AQ_GEN_PLNG_20220404_SIP_RH-SIP_AppF2d

Appendix F-2d

VISTAS Consultation with OH Division of Air
Pollution Control

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Correspondence Record
Date From To Description
June 22,
2020
VISTAS OH DAPC Request for Regional Haze Reasonable
Progress Analyses for Ohio Sources
Impacting VISTAS Class I Areas
October
29, 2020
OH DAPC VISTAS Response to VISTAS Request for Regional Haze
Reasonable Progress Analyses for
Ohio Sources Impacting VISTAS Class I Areas

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Visibility Improvement State and Tribal Association of the Southeast

June 22, 2020

Robert F. Hodanbosi, Chief
Ohio Division of Air Pollution Control
122 South Front Street
Columbus, Ohio 43215-3425

RE: Request for Regional Haze Reasonable
Progress Analyses for Ohio Sources
Impacting VISTAS Class I Areas

Dear Mr. Hodanbosi:

The Regional Haze Regulation 40 CFR § 51.308(d) requires each state to “address regional haze
in each mandatory Class I Federal area located within the State and in each mandatory Class I
Federal area located outside the State which may be affected by emissions from within the
State.” 40 CFR § 51.308(f) requires states to submit a regional haze implementation plan
revision by July 31, 2021. As part of the plan revision, states must establish a reasonable
progress goal that provides for reasonable progress towards achieving natural visibility
conditions for each mandatory Class I Federal area (Class I area) within their state. 40 CFR §
51.308(d)(1) requires that reasonable progress goals “must provide for an improvement in
visibility for the most impaired days over the period of the implementation plan and ensure no
degradation in visibility for the least impaired days over the same period.”

In establishing reasonable progress goals, states must consider the four factors specified in §
169A of the Federal Clean Air Act and in 40 CFR § 51.308(f)(2)(i). The four factors are: 1) the
cost of compliance, 2) the time necessary for compliance, 3) the energy and non -air quality
environmental impacts of compliance, and 4) the remaining useful life of any potentially
affected sources. Consideration of these four factors is frequently referenced as the “four-
factor analysis.”

To assist its member states, the Visibility Improvement State and Tribal Association of the
Southeast1 (VISTAS) and its contractors conducted technical analyses to help states identify

1 The VISTAS states are Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
Tennessee, Virginia, and West Virginia.

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sources that significantly impact visibility impairment for Class I areas within and outside of the
VISTAS region. VISTAS initially used an Area of Influence (AoI) analysis to identify the areas and
sources most likely contributing to poor visibility in Class I areas. This AoI analysis involved
running the HYSPLIT Trajectory Model to determine the origin of the air parcels affecting
visibility within each Class I area. This information was then spatially combined with emissions
data to determine the pollutants, sectors, and individual sources that are most likely
contributing to the visibility impairment at each Class I area. This information indicated that the
pollutants and sector with the largest impact on visibility impairment were sulfur dioxide (SO2)
and nitrogen oxides (NOx) from point sources. Next, VISTAS states used the results of the AoI
analysis to identify sources to “tag” for PM (Particulate Matter) Source Apportionment
Technology (PSAT) modeling. PSAT modeling uses “reactive tracers” to apportion particulate
matter among different sources, source categories, and regions. PSAT was implemented with
the Comprehensive Air Quality Model with extensions photochemical model (CAMx Model) to
determine visibility impairment due to individual sources. PSAT results showed that in 2028 the
majority of visibility impairment at VISTAS Class I areas will continue to be from point source
SO2 and NOx emissions. Using the PSAT data, VISTAS states identified, for reasonable progress
analysis, sources shown to have a sulfate or nitrate impact on one or more Class I areas greater
than or equal to 1.00 percent of the total sulfate plus nitrate point source visibility impairment
on the 20 percent most impaired days for each Class I area. This analysis has identified the
following sources in Ohio that meet this criterion:

• Ohio Valley Electric Corp., Kyger Creek Station (39053-7983011)
• Cardinal Power Plant - Cardinal Operating Company (39081-8115711)
• General James M. Gavin Power Plant (39053-8148511)
• Duke Energy Ohio, Wm. H. Zimmer Station (39025-8294311)

Information regarding projected 2028 SO2 and NOx emissions and visibility impacts on VISTAS
Class I areas is shown in the tables attached to this letter (Attachment 1).

