C-1 

## APPENDIX C – SUMMARY OF ALM ANALYSES AND RECOMMENDATIONSSummary of CMAQ 2002 Evaluation for NO3Predictions with CALPUFF inVISTAS-BARTChristelle Escoffier-Czaja & Joseph S. ScireWhat sources of NH3concentration to usewith CALPUFF?zNH3= constantzHourly or Monthly CMAQ NH3(gas) alone = excess NH3(g)zAmmonia Limiting Method (ALM) using:– Hourly CMAQ SO4– Hourly CMAQ totalNO3=NO3+HNO3– Hourly CMAQ totalNH3=NH3(gas)+NO3+2SO4It creates a space- and time-varying environment of background pollutant ateach receptor of Class I areasIt creates a space- and time-varying NH3background available for a newsource to use.CMAQ NH3(gas) ANNUAL AVERAGE-2000 -100001000 2000 3000-2000-1000010002000Ammonia Concentrations (ppb)Annual Average (2002)Ammonia(ppb)0.010.10.512345678910CMAQ NH3(gas) MONTHLY AVERAGE-2000 -100001000 2000 3000-2000-1000010002000Ammonia Concentrations (ppb)January Average (2002)Ammonia(ppb)0.010.10.512345678910-2000 -100001000 2000 3000-2000-1000010002000Ammonia Concentrations (ppb)April Average (2002)JANUARY 2002APRIL 2002CMAQ NH3(gas) COMPARED TOOBSERVATIONS – daily averagedNH3 scatter plot - daily average - Jan to May 2002012345678012345678NH3 observed (ppb)

NH3 CMAQ predicted (ppb)NH3 Q-Q plot - daily average - Jan to May 2002012345678012345678NH3 observed (ppb)

NH3 CMAQ prediction (ppb)January to May 2002 – Daily averageat St Louis Supersite, IllinoisSCATTER PLOT Quantile-Quantile PLOTCMAQ NH3(gas) COMPARED TO SEARCHOBSERVATIONS – Monthly averagedNH3 monthly average at each of the 8 SEARCH site.00.511.522.533.544.51 13 25 37 49 61 73 85Jan to Dec for each site

NH3 (ppb )NH3obsNH3cmqLocation of SEARCH Siteshttp://www.atmospheric-research.com/locations/index.htmlObservations – year 2004CMAQ – year 2002CONCLUSION for NH3(gas phase)zCMAQ NH3(gas) shows a strong spatial and temporalvariability– A constant NH3(i.e. 0.5ppb) is not consistent with this variabilityzBut at the sites where we have observations, CMAQNH3(gas) underpredicts NH3(gas) observedzSo, CMAQ NH3(gas) is not recommended to be usedalone for a refined NO3prediction with CALPUFF becauseit may underpredict NO3formationAlternative to NH3(gas) alone:ALM applicationzFor ALM application, data needed: Backgroundconcentrations such as CMAQ dataset– concentrations necessary: NO3, HNO3, SO4andTNH3=NH3(gas)+NO3+2SO4zCMAQ NO3, SO4and total NO3(NO3+HNO3) are comparedto observations from CASTNet and IMPROVE networks toevaluate CMAQ performance– 52 CASTNet sites (23 in VISTAS states) – weekly average– 46 IMPROVE sites (16 in VISTAS states) – daily average-95 -90 -85 -80 -75 -70Longitude (in Degrees)2530354045

Latitude (in deg r ees)SND152CAD150ABT147SUM156IRL141EVE419GAS153STK138BVL130ALH157SAL133VIN140CKT136MCK131MAC426CDZ171BEL116BWR139HOX148UVL124ANA115CVL151PNF126CND125COW137BFT142WSP144HWF187CTH110CAT175LYK123QAK172DCP114OXF122CHE185KEF112MKG113PSU106LRL117ARE128SPD111ESP127GRS420SHN418VPI120PED108PAR107CDR119PRK134CASTNet sitesClass I areasLocation of CASTNet sites Usedand Class I areas in the SouthEast-95 -90 -85 -80 -75 -70Longitude (in Degrees)2530354045

