Best Available Retrofit Technology (BART) Process November 15, 2006

Eric C. Massey, ManagerAir Quality Compliance Section

November 15, 2006 BART Process 2

WRAP Identification of Potentially BART Eligible Sources

April 4, 2005 SSJF ReportIdentified potentially BART applicable sources in Arizona

• 26 listed source categories (categorical sources)• Identified in-service dates for major emissions

units at source• Identified sources with total potential emissions

>250 TPY of visibility impairing pollutantsReport identified 18 potentially BART eligible sourcesReport also identified 5 additional sources that had unknown BART status

November 15, 2006 BART Process 3

State Specific Analysis RequiredPrior to making a subject-to-BART determination additional information was necessary

Clarify BART eligibility of sources in April 2005 report (i.e. unknown, potentially, likely, etc.)Specifically identify potentially BART-eligible emissions unitsIdentify the modeling parameters and emissions rate information for potentially BART-eligible emissions units

November 15, 2006 BART Process 4

Identification of Potentially BART Eligible Emissions Units

Information gathering tools:Title V permits and applicationsStationary source emissions inventoriesWeb research

5 unknown sources qualified first1 source obtained non-major source permit2 sources we determined to be non-categorical1 source did not appear to exist1 source was recommended to be listed as potentially BART-eligible.

November 15, 2006 BART Process 5

Process for Identifying Potentially BART-Eligible Emissions Units

Applied EPA’s June 15, 2005 BART rule criteria:Identify specific emissions units

• Non-Categorical = non-BART eligibleDates of construction for emissions units at categorical sources examined

• Outside 8/7/62 through 8/7/77 time frame = non-BART eligible

Reviewed stationary source emissions inventories and the NEI

• Actual emissions of visibility impairing pollutants from potentially BART eligible emissions units < 250 TPY = non-BART eligible

• If emissions ~250 TPY, then additional research required

November 15, 2006 BART Process 6

Phase I – Potentially BART-Eligible Emissions Unit Review

Completed June 9, 2006 through letter to RMC requesting modeling assistance

Identified 30 potentially eligible emissions units at 14 FacilitiesDetails of analysis provided in Technical Support DocumentTSD recommended additional research for 2 other emissions units

November 15, 2006 BART Process 7

Phase II – Potentially BART-Eligible Emissions Units Review

Modeling input data gatheringStandard Permit Application forms

• Include important stack height and exhaust characteristic information

• Include source provided estimates of potential to emit for criteria pollutants

Performance testing data• Some exhaust characteristic information• Actual emissions information if necessary

Majority of information sent to RMC on 10/30/06

Develop preliminary list of emissions units that are potentially subject-to-BART

November 15, 2006 BART Process 8

Phase III – Potentially BART-Eligible Emissions Unit Review

Written contact with facilitiesIdentify potentially subject-to-BART emissions unitsRequest response within specified time frame

• Conduct BART analysis for visibility impairing pollutants

• Provide documentation demonstrating that emissions unit should not be subject-to-BART

Based upon responses, make official subject-to-BART determinations

November 15, 2006 BART Process 9

Questions?