
                          Technical Support Document
              US EPA Proposed Approval of the State of Kansas'
                               Regional Haze SIP
                                       
    Prepared By: Tracey Casburn, Environmental Scientist, US EPA, Region 7
                                       
                                August 12, 2011

Table of Contents
Consultation									Page 6
Emissions Inventory 								Page 7
	Planned Burning Emissions Inventory				Page 8
	Ammonia Emissions Inventory					Page 9
	Mobile Source Emissions Inventory					Page 9
	Fugitive Dust Emissions Inventory					Page 10
	Point Source Emissions Inventory					Page 10
	Nonpoint Source Emissions Inventory				Page 12
Affected Class I Areas and Source Apportionment				Page 15
Best Available Retrofit Technology (BART)					Page 20
	BART Eligible Sources						Page 23
	BART Subject Sources						Page 26
		BART Determination for Westar JEC Units 1&2		Page 29
		BART Determination for Westar GEC Unit 2		Page 34
			BART Alternative for GEC Unit 2			Page 38	
		BART Determination for KCP&L Units 1&2		Page 42
Reasonable Progress/Long Term Strategy					Page 46		



List of Figures
Figure 1-Geographical Area of Regional Planning Organizations				Page 6

Figure 2- 2002 Emissions of Pollutants Contributing to Regional Haze from Kansas 		Page 13
      Nonpoint Sources

Figure 3- 2002 Percent Total Light Extinction at Eleven Class I Areas from Kansas 		Page 16
	Sources, by Species, for All Source Categories during the Worst 20% Days

Figure 4- 2002 Percent Total Light Extinction at Eleven Class I Areas from Kansas 		Page 17
      Air Emission Sources, by Source Category, for All Species during the Worst 
      20% Visibility Days

Figure 5- 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas 		Page 18
	Sources, by Species, for All Source Categories during the Worst 20% Days

Figure 6- 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas 		Page 19
      Air Emission Sources, by Source Category, for All Species during the Worst
       20% Visibility Days

Figure 7  -  2002 VOC emissions by CENRAP State and Source Sector				Page 22

Figure 8- 2002 Ammonia emissions by CENRAP state and Source Sector			Page 23

Figure 9- Map of BART-eligible Sources in Kansas						Page 26

Figure 10- Map of Class I Areas Analyzed							Page 27


List of Tables
Table 1- Baseline 2002 Kansas Emissions Summary, by Source Category and Pollutant		Page 7
Table 2- 2018 Kansas Projected Emissions Summary, by Source Category and Pollutant		Page 8
Table 3- Total Acres Burned in Kansas with Estimated Annual Emissions			Page 9
Table 4- 2002 Locomotive Emissions in Kansas (tons/yr)					Page 10

Table 5- 2002 Nonroad Mobile Source Emissions in Kansas by Equipment Type (tons/yr)		Page 10

Table 6- Total 2018 Reductions in NOx and SO2 from Kansas Emission Sources Subject to	Page 11

Table 7- Summary of Wichita Mountains Visibility Impact Results, in Percent Light Extinction 	Page 11
      Increase, and in Deciview Increase

Table 8-2009 Emissions Summary of Ethanol and EGUs					Page 12

Table 9- 2002 Top PM10 Emissions from Kansas Nonpoint (Area) Sources			Page 13

Table 10-2002 Top VOC Emissions from Kansas Nonpoint (Area) Sources			Page 14

Table 11- 2002 Top NOx Emissions from Kansas Nonpoint (Area) Sources			Page 14

Table 12- 2002 Top SO2 Emissions from Kansas Nonpoint (Area) Sources			Page 15

Table 13- 2018 Percent Total Light Extinction > 0.5% Due to Kansas Sources for 		Page 20
	Worst and Best 20% Visibility Days for the Wichita Mountains Class I Area

Table 14- Facilities with BART-eligible Units in the State of Kansas				Page 25

Table 15- List of 19 BART-eligible Source and Their Distances from each of the 		Page 27
      9 Class I Areas Analyzed. 

Table 16- Kansas BART-Eligible Emission Units with at Least One > 0.5 dv 			Page 28
	Visibility Impact Day on Selected Class I Areas during 2001 - 2003

Table 17- BART Presumptive Limits and Operational Standards for NOx and SO2 		Page 29
	at Subject-to-BART Emission Units in Kansas

Table 18- Visibility Impairment Attributable to JEC Units 1 and 2 and GEC Unit 2 (2001-2003	Page 30

Table 19-Pollutant Specific Contributions to Existing Visibility Impairment for 			Page 30
      JEC Unit 1 and 2 (2001-2003)
      
Table 20- Visibility Improvement from the Implementation of Presumptive SO2 BART		Page 31

Table 21- Summaries of Cost effectiveness of NOx controls at JEC units 1 and 2			Page 32

Table 22-Summary of Modeled Impacts from NOx Control for JEC Unit 1 (2001-2003)		Page 33

Table 23- Summary of Modeled Impacts from NOx Control for JEC Unit 2 (2001-2003)		Page 33

Table 24-Pollutant Specific Contributions to Existing Visibility Impairment 			Page 34
      for GEC Unit 2 (2001-2003)

Table 25- Summary of Emission Rates Comparing Existing Control to a Fuel 			Page 35
      Switch at GEC Unit 2

Table 26- Summary of Cost Effectiveness for Switching from No. 6 Oil to one 			Page 35
      percent sulfur fuel

Table 27- Summary of Modeled Impacts from SO2 control at GEC Unit 2 (2001-2003)		Page 36

Table 28- Summary of Cost Effectiveness for GEC Unit 2 NOx Control (SCR)			Page 37

Table 29- Summary of Modeled Visibility Impacts from SCR control				Page 38

Table 30- Comparison of Presumptive BART (1% Sulfur Fuel and LNB) to the 			Page 40
      BART Alternative

Table 31- Comparison of Presumptive BART (1% Sulfur Fuel and LNB) to the 			Page 41
      BART Alternative at Five Class I area

Table 32-Visibility Impairment Attributable to KCP&L Units 1 and 2 (2001-2003)		Page 42

Table 33- Pollutant Specific Contributions to Existing Visibility Impairment 			Page 42
      for KCP& L Units 1 and 2

Table 34- Visibility Improvement from the Implementation of Presumptive BART		Page 43

Table 35-Summary of Cost Effectiveness of NOx Control at KCP&L Units 2			Page 44

Table 36- Summary of NOx Control at KCP&L Unit 2					Page 44

Table 37- Kansas Emission Units Not Subject to BART Emitting at Least 			Page 47
	500 Tons/Yr of NOx or SO2 in 2002

Table 38- Sources with Cost per Ton Reduced Greater than $10,000/ton				Page 47

Table 39- Most Effective Control Technologies with Acceptable Control Costs 			Page 48
	for Kansas 500-Ton NOx and SO2 Emission Units

Table 40- Overall Visibility Improvements Resulting from Application of the Most 		Page 50
      Effective Controls at Selected Kansas 500-Ton NOx and SO2 Emission Units.

Table 41- Selected Kansas 500-ton NOx and SO2 Emission Units Showing Significant 		Page 51
	Visibility Improvement Resulting from Application of Most Effective Controls

Table 42- Summary of Each Unit's Cost per ton per Unit of dv Improvement			Page 52

Table 43- Summary of Reasonable Progress Non-Cost Statutory Factors 			Page 53
	For Selected Kansas Point Sources

Table 44- Ranked List of Sources under the Reasonable Progress Analysis			Page 54

Table 45- Control or Work Practice Strategies for Westar Units to Meet Kansas Long 		Page 55
      Term Strategy Requirements

Table 46- Estimated NOx and SO2 Emission Reductions for Implementation of Controls 		Page 56
      or Work Practices required by Kansas' Long Term Strategy



Consultation
      Because the pollutants that lead to regional haze can originate from sources located across broad geographic areas, EPA encouraged the States and Tribes to address visibility impairment from a regional perspective. Five regional planning organizations (RPOs) were developed to address regional haze and related issues. These organizations first evaluated technical information to better understand how their States and Tribes impact visibility (regional haze) at national park and wilderness areas (Class I areas) across the country, and then pursued the development of regional strategies to reduce emissions of particulate matter and other pollutants leading to regional haze issues. The State of Kansas participated in the planning efforts of the Central Regional Air Planning Association (CENRAP) which is affiliated with the Central States Air Resource Agencies (CENSARA). This RPO includes nine states - Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana.  

      The RPOs, such as CENRAP, provided air quality modeling to the States to help them in determining whether sources located within the State can be reasonably expected to cause or contribute to visibility impairment in a Class I area.  The modeling relied on baseline year (2002) and future planning year (2018) emissions inventories that were prepared with the participation from each of the CENRAP states. States relied on these inventories to develop control strategies to meet the visibility improvement goals of the Regional Haze Rule (Rule) and to develop their State Implementation Plans (SIPs).  This technical support document also relies heavily on the data provided by the CENRAP.
      

Figure 1-Geographical Area of Regional Planning Organizations
Emissions Inventory 
      The inventory (2002 and 2018) provided in the State's Regional Haze SIP includes: Volatile Organic Compounds (VOCs), nitrogen oxides (NOx), sulfur dioxide (SO2), fine particulate matter (PM2.5), coarse particulate matter (PM10) and ammonia (NH3).   The 2002 emissions inventory and its improvements were developed by CENRAP and its contractors as part of the development of a baseline inventory for the 2002 modeling inventory. The improvements were prepared by Sonoma Technology, Inc. (STI), a contractor retained to develop and improve three inventory categories of the baseline 2002 inventory: planned burning emissions inventory, ammonia inventory, mobile source and fugitive dust emissions inventory. The complete 2002 baseline emissions inventory can be found in Appendix 7.1 of the SIP.
Table 1- Baseline 2002 Kansas Emissions Summary, by Source Category and Pollutant

      To estimate the 2018, future year emissions, the 2002 emissions were grown using the Economic Growth Analysis System (EGAS), MOBILE 6.2 vehicle emissions software, and the Integrated Planning Model (IPM) version 2.93 for EGUs.  The complete 2018 emissions inventory can be found in Appendix 7.2 of the SIP.  
      
Table 2- 2018 Kansas Projected Emissions Summary, by Source Category and Pollutant
Planned Burning Emissions Inventory
      Agricultural and prescribed burning activities, referred to as planned burning, likely contribute to episodes of impaired visibility in the CENRAP region. STI developed planned burning emissions inventories for the CENRAP region, including Kansas. In Kansas, planned burning is an important component of the nonpoint source category, with a significant amount of emissions.  STI used a "bottom-up" approach in preparing these emissions estimates. This preparation included using the First Order Fire Effects Model (FOFEM), incorporating emission factors and fuel loadings gathered from published literature, geographic information systems (GIS) databases of land cover and vegetation, and activity data gathered through telephone surveys.

      In Kansas, a significant amount of the burning occurs on rangeland and cropland. To best characterize the amounts burned, STI performed an agricultural burning survey of the county agricultural extension service offices within the state. This survey included rangeland burning questions designed to determine the fraction of rangeland acreage typically burned each year and the timing of such burn events. Of the 105 total counties surveyed, 59 responded, which represents a 56% response rate. The results of these surveys can be found in Appendix 7.3 of the SIP.

      Assuming the responding counties comprise a representative sample, these two categories, wheat stubble burning and rangeland burning, together represent approximately 93% of the acres burned in Kansas. As can be seen in Table 3, these two categories also represent the majority of the burning inventory emissions. The baseline 2002 source category "Area Source Fire" was grown to reflect the information gathered by STI and is represented in Appendix 7.1 of the SIP.
      
      Although area source fire emissions were shown to be significant in amount, photochemical modeling, discussed in greater detail below, did not show these emissions to have a significant impact on visibility at Class I areas.


Table 3- Total Acres Burned in Kansas with Estimated Annual Emissions

Ammonia Emissions Inventory
      It is widely recognized that the formation of secondary particulate matter, which is generated from chemical transformations in the atmosphere of gaseous precursor species such as ammonia, NOx, sulfur oxides (SOx), and VOCs, contributes significantly to regional haze issues in the CENRAP region. In Kansas, agriculture-related ammonia emissions, coming from sources such as confined animal feeding operations (CAFOs) and crop fertilization, are significant in amount. Because ammonia can have an impact on the formation of secondary particulate species, CENRAP and Kansas spent considerable resources on developing an accurate ammonia inventory. STI developed a comprehensive inventory for CENRAP. 

      In Kansas, over 50% of the ammonia emissions come from livestock emissions, including CAFOs and free range grazing. In 2002, it is estimated that 91,000 tons per year (tpy or tons/year) of ammonia came from these two source categories. In addition, it is estimated that 65,000 tpy of ammonia emissions came from fertilizer emissions. The remainder of the ammonia emissions in Kansas is from biogenic and point sources categories. One of the important considerations in the development of the ammonia inventory was the temporal allocation of the ammonia emissions, both seasonally and diurnally. STI did considerable work in developing temporal profiles for the ammonia inventory in Kansas. These temporal profiles were then utilized during photochemical modeling to assess the impact of ammonia emissions on visibility impairment.   Although ammonia emissions were considered by the State to be significant to the formation of visibility impairing pollutants such as particulate matter, photochemical modeling, discussed in greater detail below, did not show that these ammonia formed pollutant emissions have a significant impact on visibility at Class I areas.

Mobile Source Emissions Inventory
      In Kansas, the emissions inventory for the on-road mobile and nonroad mobile source categories are fairly significant in amount for certain pollutants. STI prepared detailed inventories for these source categories, including refined spatial and temporal data. Table 4 has a summary of the locomotive emissions in Kansas, while Table 5 shows emissions from other nonroad source categories. There are minimal emissions from recreational boating in Kansas, thus it is not summarized here. Photochemical modeling, discussed in greater detail below, did not show these emissions to have a significant impact on visibility at Class I areas.


Table 4- 2002 Locomotive Emissions in Kansas (tons/yr)


Table 5- 2002 Nonroad Mobile Source Emissions in Kansas by Equipment Type (tons/yr)

Fugitive Dust Emissions Inventory
      The final emissions category that STI analyzed dealt with fugitive PM2.5 emissions from agricultural sources. These emissions come from sources such as tilling operations. In Kansas, it is estimated that there are over 50,000 tpy of PM2.5 emissions from agricultural tilling operations. As was the case for ammonia emissions, the temporal distribution of these emissions is important as they are seasonal in nature. Photochemical modeling, discussed in greater detail below, did not show fugitive dust emissions from agriculture to have a significant impact on visibility at Class I areas.

