### Technical Support Document

for the

Oklahoma Regional Haze State Implementation Plan and Federal

Implementation Plan
(OK TSD)

Prepared and Reviewed by:

Michael Feldman

Joe Kordzi

November 20142 T a b l e of C o nten t s

I. Relationship of this TSD to our Proposal

................................ ................................ ............... 4

A. Summary of Our Previous Action

................................ ................................ ......................... 4

B. Summary of our Proposal

................................ ................................ ................................ ....... 4

II . Background to Regional Haze

................................ ................................ ............................... 5

III. Evaluation of State Submittal

................................ ................................ .............................. 8

A. Establishment of the Reasonable Progress Goals

................................ ................................ 8

A.2. Reasonable Progress Consultation

................................ ................................ ................... 11

A.3. Reasonable Progress “Four Factor” Analysis

................................ ................................ . 20

A.4. Uniform Rate of Progress Determination

................................ ................................ ........ 27

A.5. Additional Analysis of Reasonable Progress Goal

................................ .......................... 29

A.6. Our Evaluation of Oklahoma’s Reasonable Progress Goals for the Wichita

Mountains.

................................ ................................ ................................ ......................... 39

A.7. Reasonable Progress Goal To Be Considered by Administrat or

................................ .. 42

A.8. Reasonable Progress Goal Minimum

................................ ................................ ............... 423 T a b l es

Table 1. Comparison of Reasonable Progress Goals to Uniform Rate of Progress on 20% Worst Days for Oklahoma Class I area

................................ ................................ .......... 9 Table 2. Comparison of Reasonable Progress Goal to Baseline Conditions on Least Impaired Days for Oklahoma Class I area

................................ ................................ ... 10 Table 3. Percent total contribution and point source contribution to total visibility impairment at Wichita Mountains for 2018

................................ ................................ . 17 Table 4. Sulfate controls identified for the Wichita Mountains in the Alpine Geophysics/CENRAP control sensitivity modeling analysis for Texas sources

........ 19

Table 5

- Visibility at Wichita Mountains under CENRAP Control Sensitivity Scenario (Table IX

- 4 of the OK Regional Haze SIP)

................................ ................................ .. 22

Table 6

- Sources ODEQ Considered for Additional Controls Under Reasonable Progress

................................ ................................ ................................ ................................ ........... 22

Table 7

- Comparison of URP to the Reasonable Progress Goal on Most Impaired Days for

the Wichita Mountains

................................ ................................ ................................ ... 28 Table 8. 2002 Projected sources of light extinction at the Wichita Mountains (worst quintile days in) (from Table V

- 8 of the OK Regional Haze SIP)

.............................. 30 Table 9. 2018 Projected sources of light extinction at the Wichita Mountains (worst quintile days) (from Table VIII

- 10 of the OK Regional Haze SIP)

............................ 31 Table 10. 2002 to 2018 Projected reduction in sources of light extinction at the Wichita Mountains (worst quintile days) (fro m Table VIII

- 10 of the OK Regional Haze SIP)

................................ ................................ ................................ ................................ ........... 32 Table 11. Projected light extinction for 20% worst days at the Wichita Mountains in 2002 (Mm

- 1 )

................................ ................................ ................................ ............................... 33 Table 12. Projected light extinction for 20% worst days at the Wichita Mountains in 2018 (Mm

- 1 )

................................ ................................ ................................ ............................... 33 Table 13. Projected sulfurous sources of light extinction at the Wichita Mountains (worst quintile days in 2002) (from Table V

- 1 of the OK Regional Haze SIP)

..................... 34 Table 14. Projected sulfurous sources of light extinction at the Wichita Mountains (worst quintile days in 2018) (from Table VIII

- 3 of the OK Regional Haze SIP)

................ 35 Table 15. 2018 Phase 1 EPA Source Apportionment Modeling Results, Top Ten Modeled Facilities in Texas that Impact Visib ility at Wichita Mountains

................................ 42

F ig u r es

Figure 1. Map of Class I Areas

................................ ................................ ................................ .... 5 Figure 2. Location of the Class I Area in Oklahoma

................................ ................................ . 6 Figure 3. Map of Regional Planning Organization Boundaries

................................ ............... 7 Figure 4. Glide Path and Reasonable Progress Goal at Wichita Mountains (20% Worst

Days)

................................ ................................ ................................ .............................. 9 Figure 5. Percent of total extinction in 2018 at Wichita Mountains (CENRAP PSAT

modeling results, 2007)

................................ ................................ .............................. 16 Figure 6. Percent of total extinction in 2018 at Wichita Mountains due to point sources

only (CENRAP PSAT modeling results, 2007)

................................ ........................ 164 Oklahoma Regional Haze Technical Support Document (TSD)

I. Relationship of this TSD to our Proposal

A. Summary of Our Previous Action

In a previous rulemaking, we partially approved and partially disapproved portions of the Oklahoma regional haze State Implem entation Plan ( SIP )

. 1 We approved certain core elements

of the Oklahoma Regional Haze SIP , including Oklahoma’s: identification of sources that are BART eligible and subject to BART; its determination of baseline and natural visibility conditions; its coordination of regional haze and RAVI; monitoring strategy and other implementation requirements; its coordination with States and federal land managers; and a number of the State’s NOx, SO 2 , and PM BART determinations. We disapproved Oklahoma’s

submitte d SO 2 BART determinations for Units 4 and 5 of the OG&E Muskogee plant; Units 1 and 2 of the OG&E Sooner plant; and Units 3 and 4 of the AEP/PSO Northeastern plant . We also disapproved the long

- term strategy in Oklahoma’s Regional Haze SIP because it fail ed to include appropriate controls for these six sources. To remedy these deficiencies in the Oklahoma Regional Haze SIP , we concurrently promulgated a Federal Implementation Plan ( FIP ) that

established SO 2 BART emission limits for these six sources in Ok lahoma. We have subsequently replaced our FIP for two of the sources with approval of Oklahoma’s SIP revision

BART determinations for those two sources. 2 We did not take action on whether Oklahoma satisfied the reasonable progress requirements of Section 51.308(d)(1). In our proposed action, we stated that to properly assess whether Oklahoma had satisfied these requirements, we must first evaluate and act upon the Regional Haze SIP revision submitted by the State of Texas. 3 Our proposed action here is l imited to our review of Oklahoma’s submission under Section 51.308(d)(1).

B. Summary of our Proposal

Section 51.308(d)(1) requires that in establishing its Reasonable Progress Goal ( RPG ) , a State must perform a number of tasks that are outlined in sec tions 51.308(d)(1)(i)(A)

- (B), 51.308(d)(1)(ii), and 51.308(d)(1)(iv)

- (vi). These requirements are not severable from the approval of the state’s RPGs

– they are all inter dependent and must all be approvable in order that that state’s RPG can be approved. As we discuss above, we are proposing to disapprove all of these requirements except for section 51.308(d)(1)(vi). Therefore, we must propose to disapprove Oklahoma’s RPG under section 51.308(d)(1).

This TSD is not meant to be a complete rationale for our decision. It merely provides additional information for some of the technical aspects of the basis for this action when needed. In some

of the non

- technical areas, our Federal Register notice provi des more detail than does this TSD.

1 Final action: 76 FR 81728 ( December 28, 2011) . Proposal: 76 FR 16188 (March 22, 2011).

2 Approval of OK’s partial replacement for FIP: 79 FR 12944 (March 7, 2014). Partial FIP withdrawal: 79 FR 12954 (March 7, 2014).

3 76 FR 16 177 (Mar. 22, 2011)

.5

Also, this TSD attempts to refer the reader to the specific portions of the Oklahoma’s Regional

Haze SIP that we relied upon for our analysis of particular portions of section 51.308.

Throughout this document, we often use language such as, “we find” or other similar phrases that on the surface would suggest a final determination has been made. However, all aspects of our TSD should be considered to be part of our proposal and are subject to change based on

comments an d other information we may receive during our public comment period.

II. Background to Regional Haze

In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress set forth a program for protecting visibility in Federal Class I areas which calls for the “prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Federal Class I areas which impairment results from manmade air pollution.” Congress adopted the visibility provisions to protect visibility in 156 Federal Class I areas, which include certain national parks, memorial parks, and wilderness areas over a certain size, and all international parks. These areas are defined at 40 CFR 81.400, are listed by State at 40 CFR 81.401

- 81.437, and are depi cted in Figure 1, with the Class I area within Oklahoma, the Wichita Mountains National Wildlife Refuge, depicted in Figure 2:

Figure 1 . Map of Class I Areas6 Figure 2 . Location of the Class I Area in O klahoma

On December 2, 1980, we promulgated regulations to address visibility impairment that is “reasonably attributable” to a single source or small group of sources. (45 FR 80084) These regulations represented the first phase in addressing visibility impairment and deferred action on regional haze that emanates from a variety of sources until monitoring, modeling and scientific knowledge about the relationships between pollutants and visibility impairment improved.

In the 1990 Amendments to the CAA, Congress added Section 169B and called on us to issue Regional Haze R ules. The Regional Haze R ule that we promulgated on July 1, 1999 (64 FR 35713) revised the existing visibility regulations to integrate provisions addressing regional haze visibility imp airment and establish a comprehensive visibility protection program for Federal Class I areas. These regulations represented the second phase in addressing visibility impairment. States were required to submit SIPs to us that set out each state’s plan fo r complying with the Regional Haze Rule , including consultation and coordination with other states and with Federal Land Managers (FLMs). States were required to submit a Regional Haze SIP to us within three years after the date of designation of areas un der the National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM2.5). We promulgated PM2.5 designations on December 17, 2004, and thus, regional haze SIPs were to be submitted to us by December 17, 2007, which is also specified at 40 CFR 51.308(b).

The Regional Haze Rule addressed the combined visibility effects of various pollution sources over a wide geographic region. Consequently, all 50 states, including those without Class I areas, Washington, D.C., and the Virgin Islands, were required to submit Regional Haze SIPs (40 CFR 51.300(b)(3)). We designated five Regional Planning Organizations (RPOs) to assist with the coordination and cooperation needed to address the visibility issue, as shown by Figure 3.7 Figure 3 . Map of Regional Planning O rganization Boundaries

Oklahoma, through the ODEQ joined State clean air agencies from Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, Nebraska, and Texas in forming CENRAP, in 1999. CENRAP also includes federally recognized Indian tribes located within the geographic boundaries of its member states. The State of Oklahoma Department of Environmental Quality chose to participate in CENRAP to develop the technical analyses needed to fulfill the requirements of the Regional Haze Rule

.8

III. Evaluation of Oklahoma’s Submittal

In evaluating the Oklahoma Regional Haze SIP , we reviewed all the parts of the document, including the body of the SIP itself, and all appendices. In addition, we drew upon the following

additional documents that may not have been specifically discussed in our TSD and/or the Federal Register publication(s) of our decision:

1. 40 CFR Part 51.

2. Appendix V to 40 CFR Part 51.

3. The “BART Guidelines” in Appendix Y to Part 51

— Guidelines for BART Determinations Under the Regio nal Haze Rule, 70 FR 39104, July 6, 2005.

4. Guidance for Tracking Progress Under the Regional Haze Rule, EPA

- 454/B

- 03

- 004, September, 2003.

5. Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and Regional Haze, January 2, 2001.

6. Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule,

EPA

- 454/B

- 03

- 005, September 2003.

7. The “Baseline Memo,” which is entitled, “2002 Base Year Emission Inventory SIP Planning: 8

- Hour Ozone, PM2.5 and Regional Haze Programs, dated 11/18/20 02, from Lydia Wegman to the Regional Air Directors.”

8. Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, dated June 1, 2007.

9. Visibility Monitoring Guidance, EPA

- 454/R

- 99

- 003, June 1999.

10. Emissions Inventory Guidance for Implemen tation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations,

EPA

- 454/R

- 05

- 001, dated August, 2005.

11. Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998.

A

. Establishment of th e Reasonable Progress Goals

For each mandatory Class I Federal area located within the S tate, Oklahoma must establish goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility

conditions. The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the SIP and ensure no degradation in visibility for the least impaired days over the same period.

State Submittal : Pages 104

- 117

CENRAP model ing projected visibility conditions anticipated at the Wichita Mountains in 2018.

This was b ased on the emissions reductions resulting from federal and State control programs that are either currently in effect or with mandated future

- year emission reduction schedules that predate 2018 . This included the Long

- Term Strategies ( LTSs ) of Oklahoma, Texas, and other states, and presumptive emissions reductions expected to result from the submitted Oklahoma

BART rule

. CENRAP’s projections for 20 18 for the 20% worst and best days for the Wichita

Mountains

, which the ODEQ used in developing its RPGs for the Wichita Mountains, are shown9

in Appendix D to the document titled “ Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support Regional Haze State Implementation Plans.” 4

Based on the results of the reasonable progress four

- factor analysis (desc ribed in the following section)

, the results of the CENRAP modeling, and additional information developed by

CENRAP or obtained through direct consultations with States anticipated to impact visibility at Wichita Mountains, the O DEQ decided to adopt the CENRAP modeled 2018 v isibility

conditions as the RPG s for the Wichita Mountains Class I area. The O DEQ established a RPG

of 21.47 dv for the Wichita Mountains for 2018 for the 20% worst days. This represents a 2.3 dv improvement in visibility over a baseline of 23.81 dv. It calculated that under its RPGs, it would attain natural visibility cond itions in 2102 at the Wichit a Mountains

. The O DEQ’s RPG for the

20% worst days is shown on Table 1 below , which is adapted from Tables IX

- 3 and IX

- 4 of the

Oklahoma Regional Haze SIP , and Figure 4, which is Figure IX

- 1 of the OK Regional Haze SIP

.

