Oklahoma Gas & Electric Muskogee Generating Station Best ...

Oklahoma Gas & Electric
Muskogee Generating Station – BART Determination
May 28, 2008
1.3 BART Requirements
A determination of BART must be based on an analysis of the best system of continuous emission
control technology available and associated emission reductions achievable. The BART analysis
must take into consideration: (1) the technology available; (2) the costs of compliance; (3) the
energy and non-air-quality environmental impacts of compliance; (4) any pollution control
equipment in use at the source; (5) the remaining useful life of the source; and (6) the degree of
improvement in visibility which may reasonably be anticipated to result from the use of such
technology.
Guidelines for making BART determinations are included in Appendix Y of 40 CFR Part 51
(Guidelines for BART Determinations Under the Regional Haze Rule). States are required to use
the Appendix Y guidelines to make BART determinations for fossil-fuel-fired generating plants
having a total generating capacity in excess of 750 MW, but are not required to use the guidelines
when making BART determinations for other types of sources. Because the Muskogee Generating
Station has a total generating capacity in excess of 750 MW, the Appendix Y guidelines were used
to prepare the BART determination.
The Appendix Y guidelines for BART determinations identify the following five steps in a case-bycase
BART analysis:
Step 1. Identify All Available Retrofit Control Technologies.
Step 2. Eliminate Technically Infeasible Options.
Step 3. Evaluate Control Effectiveness of Remaining Control Technologies.
Step 4. Evaluate Impacts and Document the Results.
Step 5. Evaluate Visibility Impacts.
A more detailed description of each step is provided below.
Step 1. Identify all available retrofit control technologies.
Available retrofit control options are those air pollution control technologies with a practical
potential for application to the emissions unit and the regulated pollutant under evaluation (70
FR 39164 col. 1). Step 1 of the BART determination requires applicants to identify potentially
applicable retrofit control technologies that represent the full range of demonstrated
alternatives. Potentially applicable retrofit control alternatives can include pollution prevention
strategies, the use of add-on controls, or a combination of control strategies. Control
technologies required under the new source review (NSR) program as best available control
technology (BACT) or lowest achievable emission rate (LAER) are available for BART
purposes and must be included as potential control alternatives. However, EPA does not
5