                                                                        
                                                        Technical
Support Document for the Modeling Portions of the State of West
Virginia’s Regional Haze State Implementation Plan (SIP) 

Entitled “West Virginia Regional Haze

State Implementation Plan to Preserve, Protect and Improve

Visibility in Class I Federal Areas

Final

June 2008”

TSD Prepared February, 2011

Todd A. Ellsworth

Office of Air Monitoring and Analysis, 3AP40

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

______________________/s/______________________

Reviewed by Walter Wilkie, Associate Director,

Office of Air Monitoring and Analysis (3AP40)

_________3/11/2011________

Date Signed

Technical Support Document for the Modeling Portions of the State of
West Virginia’s Regional Haze State Implementation Plan (SIP) Entitled
“West Virginia Regional Haze

State Implementation Plan to Preserve, Protect and Improve

Visibility in Class I Federal Areas

Final

June 2008”

Purpose of the Technical Support Document

This Technical Support Document (TSD) describes the Environmental
Protection Agency’s (EPA’s) evaluation of the modeling portions of
West Virginia’s State Implementation Plan (SIP) revision entitled
“West Virginia Regional Haze State Implementation Plan to Preserve,
Protect and Improve Visibility in Class I Federal Areas Final June
2008”.  This SIP revision will hereafter be referred to as the West
Virginia (WV) Haze SIP.

The purpose of this TSD is to provide more detailed information than can
be contained in the official notice published in the Federal Register. 
Readers who need more information than we provide in this TSD or want to
review the modeling in more detail should read the above referenced West
Virginia Haze SIP.  

The Regulatory Framework 

In section 169A(a)(1) of the 1977 Amendments to the CAA, Congress
created a program for protecting visibility in the nation’s national
parks and wilderness areas.  This section of the CAA establishes as a
national goal the “prevention of any future, and the remedying of any
existing, impairment of visibility in mandatory Class I Federal areas
which impairment results from manmade air pollution.”  On December 2,
1980, EPA promulgated regulations to address visibility impairment in
Class I areas that is “reasonably attributable” to a single source
or small group of sources, i.e., “reasonably attributable visibility
impairment” (RAVI).  See 45 FR 80084.  These regulations represented
the first phase in addressing visibility impairment.  EPA 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 were improved. 

 

Congress added section 169B to the CAA in 1990 to address regional haze
issues.  EPA promulgated a rule to address regional haze on July 1, 1999
(see 64 FR 35713), the Regional Haze Rule (RHR).  The RHR revised the
existing visibility regulations to integrate into the regulation
provisions addressing regional haze impairment and established a
comprehensive visibility protection program for Class I areas.  The
requirements for regional haze, found at 40 CFR 51.308 and 51.309, are
included in EPA’s visibility protection regulations at 40 CFR
51.300-309.  

The RHR addressed the combined visibility effects of various pollution
sources over a wide geographic region.  40 CFR 51.308(b) requires states
to submit the first implementation plan addressing regional haze
visibility impairment no later than December 17, 2007.  Consequently,
all 50 states, including those without Class I areas, Washington, D.C.,
and the Virgin Islands, are required to submit Regional Haze SIPs. The
USEPA designated five Regional Planning Organizations (RPOs) to assist
with the coordination and cooperation needed to address the visibility
issue. West Virginia is among those states that make up the southeastern
portion of the contiguous United States known as VISTAS (Visibility
Improvement – State and Tribal Association of the Southeast), and
includes the eastern band of the Cherokee Indians in addition to the
following states: Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee, and Virginia (See Figure 1). 
Studies show that West Virginia significantly contributes visibility
impairment in the following Class I areas: Dolly Sods Wilderness Area,
Otter Creek Wilderness Area, James River Face Wilderness Area, Linville
Gorge Wilderness Area, and Shenandoah National Park. With the help of
the Visibility Improvement - State and Tribal Association of the
Southeast (VISTAS) RPO, West Virginia has developed a SIP to address
visibility impairment in all of these Class I Federal Areas.   Figure 2
shows the 18 mandatory Federal Class I areas in the VISTAS Region.   