Table 1. Comparison of Reasonable Progress Goals to Uniform Rate of Progress on 20%

Worst Days for Oklahoma Class I area

Oklahoma

Class I A r ea Baseline

Conditions (dv) Projected

2018 Visibility (RPG) (dv) I m prove m ent Projected by

2018 using

RPG (dv) Date

Natural Visibility

Attained at
RPG Rate 2018 URP

Goal (dv) I m prove m ent

b y 2 0 1 8

at URP (dv)

Wichita

Mountains 23.81 21.47 2.33 21 02 20.01 3.80

Figure 4

. Glide Path and Reasonable Progress Goal at Wichita Mountains (20% Worst Days)

4 The TSD for CENRAP Emissions and Air Quality Modeling to Support R egional H aze State Implementation is found in Appendix 4

- 2 of the Oklahoma Regional Haze SIP.10

CENRAP’s projections for 2018 for the 20% best days for the Wichita Mountains , which

represent O DEQ’s RPGs for the 20% best days, are shown in Table IX

- 2 of the Regional Haze

SIP and in Appendix D to the TSD for CENRAP Emissions and Air Quality Modeling to Support R egional H aze State Implementation. 5 O DEQ’s RPGs for the 20% best days (CENRAP projection) are shown on Table 2 below , which is adapted from Table IX

- 2 of the Oklahoma Regional Haze SIP

.

Table 2. Comparison of Reasonable Progress Goal to Baseline Conditions on Least

Impaired Days for Oklahoma Class I area

Oklahoma Class I

Area Visibility Conditions on 20% Best Days (dv)
Achieved “No Degradation” (Y/N) Average for 20% Best Days (Baseline 2000

- 2004) RPG

(CENRAP Projection)

Wichita Mountains 9.78 9.23 Y

EPA Findings :

5 The TSD for CENRAP Emissions and Air Quality Modeling to Support R egional H aze State Implementation is

found in Appendix 4

- 2 of the Oklahoma Regional Haze SIP.11

The vehicle for ensuring continuing progress towards achieving the natural visibility goal is the

submission of a series of Regional Haze SIP s from the states that establish two RPGs (i.e., two distinct goals, one for the “best” and one for the “worst” days) for every Class I area for each implementation period. 6 See A ppendix A of the TSD of our previous action on Oklahoma Regional Haze 7 for our review of the CENRAP emission inventory and modeling that was relied

u pon in establishing the RPG for Wichita Mountain.

Figure D

- 8b of Appendix D to the TSD for CENRAP Emissions and Air Quality Modeling to Support Regional Haze SIPs

, and Table 2 above

, demonstrate that the modeled R PG for the 20% best days show s an improvement in visibility of 0.54 dv at the Wichita Mountains in 2018. The

O DEQ also submitted a RPG for the Wichita Mountains for the 20% worst days , as shown in

Table 1 above. Table 1 demonstrates that the modeled RPG for the 20% worst days shows an

im provement in visibility of 2.33 dv at the Wichita Mountains in 2018. ODEQ’s RPGs for the Wichita Mountains are consistent with the requirement that the y provide for an improvement in visibility for the most impaired days over the period of the SIP and ens ure no degradation in visibility for the least impaired days over the same period.

However, for the reasons discussed below , w e are propos ing to disapprove Oklahoma’s RPG for

the Wichita Mountains. First, in our earlier action on the Oklahoma Regional Haze SIP , we disapproved the SO 2 BART determinations for six EGUs at three power plants in Oklahoma and promulgated a FIP setting more stringent SO 2 emission limits for these EGUs. 8 Although we subsequently approved a SIP revision from Oklahoma addressing the BART requirements at one power plant, 9 and removed the FIP requirements for this facility, 10 our FIP and the revised Oklahoma SIP require greater reductions overall in emissions of SO 2 than was assumed in setting

the RPGs for the Wichita Mountains. Second, we are proposing to disapprove Oklahoma’s RPGs for the Wichita Mountains because they were based on an incomplete consultation with Texas under 51.308(d) (1)(iv) that resulted in inadequate reasonable progress towards the national visibility goal. For these reasons, the RPGs for Wichita Mountains do not reflect the degree of visibility improvement anticipated from these measures.

A .2. Reasonable Progress Consultation

In developing the RPGs for its Class I area, Oklahoma was required to consult with those States which may reasonably be anticipated to cause or contribute to visibility impairment at the

Wichita Mountains. 11 In any situation in which Oklahoma could not agree with another such State or group of States that a goal provides for reason able progress, Oklahoma was required to describe in its submittal the actions taken to resolve the disagreement. In reviewing Oklahoma’s SIP submittal, the Administrator takes this information into account in determining whether

6 See 70 FR 3915 and 64 FR 35714

. 7 Technical Support Document for the Oklahoma Regional Haze State Implementation Plan and Federal Implementation Plan, March 2011, Appendix A.

8 76 FR 81728 (Dec. 28, 2011)

. 9 79 FR 12944 (March 7, 2014).

10 79 FR 12954 (March 7, 2014).

11 Section 51.3 08(d)(1)(iv).12

Oklahoma’s goal for visibi lity improvement provides for reasonable progress towards natural visibility conditions.

State Submittal: Pages 115

- 117 , Appendix 10

- 1

The ODEQ identified several States that were projected through visibility modeling to contribute

more than 1 Mm

- 1 of light extinction at the Wichita Mountains in 2018 and invited these States

to consult. It conducted four consultations. 12 It directed its first consultation to the tribal leaders in Oklahoma and their environmental managers, on August 14, 2007. The O DEQ held the next three consultations as conference calls with representatives from CENRAP, EPA, the U.S. Fish and Wildlife Service, Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, Nebraska, and

Texas. 13 The ODEQ received written responses from the Arkansas Department of Environmental Quality, the TCEQ, and the Missouri Department of Natural Resources. 14 The ODEQ sent a letter to the Iowa Department of Natural Resources as a follow up to the

consultation calls for the Wichita Mountains. Below is a summary of Oklahoma’s consultations.

For the first call with the States, held on August 16, 2007, the ODEQ discussed the current modeling results, comparing the projected visibility conditions in 2018 to the 2018 URP goal. 15
The ODEQ identified that the Wichita Mountains is projected in the 2108 CENRAP modeling to be 1.5 dv short of its 3.8 dv reduction needed to meet the URP. It also discussed the primary anticipated causes of regional haze for the Wichita Mountains in 2018, based on modeling and

monit ored data. According to the ODEQ, high SO 2 concentrations at the Wichita Mountains reflect long range transport from Texas and the eastern two

- thirds of United States. The ODEQ identified that point sources are the most significant contributors to haze a t the Wichita Mountains based on the source apportionment results from the CENRAP modeling, with the largest contributing point sources being Texas EGUs.

The ODEQ used the AOI data developed for the Alpine Geophysics report and considered the

PSAT model ing results to identify areas, pollutants and source types that contribute to visibility impairment at the Wichita Mountains. The ODEQ identified that SO 2 emissions that impact visibility conditions at the Wichita Mountains generally originate from the so uth and east. The ODEQ identified sources within the Area of Influence of the Wichita Mountains with a ratio of

annual emissions of NOx or SO 2 to distance (Q/D) greater than 5 based on 2018 projected emissions. The ODEQ then used the Alpine Geophysics re port developed for CENRAP (as

described in more detail in our TX TSD ) to identify estimates of the costs of installing retrofit

controls for these sources. The ODEQ applied a maximum cost threshold of $5,000/ton to the list of potential controls to elimin ate controls that it considered too costly from additional analysis. The remaining sources were listed in the charts provided to the participants in the

12 Copies of agendas and presentation materials are available in the docket for this action and at http://www.deq.state.ok.us/AQDnew/rulesandplanning/Regional_Haze/SIP/Consultation/index.htm

13 These calls were recorded, referenced in OK’s regional haze SIP, and placed on ODEQ’s website.

14 Copies of these letters can be found in Appendix 10

- 1 of the Oklahoma regional haze SIP.

15 A copy of the presentation containing the information discussed by ODEQ is available in the docket for this act ion

and at: http://www.deq.state.ok.us/AQDnew/rulesandplanning/Regional_Haze/RegionalHazeStatesConsultation1_081607.p

pt13

consultation process. 16 For these sources, the ODEQ requested that the participating States provide an y available information or comments relative to which listed sources are BART sources, planned expansions or installation of controls, feasibility of controls, cost of controls, and any modeling conducted that would indicate the sources’ levels of impact o n the Wichita Mountains. It stated that it was not yet requesting reductions, but was merely soliciting

additional information.

For the August 30, 2007 meeting, the ODEQ focused on the method used to calculate natural

conditions at the Wichita Mountains. The ODEQ also reviewed and discussed information it had received following its request for information regarding the sources of interest that it had identified. ODEQ also noted that it had received information from Arkansas, Iowa, Kansas, Louisiana, and Nebraska after the first call but that it still needed information from Texas, Missouri, and Minnesota. Texas indicated that although it had contacted its EGUs, none had provided information as to how they intended to comply with CAIR. Texas stated that it had not received any enforceable commitments for controls from any of its EGUs. For other listed Texas sources, TCEQ said it was seeing significant decreases in emissions from controls or programs that were already in place. According to Texas, in ge neral, growth assumptions for non

- EGU Texas sources were wrong. Total emissions for Texas point sources, it claimed, were steadily declining in spite of great economic growth. Louisiana stated that one of it sources, Rhodia, was

under a Consent Decree an d reducing its emissions. Minnesota and Missouri also offered to provide some additional information to Oklahoma regarding their sources.

For the third and final consultation meeting on September 25, 2007, the ODEQ again followed up on the information request regarding the sources of interest that it had identified. Texas stated that there were no changes to its EGUs projections since very few of its EGUs had committed to controls in order to meet CAIR. Texas again stated that Texas point source 2018 projections were unrealistic and that Texas point source emissions have historically been dropping even when the State has been growing substantially economically. The ODEQ stated that SO 2 is 60% of the particulate issue with most of it coming from Texas, Louisiana, and other States all the way out to the east coast. The ODEQ finished the consultation call with a statement that it was considering the information provided from consultation and was using it in drafting its Regional

Haze SIP

.

During the c onsultation process, Arkansas notified the ODEQ that it disagreed that its sources contribute significantly to visibility impairment at the Wichita Mountains. Missouri similarly informed the ODEQ that it considered current controls on Missouri sources to be sufficient. Later, the ODEQ also concluded based on modeled projections that Iowa would not contribute to visibility impairment at the Wichita Mountains in 2018 and informed Iowa that additional reductions were no longer requested.

During the consulta tion process, Oklahoma and Texas exchanged letters regarding the Wichita Mountains. On August 3, 2007, the ODEQ sent a letter to the TCEQ in which it noted that

16 A spreadsheet with the list of potential controls shared with the States is available in the docket for this action and

at: http://www .deq.state.ok.us/AQDnew/rulesandplanning/Regional_Haze/RegionalHazeStatesConsultation1_081607_ ControlAssumptions.xls14

despite significant planned reductions in SO 2 and NOx emissions from sources in Oklahoma and

T exas, the Wichita Mountains was not projected to meet the URP. The ODEQ further noted that the analyses by CENRAP had made clear that the Wichita Mountains suffer from significant anthropogenic impacts from Texas. The ODEQ requested that the TCEQ require new and modified PSD sources to conduct analyses of their impacts on visibility at the Wichita Mountains and that the ODEQ be given an opportunity to review and comment on BACT determinations for proposed projects likely to have a certain impact on visibi lity at the Wichita Mountains. In addition, the ODEQ requested that the evaluations of visibility impacts be extended from within

100 km of the Wichita Mountains to within 300 km of the Wichita Mountains in deference to FLM guidance. On October 15, 2007, the TCEQ sent a response to the ODEQ, agreeing that modeling showed emissions from Texas to be a significant source of visibility impairment at the Wichita Mountains. The TCEQ also noted, however, that significant reductions from Texas will

be realized i n the next several years. In response to the ODEQ’s specific request for the opportunity to comment on BACT for new and modified major sources, the TCEQ stated that it welcomed comment during the public review and comment period and would notify federal l and managers and the ODEQ if modeling were to indicate that a proposed source might significantly impact the Wichita Mountains. In response to the ODEQ’s request that impact evaluations be extended to 300 km, the TCEQ stated that it was working with feder al land managers on mutually acceptable criteria for determining when a proposed PSD source should conduct a Class I area review and would inform ODEQ on the outcome of these discussions. In addition, the TCEQ attached its draft RPG analysis for its two C lass I areas, which included analyses the TCEQ used to determine that there are no reasonable costs of installing additional controls beyond CAIR to address Texas impacts at Big Bend National Park and the Guadalupe

Mountains.

