1. RA BART and RA BART-like Case Studies and Draft Attribution Report Bob Lebens and Kristin Gaston,WESTAR Council Market Trading Forum Workshop May 22, 2002

2. Context  Annex Backstop Market Trading Program  Challenge to Reconcile:  Market Trading Program  Allows market to determine the least-cost regional emission reductions  RA BART regulations  Mandates controls on specific source caused impairment in specific Class I areas  Air Managers Committee wanted a uniform attribution determination process to respond to FLM certifications of visibility impairment.

3. RA BART and RA BART-like Case Studies (Phase I) Completed July,2001

4. Purpose and Approach  Compile information on approaches taken in certifying visibility impairment in Class I areas that may be Reasonably Attributable (RA) to a source or a small group of sources and determine how Best Available Retrofit Technology (BART) was applied to remedy the impairment.  WESTAR formed an RA BART Working Group of state air quality and federal land management agency staff with expertise in RA BART and RA BART-like assessments.

5. RA BART Working Group  Healy Clean Coal Project/Denali National Park – Jeff Anderson, Alaska Department of Environmental Conservation  Navajo Generating Station/Grand Canyon National Park – Mike Sundblom, Arizona Department of Environmental Quality  Mohave Generating Station/Grand Canyon National Park – Bruce Polkowsky, National Park Service  Craig and Hayden Power Plants/Mt. Zirkel Wilderness Area – Dan Ely, Colorado Department of Public Health and Environment  Georgia Pacific Pulp and Paper Mill/Moosehorn Wildlife Refuge – Bud Rolofson, U.S. Fish and Wildlife Service  Centralia Power Plant/Mr. Rainier National Park – Alan Newman, Washington Department of Ecology

6. Regulatory Context  Federal Land Manager ‘certifies’ impairment  State determines whether or not impairment is ‘reasonably attributable’ to one source or a small group of stationary sources  If the state determines the impairment is attributable to one source or small group of sources, the state undertakes a BART analysis to arrive at the appropriate control level

7. Content of Case Studies  Basis of Certification  Studies Undertaken  Litigation – Negotiations – Legislation – Regulation  Outcomes  Outreach  Facility Background

8. Findings  No cases to date have been through the entire process prescribed by regulation, involving: –Certification of visibility impairment by a Federal Land Manager; –Reasonable attribution of the impairment by the source(s) undertaken by the state (or EPA for federal plans), and; –BART analysis to determine the appropriate control level.

9. Findings - Certification  Formal certifications were made in all but one case, but only two were initiated by certification of impairment.  In the other cases, visibility impairment issues were raised in the context of permitting decisions or as a result of litigation or other issues, such as state visibility regulations.  Early certification assessments were based on visual plume impacts, usually documented with photography.  More recent certification assessments of episodic haze events were based on monitoring and modeling data.

10. Findings - Attribution  In two cases, EPA made reasonable attribution findings.  A court decision upheld a low threshold for demonstrating attribution.  In five of seven cases, multi-million dollar studies were undertaken to quantify the visibility impact from the sources on Class I areas. These studies were largely inconclusive.

11. Findings - BART  In one case, a formal BART analysis was completed. In another, BART analysis was part of the technical support documentation.  However, the formal BART analysis was later substituted for a second ‘better than BART’ analysis which ultimately determined the level of control.  Controls at the power plants included lime spray dryers, wet limestone scrubbers, baghouses and low NOx burners.

12. Draft Attribution Report “Recommendations for making Attribution Determinations in the Context of Reasonably Attributable BART”

13. Working Group Members  Alice Edwards, Alaska  Mike Sundblom, Arizona  Deb Wolfe, Montana  Dana Mount, North Dakota  Dave DuBois, New Mexico  Colleen Delaney, Utah  Lisa Reiner, Quinalt Indian Nation  Bruce Polkowsky and Kristi Gebhart, National Park Service  Bob Lebens and Kristin Gaston, WESTAR

14. Objective:  To recommend a general procedure and applicable technical approaches that may be used by states and tribes to assess reasonable attribution in response to a Federal Land Manger Certification of Impairment

15. Background and Focus:  The report builds upon the work in the RA BART and RA BART-like case studies.  The focus of the report is on Reasonably Attributable Visibility Impairment (RAVI) and does not specifically address impairment due to regional haze.

16. The report does not:  Establish a threshold level at which Reasonably Attributable Visibility Impairment exists.  Include recommendations regarding state process following an attribution determination.  Include options for performing the BART analysis or incorporating BART into a SIP.

17. What the report does:  Recommend general principles of the Attribution Process  Recommend technical criteria of the Attribution Process  Provide five examples of the attribution process to demonstrate potential methods of approaching the technical analysis.

18. The First Step: Certification of Impairment  The report includes specific information about the current policy of FLM agencies regarding Certifications, but does not make any recommendations about the certification process.  The Certification is the event that triggers the requirement for the state to perform an Attribution analysis.

19. The Second Step: The Attribution Process General principles: The attribution assessment should be: 1.A collaborative process that relies on existing data with a minimum of additional analysis. 2.Technically and legally defensible 3.No more complex than necessary 4.Performed by state or tribal agency staff 5.Capable of attributing visibility impairment to an existing stationary facility potentially subject to BART.

20. Technical Criteria: 1.Impairment must be “caused or contributed to” by emissions from BART-eligible sources. Visibility-impairing pollutants of concern must be identified. 2.Factors to consider in assessing impairment include: duration, frequency, geographic extent, magnitude, and time of occurrence. 3.Identify distance from source to Class I area to determine appropriate tools for characterization of the impairment.

21. 4. Quantitative results are preferable, although qualitative results such as photographs may be adequate. 5. Use as many indicators of impairment as practicable rather than relying on a single method. 6. Consider the level of uncertainty in the assessment. 7. Use EPA guideline models whenever practicable.

22. Example of the Technical Process  Scenario 1  Data input:  Small amount of existing data (One IMPROVE site with data for 2-3 years)  Evidence of “local” impact  Limited meteorological data

23. First steps:  Examine IMPROVE data, including quality assurance  Examine extinction budget to identify the visibility-impairing pollutants  Analyze when events are occurring  Perform simple back trajectory analysis  Examine relationships between particulate species

24. Next steps:  Information from these initial techniques may or may not be sufficient to lead to an attribution determination.  If a source/receptor relationship can be identified at this point, the level of review may be adequate.  If no source/receptor relationship can be identified, further data and analysis may be necessary.

25. Additional analyses may include:  Source profiles  Met monitoring or modeling  Installation of a camera site  Additional aerosol monitoring, episodic or saturation  Optical monitoring (such as nephelometer, transmissometer)

26. Matching criteria to techniques:  One of the technical criterion is to identify the visibility-impairing pollutants of concern.  This can be determined though techniques such as: back trajectory, species relationships, relationships between source emissions and ambient monitoring, dispersion models, and so forth.

27. In summary:  The Working Group developed recommendations for the general attribution process and also identified the criteria to consider in the technical analysis.  The report contains narrative explanations of each stage in the process, and tables with narrative descriptions of the available techniques.