Is your power generation facility anywhere close to a Class I area (National Park, Wilderness Area, or Forest Service Area)? And by close we mean several hundred kilometers (km)? If so, depending on the location of the facility to a Class I area and emissions, there is the potential the facility could be a target for evaluation under the 2nd Planning Period for Regional Haze.

Unlike the 1st planning period, which focused on BART-subject sources, the 2nd planning period can target any large source of oxides of nitrogen (NOX), sulfur dioxide (SO2), and/or particulate matter (PM) across industries, including sources previously evaluated under BART. Since EPA redefined visibility impairment in its Technical Guidance for the 2nd planning period with no de minimis threshold of impact, each Regional Planning Organization (RPO) and/or state must develop its own methodology of screening potential industrial sources into the program. If a source is screened in, a four-factor analysis would be required to determine if there are “reasonable” controls available for reducing visibility impairing emissions. With no defined methodology for this process by EPA, sites need to be aware of the evaluations being conducted in their regions and be involved in the stakeholder processes for the 2nd planning period.

At the time of this article, the Western Regional Air Planning (WRAP) RPO has released its methodology for screening, which utilizes the “Q/d” ratio to determine whether sources could potentially impact a Class I area based on the magnitude of emissions released (tpy) divided by distance (km) to the nearest Class I area. Using this methodology, with a WRAP-recommended threshold of 10, the WRAP region has approximately 58 power generation facilities that were not screened out and will require reasonable progress evaluations.

For those sites located in RPOs and states that have not defined their screening methodology, we can assist with this analysis to determine if your site might be screened into this program, or we can help you be more prepared in the stakeholder process and subsequent evaluation phase. For more information, please contact Trinity at (800) 229-6655 for assistance.

In addition, for more information, please read “ Regional Haze Rule Second Planning Period” and register for: