Appendix L.8: South Mississippi Electric Power Association - Moselle and R. D. 

Morrow 

Appendix L.8 contents: 

L. 8.1 Appendix summary 

L.8.2 BART information request letters 

L. 8.3 BART eligibility letters 

L.8.4 Model plant exemption rationale 

L.8.5 BART exemption letter 
Appendix L.8.1 

South Mississippi Electric Power Association (SMEPA) - Moselle and R. D. Morrow 

plants (1 360-00035, 1440-0002 1) BART Process Summary 

As fossil fuel fired steam electric plants, SMEPA Moselle and R. D. Morrow meet the 

initial BART eligibility requirement of source category code. The Moselle facility is 169 

km from Breton National Wildlife Refuge, a Class I area, and R. D. Morrow is 138km 

from Breton. Both have a possible visibility impact. Therefore, on February 28, 2002, 

Mississippi Department of Environmental Quality (MDEQ) sent them a letter requesting 

information to determine BART eligibility. Based on the information received from 

SMEPA, several units at each facility were deemed BART eligible because they met the 

following criteria: 

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

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

SO2, NO,, or PM10. 

The following are the BART-eligible point sources for SMEPA - Moselle. 

The following are the BART-eligible point sources for SMEPA - R. D. Morrow 

Emission Unit 

Boiler 1 

Boiler 2 

Boiler 3 

Since these are subject and participating CAIR facilities, SO2 and NO, emissions do not 

need further analysis; however, the PM component needs to be addressed. Both plants' 

potential PMlO emissions are less than 100 tons per year and the facilities are greater 

than 100 lulometers from the closest Class 1 area (Breton). Therefore SMEPA's BART 

eligible facilities were deemed exempt from further demonstration. 

Heat Duty 

(MMBtulhr) 

869 

869 

869 

Emission Unit 

Boiler I 

Boiler 2 

Totals 

Heat Duty 

(MMBtulhr) 

2675 

2675 

Existing Control 

Equip. 

nla 

nla 

nla 

0 

Potential Emission Rates (tons per year) 

so2 

nla 

nla 

nla 

0 

Existing Control 

Equip. 

nla 

nla 

Potential Emission Rates (tons per year) 

84 

NOx 

nla 

nla 

nla 

so2 

nla 

nla 

PMio 

28 

28 

28 

NOx 

nla 

nla 

PMio 

32 

32 
L 

Appendix L.8.2 

STATE OF MISSISSlPPl 

DAVID RONALD MVX;ROM. OWERE(DR 

MISSI~SIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY 

OuwsH.QusoucMrcvnvrWRECroR 

February 28,2802 

Mr. Joey Ward 

South Mississippi Electric Power Association 

P.O. Box 15849 

Hattiesburg, MS 39404-5849 

COPY 

Re: BART Information Request 

Dear Mr. Ward: 

In July 1999, The Environmental Protection Agency @PA) issued regional haze 

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

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

for impmving visibility in thwc areas and to submit mate imphentation plans (SIPS) 

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

pollution. 

One component of these regulations is to reduce emissions fbm certain, existing, lwg~t 

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

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

emission units that: 

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

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

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

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

fall into one of 26 listed souroc categories, including steam electric plants and 

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

smelters. See attached list. 

The final implementation plan should be submitted to EPA by Dcccmber 31,2008, and 

must contain, among other things, the emission limits and complianoe schcduks for each 

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

sources. 

Mississippi and other southeolstern states and tribes haw formed a Rtgimal Planning 

Organization, known as VISTAS, to work on the regional haze issue and the required 
bz~g Appendix L.8.2 

implementation plans. It is our goal to have all BART subject facilities and the specific 

emission units at the facilities identified by June 2002. - 

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

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

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

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

make a detamination. 

The initial startup date for facility. 

0 The initial startup date for individual emission units. 

The dates of any modification or reconstruction for individual units. 

The BART source category of the emission units. - 

A list of emission units obtained from our files is enclosed. Please enter the dates of 

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

to the listed source category, and review and make any corrtctions to the poten'tial 

emissions. This infoxmation is also available in excel spreadsbeet format which can be 

completed and submitted electronically. -- 

Please respond by April 19,2002. If this information is not received, the facility and a]l 

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

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

Thank you for your help with this project. If you have any questions, pkme contact me 

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

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

d~rahrahbolcwm@q.stateCms.us and elliott~bick~q.statc.ms.us. 

Sincerely, 

WB-;" 

Elliott Bickerstaff, P.E. 