Point Source Inventory
      The majority of visibility-impairing point source emissions in Kansas currently come from the electric utility sector.  This sector represented 93% of the reported SO2 emissions and 57% of the NOx emissions for the 2002 inventory year.  The other large NOx emissions category in Kansas is the natural gas compression industry, which represented 28% of total NOx emissions for the 2002 inventory year.  For the point source sector, reductions in NOx and SO2 by 2018 are projected primarily at the five EGU units the State found to be subject to BART controls.  Table 6 details the reductions predicted from these emission units.
      
      

                             Subject-to-BART unit
                                  2002 NOx[1]
                                  2002 SO2[1]
                                  2018 NOx[2]
                                  2018 SO2[2]
                                 NOx reduction
                                 SO2 reduction

                                    tons/yr
KCP&L - La Cygne 1
                                                                         30,058
                                                                          6,648
                                                                          2,576
                                                                          3,948
                                                                         27,482
                                                                          2,700
KCP&L - La Cygne 2
                                                                          8,362
                                                                         19,355
                                                                          6,229
                                                                          3,993
                                                                          2,133
                                                                         15,362
Westar - Gordon Evans 2
                                                                          2,023
                                                                          3,211
                                                                            138
                                                                            0.0
                                                                          1,886
                                                                          3,211
Westar - Jeffrey 1
                                                                          9,602
                                                                         20,459
                                                                          4,268
                                                                          3,532
                                                                          5,334
                                                                         16,927
Westar - Jeffrey 2
                                                                         10,892
                                                                         23,715
                                                                          4,040
                                                                          3,465
                                                                          6,852
                                                                         20,251
                                                          Total BART reductions
                                                                         43,687
                                                                         58,451
Table 6- Total 2018 Reductions in NOx and SO2 from Kansas Emission Sources Subject to
[1] Data from EPA Clean Air Markets [2] Data from IPM 3.0	

      At the time this document was being prepared, an 895 MW coal-fired EGU was in the permitting process in Kansas.  This EGU, located in Holcomb in the southwest portion of the State, was analyzed for visibility impacts on the WIMO.  The State has asserted that CAMx PSAT modeling showed that visibility impairment in the WIMO attributed to this new source would be below 0.5 delta deciview (Δdv).  The permit for the 895 MW EGU was approved by the Secretary of the Kansas Department of Health and Environment.  The visibility modeling results for the power plant at Holcomb is provided in Appendix 11.2 of the SIP.
      
Table 7- Summary of Wichita Mountains Visibility Impact Results, in Percent Light Extinction Increase, and in Deciview Increase
      Several large natural gas compressor stations are located along pipelines crisscrossing the State, with numerous other stations clustered around the Hugoton and Panoma gas fields in the southwest.  In 2002, 19 EGUs reported NOx emissions over 100 tons, whereas in the same period 95 natural gas compressor stations reported NOx emissions over 100 tons. From 1995 to 2005, production from the Hugoton gas field, the State's largest natural gas production area, has decreased from approximately 460,000 billion cubic feet (Bcf) to 200,000 Bcf.  Over the same period, actual NOx emissions reported from the compressor stations have steadily decreased from 75,000 tons/yr to 50,000 tons/yr.  Kansas expects emissions from this sector to continue to decline as production declines and equipment is replaced with new, more efficient designs. Additional information on this sector can be found in Appendix 7.4 of the SIP.

      In 2002, there were four ethanol plants in operation in Kansas, with a total production capacity of 164 million gallons per year (Mgal/yr).  That number grew to 14 facilities in 2007 with a total capacity of 814 Mgal/yr.  Currently, there are 12 active ethanol facilities, 3 facilities under construction, 1 facility that has been permitted but not yet built, 1 facility built but not active, and 1 facility whose permit application is pending.  In 2008 and 2009, expansion of the fuel ethanol industry in Kansas slowed.  The actual emission rate of NOx for these plants is quite low as compared to EGUs.  
   
 
                                     NOx 
                                     PM10
                                      SOx
                                     EGU's
                                                                      48,176.37
                                                                       3,611.84
                                                                      51,595.27
Ethanol Plants
                                                                         374.03
                                                                         294.27
                                                                          59.93
Table 8-2009 Emissions Summary of Ethanol and EGUs

Nonpoint Source Inventory
      Nonpoint source emissions were compiled from the final 2002 National Emissions Inventory (NEI) database.  Although PM2.5 emissions values are not available from this data source, the NEI gives emissions estimates at a detailed level for source categories, so that source attribution is more easily analyzed.  (Note also the ratio of PM2.5 to PM10, can for comparative purposes be approximated as 0.2).  Only NOx, SO2, PM10, and VOC were considered in this analysis.  The relative contributions of these pollutants within the nonpoint source category are shown in Figure 2 (below).  The attribution of nonpoint source pollution on visibility at Class I areas is shown in Figure 4 (provided on page 17).  

Figure 2- 2002 Emissions of Pollutants Contributing to Regional Haze from Kansas Nonpoint Sources
	As can be seen by Figure 2, PM10 accounts for the largest nonpoint source category, and can be attributed primarily to agricultural crop production (including burning of crop residue), unpaved and paved road dust, and dust from construction activities.  Tables 9 through 12 give the relative contributions from the top sources of nonpoint emissions for the State for each of the four haze-causing pollutants.  These values are based on the 2002 National Emissions Inventory. 
      Figure 4 (provided on page 17 of this document) indicates that the visibility impairment attributed to nonpoint source pollution from sources located in Kansas is almost equivalent to the visibility impairment attributed to point source pollution from sources in Kansas.  However, although PM10 emissions are the highest of the nonpoint source category emissions, compared to NOx, VOC and SO2, Figure 3 (provided on page 16 of this document) indicates that a majority of the visibility impairment causing pollution is SO2 and NOx and not necessarily PM10.  So although nonpoint sources in Kansas may contribute to visibility impairment in Class I areas, nonpoint source PM10 is not significant.    

                             Source classification
                                    tons/yr
                              % of nonpoint PM10
                                % of total PM10
Unpaved roads
                                    275,026
                                     37.9%
                                     36.6%
Agricultural crop production
                                    253,845
                                     35.0%
                                     33.8%
Agricultural burning
                                    99,292
                                     13.7%
                                     13.2%
Road construction
                                    48,050
                                     6.6%
                                     6.4%
Paved roads
                                    32,892
                                     4.5%
                                     4.4%
Mining and quarrying
                                     7,539
                                     1.0%
                                     1.0%
Table 9- 2002 Top PM10 Emissions from Kansas Nonpoint (Area) Sources
      The nonpoint source category represents a large portion of the total anthropogenic emissions inventory for VOC emissions.  VOC emissions from nonpoint sources are projected to grow by 20% in 2018 from the 2002 estimate.  In 2018, the estimate is for approximately 105,000 tons/yr of VOC from the nonpoint source category.  Much of the nonpoint VOC is from solvent utilization and residential heating.  Figure 3 below demonstrates that VOC is not anticipated to be a large contributor to visibility impairment in the Class I areas surrounding Kansas so the remaining focus will be on NOx and SO2 nonpoint source emissions.
                             Source classification
                                    tons/yr
                                 % of nonpoint
                                      VOC
                                % of total VOC
Agricultural burning
                                                                         55,058
                                     41.4%
                                     22.7%
Residential fuel combustion
                                                                         18,758
                                     14.1%
                                     7.7%
Gasoline service stations
                                                                         13,398
                                     10.1%
                                     5.5%
Misc. commercial solvents
                                                                          7,986
                                     6.0%
                                     3.3%
Misc. consumer solvents
                                                                          7,185
                                     5.4%
                                     3.0%
Misc. industrial solvents
                                                                          6,554
                                     4.9%
                                     2.7%
Graphic arts solvents
                                                                          6,476
                                     4.9%
                                     2.7%
Surface coatings (solvent evap.)
                                                                          5,704
                                     4.3%
                                     2.4%
All other misc. solvent usage
                                                                          4,044
                                     3.0%
                                     1.7%
Table 10-2002 Top VOC Emissions from Kansas Nonpoint (Area) Sources
      NOx and SO2 make up a relatively small proportion of the State's nonpoint emissions inventory.  With the exception of agricultural burning, the major contributing source categories for NOx are associated with residential, industrial, and commercial natural gas combustion.  These categories are projected to grow at a moderate pace between 2002 and 2018.  For SO2, the major contributing categories are industrial fuel (primarily coal and distillate oil) combustion.  These categories are also projected to grow at a moderate pace between 2002 and 2018.  The nonpoint industrial coal combustion category in the NEI may be overestimated, both in the 2002 and 2018 projected inventories, as most industrial sources utilizing coal are captured in the State's point source inventory.  In addition, the distillate and residual oil combustion in the nonpoint sector are likely to remain unchanged or decrease between 2002 and 2018.  At worst, if the 2018 projections are correct, the nonpoint emissions for SO2 are still only a fraction of the point source SO2 emissions.
      
                             Source classification
                                    tons/yr
                                % of nonpoint 
                                      NOx
                                % of total NOx
Agricultural burning
                                                                         29,099
                                     68.8%
                                     7.6%
Industrial fuel combustion
                                                                          6,298
                                     14.9%
                                     1.6%
Residential fuel combustion
                                                                          4,203
                                     9.9%
                                     1.1%
Table 11- 2002 Top NOx Emissions from Kansas Nonpoint (Area) Sources






                             Source classification
                                    tons/yr
                               % of nonpoint SO2
                                % of total SO2
Industrial fuel combustion	
                                                                         24,218
                                     66.6%
                                     12.9%
Agricultural burning
                                                                         10,949
                                     30.1%
                                     5.9%
Table 12- 2002 Top SO2 Emissions from Kansas Nonpoint (Area) Sources
      
Affected Class I Areas and Source Apportionment
      There are no Class I areas hosted by the State of Kansas.  States such as Kansas, that do not host Class I areas, are not required to identify reasonable progress goals or calculate baseline and natural visibility conditions at Class I areas.  However, States without Class I areas are still required to address their apportionment of visibility impact, from the emissions generated by sources within the State's borders on Class I areas hosted by other States.  The following are the Class I areas nearest to the State of Kansas in all directions around the State's border:
   
       * Caney Creek Wilderness Area, Arkansas (CACR)
       * Upper Buffalo Wilderness Area, Arkansas (UPBU)
       * Great Sands Dunes Wilderness Area, Colorado (GRSA)
       * Rocky Mountain National Park, Colorado (ROMO)
       * Hercules Glades Wilderness Area, Missouri (HEGL)
       * Mingo Wilderness Area, Missouri (MING)
       * Wichita Mountains Wilderness Area, Oklahoma (WIMO)
       * Badlands National Park, South Dakota (BADL)
       * Wind Cave National Park, Texas (WICA)
       * Big Bend National Park, Texas (BIBE)
       * Guadalupe Mountains National Park, Texas (GUMO)

   	In order to address the issue of source attribution of regional haze for its member states, CENRAP contracted with ENVIRON to carry out PM Source Apportionment Technology (PSAT) modeling, a well known "probing tool" for the CAMx photochemical model.  ENVIRON delivered its results in the form of a customized Microsoft Access database query tool, hereinafter the PSAT tool, which allows users to select among various inputs to produce charts and tables.  Visibility impact can be represented in terms of absolute light extinction (Bext), inverse megameters (Mm[-1]), and percent total light extinction.  Data can be queried from source categories within individual states on individual or grouped Class I area receptors, for the years 2002, 2000-2005 (baseline), and 2018 (end of current planning period).  The PSAT tool used for this document is the August 27, 2007 version and is available at http://www.cenrap.org/html/projects.php

	ENVIRON used IMPROVE monitoring data for the 2000-2004 period to define baseline, natural, and  2018 conditions for each of the 11 Class I areas. PM10 was speciated into six components (sulfate, particulate nitrate, organic carbon, elemental carbon, soil, and coarse mass) which were used to develop relative response factors (RRFs) between current and predicted concentrations for each component. The RRFs were multiplied by current baseline values to estimate future concentrations. The visibility improvements for 2018 were then calculated using the original or new IMPROVE equation. Additional information about these analyses can be found in Chapter 4 of the Technical Support Document (TSD) prepared by ENVIRON and the Causes of Haze Assessment work performed by STI. These documents can be found at http://www.cenrap.org/html/projects.php

	The EPA used the PSAT tool to find projected absolute and percent total light extinction values at eleven Class I areas.  The analysis helped determine which Class I areas may be impacted by Kansas sources, and also provides a quantifiable basis of discussion for meeting the reasonable progress goals for Class I areas potentially impacted by emission sources within Kansas.
      
	The 20 % worst day estimated percent light extinction, at these eleven Class I areas, attributed to emissions from sources in Kansas (shown by pollutant species and source category) is given below. The modeling (as shown in Figures 4 and 6) indicated that Kansas sources are most likely to have the highest impact at the WIMO Class I area.  
      
                                        
Figure 3- 2002 Percent Total Light Extinction at Eleven Class I Areas from Kansas Sources, by Species, for All Source Categories during the Worst 20% Days


Figure 4- 2002 Percent Total Light Extinction at Eleven Class I Areas from Kansas Air Emission Sources, by Source Category, for All Species during the Worst 20% Visibility Days


Figure 5- 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas Sources, by Species, for All Source Categories during the Worst 20% Days


Figure 6- 2018 Percent Total Light Extinction at Eleven Class I Areas from Kansas Air Emission Sources, by Source Category, for All Species during the Worst 20% Visibility Days

      Figures 3 through 6 reveal that the largest contributors to haze for WIMO from Kansas sources are nitrates (NO3).  To get a more precise idea of relative contributions, the PSAT tool was used to generate tables for individual species, for the best 20% visibility days as well as for the worst 20% visibility days.  Table 13 summarizes the PSAT tool-generated tables, which are found in Appendix 10.1 of the State's SIP.  Table 13 shows percent total extinction values greater than 0.5% to represent percent total extinction for the respective source category and species combinations on the worst and best 20% visibility days.  Values of less than 0.5% were considered to be insignificant.  This tool confirms that on the worst 20% visibility days at WIMO, point sources of nitrates, followed by point sources of sulfates and primary organic aerosol (POA) have the greatest impact of pollutants attributed to sources in Kansas. Sources of POA can be wildfires, mobile sources, industrial and commercial combustion, residential heating and open burning, burning of construction debris, industrial and commercial processes, agricultural burning, and fugitive dust.   
      