Latitude (in degrees)ADPI1AREN1BLMO1BOND1BOWA1BRET1BRIG1CACR1CADI1CHAS1COHI1COHU1DOSO1ELDO1EVER1GRRI1GRSM1HEGL1ISLE1JARI1LASU1LIGO1LIVO1MACA1MING1MKGO1MOMO1OKEF1QUCI1ROMA1SAFO1SAMA1SENE1SHEN1SHRO1SIKE1SIPS1SWAN1TALL1UPBU1VILA1VOYA2WASH1IMPROVE sitesClass I areasLocation of IMPROVE sites Usedand Class I areas in the SOuthEastCMAQ versus IMPROVEdaily averages comparisonNO3 daily average Q-Q plot - year 20020246810121416180 2 4 6 8 10 12 14 16 18NO3 IMPROVE (ug/m3)

NO3 CMAQ (ug/m3 )SO4 daily average Q-Q plot - year 20020510152025300 5 10 15 20 25 30SO4 IMPROVE (ug/m3)

SO4 CMAQ (ug/m3)CMAQ versus CASTNetweekly averages comparisonNO3 weekly average scatter plot - year 20020246810120 2 4 6 8 10 12NO3 CASTNET (ug/m3)

NO3 CMAQ (ug/m3)SO4 weekly average Q-Q plot - year 2002024681012141618200 2 4 6 8 10 12 14 16 18 20SO4 CASTNET (ug/m3)

SO4 CMAQ (ug/m3)total NO3 weekly average Q-Q plot - year 2002024681012140 2 4 6 8 10 12 14total NO3 CASTNET (ug/m3)

total NO3 CMAQ (ug/m3)HNO3 weekly average Q-Q plot - year 20020246810120 2 4 6 810 12HNO3 CASTNET (ug/m3)

HNO3 CMAQ (ug/m3)CMAQ/Observation ratios as function ofelevation and monthsCONCLUSION ON CMAQ EVALUATIONzSO4and total NO3from CMAQ are in very good agreementwith observations (from CASTNet and IMPROVE)– CMAQ SO4slightly lower than observations– CMAQ total NO3slightly larger than observations– CMAQ NO3is larger than observations in winter and smaller in summerzNext Step to confirm CMAQ data suitable to be used forALM application:– Use of CMAQ hourly SO4, totalNO3=NO3+HNO3and totalNH3=NO3+2SO4+ NH3(gas) as input to POSTUTIL(as it would be used inALM) and compare NO3output to NO3observed and CMAQ NO3.CMAQ data INPUT in POSTUTIL for NO3predictionsNO3 weekly average - Q-Q plot - year 20020246810120 2 4 6 810 12NO3 CASTNET observations (ug/m3)

NO3 MODEL simulations (ug/m3)CHEMEQ'CMAQ'zCHEMEQ is POSTUTILNO3/HNO3equilibriumparameterizationzPink– CMAQ outputzDark blue– hourly CMAQinput in CHEMEQ + hourlyTNH3= NH3g+NO3+2SO4CONCLUSION: NO3output of POSTUTILclosely tracks CMAQ NO3. Hourly CMAQdataset can be used for ALM application withPOSTUTIL.NO3 daily averaged - Q-Q plots - year 200202468101214160 2 4 6 8 10 12 14 16NO3 IMPROVE observations (ug/m3)

NO3 MODEL simulations (ug/m3)CHEMEQCMAQNO3Predictions using CMAQ monthly averagedzTEST IF MONTHLY 2002 CMAQ CAN BEUSED TO CREATE 2001 and 2003BACKGROUNDzDark blue– hourly CMAQ input in CHEMEQ+ hourly CMAQ TNH3= NH3g+NO3+2SO4zRed– Year 2002 using monthly 2002 CMAQinput in CHEMEQ + monthly TNH3zYellow– Year 2001 using monthly 2002CMAQ input in CHEMEQ + monthly CMAQTNH3zLight Blue– Year 2003 using monthly 2002CMAQ input in CHEMEQ + monthly TNH3NO3 daily average - Q-Q plot024681012140 2 4 6 8 10 12 14NO3 IMPROVE observations (ug/m3)