Chief, Air Support Branch 
Appendix L.8.2 

STATE OF MISSISSIPPl 

DAVID RONAW MmMISSIS~XPPI DEPARTMENT OF ENVIRONMENTAL QUALITY 

wH.-MEcvrrvEWltecroR 

Mr. Joey Ward 

South Mississippi Electric Power Association 

P.O. Box 15849 

Hatticsburg, MS 39404-5849 

COPY 

Re: BART Information Request 

Dear Mr. Ward: 

In July 1999, The Environmental Protection Agency @PA) issued regional hazt 

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

wilderness areas across thecouut~~. Thcsc regulations require states to establish pals 

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

that contain enforceable mcaswcs and control stmegk for reducing visibility-impairing 

pollution. . 

One component of these qplations is to reduce emissions from catain, existing, large 

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

known as the Best Available Retrofit Technology (BART) ~#luirement, applies to 

emission units that: 

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

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

particulate matter less that I0 microns (PMlo), sulk dioxide, or volatile organic 

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

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

industrial boilas, and large industrial plants such as pulp mills, ~c:fincrics, and 

smelters. See attached list. 

The final implementation plan shoul'd be submitted to EPA by December 3 1,2008, and 

must contain, among other things, the emission limits and compliance scheduies fbr each 

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

sources. 

Mississippi and other southeastern states and tribes have fonned a Regional Plauning 

Organization, known as VISTAS, to work on the regional haze issue and the required 
e r-P 

ru." Appendix L.8.2 

d 

,J'* 

implementation plans. It is our goal to have all BART subject facilities and the specific 

emission units at the facilities identified by June 2002. 

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

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

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

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

make a dctcrmination. 

The initial starhrp date for facility. 

The initial startup date for individual emission units. 

0 The dates of any modification or reconstruction for individual units. 

The BART source category of the emission units. 

A list of emission units obtained hm our files is enclosed. Please enter the dates of 

initial start-up and any modification or reconstruction, review and make any cormdons 

to the listed source category, and review and make any corrections to tbe potential 

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

completed and submitted electronically. 

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

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

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

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

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

elaAmnic copy of the emission unit list, please send an e-mail to 

deborahrahbolewart@dcq.state.ms.us and elliott-bick-eq.state.ms.us. 

Sincerely, 

Elliott Bickm, P.E. 
*- 

Appendix L.8.3 

STATE OF MISSISSIPPI 

DAVID RONAU) ~USGROM.~VERNOR 

M~sslsslPPI DEPARTMENT OF ENVIRONMENTAL QUALITY 

atrUllEs H. CHISOLM. EXKWlW DlReCrOR 

September 9,2002 

Mr. Joey Ward 

South Mississippi Electric Power Association 

P.O. Box 15849 

Hattiesburg, MS 39404-5849 - 

Re: BART Information Response 

South Mississippi Electric Power Association 

Moselle Plant 

Jones County, Mississippi 

Dear Mr. Ward: - - 

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

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

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

reasons: -- - 

1. Units AA-001, AA-002, and AA-003 fall into the category for fossil fuelfired steam electric plants (250 ,MMBTU heat input per hour). 

2. These units began operation during the August 7, 1%2 to August 7, 1977 

date range. 

3. The emissions from these units exceed the 250 tons per year limit. - 

On May 24,2W, the D .C. circuit court vacated the BART provisions of the Regional 

Haze Rule (RHR). At issue is the method of determining the cost and benefits of 

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

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

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

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

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

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

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

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

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

have identified emission units AA-001, AA-002, and AA-003 at the facility to be 
4 li subject to this requirement. Piease note that a BART appiicablc souroe is one that will 

be considered for retrofit technology controls. It does not necessarily mean that 

additional controls will be required for the source. Those determinations will be made 

over the next several years during the Regional Haze plannhg and our State 

Imglementation Plan dtvelgrment process. 

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

of Federal Regulations. If you have questions or comments regarding the BART 

requirements or this designation, please contact me at (601) 961-3176 or Deborah 

Boleware at (601) 961-5768. 

Sincerely, 

Elliott Bickerstaff, 

Chief, Air Support 
IAppendix L.8.3 

STATE OF MI;SSISSIPPl 

DAVID RONALD MVSOROM. GOVERNOR 

Mlssissl~~l DEPARTMENT OF ENVIRONMENTAL QUALI~ 

CHARLES H. CHE0LJ.t EXECU~M WR#JTOR 

September 9,2002 

Mr. Joey Ward 

South Mississippi Electric Power Association 

P.O. Box 15849 

Hattiesburg, MS 39404-5849 

Re: BART Information Response 

South Mississippi Electric Power Association 

Morrow Plant 

Lamar County, Mississippi 

Dear Mr. Ward: 

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

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

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

reasons: 

1. Units AA-001 and AA-002 fail into the category for fossil fwl-fired steam 

electric plants (230 MMBTU beat input per hour). 

2. These units began operation during the August 7, 1%2 to August 7, 1977 

date range. 

3. The emissions from these units exceed tbe 250 tons per year limit. 

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

Haze Rule (RHR). At issue is the method of determining the cost and benefits of 

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

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

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

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

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

approach. EPA has filed a petition seeking rehearing of tbe case by the full wurt. 