As required in 40 CFR § 51.308(d)(1)(i)(A), VISTAS, on behalf of Alabama, Georgia, North
Carolina, South Carolina, Tennessee, Virginia, and West Virginia, requests that Ohio conduct, or
require that the sources in question initiate, and share when completed, the results of a
reasonable progress analysis for each noted source with VISTAS. This will be helpful to the
VISTAS states as they begin the formal Federal Land Manager consultation process for their
individual draft Regional Haze Plans in early 2021. So that the VISTAS states can include the
results of your state's reasonable progress analyses in developing the long-term strategies for
Class I areas in their states, we request that you submit this information to VISTAS no later than
October 30, 2020. If any reasonable progress analyses cannot be completed by this date, please
provide, no later than this date, notice of an attainable date for completion of the analysis. If
you determine that a four-factor analysis is not warranted for one or more of the identified
sources, please provide the rationale for this determination by the requested date.

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In developing projected 2028 emissions for these sources, VISTAS utilized ERTAC_16.1
emissions projections with additional input from LADCO. Please review these projections to
verify that they are reasonable. Should you be aware of significantly different emission
projections for 2028 for any of the sources or pollutants, please provide revised estimates
within thirty (30) days of the date of this letter. The applicable VISTAS states will review any
revised emission estimates, determine if reasonable progress analyses are not needed to meet
their regional haze obligations, and notify you accordingly.

Updated 2028 emission projections, if necessary, the results of your state’s reasonable progress
analyses for the requested sources, and any necessary ongoing communications should be sent
via email to [e-mail].

Should you have any questions concerning this request, please contact me through September
30, 2020, at 404-361-4000 or [e-mail].

Sincerely,

John E. Hornback
Executive Director
Metro 4/SESARM/VISTAS

Attachment

Copies: Ron Gore, Alabama Air Division
Karen Hays, Georgia Air Protection Branch
Mike Abraczinskas, North Carolina Division of Air Quality
Rhonda Thompson, South Carolina Bureau of Air Quality
Michelle Walker Owenby, Tennessee Division of Air Pollution Control
Mike Dowd, Virginia Air and Renewable Energy Division
Laura Crowder, West Virginia Division of Air Quality
Zac Adelman, Lake Michigan Air Directors Consortium

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Attachment 1: Projected 2028 SO2 and NOx Emissions and VISTAS Class I Area Impacts

Table 1. Ohio Valley Electric Corp., Kyger Creek Station (39053-7983011)
Modeled SO2 = 4,278.0 tpy, Modeled NOx = 6,267.3 tpy

Table 2. Cardinal Power Plant - Cardinal Operating Company (39081-8115711)
Modeled SO2 = 9,891.9 tpy, Modeled NOx = 4,044.8 tpy

Table 3. General James M. Gavin Power Plant (39053-8148511)
Modeled SO2 = 21,838.6 tpy, Modeled NOx = 7,982.6 tpy

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Otter Creek Wilderness 0.242 0.004 19.077 1.27% 0.02%
Dolly Sods Wilderness 0.229 0.003 19.349 1.18% 0.02%
James River Face Wilderness 0.170 0.006 14.404 1.18% 0.04%
Shenandoah NP 0.155 0.009 15.375 1.01% 0.06%

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Shenandoah NP 0.692 0.018 15.375 4.50% 0.12%
Dolly Sods Wilderness 0.778 0.007 19.349 4.02% 0.03%
Otter Creek Wilderness 0.727 0.008 19.077 3.81% 0.04%
James River Face Wilderness 0.520 0.008 14.404 3.61% 0.06%
Swanquarter Wilderness Area 0.203 0.007 10.894 1.86% 0.06%