Several months after this i nitial exchange of letter, the two States again exchanged letters. On March 25, 2008, following comments made by us and the federal land managers on Texas’ draft Regional Haze SIP , the TCEQ sent a letter to the ODEQ regarding emissions that affect the Wichita Mountains. The TCEQ provided a copy of the PSAT modeling results developed by CENRAP indicating the contribution for each source area to visibility impairment at the Wichita Mountains. The TCEQ stated in the letter that PSAT modeling indicated that the probable impacts of Texas sources at the Wichita Mountains will be reduced by 2018 due to expected emission reductions from current and planned controls. A list of sources tha t are within the area of interest and have an emissions over distance ratio equal to or greater than five (Q/D > 5) was included with the letter, along with information on projected emissions and distance to Wichita Mountains for those sources. The TCEQ th en requested concurrence from Oklahoma on this assessment and a verification that Oklahoma was not depending on any additional reductions from Texas sources in order to meet RPG for the Wichita Mountains. On May 12, 2008, the ODEQ sent a response to the T CEQ in which it noted that it concurred with the information the TCEQ had provided. The ODEQ stated that it had developed its RPG for the worst 20% days for the Wichita Mountains through the CENRAP deliberations and that its RPG did not anticipate

emissio n reductions beyond those that Texas already planned to implement and upon which CENRAP modeling studies have relied. The letter also states that reaching the Wichita Mountains’ RPG requires constraints on emissions from new, modified, and existing source s. The letter then recaps the ODEQ’s initial request made in its August 3, 2007 consultation letter that all sources within 300 km conduct an analyses of the impacts to the Wichita Mountains and15

that it be given the opportunity to comment on BACT for prop osed sources projected to significantly contribute to visibility impairment at the Wichita Mountains.

EPA Findings:

We reviewed the information developed by the ODEQ and the participating States during the consultation process, as well as the CENRAP source apportionment modeling results and additional data developed by CENRAP and Alpine Geophysics. We propose to agree with the following conclusions made by the ODEQ in its consultations:

With all the reductions anticipated to occur in the contributing States, the CENRAP modeling projects that the Wichita Mountains will fall short of meeting the URP goal for this planning period.

In consultation, ODEQ did not ask for additional controls for NOx sources. We agree with ODEQ’s treatment of NOx sources for this planning period since NOx is not the predominant cause at the Wichita Mountains in 2002 or 2018. ODEQ presented information about source apportionment modeling results indicating the impact of a state’s emissions and add

- on SO 2

contro ls for sources in Arkansas, Iowa, Louisiana, Missouri, Oklahoma and Texas as estimated for the Alpine Geophysics report. These sources lie within the AOI of Wichita Mountains, have

a Q/D greater than 5 and have controls estimated to be less than $5000/ton . This data 17 served as a starting point for discussions of potential reductions, visibility impacts, and the potential for visibility improvements from controls

.

Texas is a significant contributor to the visibility impairment at the Wichita Mountains . P oint sources are the most significant contributors to haze at the Wichita Mountains, and the largest contributing point sources are Texas EGUs. Figure 5 below shows the CENRAP source apportionment modeling results 18 in terms of the percent of the total vis ibility impairment projected for 2018 at the Wichita Mountains. Figure 6 shows the percent of the total visibility impairment from point sources alone. 19 Table 3 summarizes the percent of visibility impairment

at the Wichita Mountains from Oklahoma and ne arby states. Texas (all sources and pollutants) is projected to contribute 27.5% of the visibility impairment at the Wichita Mountains, compared to 16.3% for Oklahoma sources, 4.8% from Louisiana sources and 4.2% from sources in the

Eastern U.S. Point so urces in Texas are projected to account for 14% of all visibility impairment projected in 2018 at Wichita Mountains, compared to 3.9% from Oklahoma point sources, 3.4% from Louisiana point sources and 3.2% from point sources in the Eastern U.S. As discuss ed above, these model results include estimated reductions due to the implementation of CAIR,

other on

- the

- book federal and State rules, and some assumptions for BART reductions in Oklahoma and other states. Extinction due to point source SO 2 emissions in Texas (7.83 Mm

- 1) is almost 3.5 times larger than the next largest contribution from point source SO 2 emissions (2.27 Mm

- 1 from point sources in the Eastern U.S.). Extinction due to point source SO 2

17 Ref the ODEQ consultation spreadsheet.

18 CENRAP model results are from the CENRAP PSAT tool developed by ENVIRON for CENRAP available as
CENRAP_PSAT_Tool_ENVIRON_AUG27_2007.mdb

19 We note that this calculation does not include Rayleigh scattering.16

emissions in Louisiana (2.16 Mm

- 1), Oklaho ma (1.23 Mm

- 1) and Missouri (1 Mm

- 1) are smaller

still.

Figure 5. Percent of total extinction in 2018 at Wichita Mountains (CENRAP PSAT modeling results, 2007)

Figure 6. Percent of total extinction in 2018 at Wichita Mountains due to point sources

o nly (CENRAP PSAT modeling results, 2007)17

Table 3. Percent total contribution and point source contribution to total visibility

impairment at Wichita Mountains for 2018

TX OK LA KS AR MO Eastern

U. S. Total Impairment, All Source Categories, All Pollutants 27.5% 16.3% 4.8% 3.8% 2.3% 2.8% 4.2%

Total Impairment, Point Sources Only, All Pollutants 14.0% 3.9% 3.4% 1.4% 1.3% 1.7% 3.2%

In response to the information and analysis provided by ODEQ and ODEQ’s request for comment on the information provided, Arkansas sent a response letter disagreeing with ODEQ’s analysis that Arkansas’ sources contribute significantly to Oklahoma’s ability to achieve reasonable progress for WM. Arkansas also provided additional information indicating that

additional reductions were anticipated at large point sources in the State due to implementation of BART. ODEQ did not ask for additional SO 2 controls fr om Arkansas sources

. Given the relatively small projected contribution from all Arkansas sources and point source SO 2 emissions when compared to other contributing regions, we believe this to be reasonable for this planning period.18

ODEQ initially invit ed Iowa to consult and shared information on potential add

- on controls within the AOI of Wichita Mountains with costs estimated in the Alpine Geophysics repot. After further consideration of the source apportionment results, ODEQ sent Iowa a letter after the consultation calls stating that they did not require additional controls from Iowa. We find that ODEQ not requiring additional controls for Iowa sources to be reasonable because Iowa sources as a whole contribute less than 1% to the total visibility i mpairment at Wichita Mountains and point source SO 2 emissions contribute only 0.48 Mm

- 1 to the total extinction. These

contributions are small when compared to other contributing regions and the anticipated benefit from controlling any specific source would represent only a fraction of this contribution.

During the consultation call, Louisiana provided additional information on those sources with

c ost

- effective add

- on controls as identified by ODEQ from data in the Alpine Geophysics report.

Louisiana identified that Rhodia is under a federal consen t decree. ODEQ did not ask Louisiana for additional controls to address visibility impairment at Wich ita Mountains. As discussed

below and in the FIP TSD , our additional analysis confirms that impacts from sources in Texas are much larger than anticipated impacts from individual sources in Louisiana. Combined impacts from four units at two EGU facilitie s in Texas (Montic ello and Big Brown) are

estima ted to be larger than impacts from all Louisiana point sources combined.

During the consultation calls, Missouri stated that the cost numbers were not accurate for the Missouri sources identified by ODEQ a nd sent in amended cost numbers. In addition, Missouri sent a letter stating that for Missouri sources, current controls are sufficient to achieve targets in Missouri and Arkansas class I areas. Therefore, Missouri stated that it is intuitive that additi onal

control s are also sufficient for W ichita Mountains which is further away (200

- 250 miles from Missouri). In addition, under RACT, it plans to install controls for large SO 2 sources. In addition, Missouri stated that its impacts on haze for W ichita Mo untains are not of similar level

to east Texas as shown by the CENRAP source apportionment results . ODEQ reviewed Missouri’s information provided and did not ask Missouri to install additional control in the first planning period to address visibility imp airment at Wichita Mountains. We find this to be reasonable. Given the relatively small contribution to extinction from all point source emissions

of SO 2 (1 Mm

- 1), additional anticipated reductions under RACT, and that impacts from these

sources are add ressed when evaluating the impacts to other Class I areas closer to these sources, we find it reasonable for ODEQ to not ask for additional controls at this time.

During the consultations, Oklahoma identified Texas sources that had large emission s located near the Wichita Mountains. Both the ODEQ and the TCEQ shared lists of specific facilities that were identified to be of interest with respect to visibility at Wichita Mountains due to their size and location. Oklahoma used the Alpine Geophysic s study estimates of the cost

- effectiveness of

add

- on controls at some of these facilities (shown in table 4 below) and the ODEQ specifically requested additional information on feasibility and cost of controls for those facilities with

estimated controls less than $5,000/ton. The cost effectiveness for a ll of the point sources identified by Oklahoma except one was below $3,000/ton. The cost effectiveness values of less than $3,000/ton for 8 of the 9 Texas sources identified by Oklahoma are within the ran ge of cost effectiveness values that Oklahoma, other states, and we have considered reasonable for installing controls in the BART and RPG evaluations. In addition, the cost effectiveness values19

for all but two of the Texas sources identified by Oklahoma are below $2700/ton threshold Texas used in the development of its reasonable progress and LTS.

Table 4. Sulfate controls identified for the Wichita Mountains in the Alpine Geophysics/CENRAP control sensitivity modeling analysis for Texas sources

Pla nt Name and Unit Source Type for

Control Control

Measure Tons

Reduced CE

(%) Annualized

Cost ($2005) $/Ton

Reduced

SOMMERS DEELY

SPRUCE PWR 1 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 9,752.2 90 25,000,104 2

, 564

SOMMERS DEELY

SPRUCE PWR 2 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 9,592.6 90 25,000,104 2

, 606

BIG BROWN 1 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 20,827.7 90 32,766,310 1

, 573

BIG BROWN 2 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 21,276.5 90 32,766,310 1

, 540

COLETO CREEK

PLANT 1 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 14,486.3 90 36,014,449 2

, 486

HOUSTON PLANT Sulfuric Acid Plants

- Contact Absorber (98% Conversion) Increase %

Conversion to

Meet NSPS (99.7) 3,486.3 85 670,008 192

HOUSTON PLANT Sulfuric Acid Plants

- Contact Absorber (98% Conversion) Increase %

Conversion to

Meet NSPS (99.7) 5,954.0 85 2,510,927 422

DEER PARK PLANT Petroleum Industry FGD 4,941.7 90 8,474,217 1,715

COMO PLT (Shut Down) Petroleum Industry FGD 3,231.4 90 6,865,014 2,124

STREETMAN

PLANT Mineral Products Industry FGD 2,443.2 50 9,903,980 4,054

MONTICELLO STM

ELE STN 1 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 17,230.0 90 32,196,462 1,869

MONTICELLO STM

ELE STN 2 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 17,725.5 90 32,196,462 1,816

WELSH POWER

PLANT 1 Utility Boilers

- Medium Sulfur

Content FGD Wet

Scrubber 10,548.9 90 30,088,020 2,852

During the consultation calls for the Wichita Mountains, Texas stated that the Texas EGUs cost

numbers for the six EGUs included in the above table are accurate and that most of the facilities under CAIR were not going to install additional cost controls.20

For this planning period, we propose to find that Oklahoma reasonably determined that

additional SO 2 reductions from Arkansas, Louisiana, Missouri, and Iowa were not necessary for reasonable progress. This proposed determination is based, in part, on o ur review of the CENRAP modelling showing the projected impact from sources in these States and the relative

contributions from SO 2 point sources in these States.

We agree with the ODEQ’s approach for identifying those States with sources that may impact visibility at the Wichita Mountains and its decision to invite those States to consult. Through the consultation process, the ODEQ was able to gain additional info rmation regarding the potential impacts from nearby States. We do not agree, however, with the ODEQ’s approach to consultation to address impacts from emissions from Texas. At the time that Oklahoma was developing its SIP, it had (1) abundant informatio n showing the impact of Texas sources on visibility at the Wichita Mountains, particularly from EGU sources in northeast Texas, and (2)

evidence that cost

- effective controls on these sources were likely available. Despite this information, the ODEQ neit her requested that the TCEQ further investigate controls at these sources nor did it request additional reductions from Texas sources to address the impacts of emissions from these sources at the Wichita Mountains. The Regional Haze Rule requires States

t o use the consultation process under Sections 51.308(d)(1)(iv) in the development of RPGs to ensure that all States, including downwind States, take a hard look at what measures are necessary for ensuring reasonable progress towards improving and maintain ing visibility at Class I areas. Lacking development of critical information during its consultations with Texas, we believe that Oklahoma did not have adequate information to reasonably establish its RPG for the Wichita Mountains, and, as explained belo w, should have requested that the TCEQ further investigate these sources or requested additional reductions from Texas sources to ensure that all reasonable measures to improve visibility were included in Texas’ LTS and incorporated into

Oklahoma’s RPG for the Wichita Mountains.