                     Source category / particulate species
                    Percent total extinction > 0.5% (%)
          Worst 20% visibility days (total extinction = 72.01 Mm[-1])
  Point sources  -  NO3
                                    0.9572
  Point sources  -  SO4
                                    0.8404
  Area sources  -  POA
                                    0.7210
          Best 20% visibility days (total extinction = 15.14 Mm[-1])
  Point sources  -  NO3
                                    0.7386
  Point sources  -  SO4
                                    1.6518
  Area sources  -  SO4
                                    0.5526
  Area sources  -  POA
                                    1.6600
  Area sources  -  EC
                                    0.6497
Table 13- 2018 Percent Total Light Extinction > 0.5% Due to Kansas Sources for Worst and Best 20% Visibility Days for the Wichita Mountains Class I Area

Best Available Retrofit Control Technology
      Section 169A of the CAA directs States to evaluate the use of retrofit controls at certain larger, often uncontrolled, older stationary sources in order to address visibility impacts from these sources.   Specifically, the CAA requires that certain categories of existing stationary sources built between 1962 and 1977 procure, install, and operate the "best available retrofit technology", or BART, as determined by the State.    States are directed to conduct BART determinations for the sources that cause or contribute to any visibility impairment in a Class I area. 
      
      On July 6, 2005, EPA published the Guidelines for BART Determinations Under the Regional Haze Rule at Appendix Y to 40 CFR Part 51 (hereinafter referred to as the "BART Guidelines") to assist States in determining which of their sources should be subject to the BART requirements and in determining appropriate emissions limits for each such source.   In making a BART determination for a fossil fuel-fired generating plant with a total generating capacity in excess of 750 megawatts, a State must use the approach set forth in the BART Guidelines.  A State is not required to follow the BART Guidelines in making BART determinations for other types of sources.  The BART Guidelines provide five steps toward identifying BART control for these very large EGUs.  
      
   1. Identify all available retrofit control technologies;
   2. Eliminate technically infeasible control technologies;
   3. Evaluate the control effectiveness of remaining control technologies;
   4. Evaluate impacts and document the results;
   5. Evaluate visibility impacts

	In the BART determination process, states must address all significant visibility impairing pollutants.  The EPA determined that presumptively, the most significant visibility impairing pollutants are SO2, NOx, and PM. As indicated by the BART Guidelines, consideration of whether VOC or NH3 emissions impair visibility in particular Class I areas is on a state-by-state basis.  In its SIP the State determined that it did not need to consider VOC or NH3 emissions when conducting its BART analyses. Based on its own review of VOC and NH3 emissions in the State and the pollutant's impacts on visibility at Class I areas, the EPA agrees with the State's findings.  The EPA's analysis is described below.
      
      Figure 7 compares 2002 VOC emission sources from each of the CENRAP states by source sector.  As explained by Table 2 (above), and confirmed by Figure 7, a majority of the anthropogenic VOC emission from Kansas sources are emitted by nonpoint sources such as area sources, area fire sources, and off road vehicles.  Another major source of VOC emissions from the State can be attributed to on road vehicles. Since neither on road, off road, or area sources are included in the 26 major source categories describe by the BART rule, and since VOC emissions from nonpoint sources in Kansas are not expected to contribute significantly to visibility impairment (shown in Figure 3) the EPA agrees with the State that it needn't consider VOC emission reductions as part of its BART determinations.
      
      
Figure 7  -  2002 VOC emissions by CENRAP State and Source Sector
      
   Figure 8 compares 2002 NH3 emission sources from each of the CENRAP states by source sector.  As explained by Table 2 (above) a majority of the anthropogenic emission from Kansas sources are emitted by point and onroad mobile sources. A review of the 2002 NEI data shows that a majority of the point source ammonia emissions come from "Agricultural Services".   Individually, these point sources generally have less than 250 tpy of emissions. Further review of the 2002 NEI data shows that only one large point source of NH3   is in one of the 26 major source categories the EPA has required states to consider when evaluating BART.  This source is the Frontier Eldorado Refining Company and is discussed further in the BART-eligibility discussion below. Based on this information the EPA agrees with the State that it needn't consider NH3 emission reductions as part of its BART determinations.

      
Figure 8- 2002 Ammonia emissions by CENRAP state and Source Sector

BART Eligible Sources
      The EPA has reviewed the State's process for determining if a source is BART-eligible and found that the  State appropriately identified nineteen facilities as having units that were BART-eligible.  The State utilized the methodology in the BART Guidelines for determining which sources were BART-eligible.  The following criterion was used to identify an emission source as BART-eligible:
   
       *       One or more emissions units at the facility fit within one of the 26 categories listed in the BART Guidelines;
       *       The emission unit was in existence on August 7, 1977 and began operation at some point on or after August 7, 1962; and
       *       The limited potential emissions from all emission units identified in the previous two bullets were 250 tons or more per year of any of these visibility-impairing pollutants: SO2, NOx, or PM10.
         
      To identify the sources that met the criteria above, a multi-step search was conducted including a database query of the permitted air sources and a survey of the facilities.  The first step to the BART-eligible screening was done by querying the point sources based on the following criteria: 
      
       * The facility is operating;
       * The facility is coded as being class A (controlled emissions > 100 tpy), A1 (actual emissions < 100 tpy, potential emissions >100 tpy), or A2 (actual/potential emission > major source threshold);
       * The facility is in one of the Standard Industrial Classification (SIC) codes or has processes within one of the Source Classification Codes (SCCs) that meet one of the 26 major source categories.

	The second step was to eliminate sources from the fossil fuel-fired boilers category with less than a 250 MMBtu/hr heat input rate. The boiler values were summed for each of the facilities. Facilities with aggregated boiler capacity of less than 250 MMBtu/hr were then eliminated. This resulted in a list of 97 facilities. Then, for the 97 facilities on the list, year 2000 actual emissions at the emission unit level were obtained and combined with 1999 Toxics Release Inventory (TRI) ammonia emissions data at the facility level.  At this point the petroleum storage and transfer facilities with storage capacity <300,000 barrels were eliminated, along with any facilities where the potential to emit and operation/reconstruction date criteria were not met. 

      The third step included sending the facilities surveys.  Each of the 97 facilities that met the Regional Haze Rule's source category criteria was sent a survey under a request for information about the air emission units at their facilities. The facilities were requested to submit potential to emit data for NOx, SO2, PM10, VOCs, and NH3 for each identified emission unit. The survey consisted of 4 steps:
   
      1. Evaluate dates
      2. Verify BART category
      3. Enter potential emissions (tons/yr)
      4. Provide boiler and tank information, if applicable

	In Appendix 9.2 of the SIP, Kansas acknowledged that although it asked the facilities to provide VOC and NH3 emissions information, it did not intend on using that information in its BART-subject analysis.  Since only a fraction of the VOCs emission that would be reported actually form secondary organic aerosols and because the screening model (CALPUFF) cannot simulate formation of particles from anthropogenic VOCs, nor their visibility impacts it, the data would not be used in the BART determinations.  NH3 emissions were included as background in the modeling but emissions data from specific sources was not used as part of the evaluation process.
      
      Each of the facilities returned the survey forms, which were then analyzed to determine BART-eligibility. The analysis indicated there were 19 facilities in Kansas with BART-eligible units.  The nineteen facilities identified by this process are listed in Table 14.



                           BART Source Category Name
                                  Facility ID
                                 Facility Name
                         BART-Eligible Emission Units
                  Fossil-Fuel Fired Electric Generating Units
                                    0090002
              Aquila (now Sunflower Electric) - Arthur Mullergren
                            Unit 3 (Stacks 1 and 2)
                                       
                                    1750001
               Aquila (now Sunflower Electric) - Cimarron River
                                    Unit 1
                                       
                                    0570001
                Aquila (now Sunflower Electric) - Judson Large
                                    Unit 4
                                       
                                    2090008
                           Kansas City BPU - Nearman
                                    Unit 1
                                       
                                    2090048
                          Kansas City BPU - Quindaro
                                    Unit 1
                                    Unit 2
                                       
                                    1070005
                             KCP&L - La Cygne
                                    Unit 1
                                    Unit 2
                                       
                                    1130014
                       McPherson Municipal Power Plan #2
                                    Unit 1
                                       
                                    0550026
                       Sunflower Electric - Garden City
                                    Unit S2
                                       
                                    1730012
                         Westar Energy - Gordon Evans
                            Unit 2 (Stacks 2 and 3)
                                       
                                    1550033
                          Westar Energy - Hutchinson
                            Unit 4 (Stacks A and B)
                                       
                                    1490001
                            Westar Energy - Jeffrey
                                    Unit 1
                                    Unit 2
                                       
                                    0450014
                           Westar Energy - Lawrence
                                    Unit 5
                                       
                                    0350012
                       Winfield Municipal Power Plant #2
                                    Unit 4
                            Portland Cement Plants
                                    0010009
                              Monarch Cement Co.
No. 4 Kiln Stack, No.4 Kiln Clinker Cooler, No.5 Kiln Stack, No. 5 Kiln Clinker Cooler, Raw Material Unloading, Clinker Grinding and Cement Handling, Stone Quarry Processing
                             Petroleum Refineries
                                    0150004
                        Frontier El Dorado Refining Co.
Boiler B-105, Boiler B-107, Plant Process Heaters, Refinery Flare System B-1303, Plant Cooling Towers, Storage Tanks, Gas Oil Hydrotreater
                                       
                                    1130003
                  National Cooperative Refinery Assoc. (NCRA)
Alky Heater HA-002, No.9 Boiler SB-009, No.12 Boiler SB-012, Coker IR Comp. CR-003, Plat Stab Boil Htr HP-003, Plat Charge Htr HP-006, Fugitive Emissions
                          Chemical Processing Plants
                                    1730070
                    Basic Chemicals (now OxyChem - Wichita)
                 Boiler 1; Boiler 2; Boiler 3; Chloromethanes
                                       
                                    0570003
                                 Koch Nitrogen
Ammonia plant - primary reformer; Ammonia plant - other; Nitric acid plant - absorber tail gas; Ammonium nitrate plant  -  neutralizer
                         Glass Fiber Processing Plants
                                    2090010
                                 Owens Corning
70 furnace - N exhaust; 70 furnace - S exhaust; 70 riser/channel/forehearth; 70 A forming; 70 B forming; 70 C forming; 70 D forming; 70 curing oven charge end; 70 curing oven discharge end; J5 furnace; J5 riser/channel/forehearth; J6 A forming; J6 B forming; J6 C forming; J6 curing oven charge end; J6 curing oven discharge end; J6 smoke stripper; J6 north cooling (A); J6 south cooling (B); J6 asphalt coating; Raw material processing
Table 14- Facilities with BART-eligible Units in the State of Kansas

Figure 9- Map of BART-eligible Sources in Kansas

BART Subject Sources
      The EPA has reviewed the State's process for determining if a source was BART-subject and has found that the State used a satisfactory method for determining which of the BART-eligible sources were BART-subject.   The State completed a modeling analysis of all 19 sources determined to be BART-eligible, using CALPUFF. The State established a screening threshold of 0.5 dv (the same threshold described in the BART guidelines).  If the modeling results showed that a source had at least a 0.5 dv or greater visibility impact on at least one day in a three year period (2001-2003) further BART-subject analysis was required.  The one day in three-year period threshold, as well as the Class I areas selected for modeling, were based on recommendations made by staff at EPA Regions 6 and 7 in 2005.  The nine Class I areas that were determined to be significant for determining impacts from potential BART-subject sources were:
   
       *  Caney Creek Wilderness Area, Arkansas (CACR)
       * Upper Buffalo Wilderness Area, Arkansas (UPBU)
       * Great Sand Dunes Wilderness Area, Colorado (GRSA)
       * Rocky Mountain National Park, Colorado (ROMO)
       * Hercules-Glades Wilderness Area, Missouri (HEGL)
       * Mingo Wilderness Area, Missouri (MING)
       * Wichita Mountains Wilderness Area, Oklahoma (WIMO)
       * Badlands National Park, South Dakota (BADL)
       * Wind Cave National Park, South Dakota (WICA)
      

Figure 10- Map of Class I Areas Analyzed


Table 15- List of 19 BART-eligible Source and Their Distances from each of the 9 Class I Areas analyzed. Highlights indicate the Class I area that the source was evaluated for to determine Impacts.
   
      The modeling showed that eight of the nineteen BART-eligible sources met the screening criteria (0.5 dv or greater visibility impact on at least one day in a three year period). Those sources are identified below in Table 16.

                                    Source
CACR
UPBU
GRSA
ROMO
HEGL
MING
WIMO
BADL
WICA

       Number of days during 2001-2003 with visibility impact >0.5 dv
Kansas City BPU - Nearman Unit 1
                                                                             23
                                                                             21
                                                                              3
                                                                              1
                                                                             30
                                                                             16
                                                                             15
                                                                              3
                                                                              2
Kansas City BPU - Quindaro Units 1 & 2
                                                                             13
                                                                             13
                                                                              1
                                                                              1
                                                                             18
                                                                              6
                                                                              9
                                                                              0
                                                                              0
KCP&L - La Cygne Units 1 & 2
                                                                            204
                                                                            249
                                                                             17
                                                                             21
                                                                            278
                                                                            233
                                                                            142
                                                                             46
                                                                             38
Monarch Cement Kilns 4 & 5
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              1
                                                                              0
                                                                              0
Westar Energy - Gordon Evans Unit 2
                                                                             33
                                                                             30
                                                                             11
                                                                             13
                                                                             28
                                                                             17
                                                                            102
                                                                             32
                                                                             24
Westar Energy - Hutchinson Unit 4
                                                                             14
                                                                              7
                                                                              6
                                                                              5
                                                                              6
                                                                              3
                                                                             17
                                                                              9
                                                                              4
Westar Energy - Jeffrey Units 1 & 2
                                                                            150
                                                                            161
                                                                             27
                                                                             28
                                                                            182
                                                                            158
                                                                            165
                                                                             82
                                                                             55
Westar Energy -Lawrence Unit 5
                                                                             14
                                                                             14
                                                                              1
                                                                              1
                                                                             17
                                                                              7
                                                                              9
                                                                              2
                                                                              1
Table 16- Kansas BART-Eligible Emission Units with at Least One > 0.5 dv Visibility Impact Day on Selected Class I Areas during 2001 - 2003
   
      The State required each of those eight sources to submit refined modeling to the State for further review.  The refined modeling analysis for each source is given in Appendix 9.8 of the State's Regional Haze SIP.  Each facility's refined modeling results were based on CALPUFF modeling for individual source exemption provided in the State's BART modeling protocol.   Monarch Cement, Kansas City BPU - Quindaro, Kansas City BPU  -  Nearman, Westar Energy - Hutchinson, and Westar Energy - Lawrence were able to show that the emissions from their BART-eligible units are not anticipated to cause or contribute to visibility impairment in Class I areas.   The remaining facility's refined modeling results did show that emissions from their BART-eligible units were anticipated to cause or contribute to visibility impairment in Class I areas.  Five units at three sources were determined to be BART-subject and required BART determinations. Those five units are given below:
   
       * Unit 1 at Kansas City Power and Light (KCP&L), La Cygne, Facility ID 1070005
       * Unit 2 at Kansas City Power and Light, La Cygne, Facility ID 1070005
       * Unit 1 at Westar Energy (Westar), Jeffrey Energy Center (JEC), Facility ID 1490001
       * Unit 2 at Westar Energy, Jeffrey Energy Center, Facility ID 1490001
       * Unit 2 at Westar Energy, Gordon Evans Energy Center (GEC), Facility ID 1730012
      
      It should be mentioned that BPU submitted the Black & Veatch-prepared document Best Available Retrofit Technology Engineering Analysis for its Nearman Facility Unit 1 to the State in February 2007.  In November 2007, the State determined that there was a potential issue with the hourly emission rates used in the initial modeling determination resulting in Nearman Unit 1 qualifying as a BART source.  The State informed BPU of this potential issue and BPU revised both the 24 hour maximum emission rates and the BART determination modeling they had performed. On December 19, 2007 the State received the revised 24 hour maximum emission rates from BPU for Nearman Unit 1.  Along with the revised emissions rate, BPU also submitted additional CALPUFF modeling for purposes of a BART determination.  This new modeling indicated Nearman Unit 1 should not have been included as a BART source.  The modeling BPU performed was based on the approved CALPUFF modeling protocol.  It was therefore determined that BPU's Nearman Unit 1 is not a source subject to BART because it was not anticipated to have an visibility impairment of greater than 0.5 dv based on a 98[th] percentile. 