NO3 predicted (ug/m3)PUFHRPUFMONALL2002PUFMONALL2001PUFMONALL2003NO3 weekly averaged Q-Q plot024681012140 2 4 6 8 10 12 14NO3 CASTNET observations (ug/m3)

NO3 predicted (ug/m3)PUFHRPUFMONALL2002PUFMONALL2001PUFMONALL2003NO3Predictions/Observations daily averaged time series at GreatSmoky Mountains, NP, Tennessee - IMPROVENO3 daily averaged at GRSM1 - 2001 - CASTNet T, RH01234561 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3)IMPROVEPUFMONNO3 daily averaged at GRSM1 - 2002 - CASTNet T, RH01234561 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3)IMPROVEPUFMONPUFMONHRDark blue– ObservationsPink– monthly BCKG (NH3g=CMAQ)Light blue– hourly BCKG (NH3g=CMAQ)Hourly BCKG = use of hourly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gMonthly BCKG = use of monthly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gNH3g =CMAQNH3gNO3 daily averaged at GRSM1 - 2003 - CASTNet T, RH01234561 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3)IMPROVEPUFMONNO3Predictions/Observations daily averaged timeseries at Dolly Sods Wilderness - IMPROVENO3 daily averaged at DOSO1 - 2001 - CASTNet T, RH01234561 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3)IMPROVEPUFMONNO3 daily averaged at DOSO1 - 2002 - CASTNet T, RH01234561 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3)IMPROVEPUFMONPUFHRDark blue– ObservationsPink– monthly BCKG (NH3g=CMAQ)Light blue– hourly BCKG (NH3g=CMAQ)Hourly BCKG = use of hourly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gMonthly BCKG = use of monthly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gNH3g = CMAQNH3gNO3 daily averaged at DOSO1 - 2003 - CASTNet T, RH01234561 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3)IMPROVEPUFMONNO3Predictions/Observations daily averaged timeseries at Everglades NP, Florida - IMPROVENO3 daily averaged at EVER1 - 2001 - CASTNet T, RH00.20.40.60.811.21.41.61 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3)IMPROVEPUFMONNO3 daily averaged at EVER1 - 2002 - CASTNet T, RH00.20.40.60.811.21.41.61 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3)IMPROVEPUFMONPUFHRDark blue– ObservationsPink– monthly BCKG (NH3g=CMAQ)Light blue– hourly BCKG (NH3g=CMAQ)Hourly BCKG = use of hourly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gMonthly BCKG = use of monthly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gNH3g =CMAQNH3gNO3 daily averaged at EVER1 - 2003 - CASTNet T, RH00.20.40.60.811.21.41.61 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3)IMPROVEPUFMONNO3Predictions/Observations daily averaged timeseries at Everglades NP, Florida - IMPROVEDark blue– ObservationsLight blue– hourly BCKG (NH3g=CMAQ)Pink– monthly BCKG (NH3g=0.5ppb)Yellow– monthly BCKG (NH3g=1ppb)Green– monthly BCKG (NH3g=10ppb)Hourly BCKG = use of hourly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gMonthly BCKG = use of monthly averagesof SO4, NO3, HNO3 and TNH3TNH3 = NO3 +2 SO4 +NH3gIn TNH3, CMAQNH3g is replaced byeither 0.5ppb, 1ppb or 10ppbin this exampleNH3g = 1ppb gives resultscloser to observations than 0.5ppb,While NH3g=10ppb much too largein winterNO3 daily averaged atEVER1 - 2001 - CASTNet T, RH00.20.40.60.811.21.41.61 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2001

NO3 (ug/m3)IMPROVEPUFMON0p5PUFMON1ppbPUFMON10ppbNO3 daily averaged at EVER1 - 2002 - CASTNet T, RH00.20.40.60.811.21.41.61 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2002

NO3 (ug/m3)IMPROVEPUFMON0p5PUFMON1ppbPUFHRPUFMON10ppbNO3 daily averaged at EVER1 - 2003 - CASTNet T, RH00.20.40.60.811.21.41.61 31 61 91 121 151 181 211 241 271 301 331 361Days with IMPROVE observations and CASTNet T, RH - 2003