Figure 1. Geographical Areas of Regional Planning Organizations

 

                                                                        
                                                                        
                

             

 Figure 2. Class I Areas in the VISTAS Region 

                          

Introduction to West Virginia’s Visibility State Implementation Plan  
                    EPA promulgated a rule to address regional haze on
July 1, 1999 (see 64 FR 35713), the RHR.  The RHR addressed the combined
visibility effects of various pollution sources over a wide geographic
region.  40 CFR 51.308(b) requires states to submit the first
implementation plan addressing regional haze visibility impairment no
later than December 17, 2007.

This SIP was developed based on consultations and work-products of the
VISTAS Regional Planning Organization (RPO). It encompasses 1)
monitoring strategies for evaluating visibility impacts, 2) baselines
and trends, 3) long-term strategies (LTS), 4) how West Virginia meets
its fair share of the “reasonable progress goals” (RPG) towards
reducing visibility impairment in Class I areas, and 5) Best Available
Retrofit Technology (BART).  VISTAS states agreed upon a ≥ 1 percent
sulfate attribution to a Class I area in order for an upwind state to
meet the definition of “significantly contributing” to visibility
impairment for that Class I area. Studies show that West Virginia
significantly contributes visibility impairment in the following Class I
areas: Dolly Sods Wilderness Area, Otter Creek Wilderness Area, James
River Face Wilderness Area, Linville Gorge Wilderness Area, and
Shenandoah National Park. Therefore, this SIP focuses on how West
Virginia’s control measures will improve visibility in these areas.   
 

The West Virginia Division of Air Quality (WVDAQ) believes their Haze
SIP demonstrates that West Virginia has met its BART, RPG and LTS
obligations for the first visibility impairment planning period through
existing West Virginia/Federal regulations and on-the-books/on-the-way
federal emission controls. In addition to extensive consultation with
the VISTAS states, West Virginia has consulted with Federal Land
Managers (FLMs) responsible for the Class I areas, and the EPA in the
development of this SIP.

What Are The Components Of A Modeled Regional Haze Demonstration?

Modeling Process Overview                                               
                                                                        
                  

The goal of the regional haze program is to return to natural conditions
by 2064, and

States are required to demonstrate, by the end of the first planning
period ( by 2018), reasonable progress toward meeting that goal. 

West Virginia is a member of the VISTAS RPO.  The VISTAS RPO was tasked
with the assignment of preparing a PM2.5 modeling platform that all
member states could use to model their LTSs to demonstrate reasonable
progress by 2018 in meeting the ultimate goal of natural visibility
conditions by 2064.  

 The regional haze modeling was coordinated by the Southeast Regional
Planning Organization, Visibility Improvement State and Tribal
Association of the Southeast (VISTAS), which is comprised of the ten
Southeast States (Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee, Virginia and West Virginia)
and the local programs and tribal agencies located within these states.
VISTAS contracted with Environ International Corp, Alpine Geophysics,
LLC and the University of California Riverside to perform the emissions
and air quality modeling for this regional haze state and tribal
implementation plans.

                                                                        
                                                             

The VISTAS RPO used the Community Multi-scale Air Quality model (CMAQ)
version 4.5.1 as its photochemical grid model.  The model uses
simulations of chemical reactions, emission of PM2.5   and PM2.5
precursors and a sophisticated meteorological model (The Pennsylvania
State University/National Center for Atmospheric Research Mesoscale
Meteorological Model (MM5)) to produce speciated PM2.5 concentrations
over the eastern United States.  The meteorological data used in the
meteorological model was for the 2002 base year.  The photochemical grid
model was run with the base year meteorology and base year emissions to
determine if the model performance was satisfactory.  Once the model
performance was determined to be adequate, PM 2.5 concentrations were
modeled by running the model with projected emissions for 2009 and 2018
and the original 2002 meteorology. The meteorology was held constant so
that the results of changing the emissions would not be influenced by
changing meteorology.

The EPA modeling guidance recommends that modeling be used to develop
relative response factors for each of 6 components of particulate matter
between a base period (2000-2004) and a future 5-year period which will
be reviewed in 2018.  PM components used for regional haze-related
applications are:

- mass associated with sulfates;

- mass associated with nitrates;

- mass associated with organic carbon;

- mass associated with elemental carbon;

- mass associated with fine soil (i.e., crustal material);

- mass associated with coarse particulate matter (i.e., PM10 - PM2.5).

