1. A Basis for Control of BART Eligible Sources
Gary Kleiman
Regional Haze Meeting
July 24, 2001
A Basis for Control of BART Eligible Sources

2. A Basis for Control of BART Eligible Sources
I. Introduction
II. Regional Haze and Visibility Impairment in the Northeast and Mid-Atlantic States
A review of first regional haze report
A Basis for Control of BART Eligible Sources

3. A Basis for Control of BART Eligible Sources
Light absorption by fine particles
Light scattering by fine particles
Clear line of sight in absence of fine particles
A Basis for Control of BART Eligible Sources

4. (Roosevelt Campobello)
140 Mm-1 / 30 Mm-1
Great Gulf
(Presidential Range)
96 Mm-1/ 27 Mm-1
Moosehorn
(Roosevelt Campobello)
110 Mm-1 / 28 Mm-1
Acadia
144 Mm-1 / 26 Mm-1
Lye Brook
242 Mm-1 / 70 Mm-1
Washington D.C.
189 Mm-1 / 52 Mm-1
Brigantine
Sulfate EC OC
Nitrate
Rayleigh
Crustal
Visibility Conditions on
20% Worst/Best Days
(1997)
A Basis for Control of BART Eligible Sources

5. Visibility Conditions on 20% Worst/Best Days (1997)
Sulfate EC OC
Nitrate
Rayleigh
Crustal
232 Mm-1 / 51 Mm-1
Dolly Sods/Otter Creek
235 Mm-1 / 64 Mm-1
James River Face
193 Mm-1 / 45 Mm-1
Shenandoah
Visibility Conditions on
20% Worst/Best Days
(1997)
A Basis for Control of BART Eligible Sources

6. A Basis for Control of BART Eligible Sources
I. Introduction
II. Regional Haze and Visibility Impairment in the Northeast and Mid-Atlantic States
A review of first regional haze report
III. Best Available Retrofit Technology
A review of BART regulations including CAA, RH rule, and U.S. EPA BART guidance
A Basis for Control of BART Eligible Sources

7. A Basis for Control of BART Eligible Sources
BART Regulations
Identify “visibility impairing pollutants”
Set a low threshold for “subject to BART”
Once “subject to BART”, all visibility impairing pollutants and all BART eligible units must be included in review
Most stringent technologically feasible controls that do not present unreasonable costs, unacceptable energy issues or other non-air quality environmental concerns are considered BART for that source
Presumptive level of control for utility boilers set at 90-95%
“Visibility impairing pollutants” include sulfur dioxide, nitrogen oxides, particulate matter (PM10), volatile organic compounds, and ammonia.
A BART-eligible source is “reasonably anticipated to cause or contribute” to regional haze if the source emits pollutants within a geographic region from which those pollutants can be transported downwind to a Class I area.
Once a source is deemed “subject to BART”, a review must be conducted for each visibility-impairing pollutant emitted at that source and for each unit which contributes to the BART-eligible emissions.
BART review must consider all available control technologies, including both NSPS options which may be available for the source as well as those considered more stringent than NSPS. Those controls that are considered technically feasible must be ranked and an impacts assessment conducted for each. The most stringent controls for a facility that are technologically feasible, that do not present unreasonable costs, unacceptable energy issues or other non-air quality environmental concerns are considered BART for that source.
For utility boiler SO2 control, EPA has set a presumptive level of 90 to 95 percent control efficiency as cost-effective and generally achievable.
A Basis for Control of BART Eligible Sources

8. A Basis for Control of BART Eligible Sources (Cont’d)
IV. Sources of Precursor Pollutants
Geographic identification of source regions using modeling studies and statistical techniques
A Basis for Control of BART Eligible Sources

9. RADM Tagged Species Model
A Basis for Control of BART Eligible Sources

10. Statistical Correlation
A Basis for Control of BART Eligible Sources

11. Trajectory Analysis for Acadia National Park
20% Worst Visibility
A Basis for Control of BART Eligible Sources

12. Trajectory Analysis for Acadia National Park
20% Best Visibility
A Basis for Control of BART Eligible Sources

13. Trajectory Analysis for Brigantine Wilderness Area
20% Worst Visibility
A Basis for Control of BART Eligible Sources

14. Trajectory Analysis for Brigantine Wilderness Area
20% Best Visibility
A Basis for Control of BART Eligible Sources

15. Trajectory Analysis for Lye Brook Wilderness Area
20% Worst Visibility
A Basis for Control of BART Eligible Sources

16. Trajectory Analysis for Lye Brook Wilderness Area
20% Best Visibility
A Basis for Control of BART Eligible Sources

17. A Basis for Control of BART Eligible Sources
Source Apportionment
A Basis for Control of BART Eligible Sources

18. A Basis for Control of BART Eligible Sources
Regions of Influence
A Basis for Control of BART Eligible Sources

19. “Summer Coal” Region of Influence
A Basis for Control of BART Eligible Sources