NO3 (ug/m3)IMPROVEPUFMON0p5PUFMON1ppbPUFMON10ppbCONCLUSION – use of 2002 CMAQhourly datasetzCMAQ NH3(gas) is not recommended to be used alone inCALPUFF for a refined analysis- too much underprediction atmost sites evaluatedzALM application with POSTUTIL using hourly 2002 CMAQconcentrations for background is recommended.– For year 2002: hourly SO4, hourly totalNO3and hourlytotalNH3=NH3(gas)+NO3+2SO4in POSTUTIL gives NO3concentrationscomparable to CMAQ NO3at all sites.zFor years 2001 and 2003: an hourly dataset similar to CMAQ2002 would be recommendedCONCLUSION – use of 2002 CMAQmonthly averagedzCMAQ 2002 monthly averages as input in POSTUTIL underestimate thelargest NO3concentrations observed for all three years.zAt some Class I areas, up to 5 days out of 104 days (5%) – 18 days ina year can be missed(observed for 2001 and 2003).zAs an alternative to hourly background data for ALM application, 2002CMAQ monthly averaged background can be a solution, knowing that thehighest NO3concentrations will be missed and the averaged NO3concentrations may be overestimated.zIf 2002 CMAQ monthly average is considered to be used for 2001 and2003. It will also be used for 2002 for consistency over the 3 years.zFor Everglades NP, it is suggested that monthly averageTNH3=NO3+2SO4+NH3(g) be replaced by TNH3=NO3+2SO4+1ppb for ALMapplication (may be for Breton Wilderness too).

# 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 01854i 

## 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 H opkins Tallahassee – Refined Run (4-km grid) 4-4ii 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. 3-8Introduction 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 u se 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

98 th percentile day (i.e., 8 th highest within a year) predicted by the refined simulations were
compared to the 0.5 deciview threshold. Facilities with a maximum 98 th 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 ).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 mode led using the 4-km subregional Domain 2 since their distance
to the closest Class I Area (Ch assahowitzka 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 ra tes 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 PM 10 includes all PM mass (condensable plus f ilterable) emitted as particulate matter less
than 10 micrometers ( μ m) in diameter. The emissions labeled as PM 2.5 are a subset of the PM 10 composed of particles less than 2.5 μ m in diameter. All condensable emissions are assumed to be

in the PM 2.5 size range. The PM 10 and PM 2.5 categories include H 2 SO 4 emissions, which in the
model are treated as primary sulfate (SO 4 ). The emissions of H 2 SO 4 are adjusted by the ratio of
molecular weights (96/98) to obtain the emissions as SO 4 which is entered into the model.

The PM 10 size distribution was represented in the modeling as six explicit size ranges. The
particle sizes modeled were as 8.0 μ m diameter size particles (PM800) reflecting the size bin

6-10 μ m, 4.25 μ m diameter particles (PM425) for the size bin 2.5-6 μ m, 1.875 μ m particles
(PM187) for the size bin 1.25-2.5 μ m, 1.125 μ m particles (PM112) for the size bin 1.00-1.25 μ m,

