Basis Statement State Implementation Plan for Regional Haze Commenters 1) Anne Arnold, Manager . Air Planning Unit U.S. Environmental Protection Agency Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 2) Sandra V

. Silva, Chief Branch ofAir Quality United States Department of the Fish and Wildlife Service National Wildlife Refuge System Branch ofAir Quality 7333 W . Jefferson Ave., Suite 375 Lakewood CO 80235-2017 3) Thomas G

. Wagner Forest Supervisor United States Department ofAgriculture U .S. Forest Service 71 White Mountain Rd. Campton, NH 03223 4) Kevin Washington Project Manager Environmental Services Florida Power &Light Company Kevin.Washington@fpl .com

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EPA 1) Page 74 -In Section 8.2.2. Maine describes the "Emission control strategies" used to generate Future Year Emission Control Inventories. The MACTECreport (Attachment 1) documents the development of the on-the books/on-the-way (OTB/OTW) and beyondon-the-way (BOTW) inventories. However, there is no specific documentation as to how the "final modeling inventory" was developed. Therefore, Maine's Regional Haze SIP submittal should also include the documentation for the "final modeling inventory." (1)Thefinal modeling inventory was developedafter MANE-VU selected a number of control measures on which to base the modeling that would ultimately be used to developproposed reasonable progress goals. Also known as the MANE-VUAsk these measures include additional targeted S02 emission reductions at electric generating units (EGUs), the use oflow-sulfurfuels in the MANE-VUregion, and reductions in non- EGU S02emissions outside ofMANE-VU . Thefinal modeling inventory also included emission reductions attributable to the implementation of BART and anticipated changes in Canadian emission reductions. The NESCAUM report "2018 Visibility Projections " (Attachment Q) provides a detailed discussion on the development ofthefinal modeling inventory

. Additional information on thepreparation ofthe EGUemissions inventory is provided in the Alpine Geophysics report "Documentation of2018 Emissionsfrom Electric Generation Units " (Attachment S) . 2) Page 186-Maine's Regional Haze SIP includes a demonstration that Maine is achieving its share of emission reductions for the first planning period. This demonstration includes a revised projected 2018 inventory. This inventory was based on plant closures since the 2002 base year and the impact of the 0.5%sulfur limit on point source emissions . When developing this projection, Maine used the 2008 inventory and applied a growth factor of 1 to project the 2018 inventory for these point sources. Maine's demonstration should include a briefdiscussion ofthe basis of its decision to use a growth factor of 1 . (1) The Department has amended its proposal to include a discussion ofits choice to utilize a unitary growthfactor. 3) Page 128 -As stated in 40 CFR Section 51 .308(e)(1)(v), the Regional Haze SIP must include a requirement that each BART source maintain the control equipment and establish procedures to ensure such equipment is properly operated and maintained. According to Maine, this requirement will be included in the Title Voperating permits for each source subject to BART and made federally enforceable through incorporation in the Maine Regional Haze SIP. These permits were not, however, included in the current draft. (1) The Department has amended its proposal to explicitly include the requirement that each BART source maintain the control equipment and establish procedures to ensure such equipment is properly operated and maintainedpursuant to 40 CFR Section 51 .208(e)(1)(v) . Although the Department initially proposed including each Title V operating permit as an attachment to the Maine Regional Haze SIP, doing so would significantly complicate the Department's Title V licensingprogram . Incorporating the Title Vlicenses, which are alreadyfederally enforceable, in the Regional Haze SIP would make each and every element ofthe licensesfederally enforceable under Title I ofthe 1990 CleanAir Act (CAA) . As a result, any changes to these licenses, no matter how minimal, would need to be treated as SIPrevisions pursuant to Title I, and requireformal public notice and comment pursuant to Section 110 ofthe CAA . 4) Page 106 -When undertaking the five factor BART analysis, Dragon Products used apotential SOZ Emission Rate of 49.0 tons/yr. Based on this emission limit, Dragon

Products determined that it was not cost effective to operate the existing dry scrubber ($2,254,468/deciview) . However, the proposed BART license limit for S02emissions fromthe kiln systemis 200tons/yr on a 12 month rolling total basis. It is not clear why the proposed cap is so much higher than the level in the facility's analysis. (1) The Dragon Products BART analysis used a potential emission rate of49 .0 tons per year because thefacility has historically operated well belowits maximum capacity. In reality, 49.0 tons peryear represents actual, notpotential, SOz emissionsfromthe facility. Despite this, the Department agrees with results ofthe Dragon S02 BART analysis, namely that operation ofthe existing dry scrubber is not cost-effective at the current (and historical levels ofoperation) . Although S02 emissionsfromthefacility have historically been well belowthe 200 ton/yr potential, in an effort to provide operationalflexibility, the Department is reluctant to imposefurther limits at this point in time. 1 5) Page 108 -Maine DEPhas indicated that NO, BART control for the Dragon Products kiln is 45%