20. Source Region of Influence
A Basis for Control of BART Eligible Sources

21. Source Region of Influence (Trajectory Start height = 200 meters)
A Basis for Control of BART Eligible Sources

22. Source Region of Influence (Trajectory Start height = 1000 meters)
A Basis for Control of BART Eligible Sources

23. A Basis for Control of BART Eligible Sources (Cont’d)
IV. Sources of Precursor Pollutants
Geographic identification of source regions using modeling studies and statistical techniques
V. Emission Sources and Control Strategies
Analysis of emission sources located within the identified geographic regions that contribute to haze in the Northeast and Mid-Atlantic.
Analysis of potential reductions of visibility impairing pollutants from those sources through BART regulation
A Basis for Control of BART Eligible Sources

24. A Basis for Control of BART Eligible Sources
SO2 Emissions Density
A Basis for Control of BART Eligible Sources

25. A Basis for Control of BART Eligible Sources
SO2 Emissions by State
26 Bart Sectors
Boilers*
Bart Eligible Boilers**
SO2 Emissions (Millions tons/year)
2.0
1.0
A Basis for Control of BART Eligible Sources

26. SO2 Emissions from Title IV affected EG Boilers
1999 SO2 tons
25,000
500,000
1,000,000
A Basis for Control of BART Eligible Sources
Sources: EIA-767, 1999 Emissions Scorecard

27. SO2 Emissions Reductions from Potentially BART Eligible Sources
PA OH IL IN KY WV GA NC AL MI MO MD SC MS MA VA WI NY MN IA TN NH NJ CT DE ME DC AR RI VT
A Basis for Control of BART Eligible Sources

28. BART Program SO2 Reductions
1999 Emissions in Source Region
5,630,789 tons # 1
SO2 Emissions (100,000 Tons/yr) 2
* US EPA Clean Air Markets Program
1999 Emissions Scorecard 387 boiler units at 164 sources
A Basis for Control of BART Eligible Sources

29. BART Program SO2 Reductions
Emissions in Source Region after BART
621,076 tons
* US EPA Clean Air Markets Program
1999 Emissions Scorecard 312 boiler units at 164 sources
A Basis for Control of BART Eligible Sources

30. A Basis for Control of BART Eligible Sources
NOX Emissions Density
Tons/sqmile
A Basis for Control of BART Eligible Sources
Data provided by US EPA Net Inventory (1996) and Environment Canada (1995).

31. NOX Point Source Emissions by State
26 Bart Sectors
Boilers*
Bart Eligible Boilers**
NOx Emissions (Millions tons/year)
1.0
2.0
NOX Point Source Emissions by State
A Basis for Control of BART Eligible Sources

32. NOX Emissions from Boilers
1999 NOx tons
,000
80,000
180,000
400,000
A Basis for Control of BART Eligible Sources
Sources: EIA-767, 1999 Emissions Scorecard

33. NOX Emissions Reductions from Potentially BART Eligible Sources
OH KY IL WV IN MO PA NC GA TN MI AL MS MN MD SC WI NY IA MA VA NJ CT NH AR DE ME DC RI VT
Tons/year
A Basis for Control of BART Eligible Sources

34. BART Program NOX Reductions
1999 Emissions in Source Region
2,193,836 tons # 1
NOx Emissions (100,000 Tons/yr) 2
* US EPA Clean Air Markets Program
1999 Emissions Scorecard 387 boiler units at 164 sources
A Basis for Control of BART Eligible Sources

35. BART Program NOX Reductions
Emissions in Source Region after BART
161,568 tons
* US EPA Clean Air Markets Program
1999 Emissions Scorecard 387 boiler units at 164 sources
A Basis for Control of BART Eligible Sources

36. A Basis for Control of BART Eligible Sources (Cont’d)
VI. The Relationship of BART to Other Control Programs
Discussion of the BART Control Strategies in the context of other regulatory programs:
Acid Rain Program
NOX SIP Call
PM2.5 NAAQS
VII. Conclusion
A Basis for Control of BART Eligible Sources