A.3

. Reasonable Progress “ Four Factor ” Analysis

In establishing RPGs for a Class I area, Oklahoma is required by CAA §169A(g)(1) and Section 51.308(d)(1)(i)(A) to “[c]onsider the costs of compliance, the time necessary for compliance, the energy and non

- air quality environmental impacts of compliance, and the remaining useful life of any potentially affected sources, and include a demonstratio n showing how these factors were taken into consideration in selecting the goal.”

State Submittal: Pages 107

- 114 , Appendix 4

- 2

The ODEQ analyzed the largest sources of visibility impairing pollutants within Oklahoma

, including sources of sulfur, nitrates, ammonia, VOCs, and directly emitted coarse and fine particles. T he ODEQ calculated that sulfurous pollutants contribute approximately 44% and nitrate bearing pollutants contribute approximately 21% of the total lig ht extinction (or visibility impairment) to the Wichita Mountains

. The ODEQ also calculated that sources from all source categories combined within Oklahoma contribute only approximately 13% of the total pollutants that contribute to light extinction at t he Wichita Mountains in the 2002 modeled base year

.21

To evaluate any additional control measures necessary to demonstrate reasonable progress, t he ODEQ initially relied on a study commissioned by CENRAP

. CENRAP contracted with Alpine Geophysics to conduct an evaluation of possible additional point

- source controls for CENRAP

states for 2018 20 . CENRAP did not consider additional controls outside the borders of its member states in the Alpine Geophysics evaluation. The evaluation relied on AirContr olNet, 21 a database tool released by us in 2006 to enable cost

- benefit analyses of potential add

- on emissions control measures and strategies. Alpi ne Geophysics prepared cost estimates for NOx and SO 2 reductions in 2005 dollars for point sources in CENRAP states

. Alpine Geophysics and the CENRAP analysis included the following:

 The remaining useful life of a source affects the annualized costs of retrofit controls and

was included in the methods used for calculating annualized costs in the control cost

eq uations modified from EPA’s AirControlNet

. Average retirement rates were applied to control technologies within the control analysis equations and source

- specific retirement information (if available) was included in the CENRAP emission projections. Sinc e AirControlNET’s control cost equations take into consideration the useful remaining life of installed equipment and estimate the costs of compliance with these measures, two of the four reasonable progress goal considerations for these sources are addres sed.

 The Iowa Department of Natural Resources and Kansas Department of Health and

Environment staff added area

- of

- influence (AOI) data and distance calculations to each Class I area in every CENRAP member state.

 The Alpine Geophysics report also relies on a suite of early photochemical modeling sensitivity runs to estimate a sensitivity factor for each Class I area’s area of influence in the form of pollutant concentration reduced per ton per day precursor emissions reduced.

CENRAP then developed a modeling scenario to estimate the effectiveness of a specific suite of controls on facilities in the CENRAP states based on the identified potential add

- on controls and cost information developed by Alpine Geophysics. CENRAP decide d to base its control sensitivity analysis on a maximum estimated cost of $5,000 per ton of emissions of NOx or SO 2. It also evaluated only those point sources predicted to emit 100 tons or more of SO 2 or NOx in the year 2018. CENRAP further refined the sources for analysis, considering controls only for

those sources with emissions of NOx or SO 2 greater than or equal to five tons per year per

kilometer of distance ( Q/D greater than 5) to the Wichita Mountains or the nearest other Class I

area. This dist ance

- weighing criterion limited the sensitivity evaluation to sources with the greatest likely influence on visibility. For EGU sources meeting the Q/D and cost

- effectiveness

criteria for SO 2 controls (scrubbers), a control efficiency of 90% was applied. NOx control efficiencies applied varied from 35% to 95% depending on the control technology or combination of control technologies (SCR, SNCR, LNB, flue gas

- recirculation) that were determined to be less than $5000/ton. (See Tables 6.6 and 6.7 of the Alp ine Geophysics report). The CENRAP control sensitivity modeling run included emission reductions in the CENRAP

20 Appendix 4

- 2 of the Oklahoma Regional Haze SIP, available in our docket.

21 Additional information and a copy of the AirControl NET software can be found at: http://www.epa.gov/ttn/ecas/AirControlNET.htm22

states at those point sources where the cost

- effectiveness and Q/D criteria discussed above were

met. This modeling was developed as a starting point for discussion and development of refined analyses as needed. 22

As depicted in Table 5 , the CENRAP control case sensitivity evaluation projected that visibility at the Wichita Mountains would be improved by an additional 0.75 dv on the worst 20% d ays over what the ODEQ projects as its RPG of 21.47 dv for 2018, if controls were implemented at the sources that met this combination of baseline emissions, potential for cost

- effective add

- on controls , and location (21.47

- 20.72 = 0.75)

.

Table 5

- Vis ibility at Wichita Mountains under CENRAP Control Sensitivity Scenario

(Table IX

- 4 of the OK Regional Haze SIP )

Observed Visibility in 2002

- 2004 108.15 Mm

- 1 23.81 dv

Visibility projected by 2018 using RPG 85.63 Mm

- 1 21.47 dv

Visibility by 2018 at uniform rate of progress 73.97 Mm

- 1 20.01 deciviews

Visibility projected by 2018 under control scenario 81.40 Mm

- 1 20.97 (20.72) 23 dv

ODEQ pointed out that even if all CENRAP member states compelled sources to install and operate controls as effectively as the Alpine Geophysics evaluation envisions, the Wichita Mountains would still fall significantly short of meeting the URP glide path for the 20% worst days in 2018. Furthermore, ODEQ pointed out that most of the sources under consideration for

control in the Alpine Geophysics evaluation are located in Texas or other states outside of ODEQ’s territorial jurisdiction. ODEQ also stated that the control scenario presented in the Alpine Geophysics evaluation includes some already implemented, prohibitively costly, technically infeasible, or otherwise unreasonable controls.

Following this analysis, ODEQ examined additional controls for sources within Oklahoma

. The

list of sources considered for additional controls under RP is shown in Table IX

- 5 of the

Oklahoma Regional Haze SIP , and is reproduced in Table 6 below :

Table 6

- Sources O DEQ Considered for Additional Controls Under Reasonable Progress

Company County Industrial

classification Possible

Control Equipment ODEQ

De termination

Public Service Company of

Oklahoma Caddo Electric services utility Selective

catalytic

reduction Subject to

BART; controls

22 “The results of the modeling were not intended to be prescriptive; instead, they were intended to be a starting point for co ntrol discussions that would require much greater refinement.” CENRAP TSD, page 2

- 37.

23 ODEQ mistakenly referred to an estimated visibility of 20.97 dv for the control scenario instead of the correct value of 20.72 dv. See correspondence from ODEQ (Lee W arden) to EPA (Michael Feldman) on 7/14/2014.23 (2 oil or gas

- fired boilers) required under

BART

Western Farmers Electric Cooperative Choctaw Electric services utility (1 coal

- fired boiler) Selective

catalytic

reduction and flue gas

desulfurization

wet scrubber Not Subject to

BART; no

additional

emission

reductions planned

Public Service Company of

Oklahoma Comanche Electric services utility (2 natural gas

fired combustion turbines) Selective

catalytic reduction plus water injection Subject to

BART; controls required under

BART

Great Lakes Carbon Corporation Garfield Products of petroleum and

coal (2 process units) Flue gas

desulfurization Not Subject to

BART; no

additional

emissions

reductions planned

International Paper (formerly Weye regional

haze aeuser) Valliant Paper Mill McCurtain Paperboard Mill (wood bark, residual oil, and natural gas fired boilers) Selective non

catalytic reduction (urea based),

selective catalytic reduction, low NOx burners,

and wet flue

gas desulfurization Source agreed to

reduce emissions and was granted

a BART waiver

Grand River Dam Authority Mayes Electric services utility (coal fired boilers) Selective

catalytic reduction, low

NOx burner

with over

- fire air, and flue

gas desulfurization

wet scrubber Not Subject to

BART; no

emissions

reductions planned

Associated Electric Cooperative Incorporated Mayes Electric services utility (natural gas

- fired

combustion turbines) Selectiv e

catalytic reduction plus water injection Not subject to

BART; no

emissions

reductions planned24

Oklahoma Gas &

Electric Muskogee Electric services utility (3 coal

- fired boilers) Low NOx

coal

- and

- air

nozzles with

close

- coupled and separated

over

- fire air and flue gas

desulfurization

wet scrubber Subject to

BART; controls required under

BART

Oklahoma Gas &

Electric Noble Electric services utility (2 coal

- fired boilers) Low NOx

coal

- and

- air

nozzles with

close

- coupled and separated

over

- fire air Subject to

BART; controls required under

BART

Holcim United States Incorporated Pontotoc Cement manufacturing (coal

- fired kilns) Selective

catalytic

reduction and flue gas

desulfurization Not Subject to

BART; no

emissions

reductions planned

LaFarge Building

Materials Rogers Cement manufacturing (coal

- fired kilns) Selective non

catalytic reduction (urea based) and

selective catalytic

reduction Portland cement

plant at this location granted

BART waiver

Public Service Company of

Oklahoma Rogers Electric services utility (2 coal

fired boilers) Selective

Catalytic

Reduction Subject to

BART; controls required under

BART

Sinclair Oil Corporation Tulsa Petroleum Refining Industry Flue gas

desulfurization Source was

granted a BART waiver, but

emissions

reducti ons planned under refinery consent

decrees

In its analysis, the ODEQ considered the four statutory factors under Section 51.308(d)(1)(i)(A) in its evaluation of the potential for additional controls. In summary, the ODEQ analyzed the cost of compliance by reviewing the cost information previously developed by CENRAP and

m ade changes to the cost information based on its knowledge of the particular facilities and experience with implementing ozone reduction strategies. The ODEQ’s analysis focused on moderate cost controls for sources likely to contribute to visibility impairment at the Wichita25

Mountains. In considering the time necessary for compliance, the ODEQ determined that any

such controls would have to be insta lled and in operation by 2018. It did not identify any

detrimental non

- air quality environmental impacts associated with any controls considered, and any energy impacts were factored into the cost of controls. In considering the remaining useful

life of any potentially affected sources, the ODEQ stated that none of the sources considered for additional emission reductions had indicated plans to shut down.

The ODEQ also evaluated the major sources of each visibility impairing pollutant within the

State. In its analyses of additional SO 2 control, it noted that the three largest sources of sulfur emissions in the State, OG&E Muskogee, OG&E Sooner, and AEP/PSO Northeastern, were subject to BART. 24 The ODEQ also stated that sulfur controls at the Grand River Dam Authority (GRDA) would be costly and result in little visibility benefit given the location of the facility. Furthermore, the GRDA already utilized flue gas desulfurization. It noted that additional sulfur emission reductions were already required d ue to consent decrees on refineries.

T he ODEQ identified that three of the four largest NOx point sources and a number of smaller sources close to Wichita Mountains would be controlled under BART. Similar to its analysis for

SO 2 , the ODEQ also stated t hat NOx controls at the GRDA would be costly and result in little visibility benefit given the location of the facility. The ODEQ determined that controls for other point and area sources, especially those associated with oil and gas activities, would be expensive and that violations would entail large costs to detect and enforce. The ODEQ stated that improved emission inventories in the future could help in developing State rules for area sources. In addition, the ODEQ stated that new oil and gas source s are covered by new source performance standards.

Based on the above analysis of the four factors, the ODEQ concluded that retrofitting these identified point sources of NOx and SO 2 would impose unreasonable costs for negligible visibility improvement. The ODEQ reasoned that most of the largest sources of SO 2 and NOx were already being controlled through BART, consent decrees or other regulatory mechanisms; already had adequate controls in place; or are located too far from the Wichita Mountains, and

t herefore have too little visibility impact to justify the cost of additional controls. The ODEQ

concluded that further emission reductions from such sources were unreasonable. It also stated that it would be unreasonable to require severe or over

- control of Oklahoma sources to compensate for the contribution from Texas, other States, and foreign countries, especially considering that the vast majority of the visibility impairment at the Wichita Mountains originates from sources beyond the borders of Oklah oma.

