and 18 based on maximum stack test 

data; more information requested 

Some errors in the input files for summing concentrations; re-runs requested 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.489 dv 

(Okefenokee NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 245 of 266
BART Modeling Review 

Gulf Power Lansing Smith –units 1 and 2 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data and maximum heat input derived from CEMS 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.06 dv (St. 

Marks NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 246 of 266
BART Modeling Review 

Gulf Power Crist –units 6 and 7 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data and maximum heat input derived from CEMS 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.21 dv (Breton 

NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 247 of 266
BART Modeling Review 

IFF Chemicals - unit 3 (boiler 2) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx and PM emissions 

PM emissions based on maximum allowable permitted; NOx emissions based on 

maximum AP-42 emission factors, SO2 emissions based on maximum potential 

hourly rate for fuel burning plus the maximum actual 24-hour average due to CST 

(crude sulfate terpentine) vapor incineration. 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.269 dv 

(Okefenokee NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 248 of 266
BART Modeling Review 

Mosaic South Pierce –units 4, 5, 22, 23, 24, 25, 26, 30-39, and 40-43 (No.’s 10 and 11 

sulfuric acid plants, No. 2 ball mill, GTSP production plant, GTSP east storage building 

north and south scrubbers, GTSP rock hopper, molten storage tanks, and molten storage 

pits) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

Stack height for molten sulfur storage pits (unit 40-43) input at 9.1 m, protocol 

indicates stack height is 3.05 m – this is judged an insignificant error because 

these sources have very small emissions. 

Otherwise, all stack parameters are consistent with the protocol 

Emissions – 

SO2, NOx, and PM 

SO2 and H2SO4 emissions from units 4 and 5 based on maximum allowable 

permitted with maximum actual 24-hour production; SO2, NOx, and H2SO4 

emissions from the GTSP production plant based on AP-42 emission factors; SO2 

emissions from the molten sulfur storage and transfer units based on maximum 

allowable permitted; PM emissions from all sources based on maximum 

allowable permitted 

input correctly and consistent with protocol 

Assumed all PM are fine particles and are organic compounds 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.642 dv 

(Chassahowitzka NWA) using the old IMPROVE equation ; = 0.494 dv using the 

new IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 249 of 266
BART Modeling Review 

International Paper Pensacola –units 29, 30, 32, and 38 (No. 1 Recovery Furnace, No. 1 

Smelt Dissolving Tank, No. 2 Recovery Furnace, No. 2 Smelt Dissolving Tank) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

SO2 and NOx emissions based on NCASI technical bulletin 884; speciated PM 

emissions based on AP-42 table 10.2-3, based on data from the maximum stack 

test value 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

used RH-varying natural visibility 

maximum 8th highest daily visibility value at any Class I area = 0.057 dv (Breton 

NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 250 of 266
BART Modeling Review 

JEA Northside unit 3 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum AP-42 emission factors (oil/gas), daily measured oil/gas heat 

input (CEM), and monthly heating values. Note: cross-checked with the actual 

maximum stack test data and found the applicant’s method provided higher 

emission rate.

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.402 dv 

(Okefenokee NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 251 of 266
BART Modeling Review 

Lakeland Larsen –unit 4 (boiler 7) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were addressed within the final report 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum allowable permit limit 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.074 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 252 of 266
BART Modeling Review 

Lakeland McIntosh –units 1 and 5 (boilers 1 and 2) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were addressed within the final report 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum allowable permit limit 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.215 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 253 of 266
BART Modeling Review 

Mosaic Riverview –units 4, 5, 6, 63, 66, 67, and 68 (No.’s 7, 8, and 9 sulfuric acid plants, 

molten sulfur storage tanks 1, 2, and 3, and molten sulfur storage and handling pits 7, 8, 

and 9) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

For sulfuric acid plants based on maximum allowable permitted for SO2 and 

H2SO4, reduced specifically to meet the BART exemption criteria. These 

decreased emissions in the sulfuric acid plants will result from increased 

vanadium catalyst. NOx emissions based on data from a PSD permit application. 

No changes to the emissions (PM) from the molten sulfur storage tanks or pits, 

and are based on data from a PSD permit application. 