Current speciated measurements in a Class I area are used in an
empirically derived equation to estimate light extinction for each day
with measurements. Days are ranked according to their resulting light
extinction (measured in deciviews). This ranking is used to identify the
20% of days with worst and 20% of days with best visibility during each
year in the base period. The 20% worst and best days are examined to
estimate appropriate observed concentrations for the components of PM on
“best” and “worst” days. Observed component concentrations are
multiplied by the corresponding relative response factors to estimate
future concentrations for each component on “best” and “worst”
days. Future component concentrations are then inserted into the
equation relating light extinction to concentrations of particulate
matter. The resulting estimates for future light extinction on
“best” and “worst” days are compared with observations made
during the base period to assess the future year visibility improvement
and demonstrate reasonable progress by 2018 in meeting the ultimate goal
of natural visibility conditions by 2064.  

                                                                        
                                                        

Steps Required in Modeling Future Year Visibility Improvement

The modeling guidance lists nine steps for preparing modeling to
demonstrate reasonable progress toward visibility improvement goals.    

1. Develop a conceptual description of the problem to be addressed.

2. Select an appropriate model to support the demonstration.

3. Select appropriate meteorological time periods to model.

4. Choose an appropriate area to model with appropriate
horizontal/vertical resolution                                          
   and establish the initial and boundary conditions that are suitable
for the application.

5. Generate meteorological inputs to the air quality model.

6. Generate emissions inputs to the air quality model.

7. Run the air quality model with base case emissions and evaluate the
performance.

    Perform diagnostic tests to improve the model, as necessary.

8. Perform future year modeling (including additional control
strategies, if necessary) and 

    use the results to calculate future year visibility and visibility
improvement.

How Did West Virginia Address All Of The Components a Modeled
Demonstration Of  Future Year Visibility Improvement?

The West Virginia Haze SIP addresses each of the required elements of a
modeling analysis used to predict visibility improvement that is
expected by 2018. 

Conceptual Description of the Problem

A conceptual model describes how weather patterns affect the formation
and transport of PM2.5, accounting for emissions and photochemistry. 

The conceptual model for the West Virginia PM2.5 SIP is described in
Appendix B of the WV Haze SIP.  Air Resources Specialists, Inc (ARS) was
contracted by VISTAS to develop a conceptual description of the current
visibility in the VISTAS area as it relates to meteorology and source
distribution.  This document was prepared in accordance with EPA
guidance.  

Ammonium sulfate is the largest contributor to visibility impairment on
the 20% haziest

days in the baseline 2000-2004 period (69-74%) at all the IMPROVE sites
in the VISTAS region except Everglades National Park in Florida, where
Ammonium sulfate is a close second to Particulate Organic Material (
POM) (40 and 45%, respectively). Particulate Organic Material (also
referred to as organic carbon) is the second largest contributor to
aerosol extinction at all other sites, contributing to between 13 and
18% of aerosol extinction on the worst days.  Baseline conditions for
20% worst days at the inland sites (182.2 - 241.4 Mm-1) average higher
WV Regional Haze SIP Appendix B.1 – 494 3- 18 than conditions measured
at the coastal sites (116.4 - 147.3 Mm-1).

Ammonium sulfate is also the largest contributor to visibility
impairment on the 20% best

days (45-59%), with large contributions from ammonium nitrate (9-21%)
POM (11-19%). Sea salt is not a factor on the 20% worst days, but for
the 20% best days it contributes to between 2 and 7% of the aerosol
extinction at the VISTAS coastal sites.

Ammonium sulfate, Coarse Mass(CM) and POM are the largest contributors
to total mass on the 20% best and worst days. CM, although it is a
factor for total mass, has a low extinction efficiency and does not
contribute significantly to aerosol extinction. Ammonium sulfate
contributes more significantly to aerosol extinction because it readily
absorbs water vapor in the air.  