0.8125 μ m particles (PM081) for the size bin 0.625-1.00 μ m, and 0.5625 μ m (PM056) for the size
range 0.500-0.625 μ m. PM056 was also used for all particles less than 0.5 μ m diameter.
Emissions of particulate matter in the 2.5-10 μ m diameter size range define “coarse particulate
matter”. Fine particles (soil) we re defined using the particle size categories of PM187, PM112,
PM081, and PM056 which is particulate matter with a size of 2.5 μ m diameters or less. For
sources with no speciation (emissions given as PM 10 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 em issions 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 “CEM EX Brooksville 0530010.xls” file. For six of the
ten stacks, PM distribution was provided and u sed in the modeling (Table 2-1b). Appropriate
adjustments to PM 10 and PM 2.5 emissions for these six stacks were made (Table 2-1a), as
described in the footnote. For remaining four st acks (002, 009, 011 and 024), the PM distribution
was not provided, so PM 10 -H 2 SO 4 emissions were equally divided between the two size
categories of OC for modeling purposes.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 PM 10 -H 2 SO 4 emissions were equally divided betw een 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 “H opkins Tallahassee.xls” file. The PM distribution
was not provided, so PM 10 -H 2 SO 4 emissions were equally divided between the two size
categories of OC for modeling purposes.Source Parameters2-3Table 2-1a. CEMEX Brooksville: Source Parameters and Emissions1StackID #Lambert ConformalCoordinates StackHeightBaseElevationDiameterGas ExitVelocityStackGasExitTemp.SO2EmissionsH2SO4Emissions2NOxEmissionsPM10Emissions3PM2.5EmissionsNH3EmissionsLCC East LCC Northkm km m m m m/s Kg/s g/s g/s g/s g/s g/s002 1426.5697 -1148.3464 22.86 45.72 0.917.19 302.59 - - - 0.1080 0.0578 -003 1426.5918 -1148.4144 45.72 45.72 3.9610.52 374.82 0.2604 0.1275 22.21380.9153 0.86240.0911004 1426.5588 -1148.2247 15.24 45.72 3.05 9.06 444.26 - - - 0.66940.6246-005 1426.5022 -1148.1934 21.34 45.72 0.79 14.35 366.48 - - - 3.86323.6051-006 1426.5618 -1148.1830 45.72 45.72 0.61 24.26 302.59 - - - 0.03920.0365-008 1426.5548 -1148.3192 65.84 45.72 0.61 24.26 302.59 - - - 0.26140.2440-009 1426.4750 -1148.0953 42.67 45.72 0.67 26.73 338.71 - - - 0.00740.0069-011 1426.6376 -1148.3243 24.38 45.72 0.7615.52 298.15 - - - 0.2276 0.1219 -024 1426.6376 -1148.3243 24.69 45.72 0.5212.04 314.82 - - - 0.0635 0.0340 -025 1426.5419 -1148.1865 9.75 45.72 0.6124.26 294.26 - - - 0.2720 0.1457 -Source Parameters2-4Table 2-1b. CEMEX Brooksville: Particle Speciation1, 1a, 1bStackID #Particle speciationCondensableFilterablecondensablePM10filterablePM10organiccondensable (OC)inorganiccondensableH2SO4COARSESoilElemental Carbon (EC)0.625-1.0μm0.5-0.625μm0.625-1.0μm0.5-0.625μmM4=0.48SD4=2.0μm6-10μm2.5-6μm1.25-2.5μm1.0-1.25μm0.625-1.0μm0.5-0.625μm1.25-2.5μm1.0-1.25μm0.625-1.0μm0.5-0.625μm% % g/sg/sg/sg/sg/s g/sg/sg/sg/sg/sg/sg/sg/sg/sg/s002 100.0 0.00.0540 0.0540- - -003 87.6 12.4 0.0812 - 0.5953 - 0.1275 0.00920.0437 0.0553 0.0057004 85.6 14.4 0.0688 - 0.5042 - - 0.0078 0.0370 0.0469 0.0048005 85.6 14.4 0.3968 - 2.9100 - - 0.0450 0.2138 0.2704 0.0278006 85.5 14.5 0.0040 - 0.0295 - - 0.0005 0.0022 0.0027 0.0003008 85.6 14.4 0.0269 - 0.1969 - - 0.0030 0.0145 0.0183 0.0019009 85.3 14.7 0.0008 - 0.0056 - - 0.0001 0.0004 0.0005 0.0001011 100.0 0.00.1138 0.1138- - -024 100.0 0.00.0318 0.0318- - -025 100.0 0.00.1360 0.1360- - -1Emission and speciation data extracted and obtained from the “CEMEX Brooksville 0530010.xls” file.1aPM10emission provided by the state for stack 003is 0.7903 g/s. The adjustment was made inTable 1 (in blue) to match the PM speciation provided by the state in Table 2, such that:OC + IOC + Coarse + Soil + EC +H2SO4= PM10PM2.5emissions (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 adjustments weremade in Table 1 (in blue)to match the PM speciation provided by the state in Table 2, such that:Coarse = PM10- PM2.51bThe PM speciation was not provided by thestate for stacks 002,011, 024 and 025. All PM10- H2SO4emissions were equally divided between the two size categories of OC. This is aconservative approach since organic condensables have an extinction efficiency of 4 m2/g.2H2SO4emissions are entered in CALPUFF as SO4i.e., weighted by ratio of molecular weights (96/98).3PM10emission rate includes filterable and condensable emissions. The condensable component