All data input correctly and consistent with protocol 

Assumed all PM are fine particles and are organic compounds 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.494 dv 

(Chassahowitzka NWA) from modeling report 

based on new IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 254 of 266
BART Modeling Review 

Mosaic Bartow –unit 54 (No. 3 sulfuric acid plant) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2 

based on maximum allowable permitted for SO2 and H2SO4 

input correctly and consistent with protocol 

No PM emissions 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.144 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 255 of 266
BART Modeling Review 

Mosaic Green Bay –units 4, 7, and 29 (No. 4 sulfuric acid plant, South AP fertilizer plant, 

and North MAP/DAP fertilizer plant) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

based on maximum allowable permitted for PM, for all units; SO2 and H2SO4 for 

unit 4 based on maximum allowable permitted; NOx for unit 4 based on 

maximum allowable permitted limit for unit 3 sulfuric acid plan; for other units, 

NOx based on AP-42; NOx, SO2, and H2SO4 for units 7 and 29 based on AP-42 

Unit 7 dryer NOx emissions were input to the model based on fuel oil burning 

(8.9 lb/hr) – protocol indicated a maximum of 12.6 lb/hr based on LPG; this 

difference is not considered significant in this case and no re-run is deemed 

necessary 

Otherwise, input correctly and consistent with protocol 

Assumed all PM are fine particles and are organic compounds 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is inconsistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.241 dv 

(Chassahowitzka NWA) from modeling report; = 0.219 dv from model output 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 256 of 266
BART Modeling Review 

Mosaic New Wales –units 2,3,4,9,11,27,36,15,23-28,29-35,38,52,55,63, and 66-68 (No.’s 

1, 2, and 3 sulfuric acid plants, DAP plant No. 1, MAP plant, AFI plant, multifos A and B 

kilns, dryer and blending operation, and various low emitting particulate-only sources 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP 

Comments were appropriately responded to by the applicant 

Protocol includes the evaluation of two scenarios for emission reductions 

sufficient to meet the exemption criteria. A federally enforceable permit requiring 

the implementation of one or the other of these scenarios is being issued. 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

Two emission reduction scenarios evaluated – Mosaic New Wales has the option 

of choosing either . 

Scenario A – Sulfuric acid mist emissions from SAP’s No. 1,2, and 3 are reduced 

from 14.0 to 7.1 lbs/hr; DAP plant No. 1 and AFI plant dryers are fired using only 

natural gas; multifos plant kilns A and B are shut-down; DAP plant No. 1 PM 

emissions are reduced from 28.6 to 15 lbs/hr; and, MAP plant PM emissions are 

reduced from 15 to 7 lbs/hr. 

Scenario B – SO2 emissions from SAP’s 1, 2, and 3 each are reduced from 496 to 

400 lbs/hr; sulfuric acid mist emissions from the SAP’s reduced from 14.0 to 6.7 

lbs/hr; NOx emissions from the SAP’s reduced from 17 to 16 lbs/hr; DAP plant 

No. 1 and AFI plant dryers are fired using only natural gas; multifos A and B 

kilns dryer is fired with only natural gas and PM emissions are reduced from 29.8 

to 25 lbs/hr; SO2 emissions from the multifos A and B kilns dryer reduced from 

316 to 25 lbs/hr; PM emissions from DAP plant No. 1 reduced from 28.6 to 16 

lbs/hr; and, MAP plant PM emissions are reduced from 15 to 7 lbs/hr. 

All PM emissions from sources not requiring a reduction via scenario A or B use 

maximum actual values. 

All data input correctly and consistent with protocol 

Assumed all PM are fine particles and are organic compounds 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

Appendix L6 

Regional Haze SIP for Florida

Page 257 of 266
maximum 8th highest daily visibility value at any Class I area = 0.490 dv 

(Chassahowitzka NWA) for scenario A, and 0.496 dv (Chassahowitzka NWA) for 

scenario B from modeling report 

based on new IMPROVE equation 

Department recommendation: Either scenario meets BART exemption criteria, source 

exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 258 of 266
BART Modeling Review 

Osceola Farms –units 2 and 4 (mill boilers No.’s 2 and 4)

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

based on maximum stack test data for SO2,NOx, and PM (bagasse) ;based on AP42 for SO2, NOx, and PM emissions when firing fuel oil, and for determining 

condensable emissions. 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.302 dv 

(Everglades NP) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 259 of 266
BART Modeling Review 

Reliant Indian River – units 2 and 3 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum allowable rate considering both normal operation and soot 

blowing 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.178 dv 

(Chassahowitzka NWA) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 260 of 266
BART Modeling Review 

Smurfit Stone Container Fernandina Beach –units 6, 7 and 13 (No. 5 power boiler, No. 4 

recovery boiler, and No. 4 smelt dissolving tank) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

SO2 and NOx emissions from the recovery boilers and smelt dissolving tanks are 

based on maximum permitted process rate and NCASI emission factors developed 

for the industry, and by AP-42; A new SO2 emissions limit of 550 lb/hr (24-hour 

average) is being requested by the applicant on the No. 5 power boiler to limit 

their visibility impact to less than 0.5 dv. 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.915 dv 

(Okefenokee NWA) using the old IMPROVE equation and 1026 lb SO2/hr on PB 

5, and 0.495 dv, using the new emissions limitation of 550 lb SO2/hr and the new 

IMPROVE equation. 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 261 of 266
BART Modeling Review 

