Meeting
with
EPA
on
BART
Guidelines
Environmental
Defense
June
10,
2005
Peak
Impact
on
Natural
Conditions
Due
to
the
logarithmic
nature
of
the
deciview
scale
and
its
relationship
to
light
extinction
and
pollution
levels,
the
amount
of
pollution
required
to
cause
a
0.5
deciview
visibility
impact
depends
upon
the
background
visibility
levels
against
which
the
impact
is
measured.
Therefore,
a
far
greater
amount
of
pollution
is
required
to
cause
a
0.5
deciview
degradation
in
visibility
if
the
impact
is
measured
against
very
polluted
air
as
opposed
to
relatively
pristine
air
Amount
of
bext
needed
to
reach
dv
change
of
0.5
under
different
assumed
background
reference
bext
0
0.2
0.4
0.6
0.8
1
1.2
10
15
20
Assumed
Background
Extinction
b
e
x
t
n
e
e
d
e
d
t
o
r
e
a
c
h
c
h
a
n
g
e
i
n
d
v
o
f
0
.
5
0.5
NPRM
Conflated
Contribution
and
Causation
Tests
°
Statutory
Text:
A
major
stationary
source
shall
install
BART
if
it
"
emits
any
air
pollutant
which
may
reasonably
be
anticipated
to
cause
or
contribute
to
any
impairment
of
visibility
in
any
area"
(
emphasis
supplied).

°
Congressional
ratification
of
Ethyl
Corp.
v.
EPA,
541
F.
2d
1,
28
(
D.
C.
Cir.
1976)
(
en
banc).

°
Suggested
Approach:
Low
threshold
cumulative
test
that
permits
states
to
exclude
individual
sources
based
on
low
percentage
contribution.
BART
Issues
in
Texas
Key
data
on
TX
power
plants
°
21
units
that
began
operating
in
1980
or
earlier
(
which
we
estimate
would
be
BART
eligible,

assuming
a
3
year
time
horizon
from
binding
contracts
to
operation);
the
average
SO2
rate
2000­
2003
=
0.85
lb/
mmBtu
°
15
units
began
operation
after
1980;
average
SO2
rate
2000­

2003
=
0.50
lb/
mmBtu
°
75%
of
TX
SO2
emissions
come
from
units
that
began
operating
1980
or
earlier
SO
2
Emissions
(
thousand
tons)
2000­

2003
Ave
2010
2015
Texas
SO
2
emissions
without
CAIR
555
417
418
Texas
SO
2
emissions
with
CAIR
N/
A
398
352
Texas
SO2
emissions
achievable
with
BART
(
assumes
85%
reduction
at
all
coal
plants
in
TX
that
meet
age
and
size
criteria
for
BART)
N/
A
213
213
BART
issues
in
TX
(
cont'd)

Strict
application
of
BART
could
yield
greater
SO2
reductions
than
CAIR
 
EPA
estimates
CAIR
limits
SO2
emissions
to
352,000
tons
SO2
by
2015,
compared
with
2015
baseline
of
418,000;
the
implied
controlled
SO2
emissions
rate
at
all
units
=
0.46
lb/
mmBtu
 
We
estimate
BART
could
achieve
an
additional
139,000
tons
beyond
CAIR;
the
implied
controlled
SO2
emissions
at
BART
units
=
0.13
lb/
mmBtu
 
 
Under
the
BART
scenario,
the
average
implied
emissions
rate
for
all
TX
units
assuming
only
the
BART
units
are
controlled
at
85%
(
with
no
additional
reductions
being
made
at
other
units)
would
be
0.28
lb/
mmBtu
 