	BART determinations for the five subject-to-BART units in Kansas were carried out by third-party contractors on behalf of the sources' two owners and submitted to the State for approval. Because all five of the BART units are EGUs and are located at 750 MW facilities, the State stipulated that the minimum BART control level would be the presumptive limits specified in the BART Guidelines. Kansas provided each owner with a guideline for conducting their determination, titled "Guidance for Facilities Conducting a BART Analysis" (found in Appendix 9.4 of the SIP).  Although the guidance stated that if a facility was considered a presumptive EGU, and proposed controls at or beyond the presumptive emission limits, then the facility need not take into account the remaining statutory factors (as the State assumed BART would be met), the EPA has determined that each of the BART determinations did consider each of the five statutory factors. As mentioned above, the State is required to evaluate EGUs greater than 750 MW in accordance with the BART guidelines.  The BART Guidelines provide five steps (discussed previously) toward identifying BART control for these very large EGUs.  The resulting analyses are found in Appendix 9.5 (KCP&L) and Appendix 9.6 (Westar) and are discussed below.  
   
      The BART emission rates (established after consideration of each of the five statutory factors, discussed in detail below) are summarized in Table 17 and have been included in Consent Agreements with each source.

                         Subject-to-BART Emission Unit
                            BART Presumptive Limit
                           BART Operational Standard

                                      NOx
                                      SO2
                                      NOx
                                      SO2

                                   lb/MMBtu
KCP&L - La Cygne Unit 1
                                     0.10
                                     0.16*
                                     0.15
                                     0.15*
                                     0.13*
                                     0.10*
KCP&L - La Cygne Unit 2
                                     0.23
                                       
                                     0.15
                                       
                                       
                                       
Westar Energy - Jeffrey Unit 1
                                     0.15
                                     0.15
                                     0.15
                                     0.15
Westar Energy - Jeffrey Unit 2
                                     0.15
                                     0.15
                                     0.15
                                     0.15
* Weighted average
Table 17- BART Presumptive Limits and Operational Standards for NOx and SO2 at Subject-to-BART Emission Units in Kansas

BART Determination for Westar JEC Units 1 and 2
	The State determined that JEC Units 1 and 2, located in St. Mary's, Kansas and GEEC Unit 2, located in Colwich, Kansas, meet the BART eligibility criteria and contribute greater than 0.5 ∆dv to visibility impairment in a federally protected Class I area when compared to a natural background.  Therefore, these three units are subject to BART.  JEC Units 1 and 2 are each 720 MW coal-fired boilers.  GEEC Unit 2 is a 383MW oil-fired boiler (The GEEC facility has a capacity greater than 750 MW).  Therefore each of the units is a presumptive BART unit.
   
	The emission limits (described in Table 17 above) determined to represent BART for JEC Units 1 and 2 are maximum emission rates for the visibility-impairing pollutants NOx and SO2 because they are coal fired units.  Because GEC Unit 2 is an oil fired unit, it is subject to a fuel switch as BART.  The State determined that added PM2.5 controls would only improve visibility marginally, and would not be cost effective.  
   
      A summary of the visibility impairment attributable to the JEC Units 1 and 2 and GEEC Unit 2 is provided in Table 18. 
   
                                       
                               Wichita Mountains
                          Hercules Glades Wilderness
                            Caney Creek Wilderness
                                   Mingo NWR
                           Upper Buffalo Wilderness
 
                                 98th % ∆dv
                              Days > 0.5 ∆dv
                                 98th % ∆dv
                              Days > 0.5 ∆dv
                                 98th % ∆dv
                              Days > 0.5 ∆dv
                                 98th % ∆dv
                              Days > 0.5 ∆dv
                               98[th]  %   ∆dv
                              Days > 0.5 ∆dv
JEC Unit 1 and Unit 2
                                     0.99
                                      59
                                     0.90
                                      63
                                     0.73
                                      37
                                     0.49
                                      21
                                     0.85
                                      53
GEEC Unit 2
                                     1.08
                                      85
                                     0.40
                                      16
                                     0.38
                                      14
                                     0.17
                                       4
                                     0.42
                                      16
Table 18- Visibility Impairment Attributable to JEC Units 1 and 2 and GEC Unit 2 (2001-2003). "BART Five Factor Analysis- Westar Energy" Trinity Consultants




SO2 BART Determination

Table 19-Pollutant Specific Contributions to Existing Visibility Impairment for JEC Unit 1 and 2 (2001-2003). "BART Five Factor Analysis- Westar Energy" Trinity Consultants

      As shown in Table 19, the most significant visibility impairment attributable to these units is dominated by NOx emissions followed by SO2.  PM visibility impairment attribution from these units is not significant.  Because visibility impairment from PM is insignificant, the remainder of this section will focus the control strategies to reduce NOx and SO2.
  
	The five factor analysis identified several available control technologies for SO2.  This list included Dry Sorbent Injection (DSI), Wet Scrubbing, Dry Scrubbing and Circulating Dry Scrubbing (CDS).  It was found that all were technically feasible with scrubbing ranking as the control with the highest removal efficiency (Wet and Dry scrubbing have removal efficiencies that are very similar).  Because scrubbing technology has the highest removal efficiency of the above mentioned technologies, it was determined that the remainder of the analysis would evaluate only scrubbing for SO2 BART control. As the State had determined that the highest efficiency control technology would be BART, no cost comparison of lower efficiency controls was needed.
  
	The only non-air quality environmental impact raised as a potential issue was the handling of the waste product that results from scrubbing.  It was determined that this issue was related more to cost and did not prohibit the implementation of scrubbing. The remaining useful life of the units was considered as well.  It was determined that the useful life of the units were anticipated to be at least as long as the capital cost recovery period, which is 20 years, so the useful life of the units was not a hindrance to control for SO2 BART. 
  
	Next, the analysis considered the visibility improvement from scrubbing. As shown in Table 20, the implementation of scrubbing the units will result in at least a 0.68 dv improvement at the WIMO and a total visibility improvement of 2.8 dv improvement across all five Class I areas analyzed (considering maximum visibility impacts).


Table 20- Visibility Improvement from the Implementation of Presumptive SO2 BART. "BART Five Factor Analysis- Westar Energy" Trinity Consultants

      Based on the consultant's analysis, the State determined that the SO2 BART emission rate for JEC Unit 1 and Unit 2 would be 0.15 lb/MMBtu based on the operation of wet scrubbers.  The State required (through consent agreements) the facility to meet this limit for each unit on a 30-day rolling average, excluding periods of startup, shutdown and malfunction (SSM).  Compliance will be demonstrated using data from the existing continuous emissions monitoring systems (CEMS). Excluding the language on startup, shutdown and malfunction (as discussed in the Federal Register notice) in the Consent Agreements and in the State's SIP, the EPA finds that the proposed control strategy meets the presumptive limits established in the BART guidelines and sufficiently considers each of the five statutory factors.   

NOx BART Determination

	For NOx control, the State indentified Flue Gas Recirculation (FGR), Overfire Air (OFA), Low NOx Burners (LNB), Selective Catalytic Reduction (SCR) and Selective Non-Catalytic Reduction (SNCR) as being reasonably available, technically feasible technologies. The most efficient of these technologies was identified as being SCR followed by LNB systems. Because they were identified as being the most efficient, SCR and LNB were the only control technologies evaluated for cost.  

	The life expectancy considerations of these two units were discussed previously in this document. The State considered ammonia slip as a potential non-air environmental impact from SCR and SNCR NOx control but did not determine that it was significant enough an issue to eliminate SCR or SNCR from consideration.    

      In the BART guidelines, EPA states that most EGUs can meet the presumptive NOx limits through the use of current combustion control technology, i.e. LNB.  For units that cannot meet these rates using such technologies, the State should consider whether advanced combustion control technology should be considered.  The EPA calculated that for all types of boilers, other than cyclone boilers, combustion control technology is generally more cost-effective than post-combustion controls. The EPA estimated that approximately 75 percent of the BART units (non-cyclone) could meet the presumptive NOx limits at a cost of $100 to $1,000 per ton of NOx removed based on the use of combustion control technology. The EPA estimated, for the units that could not meet the presumptive limits using combustion control technology, that almost all of these sources could meet the presumptive limits using advanced combustion controls; the EPA estimated that the cost of such controls are usually less than $1,500 per ton removed.


Table 18- Cost Effectiveness Calculations for JEC Units 1 and 2. "BART Five Factor Analysis- Westar Energy" Trinity Consultants.

   Table 17 indicates that the cost effectiveness of LNB systems for JEC Unit 1 and
Unit 2 is less than $1,500 per ton of NOX removed. Tables 17 also indicates that the costs for SCR for JEC Unit 1 and Unit 2 are over $1500 per ton of NOX removed (JEC Unit 1 SCR cost = $2,211/ton and JEC Unit 2 SCR cost = $1,738/ton). As shown in Table 18 and 19 the visibility improvement from implementation of LNB at Unit 1 is estimated to be 0.57 dv at WIMO and 1.82 dv across all five Class I areas analyzed (considering maximum visibility impacts). The addition of SCR would only benefit 0.27 dv for an incremental cost increase of $6,613/ton.  Based on these facts the State determined that it was reasonable to determine that NOx BART for JEC Units 1 and 2 is the implementation of LNBs.  
  	




Table 21- Summaries of Cost effectiveness of NOx controls at JEC units 1 and 2. "BART Five Factor Analysis- Westar Energy" Trinity Consultants



Table 22-Summary of Modeled Impacts from NOx Control for JEC Unit 1 (2001-2003). "BART Five Factor Analysis- Westar Energy" Trinity Consultants


Table 23- Summary of Modeled Impacts from NOx Control for JEC Unit 2 (2001-2003). "BART Five Factor Analysis- Westar Energy" Trinity Consultants

      Based on the consultant's analysis, the State has determined that the NOx BART emission rate is 0.15 lb/MMBtu for both JEC Unit 1 and Unit 2.  The State has required the facility (through the previously discussed consent agreement) to meet this limit for both JEC Unit 1 and Unit 2 by installing LNB systems.  The State eliminated SCR as NOx BART due to the high incremental cost of SCR over LNB systems ($11,496,886 as an average over the two units) and the minimal increase in visibility improvement (0.05 dv improvement for both units).  The EPA finds that the proposed control strategy meets the presumptive limits established in the BART guidelines and sufficiently considers each of the five statutory factors.   We also believe that the State reasonably concluded that NOx BART is LNB in light of the incremental cost and the minimal impacts on visibility associated with SCR. 

BART Determination for Westar GEC Unit 2

SO2 BART Determination
Table 24-Pollutant Specific Contributions to Existing Visibility Impairment for GEC Unit 2 (2001-2003). "BART Five Factor Analysis- Westar Energy" Trinity Consultants

	As shown in Table 24 (above), the most significant visibility impairing pollutant attributable to this unit is NOx followed by SO2.  PM visibility impairment attribution from this unit is not significant.  Because visibility impairment from PM is insignificant, the remainder of this section will focus on control strategies to reduce NOx and SO2.
  
	The five factor analysis first identified several available control technologies for SO2.  These were DSI, Wet Scrubbing, Dry Scrubbing, CDS, and fuel switching.  DSI, Dry and Wet Scrubbing, as well as CDS are technologies collectively known as flue gas desulfurization (FGD) systems.  FGD applications have not been used historically for SO2 control in the U.S. electric industry on oil-fired units.  The EPA took this into account when establishing the presumptive SO2 emission rate for oil-fired units and determined that the presumptive emission rate should be based on the sulfur content of the fuel oil, rather than on FGD.  Therefore, FGDs are considered technically infeasible for the control of SO2 from GEEC Unit 2 and were not considered for BART for GEC Unit 2.  

The EPA identified, in the BART guidelines, that one percent sulfur fuel oil is the presumptive BART limit for oil-fired units.  The one percent sulfur oil is an alternative to the No. 6 fuel oil that is currently combusted by GEEC Unit 2.  The lower sulfur content of the one percent sulfur fuel oil would result in approximately a 33 percent reduction in SO2 emissions from GEC Unit 2 (see Table 25) as compared to the combustion of the current No. 6 fuel oil, which contains approximately 1.5 percent sulfur.  Fuel switching to 1 percent sulfur fuel oil is a technically feasible option for the control of SO2 from GEC Unit 2.



Unit
Emission Rate Scenario
                                 Emission Rate
 
 
                                      SO2
                                      NOX
                                    PM10* 
 
 
                                    (lb/hr)
                                    (lb/hr)
                                    (lb/hr)
GEEC Unit 2
Existing Emission Rate
                                    5,766.7
                                    4,818.3
                                     431.5
 
1 Percent Sulfur Fuel Oil
                                    3,844.5
                                    4,818.3
                                     326.3
Table 25- Summary of Emission Rates Comparing Existing Control to a Fuel Switch at GEC Unit 2. "BART Five Factor Analysis- Westar Energy" Trinity Consultants
*PM10 emissions are calculated based on AP-42 emission factors.
  
	The analysis also considered the cost of SO2 BART control of GEC Unit 2.  The cost effectiveness of switching to one percent sulfur fuel oil has been evaluated.  The cost of the fuel switching that was used in the cost effectiveness calculations was determined by calculating the cost of the current No. 6 fuel oil and determining the increased cost of switching to one percent sulfur fuel oil.  It was assumed in this analysis that the fuel switch will not require any capital expenses.  The fuel costs for one percent fuel oil was determined from the fuel costs published by the Energy Information Administration.  The fuel cost for the No. 6 fuel oil is the market price on February 14, 2007.