Smurfit Stone Panama City –units 16, 1, 19, 20, 21, 4 and 5 (No. 4 combination boiler, 

No.’s 1 and 2 recovery boilers, and No.’s 1 and 2 smelt dissolving tanks, lime kiln, and 

lime slaker) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

SO2 and NOx emissions from the recovery boilers and smelt dissolving tanks are 

based on maximum permitted process rate and NCASI emission factors developed 

for the industry, and by AP-42; A new SO2 emissions limit of 690 lb/hr (24-hour 

average) is being requested by the applicant on the No. 4 combination boiler to 

limit their visibility impact to less than 0.5 dv. The lime kiln SO2 and NOx 

emissions are based on maximum stack test data. PM emissions based on 

maximum stack test data 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.586 dv (St. 

Marks NWA) using the old IMPROVE equation, and 0.498 dv, using the new 

IMPROVE equation. 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 262 of 266
BART Modeling Review 

Sugarcane Growers –units 1, 2, 4, and 5 (boilers 1,2,4, and 5) 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, SO4, NOx, and PM 

Because of the seasonal nature of sugar cane operations, crop season (October 

through April) and off-crop season emission scenarios were modeled. 

SO2 emissions were based on industry test data and assumptions in the Title V 

permit. PM and NOx emissions were based on stack test data. PM was speciated 

using AP-42 factors for wood-fired boilers (no specific factors are available for 

bagasse-fired boilers). Condensible PM emissions were based on AP-42 and 

divided equally between organic and inorganic species. 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.634 dv 

(Everglades NP) using the old IMPROVE equation and 0.467 dv, using the new 

IMPROVE equation. 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 263 of 266
BART Modeling Review 

TECO Big Bend –units 1, 2, and 3 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

PM only 

based on maximum stack test data, with maximum allowable heat input rate 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.577 dv 

(Chassahowitzka NWA), based on the old IMPROVE equation 

maximum 8th highest daily visibility value at any Class I area = 0.466 dv 

(Chassahowitzka NWA), based on new IMPROVE equation 

New IMPROVE equation applied using VISTAS conversion spreadsheet; 

applicant used a Rayleigh scattering value of 11.4 instead of the rounded number, 

11, suggested in the spreadsheet. If “11” is used the visibility value increases to 

0.474 dv

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 264 of 266
BART Modeling Review 

U.S. Sugar Clewiston –units 1 and 2 

Requests exemption based on modeled impact less than 0.5 dv. 

Protocol: 

Followed VISTAS common protocol 

Reviewed by DEP and EPA 

Comments were appropriately responded to by the applicant 

Exemption modeling: 

Stack parameters – 

input correctly and consistent with protocol 

Emissions – 

SO2, NOx, and PM 

based on maximum stack test data for NOx and PM (bagasse and fuel oil), and for 

SO2 (boiler 1) when firing bagasse (applied to boiler 2 since nearly identical); 

AP-42 was used for PM and SO2 emissions when firing fuel oil and for 

determining condensable emissions. 

input correctly and consistent with protocol 

speciation correctly input and consistent with protocol 

Results from CALPOST –

inputs correct and consistent with protocol 

modeling output is consistent with applicant’s report

maximum 8th highest daily visibility value at any Class I area = 0.265 dv 

(Everglades NP) 

based on old IMPROVE equation 

Department recommendation: Meets BART exemption criteria, source exempt. 

Appendix L6 

Regional Haze SIP for Florida

Page 265 of 266
BART Exemption Sources 

The following sources were determined to be exempt from the BART rule in accordance 

with Rule 62-296.340(5)(a)1. or Rule 62-296.340(5)(a)2, Florida Administrative Code. 

These exemptions follow the U.S. EPA “model rule” criteria whereby BART-eligible 

sources located greater than 50 (or 100) km from any Class I area and having potential 

emissions of SO2+NOx+PM less than 500 (or 1000) tons is exempt. In making this 

determination, the PM emissions are speciated and an equivalent tonnage is calculated 

based on each species sulfate-equivalent extinction. 

ARMS 

ID

Source Name Minimum Distance to 

Any Class I Area (km)

Total Emissions SO2 + 

NOx + PM (tpy)

0330040 Solutia 166 963

0990045 Lake Worth Utilities –

Tom G. Smith Plant

104 2761

1110003 Ft. Pierce Utilities –

H.D. King Plant

190 181

1130003 Sterling Fibers 177 828

1 Only PM is considered because electric generating units are subject to CAIR 

The department has verified the distance and potential emissions data used to make these 

exemption determinations. 

Appendix L6 

Regional Haze SIP for Florida

Page 266 of 266