For most inland sites, the 20% haziest days are most likely to occur in
the summer, and

the 20% best days occur most frequently during the winter. For coastal
sites, the 20% haziest days can occur year round, with the summer days
being dominated by ammonium sulfate, while the worst days that occur
between October and February have large contributions from ammonium
sulfate, POM and sometimes ammonium nitrate

Sulfate is the key particle constituent from the standpoint of designing
control strategies to improve visibility conditions in the VISTAS
states. Significant further reductions in ambient sulfate levels are
achievable, though they will require more than proportional reductions
in SO2 emissions.

Modeling Platform

Currently one regional-scale air quality models has been evaluated and
used by VISTAS to perform air quality simulations. This is the Community
Multi-scale Air Quality modeling system (CMAQ; Byun and Ching, 1999).  
CMAQ was developed by USEPA.   CMAQ has undergone extensive community
development and peer review (Amar et al., 2005) and has been
successfully used in a number of regional air quality studies (Bell and
Ellis, 2003; Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and
Talbot, 2003; Mebust et al., 2003). 

Modeling for regional haze was performed by VISTAS for the ten
Southeastern states, including West Virginia. The sections below outline
the methods and inputs used by VISTAS for the regional modeling.
Additional details are provided in Appendices C, D and M of the WV Haze
SIP.

Meteorological Time Periods Used in the Modeling

VISTAS selected all days in the year 2002 as the modeling time period
for this demonstration. Meteorological inputs were developed for 2002
using the meteorological model. Emissions inventories were also
developed for 2002 and processed through the emissions model. These
inputs were then used in the air quality model to predict fine particle
mass and visibility.  The 2002 base year represents the baseline period
from 2000 to 2004.  CMAQ simulations were performed for the 2002 Base
Case, 2009 and 2018 Base Case, and 2009 and 2018 Control Case. All
scenarios adopt the same meteorological field (2002) and boundary
conditions, varying only emission inputs. 

Meteorological Data Used in the Air Quality Model

The VISTAS states decided to use a prognostic meteorological model that
provides life-like meteorological inputs to the photochemical grid
model.  The Pennsylvania State University/National Center for
Atmospheric Research Mesoscale Meteorological Model (MM5) version 3.6
was chosen for the modeling analysis.  The MM5 model provides a
reasonable representation of weather conditions at the surface and
aloft.  

Domain of the Model, Horizontal/Vertical Resolution and the Initial and
Boundary Conditions

VISTAS has adopted the Inter-RPO domain description for its modeling
runs.  

This 36-km domain covers the continental United States, southern Canada
and northern

Mexico. The dimensions of this domain are 145 and 102 cells in the
east-west and north-south directions, respectively (see Figure 3). To
achieve finer spatial resolution in the VISTAS states, a one-way nested
high resolution (12-km grid resolution) was used. Figure 4 shows the
12-km grid, modeling domain for the VISTAS region. This is the modeling
domain for which the reasonable progress goals are assessed. 

Figure 3. The MM5 horizontal domain is the outer most, blue grid, with
the CMAQ 36-km domain nested in the MM5 

Figure 4. A More Detailed View of the 12-km Grid Over the VISTAS Region 

   

 

Vertical resolution is the number of layers and the size of each layer
in the model.  The layers in the photochemical grid model were set up to
be compatible with the model that produced meteorological conditions for
the photochemical grid model.  The vertical resolution used in the
modeling exercise followed EPA’s modeling guidance and therefore
adequately represents the atmosphere where PM2.5 and its precursors are
emitted and transported.  

Baseline and Future Year Emission Inventories for Modeling 

Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires the
States to identify the baseline emission inventory on which strategies
are based. The baseline inventory is intended to be used to assess
progress in making emission reductions. Based on EPA guidance entitled,
2002 Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM 2.5,
and Regional Haze Programs, which identifies 2002 as the anticipated
baseline emission inventory year for regional haze, VISTAS and the State
of West Virginia are using 2002 as the baseline year. Future year
inventories were developed for 2009 and 2018 based on the 2002 base
year. The future year emission inventory include emissions growth due to
projected increases in economic activity as well as the emissions
reductions due to the implementation of control measures. 