includes H2SO4emissions.4M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO4) particle size distribution in CALPUFF.Source Parameters2-5Table 2-2a. FPL - Putnam Power Plant: Point Source Parameters and Emissions1StackID #Lambert ConformalCoordinates StackHeightBaseElevationDiameterGas ExitVelocityStackGasExitTemp.SO2EmissionsH2SO4Emissions2NOxEmissionsPM10Emissions3PM2.5EmissionsNH3EmissionsLCC East LCC Northkm km m m m m/s Kg/s g/s g/s g/s g/s g/sEU003 1493.905 -1024.347 22.25 7.01 3.1529.29 437.37 - 0.0896 - 1.0130 - -EU004 1493.909 -1024.373 22.25 7.01 3.1529.29 437.37 - 0.1134 - 1.0130 - -EU005 1494.027 -1025.041 22.25 7.01 3.1529.29 437.37 - 0.1187 - 1.0130 - -EU006 1493.927 -1024.472 22.25 7.01 3.1529.29 437.37 - 0.0983 - 1.0130 - -Table 2-2b. FPL - Putnam Power Plant: Particle Speciation1, 1aStackID #Particle speciationCondensableFilterablecondensablePM10filterablePM10organiccondensable (OC)inorganiccondensableH2SO4COARSESoilElemental Carbon (EC)0.625-1.0μm0.5-0.625μm0.625-1.0μm0.5-0.625μmM4=0.48SD4=2.0μm6-10μm2.5-6μm1.25-2.5μm1.0-1.25μm0.625-1.0μm0.5-0.625μm1.25-2.5μm1.0-1.25μm0.625-1.0μm0.5-0.625μm% % g/sg/sg/sg/sg/s g/sg/sg/sg/sg/sg/sg/sg/sg/sg/sEU003 100.0 0.00.46173 0.46173- - 0.0896 - - - - - - - - - -EU004 100.0 0.00.44982 0.44982- - 0.1134 - - - - - - - - - -EU005 100.0 0.00.44717 0.44717- - 0.1187 - - - - - - - - - -EU006 100.0 0.00.45738 0.45738- - 0.0983 - - - - - - - - - -1Emission and speciation data extracted and obtained from the “FPL Putnam.xls” file.1aThe PM speciation was partially provided by the state – 71% of PM10that is condensable is assigned to two OCsize categories. For the purpose of modeling, all PM10- H2SO4emissions were equally divided between thetwo size categories of OC. Thisis a conservative approachsince, Organic condensable have extinction efficiency of 4 m2/g.2H2SO4emissions are entered in CALPUFF as SO4i.e., weighted by ratio of molecular weights (96/98).3PM10emission rate includes filterable and condensable emissions. The condensable component includes H2SO4emissions.4M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO4) particle size distribution in CALPUFF.Source Parameters2-6Table 2-3a. Hopkins Tallahassee:Source Parameters and Emissions1StackID #Lambert ConformalCoordinates StackHeightBaseElevationDiameterGas ExitVelocityStackGasExitTemp.SO2EmissionsH2SO4Emissions2NOxEmissionsPM10Emissions3PM2.5EmissionsNH3EmissionsLCC East LCC Northkm km m m m m/s Kg/s g/s g/s g/s g/s g/sEU-001 1210.330 -975.170 60.96 41.45 3.3511.97 423.15 - 1.2978 - 4.7149 - 0.51EU-004 1210.310 -975.142 76.20 41.45 4.2722.98 415.15 - 4.7754 - 22.0311 - 1.50Table 2-3b. Hopkins Tallahassee: Particle Speciation1, 1aStackID #Particle speciationCondensableFilterablecondensablePM10filterablePM10organiccondensable (OC)inorganiccondensableH2SO4COARSESoilElemental Carbon (EC)0.625-1.0μm0.5-0.625μm0.625-1.0μm0.5-0.625μmM4=0.48SD4=2.0μm6-10μm2.5-6μm1.25-2.5μm1.0-1.25μm0.625-1.0μm0.5-0.625μm1.25-2.5μm1.0-1.25μm0.625-1.0μm0.5-0.625μm% % g/sg/sg/sg/sg/s g/sg/sg/sg/sg/sg/sg/sg/sg/sg/sEU-001 100.0 0.01.7086 1.7086- - 1.2978 - - - - - - - - - -EU-004 100.0 0.08.6279 8.6279- - 4.7754 - - - - - - - - - -1Emission and speciation data extracted and obtained from the “HopkinsTallahassee.xls” file.1aThe PM speciation was not provided by thestate for stacks EU-001 and EU-004. All PM10- H2SO4emissions were equally divided betweenthe two size categories of OC. Thisis a conservative approach since, Organic condensable have extinction efficiency of 4 m2/g.2H2SO4emissions are entered in CALPUFF as SO4i.e., weighted by ratio of molecular weights (96/98).3PM10emission rate includes filterable and condensable emissions. The condensable component includes H2SO4emissions.4M and SD stand for Geometric Mass Mean Diameter and Geometric Standard Deviation. These are the parameters used to calculate the (SO4) particle size distribution in CALPUFF.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 re gional VISTAS modeling domain are derived from
GTOPO30, a global digital elevation model (D EM) 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 un its 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 a nd 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-de gree DEMs. One-degree DE M 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. Th e 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 ar eas and Florida facilities. The subdomain extends at least 50 km