The ODEQ determined that the majority of VOC emissions are from biogenic sources. Anthropogenic sources of VOC are largely covered under federal mandates and have a small contribution to visibility impairment. Fine and coarse particulate emissions are also primarily

due to natural sources such as dust storms and fires. The ODEQ noted that despite the prominence of agricultural burning and wildfires in the Oklahoma emissions inventory, it does not believe that these sources contribute significantly to regional haze at the Wichita Mountains or at any other Class I area. It pointed out that there are State regulations already in place (see

24 In our FIP ( 76 FR 81728 ), we disagreed with the ODEQ’s BART determinations for these three facilities (two units at each facility) and required a more stringent level of control.26

the Oklahoma Administrative Code 252:100

- 13

- 7(4)) to address the burning of forestland, cropland, and rangeland. In addition, pursuant to the regional haze requirements at Section 51.308(d)(3)(v)(E), the ODEQ considered smoke management techniques for purposes of agricultural and forestry management. The ODEQ stated that it believes that most emissions of

fine and coarse PM originate from natural sources, and that even those originating in Oklahoma are beyond the regulatory purview of ODEQ.

EPA Findings :

In establishing its RPGs for 2018 for the 20% worst days, the ODEQ relied on the improvements in visibility that were anticipated to result from federal and State control programs that were either currently in effect or with mandated future

- year emission reduction schedules that predate 2018, including the long

- term strategies of Oklahoma, Texas, and other State s, and presumptive emission reductions expected to result from the submitted Oklahoma BART rule. Based on the emission reductions from these measures, CENRAP modeled the projected visibility conditions anticipated at each Class I area in the region in 201 8, and the ODEQ used these results to

establish its RPGs.

We agree with the ODEQ’s decision to focus the analysis of the four statutory factors on point
sources, as the CENRAP modeling results and ODEQ’s analysis in Section V.F of the Oklahoma Regional Ha ze SIP indicate that sulfate is the predominant pollutant that affects the State’s ability to meet the URP goals in 2002 on the worst 20% days at the Wichita Mountains, and comes primarily from point sources. CENRAP modeling results also indicate that Okl ahoma point sources contribute only 3.25 Mm

1 of the total 111.03 Mm

- 1 visibility extinction at the Wichita Mountains in 2002 and only 2.95 Mm

1 of the total 86.56 Mm

1 projected for 2018. This modeling projection does not include the level of controls re quired under BART by the FIP and the revised SIP for the three largest sources of SO 2 in the State. The ODEQ also considered sources of VOC emissions, coarse and fine PM emissions, mobile source emissions and area

source emissions in its discussion an d an alysis of the four factors.

There are large EGU sources of SO 2 for which the ODEQ did not propose control, including the

GRDA Units 1 and 2 25 , Muskogee Unit 6, and Hugo Unit 1. Oklahoma considered these sources

for additional control under reasonable progress but ultimately for the reasons described above, declined to further control them. However, the total contribution from those sources not identified for control is only a fraction of the 1.23 Mm

- 1 projected from all SO 2 point sources,

and none of the those sources are located such that we would anticipate significant visibility benefits at the Wichita Mountains on the 20% worst days should they be controlled. The 20% worst days at the Wichita Mountains are dominated by days impacted by emissions f rom sources in Texas. The largest impacts from sources in Oklahoma rarely occur on the 20% worst days as identified by the IMPROVE monitor data during the baseline period. For these reasons and others that we more fully explore herein , we believe that Ok lahoma has adequately controlled its own sources for reasonable progress to the extent necessary for this planning period

.

25 Both GRDA Units 1 and 2 plan to install low NOx burners and overfire air in order to reduce NOx by construction permit No. 2009

- 179

- C (M

- 2)(PSD) . Unit 2 of the GRDA is fitted with a dry scrubber. We have recently became aware that Unit 1 (which is not scrubbed) is scheduled to be retired or converted to natural gas and a third natural gas powered unit may be added under a draft permit evaluation

.27

As the ODEQ notes in several places in its SIP, point sources in Texas account for a much greater portion of the visibility impact a t the Wichita Mountains than Oklahoma point sources. Compared to the 1.23 Mm

- 1 due to point source emissions of SO 2 in Oklahoma discussed above, Texas point source emissions of SO 2 are projected to contribute 7.83 Mm

- 1 to the total extinction

in 2018. We agree with the ODEQ’s statement regarding this situation: “The vast majority of visibility impairment at the Wichita Mountains comes from sources beyond the borders of the State of Oklahoma. The federal Regional Haze Rule in 40 C.F.R. Section 51.308(d)(3 )(ii) does not require DEQ to compensate for the lack of control of emissions in Texas, other States, and foreign countries.” The Regional Haze Rule does not require a State to over control its own sources in order to compensate for under controlled sourc es from another State. However, the Regional Haze Rule does require, under Section 51.308(d)(1)(iv), that in developing its RPGs, Oklahoma consult with those States which may reasonably be anticipated to cause or contribute to visibility impairment at the Wichita Mountains to identify reasonable measures for improving visibility at its Class I area.

A

. 4

. Uniform Rate of Progress Determination

Section 51.308(d)(1)(i)(B) requires Oklahoma to analyze and determine the URP needed to

attain natural visibility conditions by 2064. To calculate the URP, Oklahoma must compare baseline visibility conditions to natural visibility conditions at the Wichita Mountains and determine the uniform rate of visibility improvement (measured in deciviews) that would need to be maintained during each implementation period in order to attain natural visibility conditions by 2064. In establishing the RPG, Oklahoma must consider the URP and the emission reduction measures needed to achieve it for the period covered by t he implementation plan. In a previous final rulemaking, 26 we found that ODEQ appropriately calculated the URP for the Wichita

Mountains. Therefore, the only portion of 40 CFR 51.308(d)(1)(i)(B) that we address is Oklahoma’s requirement to consider the emi ssion reduction measures needed to achieve the URP when establishing the RPG for the Wichita Mountains.

State Submittal : Pages 36 and 1 07

- 11 4

In establishing the RPGs for the Wichita Mountains, the ODEQ compared the baseline visibility conditions to the natural visibility conditions and determined the URP needed in order to attain natural visibility conditions by 2064. It calculated that the UR P results as a visibility improvement of 3.80 dv for the period covered by this SIP revision submittal (up to and including 2018). The ODEQ noted that the CENRAP modeling results indicated that complete elimination of all anthropogenic emissions in Oklahoma are likel y to be insufficient to meet the URP at the Wichita Mountains and that a majority of the visibility impairment at the Wichita Mountains comes from sources beyond Oklahoma’s borders.

After considering the URP, the results of the CENRAP modeling and the f our reasonable progress factors, the ODEQ determined that meeting the URP goal for 2018 was not reasonable

. I t then adopted the 2018 projected visibility conditions from the CENRAP photochemical modeling as the RPGs for the 20% best days and 20% worst day s for the Wichita Mountains.

26 76 FR 81728 (Dec. 28, 2011).28

Table 7

- Comparison of URP to the Reasonable Progress Goal on Most Impaired Days for

the Wichita Mountains

Extinction Deciview

Natural Visibility Conditions 21.23 Mm

- 1 7.53 dv

Baseline Visibility Conditions (2002

- 2004) 108.15 Mm

- 1 23.81 dv

Improvement Needed to Reach Natural Conditions 86.91 Mm

- 1 16.28 dv

Improvement by 2018 at Uniform Rate of Progress 34.18 Mm

- 1 3.80 dv

Improvement by 2018 under Oklahoma’s RPG 22.52 Mm

- 1 2.33 dv

Rate of Improvement from 2004

- 2018 under Oklahoma’s RPG (dv/year) - 0.166 dv/year

Shortfall between Oklahoma’s RPG and the URP (for this implementation period) - - 1.47 dv

Improvement by 2064 Extrapolated from Oklahoma’s

RPG 68.38 Mm

- 1 10.01 dv

Visibility in 2064 from Oklahoma’s RPG (extrapolated) 39.76 Mm

- 1 13.80 dv

Visibility in 2102 Extrapolated from Oklahoma’s RPG (natural visibility conditions achieved) 21.23 Mm

- 1 7.53 dv

EPA Findings:

The ODEQ believes the RPGs it established for the Wichita Mountains are reasonable, and that it is not reasonable to achieve the URP in 2018. In support of this conclusion it included a discussion of the pollutant contributions and the sources of visibili ty impairment at the Wichita Mountains (see Sections IX.D and E of the Oklahoma Regional Haze SIP ). The ODEQ also took several other factors into consideration in determining that it was not reasonable to achieve the glide path in 2018 and that the RPG ad opted by it is reasonable.

We evaluated the analysis provided by the ODEQ along with the CENRAP modeling results, CENRAP emission inventories and other information in examining the RPGs established by ODEQ. Our review of the CENRAP emission inventory, modeling protocol and model results can be found in our CENRAP Modeling TSD

. Below we present a summary of that evaluation:

 The ODEQ demonstrated through the CENRAP control sensitivity modeling, that application of a wide suite of controls across CENRAP States determined to meet a

cost

- effective threshold of $5,000/ton and emissions in relation to location criteria, would also not be sufficient to meet the URP goal, falling approximately 0.71 dv deciview short of the goal. However, we note that this cont rol sensitivity modeling also demonstrated that an additional improvement of 0.75 dv was achievable through implementation of the identified controls. Based on source apportionment data, a29 large portion of that improvement would likely result from impleme ntation of identified controls in Texas. A 0.75 dv improvement represents nearly 33% additional improvement over the 2.3 dv improvement projected to occur between the baseline period and 2018 due to all of the reductions included in the model from on

the book controls, implementation of CAIR and assumptions of reductions due to

BART.

 Evidence in the record demonstrated that additional reductions at sources in Texas were likely feasible, result in visibility improvement, and be cost

- effective, but the ODEQ did not pursue this with Texas. Consequently, we believe the ODEQ did not have sufficient information to adequately consider emission reductions for sources in Texas in establishing its RPGs and demonstrating that it is reasonable.

 We believe the current approach to estimate natural conditions used by ODEQ follows our default methods and is acceptable to establish the 2064 goal, calculate the URP, and evaluate the RPGs established by Oklahoma.

 We note the more recent IMPROVE monito red data at the Wichita Mountains indicates that more progress than anticipated by the CENRAP modeling has

occurred. 27 The most recent five

- year (2009

- 2013) average conditions for the 20% worst days is 21.2 dv. This is below the level anticipated in the C ENRAP projection for 2018 of 21.5 dv. We believe that this observed improvement is the result of meteorological conditions, reduction in the impact from fires, and reduction in the impacts from SO 2 emissions. More recent emission inventory data shows red uctions in emissions in most States beyond what was projected in the 2018 modeling, including large reductions in emissions from the Eastern United States. Emissions

from non

- EGU Texas point sources are lower than have been projected in the modeling. We note that additional reductions are still needed to meet or exceed the URP goal for 2018 of 20.01 dv. As discussed above, emissions at some of the sources that impact visibility the most are still above the emission levels projected in

the model and cost

- effective controls are likely available at these sources. Based on information provided by the TCEQ, we do not expect large additional emission

reductions of SO 2 in Texas between 2013 and 2018 under federal programs and the

SIP as submitted. 28

Based on th e above considerations, we propose to agree with the ODEQ’s demonstration that it is not reasonable to meet the URP for the Wichita Mountains for this planning period. W e also agree with the ODEQ that emissions and transport from outside of Oklahoma will severely limit the rate of progress achievable at the Wichita Mountains on the 20% worst days. As the ODEQ itself (and we through our analysis detailed in the FIP TSD) have demonstrated, there are large visibility impacts at the Wichita Mountains from out side Oklahoma, the largest percentage coming from point sources in Texas. In addition, we believe the ODEQ has also demonstrated there is the likelihood of a sizeable visibility improvement from controlling a subset of these sources, with likely cost

- effe ctive controls.

A

. 5

. Additional Analysis of Reasonable Progress Goal

27 Available at: http://vista.cira.colostate.edu/tss/

28 TCEQ comment letter to EPA on draft modeling platform dated June 24, 2014. ‘2018 EMP signed.pd f’30

Section 51.308(d)(1)(ii) provides that f or the period of the SIP, if Oklahoma establishes a RPG that provides for a slower rate of improvement in visibility than the rate that would be needed to attain natural conditions by 2064, it must demonstrate based on the factor s in section 51.308(d)(1)(i)(A) that the rate of progress for the SIP to attain na tural conditions by 2064 is not reasonable; and that the progress goal it adopted is reasonable. As part of its SIP assessment,

Oklahoma must provide to the public for review the number of years it would take to attain natural conditions if visibility imp rovement continues at the rate of progress it selected as reasonable.

Section 51.308(d)(1)(iii) provides that i n determining whether Oklahoma’s goal for visibility improvement provides for reasonable progress towards natural visibility conditions, the

Adm inistrator will evaluate the demonstrations developed by Oklahoma pursuant to s ection s 51.308(d)(1)(i) and (d)(1)(ii). Because t his language relates to our review of Regional Haze SIP s and does not require a response from the state, it is not separately e valuated here.