	The annual tons reduced that were used in the cost effectiveness calculations were determined by subtracting the estimated controlled annual emission rates from the existing annual emission rates.  The existing annual emission rates was the highest 365 day rolling totals as determined from CEMS data from 2002-2004.  The controlled annual emission rate was estimated by reducing the existing annual emission rate by 33 percent.

In the BART guidelines, EPA calculated that that the majority of BART-eligible units could meet the presumptive limits at a cost of $400 to $2,000 per ton of SO2 removed, based on the use of wet scrubbers and SDA systems.  Table 26 indicates that the cost of switching to one percent sulfur fuel oil is well above this range.  

                    Estimated No. 6 Oil  Hourly Usage Rate*
                   Estimated No. 6 Oil  Annual Fuel Usage†
                             No. 6 Oil  Fuel Cost
                     Estimated Annual No. 6 Oil Fuel Cost
                  Estimated 1% S Fuel Oil  Hourly Usage Rate*
                 Estimated 1% S Fuel Oil  Annual Fuel Usage‡
                              1% S Fuel Oil Cost
                      Estimated Annual 1% S Fuel Oil Cost
                                    Mgal/hr
                                    Mgal/yr
                                   Cents/gal
                                     $/yr
                                    Mgal/hr
                                    Mgal/yr
                                   Cents/gal
                                     $/yr
                                    27.40*
                                  108,011†
                                      85
                                  91,809,180
                                   27.96‡
                                  110,215†
                                     117.1
                                  129,061,884


                         Annual Cost of Fuel Switching
                            SO2 Cost Effectiveness
                                    ($/yr)
                                    ($/ton)
                                  37,252,704
                                    25,969
Table 26- Summary of Cost Effectiveness for Switching from No. 6 Oil to one percent sulfur fuel. "BART Five Factor Analysis- Westar Energy" Trinity Consultants
*4110 MMBtu/hr/150 MMBtu/Mgal; ‡4110 MMBtu/hr/147 MMBtu/Mgal; †Annual fuel usage is based on the hourly fuel usage rate and 3,942 annual operating hours (Assuming unit operates at an annual 45% capacity factor, 45% * 8,760 hours = 3,942 hours)

	There were no non-air quality environmental impacts raised as potential issues for fuel switching.  The analysis did consider the remaining useful life of the units. It was determined that the remaining useful life of GEC Unit 2 was not a deterrent for considering SO2 BART control at GEC Unit 2 it was assumed that fuel switching would not require capital costs, and therefore did not impact the annualized cost. 

	Finally, the analysis considered the visibility improvement from a fuel switch. As shown in Table 26, the implementation of a fuel switch at GEC Unit 2 will result in at least a 0.14 dv improvement at the WIMO and a total visibility improvement of 0.70 dv improvement across all five Class I areas analyzed (considering maximum visibility impacts).
  
The State, after initial consideration of each of the five statutory factors, determined that SO2 BART for GEC Unit 2 could be a fuel switch to one percent sulfur fuel oil.  However, after consideration of a "BART Alternative" proposed by Westar (and discussed later in this document) the State's final SO2 BART determination for GEC Unit 2 is a fuel switch to natural gas combustion.

                                       
                               Wichita Mountains
                          Hercules Glades Wilderness
                            Caney Creek Wilderness
                                   Mingo NWR
                           Upper Buffalo Wilderness
                                       
Maximum Impact (Δdv)
98% Impact (Δdv)
# Days > 0.5 Δdv
Visibility Improvement*
Maximum Impact (Δdv)
98% Impact (Δdv)
# Days > 0.5 Δdv
Visibility Improvement*
Maximum Impact (Δdv)
98% Impact (Δdv)
# Days > 0.5 Δdv
Visibility Improvement*
Maximum Impact (Δdv)
98% Impact (Δdv)
# Days > 0.5 Δdv
Visibility Improvement*
Maximum Impact (Δdv)
98% Impact (Δdv)
# Days > 0.5 Δdv
Visibility Improvement*
Existing Emission Rate
                                     2.16
                                     1.08
                                      85
                                       -
                                     1.31
                                     0.40
                                      16
                                       -
                                     1.07
                                     0.38
                                      14
                                       -
                                     0.71
                                     0.17
                                       4
                                       -
                                     2.22
                                     0.42
                                      16
                                       -
One Percent Sulfur Fuel Oil
                                     2.02
                                     0.94
                                      71
                                      13%
                                     1.19
                                     0.34
                                      10
                                      13%
                                     0.87
                                     0.34
                                       9
                                      10%
                                     0.65
                                     0.14
                                       2
                                      16%
                                     2.04
                                     0.38
                                      15
                                      10%


Table 27- Summary of Modeled Impacts from SO2 control at GEC Unit 2 (2001-2003). "BART Five Factor Analysis- Westar Energy" Trinity Consultants

NOx BART Determination
      For NOx control, the State indentified FGR, OFA, LNB, SCR and SNCR as being reasonably available, technically feasible technologies. The most efficient of these technologies was identified as being SCR followed by LNB systems. Because it was identified as being the most efficient, SCR was the only control technology evaluated for cost.  The capital cost and operating costs of SCR were estimated based on the State's SCR installation experience.  The capital costs were annualized over a 20-year period and then added to the annual operating costs to obtain the total annualized costs.  The annual tons reduced that were used in the cost effectiveness calculations were estimated by subtracting the estimated controlled annual emission rates from the existing annual emission rates.  The existing annual emission rates were the highest 365 day rolling totals as determined from CEMS data from 2002-2004.   
The controlled annual emission rates were estimated by multiplying estimated control efficiency for the SCR (90 percent) by the existing annual emission rates.  A sample of the controlled annual emission rate is shown as follows: =235 tpy

The cost effectiveness for the SCR was determined by dividing the annual cost by the annual tons reduced.  The cost is summarized in Table 28.  The cost of the SCR is greater than $5,300/ton of NOX removed.  Compared to the cost effectiveness range for NOx BART control (established by the EPA and previously discussed) the State determined that the cost of SCR was prohibitive.
   
                                       
                         Current Annual Emission Rate
                       Controlled Annual Emission Rate*
                          Estimated Reduced Emissions
                                Capital Cost†
                          Annualized Capital Cost‡
                          Annualized Fixed O&M‡
                        Annualized Variable O&M‡
                             Total Annualized Cost
                              Cost Effectiveness
 
                                     (tpy)
                                     (tpy)
                                   (ton/yr)
                                      ($)
                                    ($/yr)
                                    ($/yr)
                                    ($/yr)
                                    ($/yr)
                                    ($/ton)
SCR
                                     2,352
                                      235
                                     2,117
                                  81,000,000
                                   9,514,260
                                    218,932
                                   1,627,628
                                  11,360,820
                                     5,367
Table 28- Summary of Cost Effectiveness for GEC Unit 2 NOx Control (SCR). "BART Five Factor Analysis- Westar Energy" Trinity Consultants
*The annual emission rate represents a control efficiency of 90%.
†The SCR capital cost was determined from recent SCR installation experience
‡The costs are annualized in 2006 dollars. 

The non-air environmental impacts were evaluated for SCR.  The five factor analysis briefly describes some concern with electricity consumption of SCR and the potential for SCR to potentially cause environmental impacts related to the usage and storage of ammonia.  Storage of aqueous ammonia above 10,000 lbs is regulated by a risk management program (RMP), since the accidental release of ammonia has the potential to cause serious injury and death to persons in the vicinity of the release.  Ammonia can also be emitted in the exhaust of boilers that operate with SCR or SNCR for NOx control due to ammonia slip.  Ammonia slip from SCR and SNCR systems occurs either from ammonia injection at temperatures too low for effective reaction with NOx, leading to an excess of un-reacted ammonia, or from over-injection of reagent leading to uneven distribution; which also leads to an excess of un-reacted ammonia.  Ammonia released from SCR and SNCR systems will react with sulfates and nitrates in the atmosphere to form ammonium sulfate which are sources of regional haze.

 The remaining useful life of GEEC Unit 2 does not impact the annualized capital costs of potential controls because the useful life of the unit is anticipated to be at least as long as the capital cost recovery period, which is 20 years.

	The State compared the visibility improvement for existing emission rates to the emission rates associated with SCR.  The results of this analysis are given in Table 29 (Table 31 shows the visibility improvement expected of LNB and 1% sulfur coal).  The existing emission rates and emission rates associated with SCR were modeled using CALPUFF.  The existing emission rates were the same rates that were modeled for the BART applicability analysis.  The emission rate associated with the SCR for GEC Unit 2 was 0.12 lb/MMBtu.  The emission rate for SCR was determined by reducing the existing hourly equivalent of the maximum 24-hour emission rate by a control efficiency of 90 percent. 
   
	Comparisons of the existing visibility impacts and the visibility impacts associated with SCR, including the maximum modeled visibility impact, 98[th] percentile modeled visibility impact, and the number of days with a modeled visibility impact greater than 0.5 Δdv, for each Class I area are provided in Table 29 for GEC Unit 2.   As shown in Table 29, the installation of SCR results in a 98[th] percentile modeled visibility impact of 0.09 to 0.60 dv as compared to 0.17 to 1.08 dv (depending on the Class I area) at the existing emission rate, and attributable to GEC Unit 2.  However, as previously documented in Table 28, the cost of SCR for this unit is estimated at over $5,300/ton.  This cost is high compared to the relatively minimal associated visibility improvement.

 
                               Wichita Mountains
                          Hercules Glades Wilderness
                            Caney Creek Wilderness
                                   Mingo NWR
                           Upper Buffalo Wilderness
 
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
Existing Emission Rate
                                     2.16
                                     1.08
                                      85
                                       -
                                     1.31
                                      0.4
                                      16
                                       -
                                     1.07
                                     0.36
                                      14
                                       -
                                     0.71
                                     0.17
                                       4
                                       -
                                     2.22
                                     0.42
                                      16
                                       -
SCR
                                     1.34
                                     0.60
                                      28
                                      45%
                                     1.09
                                     0.20
                                       5
                                      51%
                                     0.65
                                     0.21
                                       4
                                      46%
                                     0.34
                                     0.09
                                       0
                                      48%
                                     1.07
                                     0.20
                                       8
                                      51%
* Improvement is based on the 98% impact visibility improvement (Δdv) of SCR over the existing emission rate.
 
 
 
 
Table 29- Summary of Modeled Visibility Impacts from SCR control. "BART Five Factor Analysis- Westar Energy" Trinity Consultants
   
Since the cost of SCR was high given the associated visibility improvements, the State determined that LNB could achieve at least the presumptive emission rate at GEC Unit 2 and therefore LNB would be NOx BART for GEC Unit 2.  However, since the concurrent analysis for SO2 reduction (discussed later in this document) demonstrated that control through fuel switching to natural gas resulted in both SO2 and NOx emission reductions, and in visibility improvements beyond those gained by presumptive BART, the State determined, and EPA agrees, that the fuel switch to natural gas meets the NOx BART requirements.

 BART Alternative for GEC Unit 2

      Based on the SO2 and NOx BART analyses, the State had determined that BART for SO2 for GEC Unit 2 was likely the combustion of one percent sulfur fuel oil and BART for NOX was the installation of LNB.  However, Westar proposed an alternative to the controls determined to meet BART for SO2 and NOX for GEC Unit 2.  In order for control strategies to be acceptable as an alternative to what is determined to meet BART, the alternatives must show greater visibility improvement on average than what is determined to meet BART based on the following visibility metrics: 
         * The maximum visibility impact 
         * The 98th percentile visibility impact 
         * The number of days where the visibility impacts are greater than 0.5 ∆dv 
 The State chose to implement this test by evaluating whether the values for the metrics listed above for an alternative BART control strategy were equal to or better than the values for the BART control strategy for each Class I area.  

      As an alternative to combusting one percent fuel oil to reduce SO2 and LNB to reduce NOx for GEC Unit 2, Westar proposed to combust natural gas in GEC Unit 2.  Westar proposed to demonstrate compliance with the alternative BART control strategy for GEC Unit 2 agreeing to submit annual certifications of compliance verifying that natural gas was the only fuel combusted in GEC Unit 2 for the year, except as provided below.  

      In order to assure electric system reliability, Westar requires the availability of an emergency fuel for backup, as well as the ability to burn a limited amount of the fuel periodically during non-emergencies to assure that the emergency system functions adequately.  When the natural gas company implements an Operational Flow Order (OFO) or declares an emergency which could result in an impact to electric system reliability, Westar will combust No. 6 fuel oil for the time period of the emergency.  Westar will diminish the existing supply of No. 6 fuel oil, once diminished the emergency fuel will be replaced with a fuel oil containing 1percent or less sulfur content.  

	The modeled visibility impacts of the BART control strategy and the proposed alternative BART control strategy are summarized in Table 30.  The visibility improvement associated with the BART and alternative BART control options are also shown in Table 30; this value was calculated as the difference between the existing visibility impairment and the visibility impairment for the BART and alternative BART control options as measured by the 98[th] percentile modeled visibility impact.  The visibility impacts for each metric are lower in all five Class I areas for the alternate BART control strategy and are shown in Table 31.
   
	Because the maximum visibility impact, the 98th percentile visibility impact and the number of days where the visibility impacts are greater than 0.5 ∆dv are equal to or better than the values for the presumptive BART control strategy (even though the emissions of NOx are higher with the alternative than the presumptive BART strategy), for each Class I area, the State determined that the BART alternative met the requirements of the Rule. 
   
	Based on the consultant's analysis, the State has determined that the fuel switch to natural gas provides greater reasonable progress than NOx and SO2 BART presumptive limits combined.  The State has required the facility (through previously discussed consent agreement) to establish compliance with this strategy by reporting to the State fuel oil usage at Unit 2 in accordance with K.A.R. 28-19-512.  The EPA is proposing to find that the proposed control strategy meets the presumptive limits established in the BART guidelines and sufficiently considers each of the five statutory factors.  EPA also is proposing to find that Kansas reasonably concluded that the BART alternative will provide for greater reasonable progress than BART.