from the Class I areas and all of the facilities in or der to provide an adequa te buffer zone at the

boundaries, and to allow the effects of flow curv ature and possible small-scale recirculation to be

evaluated.

Figure 3-1 shows contours of the terrain averag ed 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 ce lls. 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 Doma in 2 was used in CALPUFF modeling and
BART visibility analysis for CEMEX and Hopk ins facilities. VISTAS Domain 2 was designed
for modeling the Florida sources. It covers entire stat es 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 useGeophysical 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 400LCC North (km)

LCC Origin: 40.0 N, 97.0 W Standard Parallels: 33.0 N, 45.0 N

Datum: NWS-84 Elevation (meters)

GA AL

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.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 regi onal and subregional domai ns have been used
to produce a gridded field of dominant land use ca tegories. 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 mi ssing, North America USGS land use/land cover

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

cover characteristics data base that was devel oped 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 domai n 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.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 -800LCC 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 GA AL MS

-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.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 -800LCC 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 GA AL MS

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. .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 fo r 2001, VISTAS for 2002 and Midwest Regional
Planning Organization (RPO) for 2003. The MM5 gri dded 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 ha ve 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, preci pitation, buoys and upper air stations used in

the CALMET simulations for Domain 2.



### 3.4 Air Quality Monitoring Data

CALPUFF uses hourly ozone concentration measurem ents in the chemical transformation rates
(SO 2 to SO 4 , NO

x to HNO 3 /NO 3 ). The ambient ozone measurements are used in determining SO 2 loss rates due to chemical transformation to sulfate and in determining NO

x 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 ammoni a concentration of 0.5 parts per billion (ppb)
was assumed as recommended by the Intera gency Workgroup on Air Quality Modeling
(IWAQM, 1998) for forested Class I areas. In th is application of the model, the Ammonia
Limiting Method (ALM) was not used.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 -700LCC 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

722230

722235

722240 722245 722246 722250 722255

722260 722265

722267

722268 722269 722275 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.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 -800LCC 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 GA AL MS

-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.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 tota l concentrations. Emission rates of SO 2 , SO 4 , and

NO X 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 colu mn in Tables 4-1 through 4-3 provides the annual
average background b ext values for each Class I Area include d in the analysis. For each Class I
area, the Rayleigh scattering coefficient of 10 Mm -1 was subtracted from the annual average
background b ext and resulting values were en tered in CALPOST as BKSOIL.