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Otter Creek Wilderness 1.001 0.011 19.077 5.25% 0.06%
Dolly Sods Wilderness 0.945 0.009 19.349 4.88% 0.05%
James River Face Wilderness 0.582 0.016 14.404 4.04% 0.11%
Shenandoah NP 0.576 0.022 15.375 3.75% 0.14%
Great Smoky Mountains NP 0.520 0.003 13.916 3.73% 0.02%
Linville Gorge Wilderness Area 0.446 0.002 12.884 3.46% 0.02%
Joyce Kilmer-Slickrock Wilderness 0.473 0.002 13.694 3.45% 0.01%
Cohutta Wilderness Area 0.322 0.009 13.229 2.44% 0.07%
Shining Rock Wilderness Area 0.297 0.001 12.313 2.41% 0.01%
Cape Romain Wilderness 0.305 0.005 14.028 2.17% 0.04%
Swanquarter Wilderness Area 0.219 0.005 10.894 2.01% 0.05%
Sipsey Wilderness Area 0.327 0.021 16.370 1.99% 0.13%
Wolf Island Wilderness 0.224 0.003 12.957 1.73% 0.02%
Okefenokee Wilderness Area 0.203 0.002 13.400 1.51% 0.01%

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Table 4. Duke Energy Ohio, Wm. H. Zimmer Station (39025-8294311)
Modeled SO2 = 10,346.3 tpy, Modeled NOx = 5,864.1 tpy