                                       
             Presumptive BART Case-1% Sulfur, LNB at 0.8 lb/MMBTu 
            Presumptive BART Case- 1% Sulfur, LNB at 0.2 lb/MMBTu 
                      Alternative BART Case- Natural Gas 
                                Maximum (in dv)
                                     1.575
                                     1.02
                                     0.744
                                  98% (in dv)
                                     0.804
                                     0.474
                                     0.344
                                  NOx (lb/hr)
                                    3288.0
                                     822.0
                                    2136.0
                                  SO2 (lb/hr)
                                    3844.4
                                    3844.4
                                      1.7
                                  PM (lb/hr)
                                     324.7
                                     326.3
                                     30.6
Table 30- Comparison of Presumptive BART (1% Sulfur Fuel and LNB) to the BART Alternative


 
                               Wichita Mountains
                          Hercules Glades Wilderness
                            Caney Creek Wilderness
                                   Mingo NWR
                           Upper Buffalo Wilderness
 
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
                             Maximum Impact (Δdv)
                               98% Impact (Δdv)
                             # Days > 0.5 Δdv
                            Visibility Improvement
Existing Emission Rate
                                     2.16
                                     1.08
                                      85
                                       -
                                     1.31
                                      0.4
                                      16
                                       -
                                     1.07
                                     0.36
                                      14
                                       -
                                     0.71
                                     0.17
                                       4
                                       -
                                     2.22
                                     0.42
                                      16
                                       -
Existing BART-LNB +1% sulfur fuel oil
                                     2.02
                                     0.94
                                      71
                                      13%
                                     1.19
                                     0.34
                                      10
                                      13%
                                     0.87
                                     0.34
                                       9
                                      10%
                                     0.65
                                     0.14
                                       2
                                      16%
                                     2.04
                                     0.38
                                      15
                                      10%
Altnernative-Natural Gas
                                     1.66
                                     0.69
                                      44
                                      36%
                                     0.93
                                     0.21
                                       4
                                      48%
                                     0.49
                                     0.25
                                       0
                                      34%
                                     0.49
                                     0.08
                                       0
                                      55%
                                     1.62
                                     0.28
                                      11
                                      33%
* Improvement is based on the 98% impact visibility improvement (Δdv) of SCR over the existing emission rate.
 
 
 
 
 
 
Table 31- Comparison of Presumptive BART (1% Sulfur Fuel and LNB) to the BART Alternative at Five Class I area. "BART Five Factor Analysis- Westar Energy" Trinity Consultant
BART Determination for KCP&L Units 1 and 2
	The State determined that KCP&L Units 1 and 2, located in La Cygne, Kansas met the BART eligibility criteria and contribute greater than 0.5 ∆dv to visibility impairment in a federally protected Class I area when compared to a natural background.  Therefore, these units are subject to BART.  KCP&L Unit 1 is an 840 MW boiler with a scrubber for SO2 and PM control and overfire air that minimizes the formation of  NOx.   Unit 2 is a 710 MW boiler that has an electrostatic precipitator (ESP) for PM control. Unit 1 burns a blend of Powder River Basin (PRB) coal and local coal. Unit 2 burns 100 percent PRB coal. Both units are presumptive units for BART.
   
      The emission limits determined to represent BART for KCP& L Units 1 and 2 are maximum emission rates for the visibility-impairing pollutants NOx and SO2 because they are coal fired units.
      
      A summary of the visibility impairment attributable to the KCP& L Units 1 and 2 is provided in Table 32. 

Table 32-Visibility Impairment Attributable to KCP&L Units 1 and 2 (2001-2003). "BART Five Factor Analysis- Kansas City Power & Light- La Cygne" Trinity Consultants


SO2 BART Determination

Table 33- Pollutant Specific Contributions to Existing Visibility Impairment for KCP& L Units 1 and 2. "BART Five Factor Analysis- Kansas City Power & Light- La Cygnes" Trinity Consultants

	As shown in Table 33, the most significant visibility impairment attributable to these units is pretty evenly dominated by NOx and SO2.  PM visibility impairment attribution from these units is not significant.  Because visibility impairment from PM is insignificant, the remainder of this section will focus the control strategies to reduce NOx and SO2.
  
	The five factor analysis identified several available control technologies for SO2.  This list included DSI, Wet Scrubbing, Dry Scrubbing and CDS.  It was found that all were technically feasible with scrubbing ranking as the control with the highest removal efficiency (Wet and Dry scrubbing have removal efficiencies that are very similar).  Because scrubbing technology has the highest removal efficiency of the above mentioned technologies, it was determined that the remainder of the analysis would evaluate only scrubbing for SO2 BART control. The State had determined that the highest efficiency control technology would be BART, and no cost comparison of lower efficiency controls was needed.
  
	The only non-air quality environmental impact raised as a potential issue was the handling of the waste product that results from scrubbing.  It was determined that this issue was related more to cost and did not prohibit the implementation of scrubbing. The remaining useful life of the units was considered as well.  It was determined that the useful life of the units were anticipated to be at least as long as the capital cost recovery period, which is 20 years, so the useful life of the units was not a hindrance to control for SO2 BART. 
  
	Next, the analysis considered the visibility improvement from scrubbing. As shown in Table 34, the implementation of scrubbing the units will result in at least a 0.81 dv improvement at the WIMO and a total visibility improvement of 5.32 dv improvement across all five Class I areas analyzed (considering maximum visibility impacts).
  
  
Table 34- Visibility Improvement from the Implementation of Presumptive BART. "BART Five Factor Analysis- Kansas City Power & Light- La Cygnes" Trinity Consultants

      Based on the consultant's analysis, the State determined that the SO2 BART emission rate for KCP&L Unit 1 and Unit 2 would be 0.15 lb/MMBtu (as a weighted average) based on the operation of wet scrubbing technology.  However, during the process of developing the consent agreement, KCP&L proposed a more restrictive emission limit than the presumptive limit of 0.15 lb/MMBtu (weighted average), to 0.10 lb/MMBtu on a 30-day rolling weighted average.  Compliance will be demonstrated by reconfiguring the CEMS software to generate a daily report showing the two-unit 30-day rolling average. The average must remain below 0.10 lb/MMBtu, excluding periods of startup and shutdown.
   
      Compliance will be demonstrated using data from the existing CEMS. Excluding the language on SSM in the Consent Agreement and in the State's SIP (as discussed in the Federal Register notice) the EPA finds that the proposed control strategy meets the presumptive limits established in the BART guidelines and sufficiently considers each of the five statutory factors.   

NOx BART Determination
      For NOx control, the State indentified FGR, OFA, LNB, SCR and SNCR as being reasonably available, technically feasible technologies. The most efficient of these technologies was identified as being SCR followed by LNB systems. Because it was identified as being the most efficient SCR was evaluated for cost.  Because it was a combustion control technology capable of achieving the presumptive BART level for NOx, LNB was also evaluated for cost.  
   
      At the time of the five factor analysis, KCP&L was in the process of constructing an SCR system on KCP&L Unit 1. Since SCR provides the highest level of control there was no need to evaluate the cost for other NOx controls for Unit 1. The life expectancy considerations of these two units were discussed previously in this document. The State considered ammonia slip as a potential non-air environmental impact from SCR control but did not determine that it was significant enough an issue to eliminate SCR or from consideration.
   

Table 35-Summary of Cost Effectiveness of NOx Control at KCP&L Units 2. "BART Five Factor Analysis- Kansas City Power & Light- La Cygnes" Trinity Consultants

Table 36- Summary of NOx Control at KCP&L Unit 2. "BART Five Factor Analysis- Kansas City Power & Light- La Cygnes" Trinity Consultants

	Kansas stated in its SIP that the EPA is on record stating that most EGUs can meet the presumptive NOx limits through the use of current combustion control technology, i.e. LNB.  For units that cannot meet these rates using such technologies, the State should consider whether advanced combustion control technology should be considered.  The EPA estimated that approximately 75 percent of the BART units (non-cyclone) could meet the presumptive NOx limits at a cost of $100 to $1,000 per ton of NOx removed based on the use of combustion control technology. The EPA estimated, for the units that could not meet the presumptive limits using combustion control technology, that almost all of these sources could meet the presumptive limits using advanced combustion controls; the EPA estimated that the cost of such controls are usually less than $1,500 per ton removed. Kansas went on to conclude that since the cost effectiveness of SCR (and advanced combustion control technology) implementation at KCP&L is greater than the $1,500 cost effectiveness threshold to meet the presumptive emission limits for a coal fired unit, LNB are NOx BART for KCP&L Unit 2.  Although Kansas' recitation of the Federal Register and guidance is correct, use of the above estimated cost ranges at which many BART units across the nation could meet presumptive NOx limits as a cost threshold to eliminate, outright, more stringent limits associated with technology such as SCR, is inappropriate.

	Based on the consultant's analysis, the State had determined that the NOx BART emission rates were the presumptive emission rates of 0.10 lb/MMBtu and 0.23 lb/MMBtu for Unit 1 and Unit 2, respectively (or 0.16 lb/MMBtu as a weighted average), which resulted in a combined (SO2 and NOx) modeled visibility improvement of 78-81% (98[th] percentile visibility impact) and a reduction of the number of days with a visibility impact greater than 0.5 dv from a range of 57-138 days to 3-14 days. During the course of negotiating an enforceable BART agreement, KCP&L proposed limits that were more restrictive than the presumptive BART limits.  This proposal was made in order to be consistent with an agreement KCP&L has with the Sierra Club and with the knowledge that the Kansas City metro area has been close to nonattainment for ozone. The State agreed that the alternative emission limits proposed by KCP&L were better than the presumptive BART limits and KDHE incorporated these limits into the KCP&L consent agreement. The agreement includes an emission rate of 0.13 lb/MMBtu on a 30-day rolling weighted average using the already permitted SCR control for Unit 1 and some form of pre- or post-combustion control (e.g., low NOx burner, low NOx burner with overfire air, or SCR) for Unit 2.  At the 0.13 lb/MMBtu weighted average rate for both units, which is beyond the presumptive NOx rate of 0.23 lb/MMBtu, EPA would not anticipate additional significant visibility improvement for the additional significant cost of installing SCR on Unit 2. 

      Compliance will be demonstrated via reconfiguring the CEMS software to generate a daily report showing the two-unit 30-day rolling average.  The average must remain below 0.13 lb/MMBtu, excluding periods of startup and shutdown.  In the event Unit 2 suffers an outage in excess of 10 weeks the facility will meet the 0.10 lb/MMBtu presumptive limit for NOx at Unit 1.  Excluding the language on SSM in the Consent Agreement and in the State's SIP (as discussed in the Federal Register notice) the EPA finds that the proposed control strategy meets or exceeds the presumptive limits established in the BART guidelines and sufficiently considers each of the five statutory factors. 
   


Reasonable Progress/Long Term Strategy
	Since Kansas does not host a Class I area, it is not required to set Reasonable Progress Goals (RPGs).  However, it is required to determine the emission reductions needed from sources within the State that are necessary to meet the RPGs of Class I areas hosted by other states.  Kansas must provide the emission reduction strategy it will undertake to obtain those emissions in its Long Term Strategy (LTS).  A six step process was used to identify which point sources needed to be controlled as part of the LTS.  The results of each of these steps of the process will be described in sequence below.   
      
      First, the State identified all point sources with emissions of greater than 500 tpy NOx and/or SO2 by using the 2002 base year inventory (previously described in this TSD).  The State chose 500 tpy as a screening criterion because it was determined by modeling (previously discussed in this TSD) that a source emitting less than 500 tpy of either pollutant would not significantly impact (great than 0.5 delta dv) Class I areas hosted by another State.  Kansas identified a total of 30 NOx units and 28 SO2 units.  Of this set of units, 8 NOx and 10 SO2 units were removed from further review for the following reasons:
      
       * 6  of the NOx units and 6 of the SO2 units were already identified as BART-subject;
       *       2 of the NOx units and 2 of the SO2 units had installed controls since 2002 and emitted less than 500 tpy of either pollutant.
       * 2 of the SO2 units were determined to have no commercially available controls.
   
      The remaining set of 22 NOx units included 11 EGUs, 6 cement kilns, 2 gas compressor engines, 1 refinery fluid-bed catalytic cracking unit (FCCU), 1 ammonia plant, and 1 glass furnace, all located at 15 separate facilities.  The 18 SO2 units were comprised of 13 EGUs, 4 cement kilns, and 1 refiner FCCU, all located at 12 facilities. A list of these sources is provided below in Table 37.
   
                                   Source ID
                                   Facility
                                     Unit
                                   2002 NOx
                                   2002 SO2



                                    ton/yr
0910057
AGC Flat Glass North America
Glass furnace
                                                                          1,375
                                                                      [234.2] *
1330001
Ash Grove Cement
Kiln
                                                                          2,121
                                                                            747
0210002
Empire District Electric  -  Riverton
Unit 7
                                                                            582
                                                                          2,393
0210002
Empire District Electric - Riverton
Unit 8
                                                                          1,040
                                                                            866
0150004
Frontier El Dorado Refinery
FCCU
                                                                            688
                                                                            856
1250015
Heartland Cement
Kiln
                                                                            928
                                                                          1,007
2090048
Kansas City BPU - Quindaro
Unit 1
                                                                          1,599
                                                                          1,288
2090048
Kansas City BPU - Quindaro
Unit 2
                                                                          1,330
                                                                          2,123
2090008
Kansas City BPU  -  Nearman
Unit 1
                                                                          3,860
                                                                        7,625 
0930012
Kinder Morgan - Lakin Station
EU-2
                                                                            579
                                                                          [0.1]
0570003
Koch Nitrogen
Ammonia plant
                                                                            585
                                                                          [0.5]
2057022
Lafarge Midwest - Fredonia
Kiln 1
                                                                            596
                                                                            660
2057022
Lafarge Midwest - Fredonia
Kiln 2
                                                                            883
                                                                            978
0010009
Monarch Cement
Kiln 4
                                                                            652
                                                                         [74.7]
0010009
Monarch Cement
Kiln 5
                                                                            972
                                                                        [254.6]
0670035
ONEOK - Ulysses Station
Clark 1
                                                                            619
                                                                          [0.1]
0550023
Sunflower Electric - Holcomb
Unit 1
                                                                          3,781
                                                                          1,669
1730012
Westar Energy - Gordon Evans
Unit 1
                                                                        [208.5]
                                                                            618
1550033
Westar Energy - Hutchinson
Unit 4
                                                                        [209.2]
                                                                            734
1490001
Westar Energy  -  Jeffrey
Unit 3
                                                                         10,481
                                                                         23,206
0450014
Westar Energy  -  Lawrence
Unit 3
                                                                            738
                                                                          1,965
0450014
Westar Energy  -  Lawrence
Unit 4
                                                                          2,037
                                                                          1,430
0450014
Westar Energy  -  Lawrence
Unit 5
                                                                          3,762
                                                                          4,354
1770030
Westar Energy  -  Tecumseh
Unit 7
                                                                          1,531
                                                                          2,693
1770030
Westar Energy  -  Tecumseh
Unit 8
                                                                          1,877
                                                                          4,515
[*] Values within brackets indicate 2002 emissions less than 500 tpy.
Table 37- Kansas Emission Units Not Subject to BART Emitting at Least 500 Tons/Yr of NOx or SO2 in 2002

      During the second step, the State matched each of the remaining units with the emission control technology selected for it by a CENRAP contractor, Alpine Geophysics, utilizing the least marginal cost.  For units that were not identified by Alpine Geophysics, the units were matched with control technologies, control efficiencies and control cost as determined by EPA's AirControlNET version 4.1.  Units whose cost of control was determined to be $10,000/ton reduced or greater were screened out in this step.  It was agreed by members of CENRAP that $10,000/ton was an excessive cost of control.  Eight SO2 emission units were removed from the list of candidate units, and are listed in Table 38, which shows each unit's $/ton over $10,000/ton.

