1. Best Available Retrofit Technology (BART) Process November 15, 2006 Eric C. Massey, Manager Air Quality Compliance Section

2. November 15, 2006BART Process2 WRAP Identification of Potentially BART Eligible Sources April 4, 2005 SSJF Report Identified potentially BART applicable sources in Arizona 26 listed source categories (categorical sources) Identified in-service dates for major emissions units at source Identified sources with total potential emissions >250 TPY of visibility impairing pollutants Report identified 18 potentially BART eligible sources Report also identified 5 additional sources that had unknown BART status

3. November 15, 2006BART Process3 State Specific Analysis Required Prior to making a subject-to-BART determination additional information was necessary Clarify BART eligibility of sources in April 2005 report (i.e. unknown, potentially, likely, etc.) Specifically identify potentially BART-eligible emissions units Identify the modeling parameters and emissions rate information for potentially BART-eligible emissions units

4. November 15, 2006BART Process4 Identification of Potentially BART Eligible Emissions Units Information gathering tools: Title V permits and applications Stationary source emissions inventories Web research 5 unknown sources qualified first 1 source obtained non-major source permit 2 sources we determined to be non-categorical 1 source did not appear to exist 1 source was recommended to be listed as potentially BART-eligible.

5. November 15, 2006BART Process5 Process for Identifying Potentially BART-Eligible Emissions Units Applied EPA’s June 15, 2005 BART rule criteria: Identify specific emissions units Non-Categorical = non-BART eligible Dates of construction for emissions units at categorical sources examined Outside 8/7/62 through 8/7/77 time frame = non-BART eligible Reviewed stationary source emissions inventories and the NEI Actual emissions of visibility impairing pollutants from potentially BART eligible emissions units < 250 TPY = non- BART eligible If emissions ~250 TPY, then additional research required

6. November 15, 2006BART Process6 Phase I – Potentially BART-Eligible Emissions Unit Review Completed June 9, 2006 through letter to RMC requesting modeling assistance Identified 30 potentially eligible emissions units at 14 Facilities Details of analysis provided in Technical Support Document TSD recommended additional research for 2 other emissions units

7. November 15, 2006BART Process7 Phase II – Potentially BART-Eligible Emissions Units Review Modeling input data gathering Standard Permit Application forms Include important stack height and exhaust characteristic information Include source provided estimates of potential to emit for criteria pollutants Performance testing data Some exhaust characteristic information Actual emissions information if necessary Majority of information sent to RMC on 10/30/06 Develop preliminary list of emissions units that are potentially subject-to-BART

8. November 15, 2006BART Process8 Phase III – Potentially BART- Eligible Emissions Unit Review Written contact with facilities Identify potentially subject-to-BART emissions units Request response within specified time frame Conduct BART analysis for visibility impairing pollutants Provide documentation demonstrating that emissions unit should not be subject-to-BART Based upon responses, make official subject- to-BART determinations

9. November 15, 2006BART Process9 Questions?