State Submittal: Pages 104

- 114

The ODEQ’s RPG for the 20% worst days establishes a slower rate of progress than the URP for

the Wichita Mountains. As shown in Table IX

- 1 of the Oklahoma Regional Haze SIP , under the RPG adopted by ODEQ, it projected that natural visibility conditions will not be attained at the Wichita Mountains by 2064. ODEQ calculated that under the rate of progress selected by it as reasonable, it would attain natural visibility condit ions at the Wichita Mountains in 2102.

In the Oklahoma Regional Haze SIP, the ODEQ states that the RPGs it established for the

Wichita Mountains are reasonable and that it is not reasonable to achieve the URP in 2018. In support of this conclusion, it included a discussion of the pollutant con tributions and the sources of visibility impairment at the Wichita Mountains (see Sections IX.D and E of the Oklahoma Regional Haze SIP ). The ODEQ also took several other factors into consideration in determining that it was not reasonable to achieve the glide path in 2018 and that the RPG adopted by it is reasonable. T ables 8

, 9 , and 10 below summarize the visibility modeling source apportionment results by pollutant and source region for the 2002 base year and the 2018 projection modeling performed by C ENRAP.

Table 8

. 2002 Projected sources of light extinction at the Wichita Mountains (worst

quintile days in) ( from Table V

- 8 of the OK Regional Haze SIP )

( All values in

Mm

1 ) Sum Sulfurous Nitrate Organic

carbonaceous Elemental

carbonaceous Soils Coarse

Texas 28.15 13.98 7.89 3.05 1.42 0 .29 1.51

Oklahoma 14.72 1.77 6.43 2.26 1.08 0 .26 2.91 Rayleigh scattering 11.00

boundary

conditions 9.17 3.93 .87 3.61 0 .69 0 .02 0 .05

East 8.12 7.49 0 .15 0 .34 0 .13 0 .01 0 .00

Kansas 3.82 0 .92 1.94 0 .57 0 .30 0 .05 0 .05

Louisiana 3.47 2.60 0 .30 0 .42 0 .14 0 .01 0 .0031

secondary biogenic 2.91 2.91

secondary anthropogenic 2.57 2.57

Indiana 2.53 2.41 0 .07 0 .02 0 .02 0 .00 0 .00

Missouri 2.47 1.13 1.06 0 .19 0 .07 0 .02 0 .01

Canada 2.35 1.62 0 .58 0 .09 0 .05 0 .01 0 .00

Mexico 2.25 1.79 0 .37 0 .04 0 .02 0 .01 0 .02

Illinois 2.05 1.55 0 .42 0 .04 0 .03 0 .00 0 .00

Arkansas 1.97 1.03 0 .49 0 .31 0 .13 0 .01 0 .01

Ohio 1.68 1.61 0 .02 0 .02 0 .02 0 .00 0 .00

Tennessee 1.51 1.29 0 .11 0 .07 0 .03 0 .00 0 .00 Kentucky 1.47 1.35 0 .05 0 .04 0 .02 0 .00 0 .00

Alabama 1.41 1.30 0 .03 0 .06 0 .02 0 .00 0 .00

Iowa 1.16 0 .46 0 .57 0 .06 0 .03 0 .03 0 .01

Nebraska 1.11 0 .32 0 .63 0 .08 0 .04 0 .02 0 .02

West 0 .93 0 .37 0 .29 0 .20 0 .07 0 .01 0 .01

Minnesota 0 .78 0 .30 0 .31 0 .11 0 .04 0 .01 0 .00 Mississippi 0 .52 0 .32 0 .06 0 .10 0 .03 0 .00 0 .00 Michigan 0 .47 0 .42 0 .02 0 .01 0 .01 0 .00 0 .00

New Mexico 0 .46 0 .14 0 .28 0 .02 0 .01 0 .00 0 .01

Colorado 0 .45 0 .16 0 .25 0 .02 0 .01 0 .00 0 .00

North Dakota 0 .41 0 .23 0 .14 0 .02 0 .01 0 .00 0 .00 Wyoming 0 .36 0 .18 0 .16 0 .01 0 .00 0 .00 0 .00

Wisconsin 0 .33 0 .25 0 .05 0 .02 0 .01 0 .00 0 .00

South Dakota 0 .23 0 .05 0 .12 0 .02 0 .02 0 .01 0 .01

Gulf of Mexico 0 .22 0 .15 0 .06 0 .01 0 .00 0 .00 0 .00

initial conditions 0 .00 0 .00 0 .00 0 .00 0 .00 0 .00 0 .00

total 111.03 49.12 23.72 17.28 4.47 0 .79 4.64

Table 9

. 2018 Projected sources of light extinction at the Wichita Mountains (worst quintile days) ( from Table VIII

- 10 of the OK Regional Haze SIP )

2018 Model projection

( All values in

Mm

- 1 ) Sum Sulfurous Nitrate Organic

carbonaceous Elemental

carbonaceous Soils Coarse

Texas 20.79 9.68 6.08 2.57 0 .68 0 .30 1.49

Oklahoma 12.28 1.58 4.99 2.10 0 .72 0 .24 2.65 Rayleigh scattering 11.00

boundary

conditions 9.11 3.77 1.03 3.55 0 .69 0 .02 0 .05

East 3.15 2.67 0 .07 0 .31 0 .08 0 .01 0 .00

Kansas 2.90 0 .63 1.36 0 .56 0 .26 0 .05 0 .05

Louisiana 3.65 2.77 .30 0 .45 0 .12 0 .01 0 .00 secondary biogenic 2.84 2.8432

secondary anthropogenic 2.22 2.22

Indiana 0 .92 0 .86 0 .02 0 .02 0 .01 0 .00 0 .00

Missouri 2.10 1.15 0 .71 0 .17 0 .04 0 .02 0 .01

Canada 2.00 1.39 0 .46 0 .09 0 .05 0 .01 0 .00

Mexico 2.10 1.72 0 .30 0 .04 0 .02 0 .01 0 .02

Illinois 1.06 0 .78 0 .22 0 .04 0 .02 0 .00 0 .00

Arkansas 1.71 1.04 0 .30 0 .27 0 .08 0 .01 0 .01

Ohio 0 .49 0 .45 0 .01 0 .02 0 .01 0 .00 0 .00

Tennessee 0 .79 0 .65 0 .05 0 .07 0 .02 0 .00 0 .00 Kentucky 0 .70 0 .63 0 .03 0 .03 0 .01 0 .00 0 .00

Alabama 0 .55 0 .47 0 .01 0 .05 0 .01 0 .00 0 .00

Iowa 0 .99 0 .49 0 .39 0 .05 0 .02 0 .03 0 .01

Nebraska 0 .81 0 .25 0 .42 0 .07 0 .02 0 .02 0 .02

West 0 .80 0 .33 0 .22 0 .18 0 .05 0 .01 0 .01

Minnesota 0 .64 0 .31 0 .22 0 .07 0 .02 0 .01 0 .00 Mississippi 0 .36 0 .19 0 .04 0 .10 0 .02 0 .00 0 .00 Michigan 0 .40 0 .38 0 .01 0 .01 0 .00 0 .00 0 .00

New Mexico 0 .39 0 .13 0 .23 0 .01 0 .00 0 .00 0 .01

Colorado 0 .31 0 .11 0 .16 0 .02 0 .01 0 .00 0 .00

North Dakota 0 .38 0 .23 0 .12 0 .01 0 .01 0 .00 0 .00 Wyoming 0 .80 0 .33 0 .22 0 .18 0 .05 0 .01 0 .01

Wisconsin 0 .80 0 .33 0 .22 0 .18 0 .05 0 .01 0 .01

South Dakota 0 .16 0 .04 0 .08 0 .02 0 .01 0 .01 0 .01

Gulf of Mexico 0 .33 0 .22 0 .10 0 .00 0 .00 0 .00 0 .00

initial conditions 0 .00 0 .00 0 .00 0 .00 0 .00 0 .00 0 .00

total 87.54 33.58 18.38 16.33 3.09 .80 4.36

Table 10

. 2002 to 2018 Projected reduction in sources of light extinction at the Wichita Mountains (worst quintile days) ( from Table VIII

- 10 of the OK Regional Haze SIP )

2002 to 2018 Projected reduction

( All values in

Mm

- 1 ) Sum Sulfurous Nitrate Organic

carbonaceous Elemental

carbonaceous Soils Coarse

Texas 7.36 4.30 1.81 0 .48 0 .74 0 .00 0 .02

Oklahoma 2.43 0 .19 1.44 0 .17 0 .36 0 .01 0 .27 Rayleigh scattering 0 .00

boundary

conditions 0 .06 0 .16

- 0 .16 0 .06 0 .00 0 .00 0 .00

East 4.97 4.82 0 .08 0 .03 0 .05 0 .00 0 .00

Kansas 0 .92 0 .29 0 .58 0 .01 0 .04 0 .00 0 .00

Louisiana

- 0 .18

- 0 .17 0 .00

- 0 .03 0 .02 0 .00 0 .00 secondary biogenic 0 .06 0 .06

secondary anthropogenic 0 .35 0 .35

Indiana 1.61 1.55 0 .05 0 .00 0 .01 0 .00 0 .0033

Missouri 0 .37

- 0 .02 0 .35 0 .02 0 .02 0 .00 0 .00

Canada 0 .36 0 .23 0 .12 0 .00 0 .00 0 .00 0 .00

Mexico 0 .15 0 .07 0 .07 0 .00 0 .00 0 .00 0 .00

Illinois 0 .99 0 .77 0 .20 0 .00 0 .02 0 .00 0 .00

Arkansas 0 .26

- 0 .01 0 .19 0 .04 0 .04 0 .00 0 .00

Ohio 1.19 1.17 0 .01 0 .00 0 .01 0 .00 0 .00

Tennessee 0 .72 0 .64 0 .07 0 .00 0 .01 0 .00 0 .00 Kentucky 0 .76 0 .73 0 .03 0 .00 0 .01 0 .00 0 .00

Alabama 0 .86 0 .83 0 .01 0 .01 0 .01 0 .00 0 .00

Iowa 0 .17

- 0 .03 0 .18 0 .01 0 .01 0 .00 0 .00

Nebraska 0 .30 0 .06 0 .21 0 .01 0 .02 0 .00 0 .00

West 0 .13 0 .04 0 .07 0 .01 0 .02 0 .00 0 .00

Minnesota 0 .14

- 0 .01 0 .09 0 .04 0 .02 0 .00 0 .00 Mississippi 0 .16 0 .13 0 .02 0 .00 0 .01 0 .00 0 .00 Michigan 0 .06 0 .05 0 .01 0 .00 0 .00 0 .00 0 .00

New Mexico 0 .07 0 .00 0 .06 0 .01 0 .00 0 .00 0 .00

Colorado 0 .14 0 .05 0 .09 0 .00 0 .01 0 .00 0 .00

North Dakota 0 .03 0 .00 0 .02 0 .00 0 .01 0 .00 0 .00 Wyoming

- 0 .44

- 0 .15

- 0 .06

- 0 .18

- 0 .04

- 0 .01 0 .00

Wisconsin

- 0 .47

- 0 .08

- 0 .17

- 0 .16

- 0 .04

- 0 .01

- 0 .01

South Dakota 0 .06 0 .01 0 .04 0 .00 0 .01 0 .00 0 .00

Gulf of Mexico

- 0 .11

- 0 .07

- 0 .04 0 .00 0 .00 0 .00 0 .00

initial conditions 0 .00 0 .00 0 .00 0 .00 0 .00 0 .00 0 .00

total 23.49 15.54 5.34 .96 1.38

- 0 .01 0 .28

Tables 11 and 1 2 (compiled from data in Section V.E. and VIII.E of the OK Regional Haze SIP )

show the contributions to total extinction for each source category and species for 2002 and 2018, respectively. Tables 1 3

, and 1 4 show the modeled source category source apportionment results for each region for sulfurous sources of light extinction for 2002 and 2018.