Tables 4-1 through 4-3 summarize the maximum pr edicted 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 cha nge 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 refine d 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 threshol d. 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. Tabl e 4-1a shows that in the Okefenokee and
St Marks Class I areas, maximum predicted extinc tion change is below the 0.5 dv threshold value
for all three years. Maximum predicted extincti on change exceeds 0.5 dv in Chassahowitzka. The

8 th highest predicted extinction changes for Ch assahowitzka 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.Results 4

- 2 Hopkins Tallahassee was modeled on the VISTA S 4-km CALMET Domain 2 refined gird.
Visibility analyses showed that predicted ma ximum 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 ex ceed 0.5 dv. Table 4-3b shows eight highest
predicted values of extinction change for all three years for St. Marks.Results 4

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

Class I Area 2001 2002 2003 Annual

average background

b ext 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 Va lues 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 fo r FPL - Putnam Power Plant– Screening Run (12-km grid)

Class I Area 2001 2002 2003 Annual

average background

b ext 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) 21.33Results 4

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

Class I Area 2001 2002 2003 Annual

average background

b ext 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

8Results 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 Unde r the Regional Haze Rule (2003), Appendix A, Table A-3References 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 Imp acts on Regional Visibility. U.S. EPA,
Research Triangle Park, NC. EPA-454/R-98-019.

Environmental Protection Agency (EPA), 2003: Guidance for Estimati ng 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. Ya martino, 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). Ea rth 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 L4

Florida BART Exemption Contribution Threshold

and

VOC/NH3 Exclusion Analysis

## 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 Rule 1



### 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

appropr iate 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 shoul d 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 tha t, “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.”

T he 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 guidance 3 

### 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

### 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, th ey are scattered about the

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

sugg ested value of 0.5 dv.

Map of BART-eligible Sources

## 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 a nd 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

J ARI = James River Face, VA LIGO = Linville Gorge, NC MACA = Mammoth Cave, KY MING = Mingo, MO OKEF = Okefenokee, GA

### 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, GAMaximum 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.

Give n 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

VO Cs 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

F lorida, 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.

### Method

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

a re 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 theextinction coefficient in dv (deciviews), then determining the maximum impact of BARTe ligible 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 NH 3 

### 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.

### 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

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

C lass 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 L6

Summary of BART Modeling ExemptionsFACILITY

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

### 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 firin g 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 CALPOS T

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th 

### 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.

### 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

– in puts correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th 

### 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.

### 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

evaluate d 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, min or 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 8 th 

### 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

b ased on new IMPROVE equation

### Department recommendation: Either scenario meets BART exemption criteria, source

exempt.

### 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 8 th 

### 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.

### 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 8 th 

### highest daily visibility value at any Class I area = 0.522 dv (St. Marks NWA), based on the old IMPROVE equation

maximum 8 th 

### 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.

### BART Modeling Review

City of Vero Beach

– units 2, 3, and 4 Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Fo llowed 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 wi th applicant’s report

maximum 8 th 

### 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.

### 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 8 th 

### 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.

### 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

Result s from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th 

### 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 8 th 

### highest daily visibility value of 0.462 dv

Department recommendation: Meets BART exemption criteria, source exempt.

### 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 8 th 

### 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.

### 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 applican t’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.576 dv (Chassahowitzka NWA), based on the old IMPROVE equation

maximum 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### highest daily visibility value at any Class I area = 0.489 dv (Okef enokee NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### 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 8 th 

### 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.

### 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 con sistent with applicant’s report

maximum 8 th 

### 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.

### BART Modeling Review

IFF Chemicals - unit 3 (boiler 2) Reque sts 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 8 th 

### 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.

### 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 a cid 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### highest daily visibility value at any Class I area = 0.494 dv (Chassahowitzka NWA) from modeling report based on new IMPROVE equation

De partment recommendation: Meets BART exemption criteria, source exempt.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 sul furic 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 t o 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 SA P’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

### maximum 8 th 

### 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.

### 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 PMbased 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 8 th 

### 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.

### 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 bagas se -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 8 th 

### 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.

Departmen t recommendation: Meets BART exemption criteria, source exempt.

### 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 8 th 

### highest daily visibility value at any Class I area = 0.577 dv (Chassahowitzka NWA), based on the old IMPROVE equation

maximum 8 th 

### 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.

### BART Modeling Review

U.S. Sugar Clewiston

– units 1 an d 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

mod eling output is consistent with applicant’s report

maximum 8 th 

### 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.

### 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 BAR T-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 104 276 1



### 1110 003 Ft. Pierce Utilities

–

H.D. King Plant 190 18 1



### 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.