The 2002 emissions were first generated by the individual states in the
VISTAS area. The VISTAS contractor generated the future year emissions
inventories for 2009 and 2018 for

the regional haze modeling. The 2002 emissions from non-VISTAS areas
within the modeling domain were obtained from other Regional Planning
Organizations for their corresponding areas. These Regional Planning
Organizations included the Mid-Atlantic/Northeast Visibility Union, the
Midwest Regional Planning Organization and the Central Regional Air
Planning Association. 

The complete inventory and discussion of the methodology is contained in
Appendix D of the West Virginia Haze SIP.

Model Performance Evaluation

mance goals are: Mean Fractional Error (MFE) ≤ +50%, and Mean Fraction
Bias (MFB) ≤ ±30%; while the criteria are proposed as: MFE ≤ +75%,
and MFB ≤ ±60%. CMAQ prediction of PM2.5 species from STN sites and
IMPROVE sites within the VISTAS Region were paired with measurements and
statistically analyzed to generate MFE and MFB values. Considering CMAQ
performance in terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and
PM2.5 all had the majority of data points within the goal curve, some
were between the goal and acceptable criteria, and only a few were
outside the criteria curve. Only fine soil has the majority of points
outside the criteria curve, but there were some sites still within the
goal. For the VISTAS region, CMAQ performs best for PM2.5 sulfate,
followed by PM2.5, EC, nitrate, OC, and then fine soil. Regional haze
modeling also requires CMAQ performance evaluation for aerosol
extinction coefficient (Bext) and the haze index.   Modeled daily
aerosol extinction at each improve site was calculated following the
IMPROVE formula with modeled daily PM2.5 species concentration and
relative humidity factors from IMPROVE. The approach used natural
background visibility estimates and the haze index following EPA
Guidance. The modeled Bext showed a near 1:1 linear relationship with
IMPROVE observed Bext. 

Overall, WVDAQ found model performance to fall within acceptable limits.
The WVDAQ further asserts that the one atmosphere modeling performed by
the VISTAS contractors is representative of conditions in the
southeastern states and is applicable for use in setting reasonable
progress goals for the Class I areas.

Uniform Rate of Progress Goals

The key difference between SIPs from States with Class I areas and those
States without Class I areas, but may have sources that impact
visibility on Class I areas, is the calculation of the baseline and
natural visibility for their Class I areas and the determination of
uniform rate of progress goals - expressed in deciviews - that provide
for reasonable progress towards achieving natural visibility by 2064. 
It is the Class I states responsibility assess these calculations. The
Class I States must also consult with those States, which may reasonably
be anticipated to cause or contribute to visibility impairment in their
Class I areas (40 CFR 51.308 (d)(1)(i-vi)). 

The baseline visibility conditions are calculated for the baseline
period between 2002 and 2004. The average impairment for the 20 most and
20 least impaired days are determined for each calendar year and
compiled into the average of three annual averages (40 CFR 51.308
(d)(2)(i)). The natural visibility conditions are determined for the
same baseline period with the most and least impaired days determined by
available monitoring data or an appropriate data analysis technique (40
CFR 51.308 (d)(iii-iv)). 

U.S. Environmental Protection Agency (EPA) released guidance on June 7,
2007 to use in setting reasonable progress goals. The goals must provide
improvement in visibility for the most impaired days, and ensure no
degradation in visibility for the least impaired days over the State
Implementation Plan (SIP) period. The State must also provide an
assessment of the number of years it would take to attain natural
visibility condition if improvement continues at the rate represented by
the reasonable progress goal. Figure 5 illustrates an example of how
Uniform Rate of Progress is calculated.  

                                                                        
                              

Figure 5.  Example calculation of Uniform Rate of Progress

Modeled Visibility Projections for 2018

The CMAQ air quality model was used to simulate base period emissions
and future emissions.  The modeling results for the base year period
(2002) and the year representing the end of the first planning period
(2018) are used to develop relative response factors (RRF) for each
component of particulate matter identified previously in this TSD.  The
relative response factors are multiplied by the measured species
concentration data during the base period (for the measured 20% best and
worst days). This results in daily future year species concentrations
data. The projected concentrations are then used to derive daily
visibility in deciviews and are averaged across all best and worst days
to create the projected future visibility. The results of this procedure
are plotted along with the uniform progress glide slope in Appendix M of
the West Virginia Haze SIP.   