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Otter Creek Wilderness 0.302 0.012 19.077 1.58% 0.06%
Dolly Sods Wilderness 0.288 0.010 19.349 1.49% 0.05%
Cohutta Wilderness Area 0.173 0.005 13.229 1.31% 0.04%
Shining Rock Wilderness Area 0.129 0.002 12.313 1.05% 0.01%
Joyce Kilmer-Slickrock Wilderness 0.137 0.002 13.694 1.00% 0.01%
hio
Ohio Environmental
Protection Agency
October 29, 2020
Chad LaFontaine
Executive Director
Metro 4/SESARM
Mike DeWine, Governor
Jon Husted, Lt. Governor
Laurie A. Stevenson, Director
1252 W Government St Unit 1375
Brandon MS 39043-6054
Re: Response to VISTAS Request for Regional Haze Reasonable Progress Analyses for
Ohio Sources Impacting VISTAS Class I Areas
Dear Mr. LaFontaine :
On June 22, 2020, the Visibility Improvement State and Tribal Association of the Southeast
(VISTAS), on behalf of Alabama, Georgia, North Carolina, South Carolina, Tennessee, Virginia,
and West Virginia, requested that Ohio conduct a reasonable progress analysis for four Ohio
sources that were identified by VISTAS to have an impact on visibility in Class I areas located in
VISTAS' states: Kyger Creek Station, Cardinal Power Plant, General James M. Gavin Power
Plant and Zimmer Power Station. In this letter, it was also requested that if it is determined that
a four-factor analysis is not warranted for one or more of the identified sources, rationale for this
determination be provided.
Ohio's analysis for each of the sources identified by VISTAS is provided in detail below. In
summary:
• Kyger Creek Station -effectively controlled for SO2 and NOx
• Cardinal Power Plant -effectively controlled for SO2 and NOx
• Gavin Power Plant-four-factor analysis for SO2 requested; effectively controlled for NOx
• Zimmer Power Station -recently announced a planned shut down in 2027; currently in
discussions regarding an enforceable commitment for the shutdown such that a four-
factor analysis is not warranted.
U.S. EPA's Regional Haze Guidance provides example scenarios for sources that would be
considered "effectively controlled" in which U.S. EPA believes it may be reasonable for a state
not to select a particular source for further analysis. One of the example scenarios provided by
U.S. EPA which Ohio finds most pertinent is:
"For the purposes of SO2 and NOx control measures, a combustion source (e.g., an EGU or
industrial boiler or process heater) that , during the first implementation period, installed a FGD
system that operates year-round with an effectiveness of at least 90 percent or by the
installation of a selective catalytic reduction system that operates year-round with an
overall effectiveness of at least 90 percent (in both cases calculating the effectiveness as
50 West Town Street• Sui t e 700 • P.O. Box 1049 • Co lumbus, OH 43216-1049
epa.ohio.gov • [phone] • (614) 644 -3184 (fax)
Response to VISTAS Regional Haze Request
Page 2
the total for the system, including any bypassed flue gas), on a pollutant-specific basis." A
pair of footnotes add that "For purposes of this consideration, the first regional haze
implementation period started when SIPs were due on December 17, 2007 ." and "While a 90
percent control effectiveness is used in this example, we expect that any FGD system
installed to meet CAA requirements since 2007 would have an effectiveness of 95 percent or
higher. This does not apply to a source that has recently achieved a higher level of control
efficiency without the install?tion of a control system, for example if it has merely increased
the flow rate of a reagent. In such a situation, the four factors should be fully considered. The
outcome may still be that the current level of control is the measure that is necessary to make
reasonable progress. (Emphasis added)
For ease of refe rence , this example will be referred to as "FGD/SCR with at least 90%
effectiveness".
However, U.S. EPA's Regional Haze Guidance clearly indicates that the examples are meant to
be illustrative but not exhaustive. Using the general principle established in the Regional Haze
Guidance that a source may be excluded from four-factor analysis where it is "reasonable to
assume for the purposes of efficiency and prioritization that a full four-factor analysis would likely
result in the conclusion that no further controls are necessary", Ohio interprets the "FGD/SCR
with at least 90% effectiveness" example slightly broader than written in the Regional Haze
Guidance.
' Specifically, although the example only references controls installed in the first implementation