SO2 emission unit
Cost per ton reduced
Frontier El Dorado Refinery FCCU
                                    $14,069
Empire District Electric - Riverton Unit 7
                                    $11,066
Heartland Cement Kiln
                                    $28,435
Westar Energy - Lawrence Unit 4
                                    $40,598
Sunflower Electric - Holcomb Unit 1
                                    $10,767
Ash Grove Cement Kiln
                                    $24,305
Lafarge Midwest - Fredonia Kiln 1
                                    $20,127
Lafarge Midwest - Fredonia Kiln 2
                                    $13,586
Table 38- Sources with Cost per Ton Reduced Greater than $10,000/ton

      Calculations for fuel switching at Westar's Hutchinson Energy Center Unit 4 and Gordon Evans Energy Center Unit 1 involved analysis of the price of natural gas and #6 residual oil based on publicly available information from the Energy Information Administration. Calculations for Hutchinson Unit 4 included switching to all natural gas with the equivalent heat input of the 4,195 thousand gallons (Mgal) of #6 oil and 1,240 million cubic feet (MMcf) of natural gas burned in 2002.  Gordon Evans Unit 1 included fuel switching to all natural gas based on 3,930 Mgal #6 oil and 865 MMcf natural gas in 2002.  The price of natural gas used in the calculations was $1,200/Mgal for #6 oil and was $8,000/MMscf for natural gas.  Prices from June 2005 to November 2006 were used to reflect more current prices.  Negative cost results for both units (-$135/ton and -$37/ton, respectively) imply that the residual oil burned in 2002 was purchased at a lower price than the amount used for the analysis.  Also, although fuel switching for these two units was selected as a control strategy for SO2, some control of NOx was achieved as well, and was included in the CALPUFF modeling in next step of the analysis.
   

                                   Source ID
                                   Facility
                                     Unit
                           Selected control measure
                            Control efficiency (%)
          Cost per ton reduced ($2002 AirControlNET or $2005 Alpine)
                                    Source
NOx sources
                                    0910057
AGC Flat Glass North America
Glass Furnace
                                     SNCR
                                     40.0
                                    $1,041
                                 AirControlNET
                                    1330001
Ash Grove Cement
Cement Kiln
                                      LNB
                                     25.0
                                     $509
                                 AirControlNET
                                    0210002
Empire District Electric - Riverton
Unit 7
                                     LNBO
                                     55.9
                                    $1,398
                                    Alpine
                                    0210002
Empire District Electric - Riverton
Unit 8
                                     LNC3
                                     53.1
                                     $873
                                    Alpine
                                    0150004
Frontier El Dorado Refinery
FCCU
                                   LNB + FGR
                                     55.0
                                    $5,314
                                    Alpine
                                    1250015
Heartland Cement
Cement Kiln
                                Mid-kiln firing
                                     30.0
                                      $83
                                    Alpine
                                    2090008
Kansas City BPU  -  Nearman
Unit 1
                                  LNB+OFA+NN
                                     45.2
                                     $750
                             BPU  -  2006 dollars 
                                    2090048
Kansas City BPU - Quindaro
Unit 1
                                      NGR
                                     50.0
                                     $579
                                    Alpine
                                    2090048
Kansas City BPU - Quindaro
Unit 2
                                      LNB
                                     40.3
                                     $849
                                 AirControlNET
                                    0930012
Kinder Morgan - Lakin Station
EU-2
                                   A/F + IR
                                     30.0
                                    $2,027
                                 AirControlNET
                                    0570003
Koch Nitrogen
Ammonia Plant
                                    OT + WI
                                     65.0
                                     $688
                                    Alpine
                                    2057022
Lafarge Midwest - Fredonia
Kiln 1
                                Mid-kiln firing
                                     30.0
                                      $83
                                    Alpine
                                    2057022
Lafarge Midwest - Fredonia
Kiln 2
                                Mid-kiln firing
                                     30.0
                                      $83
                                    Alpine
                                    0010009
Monarch Cement
Kiln 4
                              Biosolid injection
                                     23.0
                                     $466
                                    Alpine
                                    0010009
Monarch Cement
Kiln 5
                              Biosolid injection
                                     23.0
                                     $466
                                    Alpine
                                    0670035
ONEOK - Ulysses Station
Clark 1
                                   A/F + IR
                                     30.0
                                     $323
                                    Alpine
                                    0550023
Sunflower Electric - Holcomb
Unit 1
                                      LNB
                                     16.0
                                    $1,383
                                 AirControlNET
                                    1490001
Westar Energy - Jeffrey
Unit 3
                                     LNC3
                                     58.3
                                    $1,560
                                    Alpine
                                    0450014
Westar Energy - Lawrence
Unit 3
                                     LNC1
                                     33.1
                                     $683
                                    Alpine
                                    0450014
Westar Energy - Lawrence
Unit 4
                                     LNC1
                                     43.3
                                     $325
                                    Alpine
                                    0450014
Westar Energy - Lawrence
Unit 5
                                     LNC3
                                     58.3
                                    $1,628
                                    Alpine
                                    1770030
Westar Energy - Tecumseh
Unit 7
                                     LNC1
                                     33.1
                                     $432
                                    Alpine
                                    1770030
Westar Energy - Tecumseh
Unit 8
                                     LNC3
                                     53.1
                                     $518
                                    Alpine
SO2 sources
                                    0210002
Empire District Electric - Riverton
Unit 8
                               FGD wet scrubber
                                     90.0
                                    $5,782
                                    Alpine
                                    2090008
Kansas City BPU  -  Nearman
Unit 1
                               Semi-Dry scrubber
                                     88.5
                                    $2,024
                              BPU - 2006 dollars
                                    2090048
Kansas City BPU - Quindaro
Unit 1
                               FGD wet scrubber
                                     90.0
                                    $5,825
                                    Alpine
                                    2090048
Kansas City BPU - Quindaro
Unit 2
                               FGD wet scrubber
                                     90.0
                                    $3,522
                                    Alpine
                                    1730012
Westar Energy - Gordon Evans
Unit 1
                                Fuel switching
                                     99.9
                                     ($37)
                                     KDHE
                                    1550033
Westar Energy - Hutchinson
Unit 4
                                Fuel switching
                                     99.9
                                    ($135)
                                     KDHE
                                    1490001
Westar Energy - Jeffrey
Unit 3
                               FGD wet scrubber
                                     75.0
                                    $1,695
                                 AirControlNET
                                    0450014
Westar Energy - Lawrence
Unit 3
                               FGD wet scrubber
                                     90.0
                                    $5,339
                                    Alpine
                                    0450014
Westar Energy - Lawrence
Unit 5
                               FGD wet scrubber
                                     79.2
                                    $9,265
                                 AirControlNET
                                    1770030
Westar Energy - Tecumseh
Unit 7
                               FGD wet scrubber
                                     90.0
                                    $4,519
                                    Alpine
                                    1770030
Westar Energy - Tecumseh
Unit 8
                               FGD wet scrubber
                                     90.0
                                    $3,715
                                    Alpine
Table 39- Most Effective Control Technologies with Acceptable Control Costs for Kansas 500-Ton NOx and SO2 Emission Units

      As part of the third step, the 22 NOx and 10 SO2 units within 17 facilities remaining were evaluated for visibility impacts at Class I areas.  Essentially the same CALPUFF protocol was followed as for BART screening, so modeling was carried out on a facility-by-facility basis, and NOx and SO2 impacts were calculated together.  Post-control model inputs for emissions were calculated using the control efficiencies included with each control technology selected in the second step of this analysis (previously described).  Instead of looking at number of days with greater than 1.0 dv impact as was done for BART screening, in this analysis actual deciview values for each facility's modeled impacts were pulled from the post-processing file and examined by the State.  Pre- and post-control 98[th] percentile deciview values for the Class I area with greatest impact were recorded, and are presented in Table 40.  Respective differences in deciview are labeled as visibility improvements and the Class I areas with greatest impact are shown.

                                   Source ID
                                   Facility
                       Max. 98th percentile pre-control
                       Max. 98th percentile post-control
                      Visibility improvement (pre - post)
                             Class I area impacted
                                       
                                      dv
                                      dv
                                      dv
                                       
                                    0910057
AGC Flat Glass North America
                                     0.065
                                     0.043
                                     0.022
                                 Upper Buffalo
                                    1330001
Ash Grove Cement
                                     0.110
                                     0.086
                                     0.024
                                 Upper Buffalo
                                    0210002
Empire District Electric - Riverton
                                     0.257
                                     0.165
                                     0.092
                                Hercules-Glades
                                    0150004
Frontier El Dorado Refinery
                                     0.068
                                     0.053
                                     0.015
                               Wichita Mountains
                                    1250015
Heartland Cement
                                     0.069
                                     0.053
                                     0.016
                                Hercules-Glades
                                    2090048
Kansas City BPU - Quindaro
                                     0.215
                                     0.082
                                     0.133
                                Hercules-Glades
                                    0930012
Kinder Morgan - Lakin Station
                                     0.021
                                     0.015
                                     0.006
                               Wichita Mountains
                                    0570003
Koch Nitrogen
                                     0.028
                                     0.010
                                     0.018
                               Wichita Mountains
                                    2057022
Lafarge Midwest - Fredonia
                                     0.111
                                     0.105
                                     0.006
                               Wichita Mountains
                                    0010009
Monarch Cement
                                     0.074
                                     0.066
                                     0.008
                                 Upper Buffalo
                                    0670035
ONEOK - Ulysses Station
                                     0.026
                                     0.018
                                     0.008
                               Wichita Mountains
                                    0550023
Sunflower Electric - Holcomb
                                     0.189
                                     0.173
                                     0.016
                                   Wind Cave
                                    1730012
Westar Energy - Gordon Evans
                                     0.117
                                     0.006
                                     0.111
                               Wichita Mountains
                                    1550033
Westar Energy - Hutchinson
                                     0.039
                                     0.008
                                     0.031
                               Wichita Mountains
                                    1490001
Westar Energy - Jeffrey
                                     1.174
                                     0.341
                                     0.833
                               Wichita Mountains
                                    0450014
Westar Energy - Lawrence
                                     0.428
                                     0.285
                                     0.143
                                Hercules-Glades
                                    1770033
Westar Energy - Tecumseh
                                     0.308
                                     0.094
                                     0.214
                                Hercules-Glades
Table 40- Overall Visibility Improvements Resulting from Application of Most Effective Controls at Selected Kansas 500-Ton NOx and SO2 Emission Units. Note that Kansas City BPU Nearman was not evaluated in this table because at the time the modeling was performed the Nearman facility was determined to be a BART source.

      As a refinement to the modeling, the State re-ran CALPUFF for the remaining sources considering the impacts of NOx and SO2 separately.  The State considered the pollutant emissions' visibility impacts separately because potential controls for a facility, to meet reasonable progress goals in a Class I area hosted by another State, could be pollutant dependent.
                                       
                                   Source ID
                                   Facility
                             Max. 98th percentile 
                                  pre-control
                      Max. 98[th] percentile post-control
                            Visibility improvement
                             Class I area impacted
                                       
                                      Dv
                                       
                                       
                                       
                                      NOx
                                      SO2
                                      NOx
                                      SO2
                                       
                                    1330001
Ash Grove Cement
                                     0.110
                                     0.090
                                     0.024
                                 Upper Buffalo
                                    0210002
Empire District Electric - Riverton
                                     0.257
                                     0.205
                                     0.145
                                     0.052
                                     0.112
                                Hercules-Glades
                                    2090048
Kansas City BPU - Quindaro
                                     0.215
                                     0.174
                                     0.142
                                     0.041
                                     0.073
                                Hercules-Glades
                                    2090008
Kansas City BPU- Nearman
                                     0.378
                                     0.318
                                     0.198
                                     0.060
                                     0.180
                                Hercules-Glades
                                    2057022
Lafarge Midwest - Fredonia
                                     0.111
                                     0.105
                                     0.006
                               Wichita Mountains
                                    0550023
Sunflower Electric - Holcomb
                                     0.189
                                     0.170
                                     0.016
                                   Wind Cave
                                    1730012
Westar Energy - Gordon Evans
                                     0.117
                                     0.010
                                     0.111
                               Wichita Mountains
                                    1490001
Westar Energy - Jeffrey
                                     1.174
                                     1.06
                                     0.469
                                     0.114
                                     0.705
                               Wichita Mountains
                                    0450014
Westar Energy - Lawrence
                                     0.428
                                     0.329
                                     0.310
                                     0.099
                                     0.118
                                Hercules-Glades
                                    1770033
Westar Energy - Tecumseh
                                     0.308
                                     0.271
                                     0.159
                                     0.037
                                     0.149
                               Hercules - Glades
Table 41- Selected Kansas 500-ton NOx and SO2 Emission Units Showing Significant Visibility Improvement Resulting from Application of Most Effective Controls

	In the fourth step, the State calculated the cost per ton per unit of dv improvement ($/ton/dv).  The State estimated that the single value of $/ton/dv combined the cost and visibility improvement in a way that its numerical value increases: 
   
   a. as the cost of controls increases and 
   b. as the visibility improvement decreases.  

	The State determined that the facility with the lowest $/ton/dv would be the first to be reviewed for possible controls to meet reasonable progress goals in Class I areas hosted by other States.  




