Subject: [Fwd: FW: VISTAS Draft BART Protocol -- Please Comment by Friday Oct 21, 2005] Date: Mon, 24 Oct 2005 09:19:47 -0400 From: Rosalina Rodriguez To: Pat Brewer , Sheila Holman , itombach , Rosalina Rodriguez , "Bacon, Leigh" , "Rogers, Tom" , CHRIS ARRINGTON , "Kiss,Michael" , Joe Scire , Joelle Burleson More comments. -- * * * * * * * * * * * * * * * * * * * Rosalina Rodriguez NC Division of Air Quality * * * * * * * * * * * * * * * * * * * * * * * * * * E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. * * * * * * * * * * * * * * * * * * * * * * * * * * --------------------------------------------------------------------- Subject: FW: VISTAS Draft BART Protocol -- Please Comment by Friday Oct 21, 2005 Date: Fri, 21 Oct 2005 08:27:11 -0400 From: "Spooner, Brad" To: , Rosalina, John Cline of SEVIC had forwarded your email to me on the draft BART protocol and suggested that questions/comments be sent directly to you. The comments may be most relevant to smaller BART-eligible units, as I would expect that it would be difficult for larger utility and industrial sources to "model out" of the BART process: - The Preface suggests that all BART-eligible units must use the BART Guidelines (App Y to Part 51). My understanding is that states must use the guidelines for large EGU's (>750MW plants), but states have more discretion for other units. See p. 39158, column 1 in July 6 Fed Reg (final BART rule). - The process on who does which modeling at which time is not clear to me. Page 1 of the draft BART modeling protocol indicates that sources submit a site-specific protocol, but does this cover just "modeling out" of BART or also the alternative BART control options (the two bulleted items on page 2)? Does the state do the initial modeling of the second item and the source then does its own modeling to refute the state's findings? The BART guidelines appear to apply to states and not individual sources - suggesting that states do the first round of modeling. A flow chart/schedule would help clarify what the process would look like. - How long will it take states to review and approve the site-specific protocol, and then for sources to do the modeling and get it accepted by the state? How does this fit into the overall schedule, and does all of the modeling, etc. have to precede the 2007 SIP submittal? - The BART modeling protocol does not seem to address the second bullet on Page 2 (alternative control options) much. All I could find was a short write-up on page 31. - The BART modeling protocol calls for using worst case 24-hour emission rates (actual historical measured "highest emitting day", permit limits or AP-42 factors if actuals not available) - see pages 5, 39. What if the unit /source has made emissions reductions (e.g. due to other new regulatory requirements, voluntary fuel type changes, etc.)? Shouldn't those be considered? - The BART modeling protocol mentions in several places that Earth Tech will be supplying various data sets, meteorology files and fields, modeling files, mixing height data, other software, etc. (p. 34, 37, 38, 42, 56). If sources are expected to do modeling, it would be important that all such information be in the public domain and usable by sources or their chosen consultants. Thanks, Brad Spooner MEAG Power 1470 Riveredge Parkway, NW Atlanta, GA 30328 Tel 770-563-0394 Cell 404-353-4100 Fax 770-661-2800 E-mail bspooner@meagpower.org MP -----Original Message----- From: mail@vistas-sesarm.org [mailto:mail@vistas-sesarm.org] On Behalf Of Rosalina Rodriguez Sent: Monday, September 26, 2005 4:33 PM To: BART@ncmail.net; bob_carson@nps.gov; Cindy M Huber; shane_spitzer@nps.gov; Jim Renfro; dwergowske@fs.fed.us; sandra_v_silva@fws.gov; Gary L. Achtemeier; Tim Allen; vince_carver@fws.gov; dennis_haddow@partner.nps.gov; Bill Jackson; Aaron Worstell; Bob Stroik; bruce_polkowsky@nps.gov; John_vimont@nps.gov; don_shepherd@nps.gov; John_Bunyak@nps.gov; John_Notar@nps.gov; Brenda Johnson; Wilkie.Walter@epamail.epa.gov; Denny Lohman; Campbell.Dave@epamail.epa.gov; Stahl.Cynthia@epamail.epa.gov; tech@vistas-sesarm.org; plan@vistas-sesarm.org; data@vistas-sesarm.org; hawes.todd@epa.gov; kaufman.kathy@epa.gov; beal.bill@epa.gov; langdon.robin@epa.gov; evangelista.mark@epa.gov; bailey.desmond@epa.gov Cc: Joe Scire Subject: [Tech Workgroup] VISTAS Draft BART Protocol -- Please Comment by Friday Oct 21, 2005 Hi, Everyone: Last week as part of the VISTAS Meeting in RTP, we had a day-long discussion of the VISTAS DRAFT BART Protocol. During the discussion, we did not identify significant issues that needed to be changed in the DRAFT Protocol before starting this more formal 4-week review period. Therefore, I am sending you a copy of the DRAFT Protocol and Appendices via this message to ask that you review the document and provide comments by Friday October 21, 2005. Your insights and suggestions will be most useful to finalize the Protocol in November. The goal is to finalize the BART Protocol in November to support the needs of the States, stakeholders, and BART-eligible sources as they proceed along some tight deadlines to comply with the Regional Haze Rule. I will appreciate it if the State BART contacts share the DRAFT Protocol for comment with appropriate BART-eligible sources. Please let me know if you have any questions. Feel free to send your comments via email to me on or before the deadline of Oct 21. Thanks for your continued help. Rosalina M. Rodríguez NC DENR 919-715-3846 -- * * * * * * * * * * * * * * * * * * * Rosalina Rodriguez NC Division of Air Quality * * * * * * * * * * * * * * * * * * * * * * * * * * E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. * * * * * * * * * * * * * * * * * * * * * * * * * *