Table 11 . Projected light extinction for 20% worst days at the Wichita Mountains in 2002 (Mm

- 1 )

Total 1 Point Area Non

- road On

- road Biogenic

SO 4 49.12 38.76 4.59 1.0 0.79 0.05

NO 3 23.72 6.8 3.41 3.16 6.87 2.61

POA 17.28 0.86 5.79 0.66 0.3 0.6

EC 4.47 0.1 1.89 1.14 0.51 0.14

Soil 0.79 0.05 0.65 0.0 0.0 0.07

CM 4.60 0.04 4.01 0.0 0.01 0.53 Rayleigh scattering 11

Sum 111.03 46.61 20.34 5.96 8.48 4.0

1 Totals include contributions from boundary conditions and secondary organic matter

Table 1 2 . Projected light extinction for 20% worst days at the Wichita Mountains in 2018 (Mm

- 1 )34 Total 1 Point Area Non

- road On

- road Biogenic

SO 4 33.33 24.64 4.51 0 .28 0.1 0.04

NO 3 18.10 6.25 3.96 2.18 1.92 2.76

POA 15.98 1.19 4.99 0.61 0.11 0.47

EC 3.00 0.09 1.45 0.55 0.11 0.11

Soil 0.79 0.08 0.62 0.0 0.0 0.07

CM 4.30 0.05 3.70 0.0 0.01 0.53 Rayleigh scattering 11

Sum 87.54 32.3 19.23 3.62 2.25 3.98

1 Totals include contributions from boundary conditions and secondary organic matter

Table 1 3

. Projected sulfurous sources of light extinction at the Wichita Mountains (worst

quintile days in 2002) ( from Table V

- 1 of the OK Regional Haze SIP )

( All values

in Mm

- 1 ) Total Point Area Non

- road

Mobile On

- road

Mobile Biogenic

Texas 13.98 11.56 1.85 0 .28 0 .29 0 .00

East 7.49 6.90 0 .40 0 .09 0 .10 0 .00 boundary

conditions 3.93

Louisiana 2.60 1.93 0 .56 0 .08 0 .03 0 .00

Indiana 2.41 2.29 0 .09 0 .02 0 .02 0 .00

Mexico 1.79 1.67 0 .09 0 .01 0 .01 0 .00

Oklahoma 1.77 1.28 0 .33 0 .06 0 .09 0 .01

Canada 1.62 1.50 0 .08 0 .02 0 .01 0 .00

Ohio 1.61 1.54 0 .02 0 .02 0 .02 0 .00

Illinois 1.55 1.47 0 .03 0 .03 0 .02 0 .00 Kentucky 1.35 1.23 0 .08 0 .02 0 .01 0 .00

Alabama 1.30 1.16 0 .11 0 .02 0 .02 0 .00

Tennessee 1.29 1.15 0 .08 0 .03 0 .02 0 .00

Missouri 1.13 0 .95 0 .14 0 .03 0 .02 0 .00

Arkansas 1.03 0 .73 0 .21 0 .04 0 .03 0 .01

Kansas 0 .92 0 .71 0 .16 0 .04 0 .02 0 .00

Iowa 0 .46 0 .42 0 .01 0 .02 0 .01 0 .00 Michigan 0 .42 0 .37 0 .02 0 .02 0 .01 0 .00

West 0 .37 0 .28 0 .03 0 .03 0 .01 0 .02 Mississippi 0 .32 0 .25 0 .01 0 .04 0 .01 0 .00

Nebraska 0 .32 0 .25 0 .03 0 .03 0 .01 0 .00

Minnesota 0 .30 0 .24 0 .03 0 .02 0 .01 0 .01

Wisconsin 0 .25 0 .23 0 .01 0 .01 0 .01 0 .00

North

Dakota 0 .23 0 .21 0 .01 0 .01 0 .00 0 .00

Wyoming 0 .18 0 .15 0 .02 0 .01 0 .00 0 .0035

all other 0 .49 0 .28 0 .17 0 .03 0 .01 0 .00

total 49.12 38.76 4.59 1.00 0 .79 0 .05

Table 1 4

. Projected sulfurous sources of light extinction at the Wichita Mountains (worst quintile days in 2018) (from Table VIII

- 3 of the OK Regional Haze SIP )

( All values

in Mm

- 1 ) Total Point Area Non

- road

Mobile On

- road

Mobile Biogenic

Texas 9.68 7.83 1.73 0 .08 0 .04 0 .00

East 2.67 2.27 0 .37 0 .01 0 .01 0 .00 boundary

conditions 3.77

Louisiana 2.77 2.16 0 .56 0 .05 0 .00 0 .00

Indiana 0 .86 0 .78 0 .07 0 .00 0 .00 0 .00

Mexico 1.72 1.61 0 .09 0 .01 0 .00 0 .00

Oklahoma 1.58 1.23 0 .33 0 .01 0 .01 0 .00

Canada 1.39 1.28 0 .08 0 .02 0 .00 0 .00

Ohio 0 .45 0 .41 0 .03 0 .01 0 .00 0 .00

Illinois 0 .78 0 .74 0 .03 0 .00 0 .00 0 .00 Kentucky 0 .63 0 .54 0 .07 0 .01 0 .00 0 .00

Alabama 0 .47 0 .37 0 .09 0 .01 0 .00 0 .00

Tennessee 0 .65 0 .56 0 .07 0 .01 0 .00 0 .00

Missouri 1.15 1.00 0 .14 0 .00 0 .00 0 .00

Arkansas 1.04 0 .82 0 .21 0 .01 0 .00 0 .01

Kansas 0 .63 0 .46 0 .17 0 .00 0 .00 0 .00

Iowa 0 .49 0 .48 0 .01 0 .00 0 .00 0 .00 Michigan 0 .38 0 .35 0 .02 0 .01 0 .00 0 .00

West 0 .33 0 .28 0 .03 0 .00 0 .00 0 .02 Mississippi 0 .19 0 .16 0 .01 0 .02 0 .00 0 .00

Nebraska 0 .25 0 .21 0 .04 0 .00 0 .00 0 .00

Minnesota 0 .31 0 .27 0 .04 0 .00 0 .00 0 .00

Wisconsin 0 .21 0 .20 0 .01 0 .00 0 .00 0 .00

North

Dakota 0 .23 0 .22 0 .01 0 .00 0 .00 0 .00

Wyoming 0 .21 0 .18 0 .02 0 .00 0 .00 0 .00

all other 0 .50 0 .23 0 .27 0 .00 0 .00 0 .00

total 33.33 24.64 4.51 0 .28 0 .10 0 .04

The ODEQ indicated that Oklahoma’s ability to meet the URP is impeded primarily by the following: the significant contribution of emissions from Texas and other areas outside the ODEQ’s jurisdiction; the uncertainty in the effect of CAIR; the economic and energy cost of additional controls on Oklahoma point sources; the lack of a quality

- assured enhanced Oklahoma emissions inventory and ODEQ’s reluctance to target area sources for emissions controls until such an emissions inventory is developed; the ODEQ’s lack of jurisdiction over non

- road and

on

- road mobile sources; and, the limitations involved with utilizing the default EPA method to36

determine natural visibility conditions

. The ODEQ’s discussion of these factors in the Oklahoma Regional Haze SIP is sum marized below:

 As discussed in the previous section, in considering the URP, the ODEQ determined that the CENRAP modeling results indicate that complete elimination of all anthropogenic

emissions in Oklahoma is likely to be insufficient to meet the URP at the Wichita

Mountains.

 The CENRAP control sensitivity modeling scenario demonstrated that if all CENRAP member states compelled sources to install and operate add

- on controls as identified in the Alpine Geophysics evaluation at facilities meeting the CEN RAP selected criteria for

cost

- effectiveness of $5

, 000/ton and Q/D greater than 5, the Wichita Mountains would still fall short of meeting the URP glide path for the 20% worst days in 2018.

 ODEQ stated that as the data in Tables 8 through 1 4 demonstrate, most of the visibility impairment at the Wichita Mountains comes from sources beyond the borders of the State of Oklahoma, including Texas

, e astern states, international sources , and other areas outside the ODEQ’s jurisdiction

. For instance, b ased on the CENRAP’s modeling, Texas

contributes 28.15 Mm

- 1 (13.94 Mm

- 1 from point sources) , Eastern states 8.12 Mm

- 1 (7

Mm

- 1 from point sources) , areas outside the modeling domain 9.17 Mm

- 1 , and Oklahoma

14.72 Mm

- 1 (3.25 Mm

- 1 from point sources) of the total 111.03 M m - 1 light extinction at the Wichita Mountains on the 20% worst days in 2002 (see Section V.F. of the Oklahoma Regional Haze SIP and Table 8 above ). The modeling domain includes the continental U.S., Northern Mexico, and Southern Canada and contributions from all other sources outside of the modeling domain are captured by the “boundary conditions.” We note that

the total extinction of 111.03 Mm

- 1 inc ludes 11 Mm

- 1 due to Rayleigh scattering, or light extinction due to scattering of light by atmospheric gases.

 Based on the CENRAP’s 2018 projection modeling, Texas contributes 20.79 Mm

- 1
(10.58 Mm

- 1 from point sources) , Eastern states contribute 3.15 Mm

- 1 , areas outside the modeling domain contribute 9.11 Mm

- 1 , and Oklahoma contributes 12.28 Mm

- 1 (2.97

Mm

- 1 from point sources) of the total 87.54 Mm

- 1 light extinction at the Wichita Mountains on the 20% worst days in 20 18 (see Section V III. of the Oklahom a Regional

Haze SIP and Table 9 above). We note that the total extinction of 8 7 .54 Mm

- 1 includes

11 Mm

- 1 due to Rayleigh scattering, or light extinction due to scattering of light by atmospheric gases.

 The ODEQ stated that it is unreasonable to require severe control of Oklahoma sources to compensate for the contribution (and lack of additional controls) from Texas, other states, and foreign countries, especially considering that the vast majority of the vis ibility impairment at the Wichita Mountains originates from sources beyond the borders of

Oklahoma. It also noted that additional emissions reductions from sources outside

Oklahoma would be necessary to achieve progress in visibility improvement at the

Wi chita Mountains.37

 Since the Clean Air Interstate Rule (CAIR)/Cross State Air Pollution Rule (CSAPR) is a cap and trade program that allows trading SO 2 and NOx emissions allowances among EGUs, there is uncertainty in the eventual geographic location of em issions reductions within the states covered by CSAPR. The ODEQ argued that this uncertainty cascades to uncertainty in predicting the visibility improvement at the Wichita Mountains, especially

since CAIR/CSAPR is predicted to provide the majority of the emissions reductions in underlying the 2018 visibility projections.

 I n determining whether it is reasonable to require Oklahoma point sources to install controls under reasonable progress, the ODEQ noted that it had already considered

controls for the majority of the point sources in Oklahoma that are likely to contribute to visibility impairment at the Wichita Mountains under the BART review process, refinery consent decrees, or other controls already included in the reasonable progress goal (see

table 6 ) . In its analysis of the four reasonable progress factors under 40 CFR 51.308(d)(1)(i)(A), the ODEQ eliminated exorbitantly costly controls and sources already subject to reasonable controls from consideration, which left very few existing sources in

O klahoma left for consideration. The ODEQ also evaluated the major sources of each visibility impairing pollutant within the state. After considering the four reasonable progress factors, the ODEQ concluded that because of the considerable distance between the set of point sources under consideration and the Wichita Mountains and the sources’ likely minimal visibility impact, requiring controls under reasonable progress for Oklahoma point sour ces would result in high economic and energy costs and was therefore not reasonable. It also considered sources of VOC emissions, course and fine

PM emissions and area source emissions in their discussion and analysis of the four

factors.

 The ODEQ stat ed that it lacks confidence in the estimated considerable contribution of area sources, especially oil and gas industrial processes, to the Oklahoma NOx emissions inventory presented in the SIP. It noted that it would like to develop a quality

- assured

enh anced emissions inventory before considering emissions controls on area sources. In particular, it stated it would like to further refine an oil and gas emissions inventory it developed in 2008, so that its future control assessments can build on that inf ormation.

 The ODEQ noted that it lacks jurisdiction over non

- road and on

- road mobile sources, which contribute to the Oklahoma NOx emissions inventory presented in the SIP. Since

many non

- road and on

- road mobile sources move to and from other states, t he ODEQ stated it relies on the federal motor vehicle emissions control programs and other EPA regulations to limit emissions from this sector.

 Only a small portion of VOC emissions in Oklahoma originate from area, industrial, point, and mobile sources (s ee section IV of the Oklahoma Regional Haze SIP ). Taking into consideration the small and uncertain contribution of anthropogenic sources of VOC to visibility impairment at the Wichita Mountains, the ODEQ did not find further controls

on sources of VOC em ission reasonable.38

 The ODEQ stated it believes that most coarse and fine PM emissions from Oklahoma originate from natural sources. It stated it lacks confidence in the Oklahoma emissions inventory presented in this SIP, which assigns most coarse PM em ission to road dust. It noted that unpaved roads typically lack the traffic necessary to justify the expense of

pavement. The ODEQ also stated that it believes that dust storms, which occur naturally in dry environments, are a significant source of coars e PM emissions affecting visibility

at the Wichita Mountains. It noted that despite the prominence of agricultural burning and wildfires in the Oklahoma emissions inventory, it does not believe that these sources contribute significantly to regional haze at the Wichita Mountains nor at any other Class I

area. It pointed out that there are State regulations already in place (see the Oklahoma

Administrative Code 252:100

- 13

- 7(4)) to address the burning of forestland, cropland, and rangeland. In addition, pu rsuant to the r egional h aze requirements at 40 CFR 51.308(d)(3)(v)(E), ODEQ considered smoke management techniques for purposes of agricultural and forestry management. The ODEQ stated that it believes that most emissions of fine and coarse PM originate f rom natural sources, and that even those originating in Oklahoma are beyond its regulatory purview

.