   
                                   Source ID
                                   Facility
                                   Pollutant
                               Emission unit(s)
                                Cost per ton[1]
                            Visibility improvement
                       Class I area (98[th] percentile)
                              Cost per ton per dv
                                       
                                     $2002
                                      Dv
                                       
                                 $2002/ton-dv
                                    1330001
Ash Grove Cement
                                      NOx
                                  Cement kiln
                                     $509
                                     0.024
                                 Upper Buffalo
                                    $21,208
                                    0210002
Empire District Electric - Riverton
                                      NOx
                                Units 7 & 8
                                    $984[2]
                                     0.052
                                Hercules-Glades
                                    $18,923
                                    0210002
Empire District Electric - Riverton
                                      SO2
                                    Unit 8
                                    $5,326
                                     0.112
                                Hercules-Glades
                                    $47,554
                                    2090048
Kansas City BPU - Quindaro
                                      NOx
                                Units 1 & 2
                                     $660
                                     0.041
                                Hercules-Glades
                                    $16,098
                                    2090048
Kansas City BPU - Quindaro
                                      SO2
                                Units 1 & 2
                                    $4,045
                                     0.073
                                Hercules-Glades
                                    $55,411
                                    2090008
Kansas City BPU - Nearman
                                      NOx
                                    Unit 1
                                    $743[3]
                                     0.060
                                Hercules-Glades
                                    $12,383
                                    2090008
Kansas City BPU - Nearman
                                      SO2
                                    Unit 1
                                   $2,024[3]
                                     0.213
                                  Caney Creek
                                    $9,502
                                    2057022
Lafarge Midwest - Fredonia
                                      NOx
                                Kilns 1 & 2
                                      $76
                                     0.006
                               Wichita Mountains
                                    $12,667
                                    0550023
Sunflower Electric - Holcomb
                                      NOx
                                    Unit 1
                                    $1,383
                                     0.016
                                   Wind Cave
                                    $86,438
                                    1730012
Westar Energy - Gordon Evans
                                      SO2
                                    Unit 1
                                     ($37)
                                     0.111
                               Wichita Mountains
                                    ($333)
                                    1490001
Westar Energy - Jeffrey
                                      NOx
                                    Unit 3
                                    $1,437
                                     0.114
                               Wichita Mountains
                                    $12,605
                                    1490001
Westar Energy - Jeffrey
                                      SO2
                                    Unit 3
                                    $1,695
                                     0.705
                               Wichita Mountains
                                    $2,404
                                    0450014
Westar Energy - Lawrence
                                      NOx
                              Units 3, 4, & 5
                                     $989
                                     0.099
                                Hercules-Glades
                                    $9,990
                                    0450014
Westar Energy - Lawrence
                                      SO2
                                Units 3 & 5
                                    $7,791
                                     0.118
                                Hercules-Glades
                                    $66,025
                                    1770030
Westar Energy - Tecumseh
                                      NOx
                                Units 7 & 8
                                     $450
                                     0.037
                                Hercules-Glades
                                    $12,162
                                    1770030
Westar Energy - Tecumseh
                                      SO2
                                Units 7 & 8
                                    $3,699
                                     0.149
                                Hercules-Glades
                                    $24,826
 Table 42- Summary of Each Unit's cost per ton per Unit of dv Improvement
[1] Alpine Geophysics reported costs in $2005, which have here been adjusted to 2002 dollars using a factor derived the ratio of Consumer Price Index average price data values for the two years, or 179.9/195.3 = 0.92115 (8)
[2]  Empire submitted estimates of $2,427 (60% efficient) and $1,826 (30% efficient) for NOx controls on Units 7 and 8, respectively. The values shown are from Alpine, however, since further visibility modeling was not carried out for the source.
[3]  Cost supplied by Kansas City BPU in an engineering analysis report.  Costs are in 2006 dollars.

      As part of the fifth step, Kansas evaluated non-cost factors such as non-air environmental impacts, the remaining life of the unit and the compliance timeframe.  Table 43 presents a summary of the factors for the sources remaining after cost and visibility impact was considered. 
                                   Source ID
                                   Facility
                                   Pollutant
                               Emission unit(s)
                           Selected control measure
                                  Compliance
                                   Timeframe
                                    Non-air
                                    quality
                                 environmental
                                    impacts
                                   Remaining
                                  useful life
NOx
                                    1330001
Ash Grove Cement
                                      NOx
                                  Cement kiln
                                      LNB
                       3-4 years following SIP approval
                             Potential permitting
                         issues, control device energy
                                 requirements
                                  10-30 years
                                    0210002
Empire District Electric - Riverton
                                      NOx
                                    Unit 7
                                     LNBO
                                       
                             Potential permitting
                             issues, reduction in
                            electricity production
                                   capacity
                                  5-10 years
                                    0210002
Empire District Electric - Riverton
                                      NOx
                                    Unit 8
                                     LNC3
                                       
                                       
                                       
                                    2090048
Kansas City BPU - Quindaro
                                      NOx
                                    Unit 1
                                      NGR
                                       
                             Potential permitting
                             issues, reduction in
                            electricity production
                                   capacity
                                  30-50 years
                                    2090048
Kansas City BPU - Quindaro
                                      NOx
                                    Unit 2
                                      LNB
                                       
                                       
                                       
                                    2090008
Kansas City BPU - Nearman
                                      NOx
                                    Unit 1
                                  LNB+OFA+NN
                                       
                                       
                                  30-50 years
                                    2057022
Lafarge Midwest - Fredonia
                                      NOx
                                Kilns 1 & 2
                                Mid-kiln firing
                                       
                             Control device energy
                                 requirements
                                  10-30 years
                                    0550023
Sunflower Electric - Holcomb
                                      NOx
                                    Unit 1
                                      LNB
                                       
                             Potential permitting
                             issues, reduction in
                            electricity production
                                   capacity
                                  30-50 years
                                    1490001
Westar Energy - Jeffrey
                                      NOx
                                    Unit 3
                                     LNC3
                                       
                                       
                                       
                                    0450014
Westar Energy - Lawrence
                                      NOx
                                Units 3 & 4
                                     LNC1
                                       
                                       
                                       
                                    1770030
Westar Energy - Tecumseh
                                      NOx
                                    Unit 7
                                     LNC1
                                       
                                       
                                       
                                    1770030
Westar Energy - Tecumseh
                                      NOx
                                    Unit 8
                                     LNC3
                                       
                                       
                                       
SO2
                                    0210002
Empire District Electric - Riverton
                                      SO2
                                    Unit 8
                               FGD wet scrubber
                       3-4 years following SIP approval
                    Potential permitting & wastewater 
                             issues, reduction in
                            electricity production
                                   capacity
                                  5-10 years
                                    2090048
Kansas City BPU - Quindaro
                                      SO2
                                Units 1 & 2
                               FGD wet scrubber
                                       
                                       
                                  30-50 years
                                    2090008
Kansas City BPU - Nearman
                                      SO2
                                    Unit 1
                               Semi-Dry scrubber
                       3-4 years following SIP approval
                             Potential permitting
                             issues, reduction in
                            electricity production
                                   capacity
                                       
                                    1730012
Westar Energy - Gordon Evans
                                      SO2
                                    Unit 1
                                Fuel switching
                              Currently feasible
                                       -- 
                                       
                                    1490001
Westar Energy - Jeffrey
                                      SO2
                                    Unit 3
                               FGD wet scrubber
                       3-4 years following SIP approval
                    Potential permitting & wastewater 
                             issues, reduction in
                            electricity production
                                   capacity
                                       
                                    1770030
Westar Energy - Tecumseh
                                      SO2
                                Units 7 & 8
                               FGD wet scrubber
                                       
                                       
                                       
Table 43- Summary of Reasonable Progress Non-Cost Statutory Factors for Selected Kansas Point Sources
   
      The two EGUs at Empire District - Riverton, Units 7 and 8, have startup dates of 1950 and 1954, respectively, and it is likely they will be retired before 2018.  It is unknown why the IPM 3.0 future year modeling did not reflect this, but merely indicated reduced (controlled) SO2 emissions for Unit 7 starting in 2010.  In addition, there is currently a question about Westar Energy's ability to use wet scrubbers at its Jeffrey facility at Unit 3 due to environmental concerns for wastewater sulfur levels.

      In the final step, the State ranked the remaining sources listing the sources from the previous step in increasing order of $/ton/dv and using $15,000/ton/dv as a max allowable cost. The final ranked list is given below in Table 44.

                                     Rank
                                   Source ID
                                   Facility
                               Emission unit(s)
                                   Pollutant
                            Visibility improvement
                           Cost per ton per deciview
                                       
                                      Dv
                                 $2002/ton-dv
                                       1
                                    1730012
Westar Energy - Gordon Evans
Unit 1
                                      SO2
                                     0.111
                                    ($333)
                                       2
                                    1490001
Westar Energy  -  Jeffrey
Unit 3
                                      SO2
                                     0.705
                                    $2,404
                                       3
                                    2090008
Kansas City BPU - Nearman 
Unit 1
                                      SO2
                                     0.213
                                   $9,502[*]
                                       4
                                    0450014
Westar Energy  -  Lawrence
Units 3, 4, & 5
                                      NOx
                                     0.099
                                    $9,990
                                       5
                                    1770030
Westar Energy  -  Tecumseh
Units 7/9 & 8/10
                                      NOx
                                     0.037
                                    $12,162
                                       6
                                    2090008
Kansas City BPU - Nearman
Unit 1
                                      NOx
                                     0.060
                                    $12,383
                                       7
                                    1490001
Westar Energy  -  Jeffrey
Unit 3
                                      NOx
                                     0.114
                                    $12,605
                                       8
                                    2057022
Lafarge Midwest  -  Fredonia
Kilns 1 & 2
                                      NOx
                                     0.006
                                    $12,667
Table 44- Ranked List of Sources under the Reasonable Progress Analysis
[*]Cost is based on 2006 dollars at Caney Creek.  Hercules-Glades cost is $11,244 again in 2006 dollars

      The results of this process are described below.  Kansas determined that controls or fuel switching on the sources listed below are reasonable and will result in significant visibility improvements at the WIMO.
      
                                 Facility/Unit
                        Emission rate or work practice
                       Gordon Evans Energy Center-Unit 1
a fuel switch to natural gas at all times, with the exception of a gas curtailment order from the gas supplier, in which case the facility will be allowed to utilize backup # 6 fuel oil
                              Hutchinson -Unit 4
a fuel switch to natural gas at all times, with the exception of a gas curtailment order from the gas supplier, in which case the facility will be allowed to utilize backup # 6 fuel oil
                        Murray Gill- Units 1,2,3 and 4
a fuel switch to natural gas at all times, with the exception of a gas curtailment order from the gas supplier, in which case the facility will be allowed to utilize backup # 6 fuel oil
                                Neosho- Unit 7
a fuel switch to natural gas at all times, with the exception of a gas curtailment order from the gas supplier, in which case the facility will be allowed to utilize backup # 6 fuel oil
                         Jeffery Energy Center-Unit 3
           an emission limit of 0.15 lbs/MMBtu for both SO2 and NOx
                                Lawrence -Unit3
                  an emission limit of 0.18 lbs/MMBtu for SO2
                               Lawrence- Unit 4
an emission limit of 0.18 lbs/MMBtu for SO2; an emission limit of 0.15 lbs/MMBtu for NOx
                               Lawrence -Unit 5
           an emission limit of 0.15 lbs/MMBtu for both SO2 and NOx
                               Tecumseh-Unit 7/9
                  an emission limit of 0.18 lbs/MMBtu for SO2
                              Tecumseh-Units 8/10
                  an emission limit of 0.18 lbs/MMBtu for SO2
Table 45- Control or Work Practice Strategies for Westar Units to Meet Kansas Long Term Strategy Requirements

      * Murray Gill, Hutchinson and Tecumseh Units- were added to the list due to their inclusion in a previous Consent Agreement Westar has with the Sierra Club. 
         
      * BPU - Nearman Unit 1-this source primarily impacts the Class I areas in Missouri and Arkansas.  Through Kansas' consultation process with Missouri and Arkansas it was determined that no additional controls beyond expected BART and on the books controls would be needed to meet the Reasonable Progress Goals for the Class I areas in these states.  However, with the vacatur of the Clean Air Interstate Rule (CAIR) and subsequent remanding of the case back to EPA without vacatur, Kansas suspects that it may be necessary to revisit this issue through the consultation process with Missouri and Arkansas.  This discussion would occur once a final CAIR decision (or replacement rule) is finalized by the EPA and would be initiated by Missouri and/or Arkansas.
      
      * Lafarge Midwest - Fredonia Kiln Unit 1 & 2- The facility and the State have concerns regarding design and lay-out constraints of some of the control technologies identified for this type of facility.  The small level of improvement in visibility gained by control at this facility (0.006 dv for Wichita Mountains), in combination with the control system design concerns, led to the State to decide not to require controls at this time.  Additional technical and cost evaluations will be conducted during the five-year progress review. 
   
      Consent Agreements (given in Appendix 9.7 to the SIP) provide a mechanism to enforce these determinations and sets the compliance schedules for these measures. The controls detailed above are expected to achieve approximately 10,409 tpy of NOx and 22,812 tpy of SO2 reductions.
      
                                   Facility
                                     Unit
                           2002 NOx Emissions (tpy)
                           2002 SO2 Emissions (tpy)
                            Post Control NOx (tpy)
                            Post Control SO2 (tpy)
                             NOx Reductions (tpy)
                             SO2 Reductions (tpy)
                                 Gordon Evans
                                       1
                                     258.7
                                     617.7
                                     211.9
                                      0.5
                                     46.8
                                     617.2
                                  Hutchinson
                                       4
                                     267.1
                                     734.3
                                     158.5
                                      0.6
                                     108.5
                                     733.7
                                   Jeffrey 
                                       3
                                   10,807.4
                                   23,206.0
                                    4,913.1
                                    4,913.1
                                    5,894.3
                                   18,292.9
                                   Lawrence
                                       3
                                     728.4
                                    1,965.4
                                      0.0
                                    1,965.4
                                     728.4
                                      0.0
                                   Lawrence
                                       4
                                    1,986.5
                                    1,430.0
                                     835.4
                                     835.4
                                     984.1
                                     594.7
                                   Lawrence
                                       5
                                    3,546.3
                                    4546.3
                                    2,564.7
                                    2,564.7
                                     981.6
                                    1,789.0
                                  Murray Gill
                                       1
                                      0.0
                                      0.0
                                      0.0
                                      0.0
                                      0.0
                                      0.0
                                  Murray Gill
                                       2
                                      4.5
                                      0.0
                                      4.0
                                      0.0
                                      0.5
                                      0.0
                                  Murray Gill
                                       3
                                     181.6
                                     452.1
                                     148.6
                                      0.3
                                     33.0
                                    4,51.8
                                  Murray Gill
                                       4
                                     103.8
                                     333.3
                                     85.2
                                      0.2
                                     18.7
                                     333.1
                                    Neosho
                                       7
                                      0.0
                                      0.0
                                      0.0
                                      0.0
                                      0.0
                                      0.0
                                   Tecumseh
                                       7
                                    1,530.6
                                    2,692.7
                                     691.6
                                    2,692.7
                                     839.0
                                      0.0
                                   Tecumseh
                                       8
                                    1,876.9
                                    4,514.9
                                    1,103.1
                                    4,514.9
                                     773.8
                                      0.0
                                     Total
 
 
 
 
 
                                                                       10,408.7
                                                                       22,812.4
Table 46- Estimated NOx and SO2 Emission Reductions for Implementation of Controls or Work Practices Required by Kansas' Long Term Strategy
