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BART (Best Available Retrofit Technology)
INFORMATION RESOURCES

Photos of Shenandoah National Park are from the IMPROVE web site's photo archives

The U.S. Environmental Protection Agency announced a major effort to improve air quality in national parks
and wilderness areas in 1999.  This effort resulted in the development of the Regional Haze Rule.  This rule calls for state and federal agencies to work together to improve visibility in 156 national parks and wilderness areas known as class I areas.  The class I areas located in Virginia are the Shenandoah National Park  and the James River Face Wilderness.

Under the rule, states must require certain older, large facilities to install the best emission controls as part of the states strategy to meet the regional haze rule.  This requirement, known as the best available retrofit technology (BART) requirement applies to plants emitting pollutants that contribute to visibility degradation. The Environmental Protection Agency (EPA) published amendments to the regional haze rule and the final BART guidelines in the Federal Register on July 6, 2005.  The identification of a BART eligible emission unit at a facility involves a 3-step process:

1. The emission unit must have been in existence prior to August 7, 1977 and begun operation after August 7, 1962.
   
   
2. The emission unit must be located at a facility which falls into one of 26 categories.
   
   
3. The aggregate potential emissions of all emission units identified in Steps 1 and 2 must be greater than or equal to 250 tons per year of any visibility impairing pollutant.   The pollutants that reduce visibility include particulate matter (PM10 and PM2.5), and compounds which contribute to PM2.5 formation, such as nitrogen oxides (NOx), sulfur dioxides (SO2), and under certain conditions volatile organic compounds, and ammonia.

In 2004, the draft BART eligible emissions inventory was developed for Virginia facilities. A letter was mailed to each facility in July 2004 requesting the identification of BART eligible units. A final list was drafted conforming to the BART rule, on the basis of inputs provided by the sources as to the dates of commissioning of the individual units.

After the BART eligible units have been identified, each facility has the option of either conducting BART exemption modeling to determine the aggregate impact of the BART eligible emissions units or proceeding straight to the BART permitting process. 

If the source proceeds with the exemption modeling, a site specific modeling protocol must be submitted to DEQ for review and approval by April 15, 2006 as well the modeling inventory with the maximum actual emission rates, particulate matter speciation data and particle size distributions that will be used in the exemption modeling.  VISTAS  (Visibility Improvement State and Tribal Association) has developed a “common” modeling protocol that provides the general information for carrying out air quality modeling for BART exemptions.  Facilities that qualify for exemption from the BART process must under go a 30-day public notice and comment period no later than September 2006. 

Please note that the determination of BART eligible emission units is based on potential annual emissions.  The BART exemption modeling, however, utilizes a daily emission rate which may be either the potential emission rate for a unit or the maximum actual emission rate for the unit during the modeling period (2001 through 2003).  Appropriate documentation of an actual emission rate must be provided to the Department of Environmental Quality (DEQ) if a facility wishes to utilize actual emissions in the modeling analysis in lieu of the maximum potential hourly emission rate for an emission unit.  Documentation may be in the form of Continuous Emissions Monitoring (CEM) data or an alternative DEQ-approved methodology.

All modeling protocols and analyses will be shared with EPA and the Federal Land Manager (FLM) for their review and comment.  DEQ will decide whether the protocol is approved or denied and will respond to the individual facilities with that decision.  Once all the exemption demonstrations have been reviewed, there will be a public notice and comment period on those submittals that demonstrated that a BART eligible source is exempt. Those sources unable to demonstrate exemption will continue on to the BART permitting process.

If facilities are deemed NOT exempt from BART or elect to go directly to the BART permitting process, the facility will be required to submit a permit application identifying the BART eligible emissions units and the appropriate BART controls.  There are five steps to making a BART determination for each source subject to BART: 

Step 1:  Identify cost effectiveness of operation of the BART control;

Step 2:  Evaluate the energy and non-air quality environmental impacts of the BART control;

Step 3:  Consider any existing pollution control technology in use at the source;

Step 4:  Consider the remaining useful life of the source subject to BART; and

Step 5:  Assess the degree of improvement in visibility which may be reasonably anticipated to result from the

   BART control option using CALPUFF or another appropriate dispersion model. 

Once the BART determinations are made, the requirements will be written in state operating permits as federally, enforceable conditions and submitted to EPA as part the Virginia State Implementation Plan (SIP). 

Note that in the final BART rule, EPA has determined that the Clean Air Interstate Rule (CAIR) is better than BART for those electric generating units subject to CAIR and for the pollutants regulated by CAIR (SO2 and NOX).  EPA has indicated to DEQ that electric generating units will have to undergo BART analysis for particulate matter.

DEQ has developed a detailed draft schedule for the BART rulemaking, exemption, permitting and State Implementation Plan (SIP) processes. (DEQ) is obligated to submit a regional haze plan, including BART requirements, to EPA by December 17, 2007.