 The ODEQ also discussed the uncertainty in its estimate of natural visibility conditions at the Wichita Mountains, and how that may impact the evaluation of the established RPG

and the need for additional controls. Our Western default natural visibility conditions for the Wichita Mountains is based on an algorithm for estimating natural conditions, and is

consistent w ith EPA’s designation of 98°W longitude as the division between East and
West. However, the ODEQ noted that because Oklahoma lies near the boundary between East and West, it does not strictly belong to either region. It noted that there is a lack of

data from the south central U.S. to formulate natural visibility estimates for this region, and that it believes that the default western target does not represent the actual conditions at the Wichita Mountains. In addition, the ODEQ stated that Oklahoma’s de signation as

a “Western” State for purposes of estimating natural visibility conditions at the Wichita Mountains is inconsistent with airflow patterns, which suggest that a considerable portion of the emissions contributing to visibility impairment at the Wichita Mountains originate

from Eastern states. It stated that because of the extremely general character of these estimates and their inherent assumptions, they should be considered as broad regional averages that do not necessarily apply to specific po ints

, and that include a large margin

of error. The ODEQ indicated that in the future it may update the estimates of natural particulate mass concentrations for each component based on recent peer

- reviewed literature rather than using the default values o r that it may refine the current default approach. Given that the actual natural visibility conditions at the Wichita Mountains may differ markedly from the estimated natural visibility conditions, the ODEQ does not find that it is reasonable to require a dditional controls for Oklahoma sources. Furthermore, the ODEQ suggested that if natural conditions account for a greater proportion of the presently observed visibility impairment than what is reflected by our Western default estimate, natural visibility conditions may be achievable around 2064 with the reasonable progress goal selected by ODEQ.39

A. 6 . Our Evaluation of Oklahoma’s Reasonable Progress Goals for the Wichita

Mountains.

In the sections above, we discuss how Oklahoma constructed its RPGs for the Wichita Mountains, how in doing so it consulted with Texas and other States, applied the four reasonable progress factors in evaluating sources within Oklahoma for additional controls in the development of that RPG, and calculated the URP for the Wich ita Mountains. In this section we consider those efforts and present our evaluation of Oklahoma’s RPGs for the Wichita

Mountains.

We believe that with the exception of certain BART sources, Oklahoma appropriately concluded that no additional reasonable progress measures for Oklahoma sources were necessary during this first planning period. However, BART is a component of reasonable progress, and the RPGs selected by the ODEQ for the Wichita Mountains do not include the level of reductions necessary to meet the requirements under Section 51.308(e) for BART. I n our December 28, 2011 rulemaking, we disapproved the SO 2 BART determinatio ns for certain units and promulgated a BART FIP to impose controls for these units. 29 Therefore , implementation of our

SO 2 BART FIP and the revised BART SIP for the AEP units is expected to result in greater reasonable progress than is anticipated in Oklah oma’s February 19, 2010, Regional Haze SIP

submittal. 30

.

In addition, as required by Section 51.308(d)(1)(iv), Oklahoma’s development of its RPGs must be informed by its consultations with other States. Oklahoma demonstrated that the unrealistic

scenario of eliminating all Oklahoma sources would not be sufficient to meet the URP for 2018. It realized that efforts to meet the goal of natural visibility by 2064 would require further emission reductions from other States in the region. The CENRAP modeling, monitoring data and other technical analyses that informed consultations demonstrated that NOx and SO 2 are the primary causes of haze at the Wichita Mountains with SO 2 from point sources being the predominant driver. It also showed that SO 2 point sources in Texas were a significant contributor to the haze at the Wichita Mountains. Furthermore, the control and cost information developed by CENRAP and Alpine Geophysics showed that cost

- effective controls on Texas sources were likely available, some with a c ost

- effectiveness on a $/ton basis within TCEQ’s own benchmark. The Regional Haze Rule envisioned that a State would use the consultation processes under Sections 51.308(d)(1)(iv) in the development of its RPGs, and 51.308(d)(3)(i) regarding the developme nt of its long

- term strategy, in identifying visibility impairing emissions that cross State boundaries, and in the coordination of strategies to reduce those emissions. However, despite this information in the record about the impact of Texas sources on the Wichita Mountains, the ODEQ did not request that the TCEQ further investigate these sources, nor did it request additional reductions from Texas sources to address this impact. As we discuss in Section V.E, we believe that the technical analysis devel oped by Texas did not provide the information necessary to identify reasonable reductions from its sources, and inform

29 76 FR 81728 (Dec. 28, 2011).

30 In our August 21, 2013

, proposed approval of Oklahoma’s June 20, 2013 , regional haze SIP revision we proposed

to find that the SO 2 emission reduction s associated with Oklahoma’s revised BART determination for Northeastern Units 3 and 4, when combined with enforceable commitments from ODEQ, will be consistent with the levels of control assumed in the CENRAP modeling and relied on by other State s as part of their reasonab le progress demonstrations (78 FR 51586).40

consultations in order to develop coordinated management strategies with Oklahoma. Therefore, due to this absence of the development of this critical information during consultations, we believe that Oklahoma did not have adequate information to establish its RPG for the Wichita Mountains, and should have requested that the TCEQ further investigate these sources or requested additional red uctions from Texas sources to ensure that all reasonable measures to improve visibility were included in Texas’ LTS and incorporated into Oklahoma’s RPG for the Wichita Mountains. Thus, the basic intent of our consultation requirements was not realized.

In addition to the explicit statutory requirement under Section 51.308(d)(1)(ii) to consider the four reasonable progress factors, the Regional Haze Rule also establishes an analytical requirement to ensure that each State considers the emission reduction measures necessary to attain the URP. The Regional Haze Rule provides that we will evaluate Oklahoma’s consideration of the four factors in Section 51.308(d)(1)(i)(A), its analysis of the URP required under Section 51.308(d)(1)(i)(B) and the demonstrati on developed pursuant to Section 51.308(d)(1)(ii), “[i]n determining whether the State’s goal for visibility improvement provides for reasonable progress.” As explained in the preamble to the Regional Haze Rule, the URP analysis was adopted to ensure that States use a common analytical framework and to ensure an informed, equitable, and transparent decision making process that would, among other things, ensure that the public would be provided with the information necessary to understand the

emission reduc tions needed, the costs of such measures, and other factors associated with improvements in visibility. We note that this analytical requirement is met only through consultation and is not restricted to the consideration of only those sources within the S tate with the impacted Class I area. As we stated in the Regional Haze Rule regarding this requirement 31 :

In doing this analysis, the State must consult with other States which are anticipated to contribute to visibility impairment in the Class I area un der consideration. Because haze is a regional problem, States are encouraged to work together to develop acceptable approaches for addressing visibility problems to which they jointly contribute. If a contributing State cannot agree with the State

establ ishing the reasonable progress goal, the State setting the goal must describe the actions taken to resolve the disagreement.

However, Oklahoma’s consultation was incomplete. While the analyses developed by CENRAP provide a great deal of information on co ntributions to visibility impairment and a set of potential available add

- on controls and cost associated with those controls, the data was insufficient to fully assess the impacts and available emission reduction measures for Texas

sources. Given the lar ge contributions from sources in Texas and EGU point sources in particular, Oklahoma could not reasonably consider all the emission reductions needed to meet or approach the URP without considering emission reduction measures available for those

sources in Texas that contribute the most to visibility impairment at Wichita Mountains. In summary, we propose to find the following:

 Oklahoma has demonstrated that it is not reasonable to require additional emission reductions for its sources for this planning p eriod.

31 64 FR 35732 (July 1, 1999).41

 BART is a component of developing the RPGs, and the RPGs are inadequate because BART controls were not adequately considered. We note this deficiency is addressed by our BART FIP and the revised Oklahoma SIP.

 Oklahoma’s consultations with Texas were flawed, which prevented it from adequately developing its RPGs for the Wichita Mountains.

 Also because Oklahoma’s consultations with Texas were flawed, Oklahoma did not consider the emission reduction measures necessary to achieve the URP for the

Wich ita Mountains and did not adequately demonstrate that the RPGs it established were reasonable based on the four statutory factors under 51.308(d)(1)(ii).

In consideration of these flaws, we propose to disapprove Oklahoma’s submission under Section

51.308 (d)(1), except for those portions addressing Section 51.308(d)( 1)(vi), which we propose to

approve.

Our Additional Analysis of Impacts from Texas Sources

As the ODEQ itself (and we through our analysis detailed in the FIP TSD and described briefly

below ) have demonstrated, there are large visibility impacts at the Wichita Mountains from outside Oklahoma, the largest percentage coming from point sources in Texas. In addition, we believe the ODEQ has also demonstrated there is the likelihood of a sizeable visibility improvement from controlling a subset of these sources, with likely cost

- effective controls.

As discussed in detail in the FIP TSD , in evaluating the Texas and OK R egional Haze SIPs , we determined that additional technical analyses concerning Texas’ visibility impacts on Class I

areas was necessary. Our modeling study provides information on projected 2018 visibility impacts of individual selected sources that we determined have the greatest potential to impact visibility at surrounding Class I areas. We performed a modeling analysis using CAMx based on the 2018 CENRAP emission inventory and utilized source apportionment for a small subset of sources in Texas, which we selected usin g a Q/ D analysis. In conducting this analysis, we focused on the percent contribution of these Texas sources compared to other sources of visibility impairment. Our study confirms that a small number of Texas sources are responsible for the majority of t he impact from Texas point sources at the Wichita Mountains. For example, the three Texas facilities with the largest predicted impact in 2018, are modeled to contribute a combined 4.25% to the total visibility impairment at Wichita Mountains. These thre e facilities alone have a larger impact than all the point source emissions in any single nearby state, including Oklahoma. The top impacting facility alone has a projected contribution of 1.73% of the total visibility impairment at Wichita Mountains.

We note that in its consultation process ODEQ used a contribution threshold of greater than one inverse megameter (Mm

- 1 ) of light extinction, when determining if emissions from a state were significant and consultation with that state was required. Withou t regard to the suitability of this as a threshold, our modeling study projects that impacts from some individual facilities in Texas in 2018, even after accounting for predicted reductions due to CAIR included in the 2018 CENRAP emission inventory , exceed the 1 Mm

- 1 threshold for the 20% worst days ODEQ selected to apply to an entire state’s impact. For example, our projected impacts in 2018 from the top ten facilities in Texas that impact visibility at Wichita Mountains are summarized in42

Table 1 5 below. We note that, although the modeled impacts from Martin Lake are less than Monticello and Big Brown , we estimate that the predicted emission impacts from this facility would be larger than 1 Mm

- 1 if it were modeled at its recent average annual emission lev el (see

the FIP TSD for more details).

Table 15 . 2018 Phase 1 EPA Source Apportionment Modeling Results, Top T en Modeled

Facilities in Texas that Impact V isibility at Wichita Mountains

Rank Facility Name Extinction (Mm

- 1 ) % Contribution to

Total Visibility Impairment

1 Monticello 1.275 1.73%

2 Big Brown 1.169 1.59%

3 Martin Lake 0.686 0.93%

4 Works No 4 0.635 0.86%

5 Reliant Energy (Limestone) 0.478 0.65%

6 Oklaunion Power 0.417 0.57%

7 Sommers Deely Spruce 0.410 0.56%

8 HW Pirkey Power 0.368 0.50%

9 Coleto Creek 0.354 0.48%

10 Welsh Power 0.349 0.47%

A

. 7

. Reasonable Progress Goal To Be Considered by Administrator

The language under Section 51.308(d)(1)(v), “The reasonable progress goals established by the State are not directly enforceable but will be considered by the Administrator in evaluating the adequacy of the measures in the SIP to achieve the progress goal adopted by the State,” is a statement relating to our review of Regional Haze SIP s. Since it does not require a response from the state, it is not separately evaluated here.

A

. 8

. Reasonable Progress Goal Minimum

Oklahoma may not adopt a reasonable progress goal that represents less visibility improvement than is expected to result from implementation of other requirements of the CAA during the applicable planning period.

State Submittal: Pages 104

- 114, Appendix 4

- 2

The RPGs established by Oklahoma are based on CENRAP 2018 modeling projections. The modeling projecti ons conducted by CENRAP contain projections of the visibility conditions that are anticipated to be realized at each Class I area between the 2002 base ye ar and the 2018 future

year. These projections are based on the emissions reductions resulting from federal and State control programs that are either currently in effect or with mandated future

- year emission reduction schedules that predate 2018, includi ng the LTSs of Oklahoma, Texas, and other states,43

and presumptive emissions reductions expected to result from the submitted Oklahoma BART

rule.

EPA Findings:

ODEQ’s RPGs are based on the visibility improvement predicted by CENRAP’s modeling projection s between the baseline year and 2018 . Since CENRAP’s 2018 modeling projections are based on local, State, and federal control programs that are either currently in effect or with

mandated future

- year emission reduction schedules, the O DEQ’s RPGs represent at least as much visibility improvement as is expected to result from implementation of other requirements

of the CAA (i.e., requirements other than r egional h aze ) during the applicable planning period.

We therefore propose to approve Oklahoma ’s submission under section 51.308(d)(1)(vi) that its RPG for the Wichita Mountains does not represent less visibility improvement than is expected to result from the implementation of other requirements of the CAA during this planning period

.