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 letterAppendix L.8.1

South Mississippi Electric Power Association (SMEPA) - Moselle and R. D. Morrow plants (1 360-00035, 1440-00021) 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 32L Appendix L.8.2

STATE 

### OF MISSISSlPPl DAVIDRONALD MVX;ROM.OWERE(DR MISSI~SIPPI DEPARTMENT OFENVIRONMENTAL QUALITY OuwsH.QusoucMrcvnvrWRECroR


### February 28,2802 

### Mr. Joey 

### Ward SouthMississippi Electric Power Association 

### P.O. Box 15849 Hattiesburg,

### MS 39404-5849 

# COPY

Re: BART Information

### Request Dear

### Mr.Ward: 

### In July 1999,The EnvironmentalProtection Agency @PA) 

### issued regional haze regulationsto improve visual 

### air quality, or visibility, 

### in specifiednational parks and wilderness 

### areas acrossthe 

### country. These regulations

### require states to establish goals for impmvingvisibility 

### in 

### thwc areas and to submit mateimphentation plans (SIPS) that contain enforceable

### masuesand control strategies for 

### reducingvisibility-impairing pollution. 

### One component oftheseregulations 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, appliesto emission 

### units that:

wm built between August 7,1962 and August 7, 1977; have the potential to emit 250 tons 

### pcr year or

### more ofammonia, 

### nitrogen oxides, particulate matter less that 10microns 

### (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 electricplants and industrialboilers, and large industrial plants such 

### aspulp mills, 

### refineries, and smelters. See attached list. The 

### finalimplementation plan should be submitted to 

### EPA by 

### Dcccmber 31,2008, and 

### must contain, among other 

### things, the emission limits 

### and complianoeschcduks for each BART subject source. The 

### first step 

### in this processis to identify all 

### BART subject sources. Mississippi and other southeolstern states 

### and 

### tribeshaw formed a 

### Rtgimal Planning Organization, known 

### as

### VISTAS,to work 

### on the regional 

### haze issue and the requiredbz~g Appendix L.8.2

implementation plans. It is our goal to have all 

### BART subject facilities and 

### the 

### specific emission

### units at the facilitiesidentifiedby June 

### 2002. - 

### An initial filereview indicates that your facility is potdally subjectto the 

### BART requirement because it falls into one ofthe 26 sourcecategories, was built prior to August 7, 1977, and 

### has potential emissions greater than 250 tons

### per ytar for at least one ofthe 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 orreconstructionfor individual units. The BART source category ofthe emissionunits.

- A list of emission units obtained from our files is enclosed. Please enter the dates of initial start-up and 

### anymodification or reconstruction, review 

### and make any corrections to the listed 

### sourcecategory, and review and make any corrtctionsto the poten'tial emissions. This infoxmation is 

### also available in excel 

### spreadsbeet format which can be completed and submitted electronically.

-- 

### Please respondby April 19,2002. Ifthis information isnot received, the facility and a]l emission units at the facility will be considered subjectto the BART requirements. However, the 

