1. RH Requirement for BART  §308 (e) contains BART requirements for regional haze visibility impairment…. The State must submit an implementation plan containing emission limitations representing BART and schedules for compliance with BART for each BART-eligible source that may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area

2. BART Definition  BART is an emission limitation  §308 (e)(1)(ii)(A) requires that this limitation incorporate: the best system of continuous emission control technology available …… taking into consideration

3. BART Factors  the control technology available  the costs of compliance  the energy & non-air quality environmental impacts  any pollution control equipment in use at the source  the remaining useful life of the source ….. AND

4. BART Factors  Under §308 (e)(1)(ii)(B) also requires BART to consider …… the degree of visibility improvement that would be achieved in each mandatory Class I Federal area as a result of the emission reductions achievable from all sources subject to BART located within the region that contribute to visibility impairment in the Class I area

5. BART Factors  The “degree of visibility improvement” factor is addressed by July 6, 2006 EPA BART “Guidelines” Sources “Subject to BART” are required to determine visibility improvement resulting from their proposed BART implementation plan, through visibility modeling

6. “Subject to BART”  Late 2005,WY District Engineers identified BART Eligible Sources using the July 6 th Guidelines (250 TPY, constructed in the ’63-’77 window & one of the 26 listed source categories)  WY conducted CALPUFF modeling to determine whether sources “contribute” 0.5 dV of visibility impairment to the nearest Class I area 24 hr average actual emission rate/highest emitting day  Sources that “contribute” are “Subject to BART

7. Wyoming Companies “Subject to BART”  Coal Power Plants Pacificorp Dave Johnston Plant: U3(230) & U4(360MW) Pacificorp Jim Bridger Plant: Units 1, 2, 3 & 4 (578 MW) Pacificorp Naughton Plant: U1(110), U2(220) U3(360MW) Pacificorp Wyodak Plant: one 360 MW unit Basin Laramie River Plant: Units 1, 2 & 3 (570 MW)  Coal Fired Industrial Boilers FMC GR Trona Plant: 2 @ 887MM; 1 @ 334MM Btu/Hr FMC Granger Trona Plant: 2 @ 358 MM Btu/Hr General Chemical GR Trona Plant: 534 & 880 MM Btu/Hr

8. Wyoming BART Rule  Emission limits require the Administrator’s authority  To assure this authority is available WY EQC passed a “BART Rule” October 10, 2006  Signed for Agency Adoption October 12 th  Under SOS Review; Expected Final 12/26/06

9. Wyoming BART Rule  Applicability  Definitions  BART Guidelines  Subject to BART Source Identification  BART Requirements (permit appl & review)  BART Alternatives (Trading)  Monitoring, Recordkeeping & Reporting Requirements

10. BART Control Analyses  “Subject to BART” letters to the 8 Companies; June 14, 2005 “Not Subject to BART” letters to the other 6 Companies that were BART Eligible, but did not “contribute” to visibility impairment  These 8 must now conduct BART control analyses using the five factors (technology available, costs, energy & non-air impacts, existing pollution control, and remaining useful life of the source  control plans to be completed by December 15, 2005 (appx)  AQ NSR Program will review control proposals for agreement and set emission limits for these sources (similar to BACT)

11. Presumptive Levels  Provided Modeling Protocol for evaluating degree of visibility improvement from control of “Subject to BART” Sources on October 2, 2006  Previously had advised that selecting Presumptive Limits for SO2 and NOx control eliminated the need for detailed analysis of the 5 BART Factors  Because of expressed EPA concern that there might be some economic benefit or peculiarity associated with specific site applications, WY is now advising that a “minimal” evaluation of all BART factors (1-technology, 2-costs, 3-energy/non-air env. impacts, 4-existing pollution control 5-remaining life) is required