period (i.e. after December 17, 2007), Ohio does not believe the installation date is pertinent to
whether the source is effectively controlled, so long as the device is getting sufficient removal.
Ohio believes that conducting a four-factor analysis on a source with an FGD or SCR with 90%
control efficiency, regardless of the date installed, would likely result in the conclusion that no
further controls are necessary. Therefore, Ohio considered control devices installed prior to the
first implementation period to meet our interpretation of this example.
Kyger Creek Station
Kyger Creek Station (Facility ID 0627000003) operates five coal-fired boilers (B001, B002, B003,
B004 and B005), which are considered effectively controlled for SO2 and NOx in accordance
with the "FGD/SCR with at least 90% effectiveness" example in the Regional Haze Guidance.
FGDs with 98% control efficiency were installed March 19, 2012 on B001 and B002 , and
November 4, 2011 on B003, B004 and B005. Each of these controls operate year-round . Each
of the five units have a federally enforceable SO2 emissions limits of 1.2 lb/MMBtu based on a
rolling, 30-day average (permit no. P0104412, effective 02/17/2011). As shown in Table 1, recent
SO2 emission rates are 0.16 lb/MMBtu or less.
SCRs with 90% control efficiency were installed October 1, 2002 on B001, December 1, 2002
on B002, February 1, 2003 on B003, April 1, 2003 on B004 and June 1, 2003 on B005. Each of
these controls operate year-round. As shown in Table 1, recent NOx emission rates are 0.24
lb/MMBtu or less.
Response to. VISTAS Regional Haze Request
Page 3
Table 1. Kyger Creek B001 , B002, B003, B004 and B005 emissions (2016 to 2019)
Unit ID Year S02 (tons) S02 rate NOx NOx Rate
(lb/MMBtu) (tons) (lb/MMBtu)
2016 755 . 0 .14 1,197 0.22
2017 1,025 0.15 970 0.15 B001 2018 1,157 0.16 1,385 0.20
2019 675 0.12 997 0.19
2016 700 0.14 1,109 0.24
2017 844 0.15 687 0.13 B002 2018 1,144 0.16 1,404 0.20
2019 718 0 .11 1,245 0 .20
2016 853 0.15 1,848 0.23
B003 2017 867 0.15 729 0 .13
2018 914 0.15 1,100 0 .18
2019 744 0 .13 1,043 0.18
2016 828 0.16 1,793 0.22
B004 2017 982 0.15 968 0 .15
2018 880 0.15 1,102 0.19
' 2019 823 0.13 1,086 0.17
2016 845 0.15 1,831 0.22
BOOS 2017 964 0.15 885 0.14
2018 876 0.15 1,001 0 .18
2019 787 0.13 1,003 0.17
None of the units are significant sources of PM2 .5 or ammonia.
Cardinal Power Plant
PM25-PRI NH3
(tons) (tons)
112 0
141 0
144 1
112 0
104 0
113 0
142 0
128 0
120 0
127 0
129 0
127 0
117 0
144 0
124 0
140 0
120 0
142 0
125 0
130 0
Cardinal Power Plant (Facility ID 0641050002) operates three coal-fired boilers (B001 , B002
and B009), each of which is considered effectively controlled for SO2 and NOx in accordance
with the "FGD/SCR with at least 90% effectiveness" example in the Regional Haze Guidance.
FGDs with 95% control efficiency were installed March 1, 2008 on B001 , December 1, 2007 on
B002, and December 30, 2011 on B009. The FGDs must be continuously operated on and after
December 31 , 2008 for B001 and B002, and December 31, 2012 for B009 , in accordance with
the requirements of a federal Consent Decree in United States, et al. v. American Electric Power
Service Corp., et al., Civil Action Nos. C2-99-1182 and C2-99-1250 and United States, et al. v.
American Electric Power Service Corp., et al., Civil Action Nos. C2-04-1098 and C2-05-360
(Consent Decree).
B001 and B002 each have federally enforceable SO2 emissions limits of 1.056 lb/MMBtu based
on a rolling, 30-day average (permit no. P0104412 , effective February 17, 2011 ). B003 has a
federally enforceable SO2 emissions limit of 0.66 lb/MMBtu based on a rolling , 30-day average
(permit no. P0104411, effective February 17 , 2011 ). As shown in Table 2, recent SO2 emission
rates are 0.27 lb/MMBtu or less.
Response to.VISTAS Reg ional Ha ze Request
Page 4
SCRs with 90% contro l efficiency we re installed June 1, 2003 on 8001, and May 1, 2003 on
8002 and 8009 . The SCRs must be continuously operated on and after January 1, 2009 in
acco rdance with t he requ irements of the Consent Decree. As shown in Table 2 , recent NOx
emission rates are below 0.1 lb/MM8tu .
Tab le 2 . Cardinal Power Plant 13001 , 8002 and 8009 emissions (2016 to 2019)
Unit ID Year S02 (tons) S02 rate NOx NOx Rate PM25-PRI NH3
(lb/MMBtu) (tons) (lb/MM Btu) (t ons) (tons)
2016 3,885 0.22 1,497 0 .09 54 1
8001 2017 3,796 0 .24 1,166 0.08 50 1
2018 3,794 0.22 1,348 0.08 74 1
2019 3,685 0 .18 1,479 0 .08 92 1
2016 3,986 0 .27 1,146 0 .08 73 1