The modeling results presented in Appendix M of the West Virginia Haze
SIP show all VISTAS sites are projected to meet or exceed the uniform
rate of progress goals for 2018 on the 20 percent worst days. In
addition, no site anticipates increases in visibility impairment
relative to the baseline on the 20 percent best days. 

                                                                        
                                                           Summary of
Photochemical Grid Modeling Results

In summary, the photochemical grid modeling, presented in the West
Virginia Haze SIP, follow EPA’s modeling guidance and is acceptable to
EPA.  All VISTAS Class I sites are projected to meet or exceed the
uniform rate of progress goal for 2018 on the 20 percent worst days. In
addition, no site anticipates increases in visibility impairment
relative to the baseline on the 20 percent best days. 

Contribution Assessment

The 1999 Regional Haze Rule requires States and Tribes to submit State
Implementation Plans (SIPs) to the U.S. Environmental Protection Agency
(USEPA) for approval by January 2008 at the latest. The haze SIPs must
include a “contribution assessment” to identify those states or
regions that may be influencing specially protected federal lands known
as Federal Class I areas. These states or regions would then be subject
to the consultation provisions of the Haze Rule. The Haze Rule also
requires a “pollution apportionment” analysis as part of the
long-term emissions management strategy for each site.

As described in the Conceptual Description portion of this TSD, sulfate
alone accounts for anywhere from one-half to two-thirds of total fine
particle mass on the 20 percent haziest days at VISTAS Class I sites. As
a result of the dominant role of sulfate in the formation of regional
haze in the VISTAS area, VISTAS concluded that an effective emissions
management approach would rely heavily on broad-based regional SO2
control efforts in the eastern United States.

Area of Influence for VISTAS Class I Areas 

There are 20 Class I areas located in the VISTAS area. The objective of
the VISTAS Area of Influence analysis is to identify the geographic
source regions that are contributing to visibility impairment at the
Class I areas on the worst 20 percent visibility days. This information
is being used by the VISTAS states as part of the evaluation and
demonstration of reasonable progress toward visibility improvement in
Class I areas. In order to identify states whose emissions are most
likely to influence visibility in VISTAS Class I areas, VISTAS prepared
a report entitled “VISTAS Area of Influence Analyses” located in
Appendix M of the West Virginia Haze SIP.  

Based on that work, VISTAS concluded that it was appropriate to define
an “Area of Influence” (AOI) including all of the states
participating in VISTAS plus other states outside VISTAS for which
analyses indicated they contributed at least one percent (1%) of the
sulfate ion in VISTAS Class I areas in 2002. 

Contribution Assessment Results

VISTAS States decided that any state or region that contributed at least
1 percent of total sulfate observed on 20 percent worst visibility days
in 2002 is contributing significantly to the haze problem in that
particular Class I area.  

With respect to sulfate, the Contribution Assessment estimated emissions
from within VISTAS in 2002 contributed significantly to the total
sulfate at Class I areas located within and nearby to the VISTAS region
(see Appendix M of the West Virginia Haze SIP). The contribution of
sulfate at these Class I areas from other regions outside the VISTAS
were also significant. 

Studies showed that West Virginia “contributes” to the following
Class I areas: Dolly Sods Wilderness Area, Otter Creek Wilderness Area,
James River Face Wilderness Area, Linville Gorge Wilderness Area, and
Shenandoah National Park. Therefore, this SIP focuses on how West
Virginia’s control measures will improve visibility in these areas.   
 

  

BART 

On July 6, 2005 (70 FR 39104) EPA finalized 40 CFR 51 – Regional Haze
Regulations and Guidelines for Best Available Retrofit Technology (BART)
Determinations addressing the issues from the Circuit Court decisions.
The BART requirements were most recently updated on October 5, 2006.
BART is defined as an emission limitation based on the degree of
reduction achievable through the application of the best system of
continuous emission reduction for each pollutant, which is emitted by a
BART-eligible source. The changes to the rule included how the States
would identify the best system of continuous emission control technology
and by which States can consider an individual facility’s contribution
to regional haze when determining to require controls, and what the
level of control should be met. The rule changes also clarified the
requirements associated with demonstrating how emissions trading or
alternative programs may be used as an alternative to applying Best
Available Retrofit Technology (BART) Requirements. 