still
lower
than
CAIR
Western
Issues
Sources
identified
by
the
WRAP
as
potentially
BART­
eligible
account
for
two­
thirds
of
point
source
NOx
emissions
and
three­
quarters
of
point
source
SO
2
emissions
in
the
region.
64%
66%
68%
70%
72%
74%
76%
78%
80%
1996
1997
1998
1999
2000
2001
2002
2003
Average
annual
capacity
factor
of
BART­
eligible
coal­
fired
electric
generating
units
in
the
WRAP
region
64%
66%
68%
70%
72%
74%
76%
78%
80%
1996
1997
1998
1999
2000
2001
2002
2003
Average
annual
capacity
factor
of
BART­
eligible
coal­
fired
electric
generating
units
in
the
WRAP
region
Source:
EIA
F767,
1996
­
2003
State
National
Parks
and
Monuments
with
air
monitoring
National
Parks
and
Monuments
with
worsening
air
pollution
trends
Number
of
potentially
BART
eligible
sources
Total
NOx
emissions
from
potentially
BART
eligible
sources
Total
SO
2
emissions
from
potentially
BART
eligible
sources
AZ
Chiracahua,
Grand
Canyon,
Organ
Pipe,
Petrified
Forest,
Saquaro,

Tonto
Grand
Canyon,

Organ
Pipe,

Petrified
Forest,

Tonto
19
72,000
63,000
CO
Great
Sand
Dunes,

Mesa
Verde,
Rocky
Mountain
Great
Sand
Dunes,

Mesa
Verde,
Rocky
Mountain
18
68,000
85,000
MT
Glacier,
Little
Bighorn,
Yellowstone
Glacier,
Little
Bighorn,
Yellowstone
14
43,000
34,000
NM
Bandelier,
Capulin
Volcano,
Gila
Cliffs
Bandelier,
Gila
Cliffs
16
91,000
62,000
ND
Theodore
Roosevelt
none
11
78,000
157,000
UT
Bryce
Canyon,
Canyonlands
Bryce
Canyon,
Canyonlands
10
38,000
30,000
WY
Yellowstone
Yellowstone
22
91,000
103,000
Western
BART
NOx
Rates
Area
2002
Actual
Presumptive
limits
Alternative
scenario
WRAP
region
368,550
231,520
181,716
Arizona
54,115
38,109
29,276
Colorado
41,239
32,698
24,198
Montana
12,481
4,979
6,638
New
Mexico
62,167
38,251
24,138
North
Dakota
44,600
23,146
17,452
Nevada
27,311
20,114
12,952
South
Dakota
14,954
4,112
3,575
Utah
18,630
9,283
9,284
Washington
15,463
14,206
10,147
Wyoming
77,591
46,623
44,056
Regional
WRAP
NOx
emissions
from
BART­
eligible
coal­
fired
EGUs
under
alternative
emission
rates
NOx:
Western
Health,
Haze
and
Ecosystem
Impacts
°
PM2.5
poses
significant
health
threats
in
the
West,
where
nitrate
is
a
key
constituent.

°
OAQPS
projects
that
19%,
51%
and
80%
of
counties
with
monitors
in
the
Southwest,
Northwest
and
Southern
California,
respectively,
would
be
out
of
attainment
with
either
an
annual
PM2.5
standard
of
14
µ
g/
m3,

or
a
24­
hour
standard
of
30
µ
g/
m3.[
1]

°
Nitrate
concentrations
contribute
up
to
one­
third
of
annual
average
PM2.5
mass
in
western
cities.

°
Annual
average
ammonium
nitrate
concentrations
increased
at
15
national
parks
and
monuments
across
the
Southwest
from
1993
 
2002.[
2]
Increases
were
seen
at
all
of
the
National
Park
Serviceadministered
sites
in
the
region
where
monitoring
was
done,
except
sites
on
the
California
coast.

°
[
1]
OAQPS,
Review
of
the
National
Ambient
Air
Quality
Standards
for
Particulate
Matter:
Policy
Assessment
of
Scientific
and
Technical
Information,
OAQPS
Staff
Paper
 
Second
Draft,
January
2005.

[
2]
Vimont,
J.
(
2003)
Nitrate:
Contribution
to
Visibility,
Presentation
to
Western
Regional
Air
Partnership.

http://
www.
wrapair.
org/
forums/
ioc/
meetings/
030728/
index.
html,
2003.