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

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

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

have identified emission units AA-001 and AA-002 at the facility to be subject to this 
S/; ' Appendix L.8.3 

requirement. Please note that a BART applicable source is one that will be considered 

for retrofit tccbaology controls. It does not necessarily mean that additional controls 

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

several years during the Regional Haze planning and our State Implementation Plan 

development process. 

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

of Federal Regulations. If you have questions or comments regard* the BART 

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

Boleware at (601) % 1-5768. 

Sincerely, 
Appendix L.8.4 

BART Exemption Rationale for SMEPA Moselle Plant and R. D. Morrow Plant 

South Mississippi Electric Power Association (SMEPA) Moselle and R. D. Morrow 

Plants are both BART eligible facilities. We are electing to use the Model Plant rule as 

given in Part 111, Option 2 of the BART Guidelines to exempt these facilities. 

The model plant criteria states for exemption potential emissions of SO2 or NO, or SO2 + 

NO, should be less than 500 tons for facilities greater than 50 kilometers (krn) from the 

nearest class I area or potential emissions should be less than 1000 tons for facilities 

greater than 100 km from the nearest class I area. The model plant criteria proposed by 

the EPA does not consider the contribution from PM. 

Since these are subject and participating CAIR facilities, SO2 and NO, emissions do not 

need further analysis; however, the PM component needs to be addressed. Both plants' 

potential PMlO emissions are less than 100 tons per year and the facilities are greater 

than 100 kilometers from the closest Class 1 area (Breton). Logic to appropriately 

include PM in the model plant exemption process was developed by Jim Boylan of 

Georgia DNR. This rationale determines a "PM factor" to relate primary PM to 

secondary sulfate PM from S02. Using his reasoning as our basis gives the following 

rationale to exclude the SMEPA plants. 

Only a fraction SOz is converted to SO4 is and the amount is a function of the SOz 

to SO4 conversion rate, the distance and the wind speed. 

Using a conversion rate of 1.5 % per hour, wind speed of 5ds and a distance of 

lOOkm gives a SOz to So4 conversion of 8.3%. 

0 Conversion of 1 ton SO? (molecular weight =64) will produce 2.06 tons 

Ammonium Sulfate (MW= 132). 

Therefore, 1000 tons S02*8.3% conversion*2.06 ton SOLJton SO2 equals 171 tons 

so4. 

0 Assuming that all PM emissions are sulfate, gives a PM factor of 10001171 or 

5.85. In reality, only a fraction of the PM would be sulfate and most other 

components have lower extinction coefficients than that of sulfate, making this a 

very conservative value. 

The SMEPA R. D. Morrow Plant is 168 km from the nearest Class 1 area and has PMlO 

potential emissions of 64.61 tons per year for its BART eligible units; 

64.61* 5.85 = 378. The Moselle Plant is 138 km from the nearest Class 1 area and has 

PM10 potential emissions of 83.1 tons per year for its BART eligible units; 

83.1 *5.85 = 486. Including the factors, both facilities' emissions are less than the model 

plant thresholds and would be exempt from further review. 
Appendix L.8.5 

STATE OF MISSISSIPPI 

~~ 

COVWNOll 

MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY 

Tlll~l~D.F~wmExaamvsDascror 

October 8,2007 

Joey Ward 

South MS Electric Power Association. 

P 0 Box 1 5849 

Hattiesburg, MS 39404-5849 

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

R D Morrow plant, (1440)073-0002 1 

Lamar County, Mississippi 

Moselle plant (1 360)067-00035 

Jones County, Mississippi 

Dear Mr. Ward: 

Due to the South MS Electric Power Association (SMEPA) - R D Morrow and Moselle facilities 

being BART eligible, the visibility impacts of the BART eligible sources had to be analyzed to 

determine if they were BART subject. Since R D Morrow and Moselle are subject to CAIR, NO, 

and SO2 from the eligible units did not have to be analyzed further. The remaining pollutant for 

BART demonstration is PM 10. The total potential PMlO emissions for your BART eligible units 

were small enough to use the model plant option in the BART Guidelines to propose exemption 

for the plants. Please see attached explanation of the model plant option and calculations for the 

SMEPA facilities involved. Mississippi Department of Environmental Quality (MDEQ) will 

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

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

Agency (EPA) and other parties with South MS Electric Power Association - R D Morrow's and 

Moselle's exemptions contingent on EPA's approval. 

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

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

Sincerely, 

Maya ~a4 P.E., BCEE 

Chief, Air Division 

OFFICE OF POLLUTION CONTROL ~nrr n-~m II-IRQ< ~wucn~ MICCICPI~ 197A9rOUt5 TFI - 1~111 (W;1.5171 FAY: (601) 35dMi12 -.dmaermus