RA BART and RA BART-like RA BART and RA BART-like Case StudiesCase Studies

andandDraft Attribution ReportDraft Attribution Report

Bob Lebens and Kristin Gaston,WESTAR Council

Market Trading Forum Workshop

May 22, 2002

ContextContext 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.

RA BART and RA BART-like Case RA BART and RA BART-like Case StudiesStudies

(Phase I)(Phase I)

Completed July,2001

Purpose and Approach 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.

RA BART Working GroupRA 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

Regulatory ContextRegulatory 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

Content of Case StudiesContent of Case Studies

Basis of Certification Studies Undertaken Litigation – Negotiations – Legislation –

Regulation Outcomes Outreach Facility Background

FindingsFindings

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.

Findings - CertificationFindings - 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.

Findings - AttributionFindings - 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.

Findings - BARTFindings - 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.

Draft Attribution ReportDraft Attribution Report

“Recommendations for making Attribution Determinations in the

Context of Reasonably Attributable BART”

Working Group MembersWorking 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

Objective: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

Background and Focus: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.

The report does not: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.

What the report does: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.

The First Step: The First Step: Certification of ImpairmentCertification 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.

The Second Step:The Second Step:The Attribution ProcessThe 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 defensible3. No more complex than necessary4. Performed by state or tribal agency staff5. Capable of attributing visibility impairment to an

existing stationary facility potentially subject to BART.

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.

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.

Example of the Technical ProcessExample 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” impactLimited meteorological data

First steps: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

Next steps: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.

Additional analyses may include: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)

Matching criteria to techniques: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.

In summary: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.