control efficiency on a 24-hour basis as opposed to the current recorded 18 - 22 % average control efficiency. However, Maine is proposing that the current 90-day rolling average emission limit and existing 12-month rolling average emission limit are sufficient for the BART emission limit. Why isn't the emission limit being reduced to reflect the required increase in control efficiency? (1) The Department did not establish a more stringent short-term (24-hour) emission limit because there is not enough emission (stack) testing information available to develop hourly (or 24-hour) mass-based emission limits at this point in time. The Department is committing to establish short-termemission limits no later than January 1, 2013 as part ofits 5 -year periodic implementation plan revision. 6) Draft license -The Dragon Products license includes a provision stating. "Compliance with the 45% control efficiency shall be determined on a 24 hour basis using CEM

data and/or other methods approved by the Department ." EPAdoes not allowfor Director discretion in State Implementation Plans. The underlined phrase should be deleted and replaced with the appropriate EPAReference Test Methods. (1) The Department has made the suggested change.

1 On October 1, 2010, and on November 8, 2010, Dragon Products, LLCsubmitted documentation asserting that the facility (kiln) qualifies as a reconstructed source (See Attachment M-2) . The Department is therefore deferring the BART applicability determination for this source to U .S.EPA. The discussion regardingthe Dragon Products BART determination in this Basis Statement and elsewhere in the Maine Regional Haze SIP represents the Department's draft BART determination prior to the submission ofthis documentation. In the event that U .S . EPAfinds that Dragon Products, LLCis, in fact, BART eligible, the Department is committing to issue afinal BART orderwithin 60 days of said finding.7) Page 109 -Maine is proposing 1 % sulfur oil as BART for Boiler #3 at FPL Energy Wyman, LLC

. The visibility cost effectiveness table, however, indicates that it is more cost effective to switch to the 0 .7%sulfur oil than to the 1 .0%sulfur oil ($0.56 million/dv and $0.69 million/ldv, respectively) . In addition, Boiler #4 is already required to burn 0 .7%sulfur oil . Furthermore, the MANE-VUrecommended limit for EGUs is 0 .3% sulfur fuel oil . Maine should betterjustifywhy 1 % sulfur oil is considered BART for Boiler #3. (1) The Department has amended the BART determination for Boiler# 3 at FPL Energy Wyman, LLC to require the use of0 . 7% sulfur oil . 8) In its discussion ofthe SD Warren Company BART analysis on page 115, Maine states, "Since no combustion takes place within smelt tanks, S02is not generated within the emission unit . SDW was not able to identify any retrofit control technologies applicable to the control of S02 emissions fromthe smelt tank." This statement does not seemaccurate, since the analysis of the VersoAndroscoggin smelt tanks shows that the scrubbers utilized for PM control have a side benefit of reducing S02 emissions. The SD Warren BART analysis should include a discussion of the benefit of the existing scrubber, in addition to the low overall SOZ emissions and minimal visibility impact of the smelt tanks. (1) The Department has amended the Maine Regional Haze SIPto include a discussion of the co-benefits provided by the existing scrubber at the SAPPI (S.D . Warren)facility. 9) Page 136 -Included in the list of BART units in Table 11-5 is SAPPI (SDWarren) Power Boiler 1 . Table 11-5 indicates that the SOZ emissions for this unit will be reduced from2884 tons in 2002 to 1442 tons in 2018. However, a discussion of the BART determination for this source, or a discussion of the manner in which these emission reductions are to be achieved, is not included. (1) Although the No. 1 Power Boiler was initially thought to meet the definition ofa "BARTeligible source ", it has since been demonstrated that Power Boiler #1 does not meet the any ofthepotential applicability categories under 40 CFRPart 51 .300 . The No. l Power Boiler has been limited tofiring less than 250million BTU/ hr ofoil by State and Federally enforceable operational limits since 1976 . In 2004, U