 

Congress defined sources potentially subject to BART - as major
stationary sources, including reconstructed sources; from one of 26
identified source categories which included utility and industrial
boilers, and large industrial plants such as pulp mills, refineries and
smelters; which have the potential to emit 250 tons per year or more of
any air pollutant, and which were placed in operation between August
1962 and August 1977. [CAA 169A (b)(2)(A) & (g)(7)].

Five Factor Analysis for Each BART Source 

States are required to determine BART for each BART-eligible source.
According to 40 CFR 51.308(e)(1)(ii)(A) the determination of BART must
be based on an analysis of the best system of continuous emission
control technology available and associated emission reductions
achievable. 40 CFR 51.308(e)(1)(ii)(A) requires the analysis to take
into consideration the following five factors for the technology
available : 

1) The costs of compliance, 

2) The energy and non-air quality environmental impacts of compliance,
any 

3) Pollution control equipment in use at the source, 

4) The remaining useful life of the source, and 

5) The degree of improvement in visibility which may reasonably be
anticipated to result from use of the technology. 

Under the BART Guidelines, WVDAQ may consider exempting some sources
from   BART if it is found that they do not cause or contribute to
visibility impairment in a Class I area. In accordance with the BART
guidelines, WVDAQ chose to perform source-specific analyses to determine
which sources cause or contribute to visibility impairment using the
California Puff Model (CALPUFF). The CALPUFF modeling protocol used for
determining which facilities are subject to BART is included in Appendix
H of the WV Haze SIP. In accordance with the Guidelines, a contribution
threshold of less than 0.5 deciviews was employed for determining which
sources were exempt from BART.

CALPUFF is a multi-layer, multi-species, non-steady state puff
dispersion model which can simulate the time and space varying
meteorological conditions on pollutant transport, transformation and
removal. CALPUFF uses three dimensional meteorological fields developed
by the meteorological processing program CALMET. 

CALPUFF contain algorithms for near source effects such as building
downwash, traditional plume rise, partial plume penetration, sub-grid
scale terrain interactions, as well as long range effects such as
pollutant removal (dry and wet deposition), chemical transformation,
vertical wind shear, over-water transport, and coastal interaction
effects.

The CALPUFF modeling performed for all of West Virginia’s BART sources
conforms to EPA modeling guidance.  A detailed description of the
CALPUFF modeling can be found in Appendix H of the West Virginia Haze
SIP. 

West Virginia Sources Subject to BART

 Twenty-one (21) of West Virginia’s twenty-two (22) BART-eligible
sources submitted exemption modeling demonstrations. Nineteen (19) of
the twenty-one (21) sources were able to demonstrate exemption.
Additional details are available in Appendix H. Capitol Cement
(003-00006) was the only BART-eligible source which chose not to submit
exemption modeling.

Although PPG Industries initially modeled a visibility impact greater
than 0.5 deciviews on multiple Class I areas, PPG elected to accept a
permit limit on its BART eligible unit which reduces its visibility
impact to below the exemption threshold of 0.5 deciviews of impact at
any Class I area. Permit, R14-027B, requires 4690.56 tpy of SO2 emission
reductions from Boiler #5 by May 1, 2008. Therefore, PPG is considered
BART exempt.

Only Dominion’s Mt. Storm Power Station in Mt. Storm was unable to
demonstrate a

contribution of less than 0.5 deciview at all Class I area within 300 km
from their BART eligible sources. Therefore, Mt. Storm was the only
source considered to be “subject to BART” and required to submit a
permit application, containing their evaluation of potential BART
options and a proposed BART determination. Mt. Storm submitted a BART
determination on November 3, 2006. A copy of the BART determination was
sent to EPA and the Federal Land Managers for review on January 22,
2007.  On September 5, 2007 the company submitted a permit application
to incorporate the results of the BART determination. The WVDAQ
published a legal ad, which commenced the thirty day public comment
period, on September 18, 2007. A copy of the application and draft
permit were sent to the Federal Land Managers for review, via email, on
September 17, 2007. Permit R13- 2735 was issued December 13, 2007. [See
Appendix L for copies of application, draft permit and final permit.]
The current PM controls at Mt. Storm were determined to satisfy BART,
however, the allowable PM10 emission rate was lowered from 0.05 lb/mmBtu
to 0.03 lb/mmBtu, resulting in a reduction of up to 508 tpy per unit, or
a maximum reduction of 1524 tpy. 

