1. BART Overview Lee Alter Western Governors’ Association
WRAP SSJF Meeting
Denver, CO
February 18, 2004

2. WRAP Emissions (13 Contiguous States)
SO2
NOx
PM10
1996
2018
Note: Emissions do not include wind-blown dust or EPA’s proposed Tier IV off-road engine standards.
Natural gas compressors span the point and area source categories.

3. WRAP Point Source Emissions (1996)
Not all these categories are BART-eligible.

4. What Is BART?
An emission limitation based on the degree of reduction achievable through the application of the best system of available continuous emission reduction for each pollutant.
When determining BART, states and EPA must take into consideration:
The costs of compliance,
The energy and nonair quality env. impacts of comp.,
Any existing controls at the source,
The remaining useful life of the source, and
The degree of visibility improvement which may reasonably by anticipated to result.

5. To Whom Does It Apply?
To BART-eligible sources emitting any pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area.
A BART-eligible source is that portion of a facility which:
Belongs to any one of 26 source categories,
Was in “existence” on 8/7/77,
Was not in “operation” before 8/7/62, and
Has the potential to emit > 250 tpy of any visibility impairing pollutant (SO2, NOx, PM, VOC, NH3).

6. Alternatives to BART within the RHR
Must include all BART-eligible sources
Must provide for greater reasonable progress
Emissions analysis (tonnage and distribution)
If significant change in distribution, then a dispersion modeling analysis to show that:
On average, areas show greater progress, and
No area experiences a decrease in visibility
May phase in reductions over the entire planning period (2018) rather than 5 years
May contain elements to address geographic enhancements

7. WRAP BART Efforts Help identify BART-eligible sources ($100,000)
Objectives
Provide direct assistance to some states and tribes to identify BART-eligible sources
Coordinate approach among all states and tribes
Identify and track status of sources in the region
Challenges
Operation and existence dates
Reconstructed and modified units
Data availability
Proposals due today

8. WRAP BART Efforts
Resources available to help determine which BART-eligible sources should be subject to BART ($100,000)
Not necessary if pursuing an alternative to BART
Possibly ...
Determine emission reductions attributable to BART
Can be done on a category-wide basis if pursuing an alternative to BART
Develop an alternative to BART
Review EPA revisions to BART regulations and guidance and comment where appropriate

10. IMPROVE Monitoring Data (2002)
Percent Light Extinction Due to
Ammonium Sulfate on the 20% Worst Days

11. IMPROVE Monitoring Data (2001)
Percent Light Extinction Due to
Ammonium Nitrate on the 20% Worst Days
Percentages are higher when natural sources of haze are excluded
On some of the hazy days on the CP, nitrate is %

12. IMPROVE Monitoring Data (2002)
Percent Light Extinction Due to
Ammonium Nitrate on the 20% Worst Days

13. Point Source NOx Emissions (1996)
763 plants > 100 tpy
These account for 94% of SS emissions
~150 are power plants