.S . EPA issued an Administrative Order requiring S .D . Warren to permanently reduce the capacity ofthe No. 1 Power Boiler tofire less than 250MMBtu/hr ofoil . Reviewing the criteriafor defining a BART-eligible source (40 CFR Section 52.301), a BART-eligible source is defined to include thefollowing categories that mightpotentially apply to the No. l Power Boiler: 1) Fossil-Fuel Fired SteamElectric Plants ofMore than 250 MMBtu/hr Heat Input ;2) Kraft Pulp Mills; and 3) Fossil-Fuel Boilers ofMore than 250MMBtu/hr Heat Input. Lookingat each ofthese categories, we see that the No. 1 Power Boiler is not covered by the "Fossil-Fuel Fired Steam Electric Plants ofMore than 250MMBtu/hr Heat Input " category because (in accordance with EPAguidance), units constructedprior to 1990 that supply less than one-third oftheir potential electrical output capacity, or less than 219,000MWe-hrs on an annual basis to a utility power distribution system for sale are exempt (the No. 1 Power Boiler has not supplied more than one-third ofits potential electrical output capacity nor more than 219, 000MW/yr to a utility distribution system for sale on an annual basis) . The No . 1 Power Boiler does not qualify as a "Kraft Pulp Mill " because, pursuant to 40 CFR Part S1, Appendix Y, a boiler less than 250 MMBtu/hr input that is not an integral part ofa process description at a plant that is in a different BART category (Kraft Pulp Mill in this case) is not subject to BART . Since the No. l Power Boilerproduces only steam, and is not integral to the pulp or paper makingprocess, it is not subject to BART as a Kraft pulp Mill . Finally, since the No

. 1 Power Boiler has had state andfederally enforceable operational limits that restrict the use ofoil to less than 250MMBtu/hr since 1976, and had actual physical limitationsfurther limiting the capacity ofthe unit tofire oil at less than 250 MMBtu/hr installed in 2004, the unit is notsubject to BART as a "Fossil-Fuel Boiler of More than 250MMBtu/hr Heat Input ". It is important to note that although the No. 1 Power Boiler is no longer a BART-eligible source, its projected 2018emissions of1442 tons peryear is nevertheless accurate. The S .D . Warrenfacility has implementedoperational changes to the No. l Power Boiler that will reduce its S02emissions by 50%from the 2002 baseline of2884 tons, with these changesfederally enforceable under its Title Voperating permit .2 Since these S02

. emission reductions will be occurring (albeit not under the BARTprogram), it is not necessary to adjust the reasonable progress modeling. The Department has addeda note to Table 11-5 and Table 12-1 indicating that these reductions are no longer due to BART, but instead other programs. 10) Page 120 -Maine is proposing 0.7%sulfur in fuel oil as BART at the Verso Androscoggin mill . The cost effectiveness of this option was estimated at $631 per ton SOZ reduced. The MANE-VUrecommended limit for theseunits, however, is 0 .5% sulfur oil . There is no analysis or discussion in the draft as to whether this option was considered. (1) Verso Androscoggin, LLC did not consider the use of0 .5% sulfur or lowerfuel oil in its 2 As part of its best practical treatment (BPT) requirements, in 2004 the Department required the installation of a white liquor scrubber on odiferous gases that allows these gases to be combusted in either the No. 1 Power Boiler or in the Lime Kiln. The white liquor scrubber provides a 50%reduction in SOZ emissions.BARTanalysis because the Department's ability to require the use ofthesefuels is

limited by 38 M

.R.S.A. §603-A, sub-§8which states: "8. Best available retrofit technology or BART requirements. For those BARTeligible units determined by the department to need additional sulfur air pollution controls to improve visibility, the controls must : A . Be installed and operational no later than January 1, 2013; and B . Either: (1) Require the use ofsulfur oil having 1 % or less ofsulfur by weight; or (2) Be equivalent to a 50%reduction in sulfur emissionsfroma BART eligible unit based on a BARTeligible unit source emission baseline determined by the department under 40Code ofFederal Regulations, Section 51 .308 (d)(3)(iii)(2006) and 40 Code ofFederal Regulations, Section SI Attachment Y (2006) . " Since Power Boilers # 1 and #2 at thefacility currentlyfire 1 .8%sulfurfuel oil, 0 . 7% sulfurfuel was chosen as BART, for it is a widely available fuel that satisfies notjust one, but both, ofthe statutory criteria. Although 0 .5%sulfurfuel oil would also satisfy both of these criteria, the Department's ability to require its consideration is limited by the above statute.3 It should also be noted that this source, along with all other users ofresidual oil will be subject to a 0

.5% sulfur limit (or equivalent control) beginningJanuary 1, 2018 . Additional discussion regarding the interplay between BART and the Maine Low Sulfur Fuel Programis provided in Section 10-3 ofthe Maine Regional Haze SIP and in Comments #25 and 27, below . 11) Page 121 -Although the expected visibility improvements frominstalling SCRis 1 .7 dv, this control is not proposed to be BART based on the limited use of Power Boilers 1 and 2 . The limited use must be made enforceable to be considered in the BART determination. (1) . The Department disagrees with the Commenters'position that the limited use ofPower Boilers 1 and 2 must be made enforceable to be considered in the BART determination. As the commenter knows, the BART determination includes a determination ofthe cost of compliance, which is, in turn, dependent upon a number ofoperational parameters. For Verso Paper, operationalfexibility in generating power and steamis important to both supply reliability, and cost-competitiveness. Verso Paper's main steamheader is supplied by two oil-fired boilers, a multifuel boiler, two recovery boilers, and three 3 Recognizing that EPAcan independently impose more stringent emission limitations, regardless of State law, some Maine BART sources chose to voluntarily consider and accept more stringent limits than required by statute (e.g., FPL Wyman, LLCUnit #3) .combustion turbines whichfireprimarily natural gas. Steamis typically supplied by