Capitol Cement in Martinsburg chose not to submit exemption modeling,
but simply to acknowledge that Kiln 9 was BART-subject. Capitol Cement
had previously applied for and been granted a PSD (Prevention of
Significant Deterioration) permit (R14-026, issued June 2, 2005) for the
replacement of two existing long wet process cement kilns and associated
clinker coolers with a modern precalciner system and associated
equipment. The only BART-eligible unit at the facility (Kiln 9) was one
of the two kilns being replaced, and the permit included a requirement
for the permanent shutdown of the existing kilns when full-production
was achieved with the replacement kilns, or no later than 180 days after
startup. Therefore, the company requested that the permit be modified to
require the permanent shutdown of the Kiln 9 system by the BART
compliance deadline or when full-production was achieved with the
replacement kilns, or no later than 180 days after startup, whichever
came first. The WVDAQ issued an Administrative Update to permit R14-026B
on October 11, 2006, requiring that “Operation of the existing kiln 9
system shall permanently cease after the pre-heater-precalciner kiln 
system achieves full production or within 1280 days after the
pre-heater-precalciner kiln system first becomes operational or before
the BART compliance deadline  (approximately 2013) whichever comes
first”. [See Appendix L for copies of letter and permit.] The
modifications at Capitol Cement are expected to result in 1,741.51 tpy
of SO2 reductions, 1,374.81 tpy of NOx reductions, and 66.01 tpy of PM10
reductions. 

 Summary of EPA’s Technical Findings

The technical analyses and modeling used to assess uniform rate of
progress and to support the LTS were successfully developed consistent
with EPA’s interim and final modeling guidance.  All VISTAS sites and
MANE-VU sites, significantly impacted by VISTAS sources, are projected
to meet or exceed the uniform rate of progress goal for 2018 on the 20
percent worst days. In addition, no site anticipates increases
visibility impairment relative to the baseline on the 20 percent best
days. The technical analyses and modeling used in the West Virginia Haze
SIP’s contribution assessment and prediction of visibility impacts
from BART controls comply with EPA modeling guidance and
recommendations.  EPA finds the VISTAS technical modeling analyses
presented in the West Virginia Haze SIP to be acceptable because the
models that were used were applied according to EPA modeling guidance. 

Areas designated as mandatory Class I Federal areas consist of  national
parks exceeding 6000 acres, wilderness areas and national memorial parks
exceeding 5000 acres, and all international parks that were in existence
on August 7, 1977 (42 U.S.C. 7472(a)).  In accordance with section 169A
of the CAA, EPA, in consultation with the Department of Interior,
promulgated a list of 156 areas where visibility is identified as an
important value (see 44 FR 69122, November 30, 1979). The extent of a
mandatory Class I area includes subsequent changes in boundaries, such
as park expansions (42 U.S.C. 7472(a)).  Although states and tribes may
designate as Class I additional areas which they consider to have
visibility as an important value, the requirements of the visibility
program set forth in  section 169A of the CAA apply only to
‘‘mandatory Class I Federal areas.”  Each mandatory Class I
Federal area is the responsibility of a ‘‘Federal Land Manager’’
(FLM).  (42 U.S.C. 7602(i))  

	



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Albuquerque/Bernalillo County in New Mexico must also submit a regional
haze SIP to completely satisfy the requirements of section 110(a)(2)(D)
of the CAA for the entire State of New Mexico under the New Mexico Air
Quality Control Act (section 74-2-4).

 Guidance on the Use of Models and Other Analyses for Demonstrating
Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze, EPA
-454/B-07-002, April 2007

 The Class I designation applies to national parks exceeding 6,000
acres, wilderness areas and national memorial parks exceeding 5,000
acres, and all international parks that were in existence prior to 1977.

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