8002 2017 5,205 0.25 1,446 0.07 247 0
2018 3,103 0.22 1 ,024 0.08 38 1
2019 3,714 0.23 1,242 0.08 43 1
2016 1,325 0 .10 1,112 0.09 969 1
8009 2017 2,256 0 .13 1 ,272 0 .08 88 1
2018 2,807 0.14 1,468 0.08 166 1
' 2019 2,053 0 .15 1,157 0 .09 118 1
8001 and 8002 are not significant sources of PM2 .s. Although 8009 is reported to have emitted
969 tons of PM 2.s in 2016, em issions have dropped substantially in more recent years. This
decrease may likely be due in part to more recent stack testing, along with new requirements for
condensable stack testing under U.S. EPA's Method 202 established in March 20161, which
forms the basis of the emissions estimates for the condensable fraction of PM . Further, 8009 is
equipped with an Electrostatic Precipitator (ESP) with 99.5% control efficiency installed
September 1, 1977.
None of the units are significant sources of ammonia.
General James M. Gavin Power Plant
General James M. Gavin Powe r Plant (Facil ity ID 0627010056) operates two coal-fired boilers
(8003 and 8004).
FGDs with 95 % control efficiency were installed December 1, 1994 on 8003 and March 1, 1995
on 8004. The FGDs must be continuously operated in accordance with the requirements of a
federal Consent Decree in Un ited State s of America and the State of New York, et. al and Ohio
Citizen Action et al. v. American Electric Power Service Corp . et a l, (S.D . Ohio Case No . 2 :99 -
CV-01182), lodged on October 9 , 2007 and entered on December 10 , 2007, as amended on
April 5, 2010 , December 28 , 2010, May 14, 2013, and January 23 , 2017 (hereinafter "Consent
Decree").
1 https://www.e pa.gov/e mc/metho d-202-cond e nsa ble-pa rticulate-matte r
Response to VISTAS Regional Haze Request
Page 5
8003 and 8004 each have federally enforceable SO2 emissions limits of 7.41 lb/MM8tu (permit
no. P0089258, effective April 15, 2020). As shown in Table 3 , recent SO2 emissions rates are
0.39 lb/MM8tu or less. Although the FGDs operate year-round with a 95% control efficiency,
Ohio has requested a fou r-factor analysis with respect to SO2 .
B003 and 8004 are considered effectively controlled for NOx in accordance with the with the
"FGD/SCR with at least 90% effectiveness" example in the Regional Haze Guidance. SCRs with
90% control efficiency were installed May 1, 2001 on 8003 and B004. The SCRs must be
continuously operated in accordance with the requirements of the Consent Decree . As shown in
Table 3, recent NOx emission rates are 0.11 lb/MM8tu or less.
Table 3. Gavin Power Plant B003 and B004 emissions (2016 to 2019)
Unit ID Year S02 {tons)
S02 rate NOx NOx Rate PM25-PRI NH3
{lb/MMBtu) {tons) {lb/MMBtu) {tons) {tons)
2016 9,039 0.27 3,572 0.11 608 1
8003 2017 13,785 0.32 4,441 0.10 650 1
2018 13,172 0.38 3,495 0.10 567 1
2019 12,161 0.37 3,485 0.11 219 1
2016 10,990 0.29 3,757 0.10 1,007 1
8004 2017 11,640 0 .36 3,382 0.11 518 1
' 2018 14,420 0.34 4,553 0.11 644 1
2019 14,313 0.39 3,857 0.11 403 1
Although 8003 and 8004 are reported to have emitted higher emissions of PM2 .s in 2016, as
shown in Table 3, emissions have dropped substantially in more recent years. These d ifferences
are due to updated stack testing in 2017 which forms the basis of the emissions estimates for
the condensable fraction of PM2. Thus , the recent emissions based on more recent data are
expected to more accurately reflect current conditions. Ohio EPA does not consider B003 or
B004 to be a significant source of PM2.s based on recent reported emissions.
In addition, B003 and B004 each are equipped with an Electrostatic Precipitator (ESP) for
particulate control with greater than 99% control efficiency of particulates . B003 and B004 each
have federally enforceable particulate emissions limits of 0 .1 lb/MM8tu (permit no. P0089258,
effective 04/15/2020).
Neither unit is a significant source of ammonia.
Zimmer Power Station
Zimmer Power Station (1413090154) operates one coal-fired boiler (B006). Zimmer recently
announced a planned shut down in 2027 . Ohio and Zimmer are currently in discussions
regarding an enforceable commitment for the shutdown such that a four-factor analysis is not
warranted.
2 The 2016 and 2017 emissions are based on stack testing conducted 02/26/09 , whereas t he 2018 and 2019
emissions are based on a stack test conducted on 08/23/2017.
Response to VISTAS Regional Haze Request
Page 6
If you have questions, please contact Jennifer Van Vlerah in our Division of Air Pollution Control
at [phone].
s~/~~-
Robert F. Hodanbosi
Chief, Division of Air Pollution Control, Ohio EPA