### final dctenninationswill not be made until the 

### SIPdevelopment process. Thank you for yourhelp with thisproject. 

### If you have any questions, pkme contact

### me at (601)961-5176 or 

### DeborahBoleware at (601)961-5768. 

### If you would like the electronic copy 

### ofthe emissionunit 

### 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 SupportBranchAppendix L.8.2

STATE 

### OF MISSISSIPPl DAVID RONAWMmMISSIS~XPPI DEPARTMENT OF ENVIRONMENTAL QUALITY wH.-MEcvrrvEWltecroR



### Mr. Joey

### Ward SouthMississippi 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 

### regulationsto 

### improve visual 

### air quality, or visibility, 

### in specified 

### national parks 

### and wilderness areas acrossthecouut~~. Thcsc

### regulationsrequire states 

### to establishpals for improvingvisibility 

### in these 

### areas and to submit state 

### implementation plans 

### {SIPS) that 

### contain enforceablemcaswcs and control 

### stmegk for reducing visibility-impairing pollution.

. One

### component of

### these qplations isto reduce 

### emissions 

### fromcatain,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 ofammonia, nitrogen oxides, particulate matter less 

### that I0microns (PMlo), 

### sulkdioxide, or volatile organic 

### compounds, cithcr individuallyor 

### in combination with 

### other 

### such units; 

### and fall into one of26 listed sourcecategories, including steam 

### electricplants 

### and industrial

### boilas, 

### and large industrial 

### plants such 

### as pulp mills, ~c:fincrics, and 

### smelters. See 

### attached list. 

### The final implementationplan shoul'dbe 

### submitted to 

### EPA by 

### December 3

### 1,2008, and must contain, 

### among other 

### things,the emission limits and compliance scheduies fbreach 

### BART subject source. The first stq

### in this process 

### is to identify 

### all 

### BART subject sources. Mississippi and other southeasternstates 

### and 

### tribeshave fonned a Regional 

### Plauning Organization, known 

### as VISTAS, to work on the 

### regional 

### haze issue 

### and the requirede r-P ru." Appendix L.8.2 d ,J'* 

### implementationplans. It is ourgoal 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 requirementbecause it falls into one ofthe 26 

### source categories, was 

### built prior to August 

### 7,1977, 

### and 

### haspotential 

### emissions greater

### than 250 tons 

### per year for 

### at kast one of

### the visibility-impairing pollutants. However, the information listed below 

### is neededto 

### make 

### a dctcrmination. 

### The initial starhrp date 

### for facility. The initial startup 

### date for individual 

### emission units.
0 

### The dates of 

### any modification

### orreconstruction for individual units. 

### The BART source category

### ofthe 

### emission units. A 

### list of 

### emissionunits obtained 

### hm our files is enclosed. Please enterthe 

### dates of initial start-up and any 

### modification orreconstruction, review and 

### make

### any cormdons to the 

### listed source category, and review 

### and make 

### any corrections to 

### tbepotential 

### emissions. 

### This information is 

### also available 

### inexcel tpdsket

### formatwhich 

### canbe 

### completed and submitted electronically. Please respondby 

### April 19,2002. 

### Ifthis informationisnot received, 

### the facility and all emissionunits at tht facilitywill 

### be considered subjectto 

### the

### BART requirements. However, the 

### finaldeterminationswill 

### not be 

### made until the 

### SIP developmentprocess. 

### 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 ofthe 

### 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 atrUllEsH. CHISOLM. EXKWlWDlReCrOR


### 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 electricplants (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 determinationto be 

### made on 

### a group 

### or collectivebasis; however, it was argued that the 

### Clean Air Act 

### requires this determinationto be 

### made on a source by 

### sourcebasis. 

### 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 be4 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 determinationswill 

### be 

### made over the next several 

### years during the 

### Regional Haze plannhg and our State ImglementationPlan dtvelgrmentprocess. 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 SupportIAppendix L.8.3

STATE OF MI;SSISSIPPl DAVIDRONALDMVSOROM. GOVERNOR 

### Mlssissl~~l DEPARTMENT OF ENVIRONMENTAL QUALI~ CHARLESH. 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) informationrequest. 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 

### (230MMBTU 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 caseby 

### 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 identifiedemission units AA-001 

### and AA-002 

### at 

### the facility 

### to be subject to 

### thisS/; ' 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 additionalcontrols 

### 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 

### applicabledefinitions from 

### the Code 

### of Federal Regulations. Ifyou 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 SOzis converted to SO4 is and the amount is a function of the SOz to SO4conversion 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 SOzto So4conversion 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 SOLJtonSO2 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 168km 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 138km 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



### STATEOF MISSISSIPPI 

### ~~

COVWNOll MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY Tlll~l~D.F~wmExaamvsDascror

October 8,2007 Joey Ward South MS Electric Power Association. P 0Box 15849 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 (1360)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 ofthe BART eligible sources had to be analyzed to determine ifthey were BART subject. Since R D Morrow and Moselle are subject to CAIR, NO, and SO2from 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 1-961-5 176)or Deborah Boleware (60 1-96 1-5768)of my staff. Sincerely,

Maya ~a4 P.E., BCEE Chief, Air Division

OFFICE OF POLLUTIONCONTROL
~nrr n- ~m II-IRQ< ~wucn~ MICCICPI~ 197A9rOUt5 TFI

### - 1~111 (W;1.5171 FAY: (601) 35dMi12 -.dmaermus