either the power boilers or the combustion turbines. When the combustion turbines are used, this cogeneration systemsupplants the operation ofthe No. 1 and 2 Power Boilers as the principal source ofsteam, reducing the use ofthe power boilers and substantially reducing emissions. Together, the No. 1 and No. 2 Power Boilers had only 3,921 operating hours in 2008 and 3,076 hours in 2009, or a capacityfactor of20%for the two units (the two units together would have 17,472 hours of operation atfull capacity) . The Department agrees with Verso's contention that this steam generationflexibility, and the economic importance ofmaintaining it, should be considered when examining the cost-effectiveness of

further controlling emissions fromthefacility's twopower boilers. In its BART analysis, Versofollowed the EPA-recommended approach when developing its baseline emissions, with the result thatpower boiler emissions and the cost-analysis were based on utilization rates that are not representative ofoperations at the mill since the combustion turbines were acquired by Verso in 2006 . Ifactual NOx emissions were utilized, the estimated costfor add-on controls would have been more than $15, 000per ton.4 Since thefive-step BART analysis considers both the technicalfeasibility ofcontrols and the cost ofcompliance, an emission or operating cap is not requiredfor those cases in which the projected cost ofcompliance is economically unfeasible. Nevertheless, while the Department is not requiring additional NO, controls on the No 1 and No. 2 Power Boilers at this point in time, we are committing to re-assess thefeasibility and needfor additional NO, controls at these units no later than January 1, 2013 as part ofits 5-year periodic implementation plan revision. 12)Verso Bucksport Draft license -The condition which includes proposed emission caps with the exception for a "catastrophic event" is not practically enforceable. The emission limits must be made permanent and enforceable. (1) The Department has amended the BART Determinationfor Verso Bucksport to eliminate the catastrophic event exception, and make the 250tons peryear emissions capfederally enforceable. 13) Page 12 -The 4th paragraph should be revised to read: "While all eastern states have depended in varying degree on CAIR" (1) The Department agrees and has made the suggested change. 14) Page 14, 4th bullet -The statement, "By the time the first regional haze SIP progress report, in 2013," is not consistent with the page 21, 3rdparagraph, statement, "Maine

4 In 2008, the boilers burned 5.6 million gallons of oil . In 2009, they burned 9 million gallons. If these rates had been employed in the NO,, cost analysis, the control cost would have been $28,313/ton ($3,181,111/112tons) for 2008 and $15,234 per ton ($3,221,937/212tons) for 2009.commits to submitting the first progress report, in the formof a SIP revision, not later

than December 17, 2012." (1) The Department has amended its narrative to correct the statement in the 4th bullet on page 14: " "By the time of thefirst regional haze SIPprogress report, which is due no later than December 17, 2012, the regulatoryframeworkfor the CAIR replacement should be clearer, and new modeling results should be available . It should then be possible tofine-tune regional haze plans to address any rule that EPA has promulgated to replace CAIR . Maine is committed to reviewing and updating its regional haze SIPas new information becomes available . " 15) Page 66, Figure 8-7 -Remove the footnote since the data is no longer included in the graph. Also, in the page 65 discussion of this graph, references to "emissions over this time period" and "emissions trends" should be deleted as the graph does not include multiple years of data. (1) The Department has made the suggested change. 16) Page 182 -Item2 states, "Timely implementation of BART requirements yielding a 50 percent reduction in SOZ emissions fromMaine sources subject to BART;" Is this statement accurate? (1) The Department has amended its proposal to read: "Timely implementation of BART requirements at Maine sources subject to BART . " 17) Page 184 -Figure 12-5 is unclear. Maine should include a discussion ofthe significance of the data presented in this figure. (1) Figure 12-5 was intended . to demonstrate the potentialfor contamination when small volumes ofhigher sulfur distillatefuel are inadvertently mixed with ultra low sulfur (15 ppm sulfur) distillate. For example, 7 gallons (or 0 .1 % by volume) ofdistillate with a sulfur content of2, 000pp .madded to 7,500 gallons (a standard tank-truck load) ofultralow sulfur distillatefuel would raise the sulfur content ofthe resulting mix by 2 . 0ppm . Thepotentialfor contamination is great enough that at least one company (e.g., Marathon Oil) has recommended completely draining and/orfushing any storage vessel or transport truck compartments before introducing ultra low sulfur distillate. While arguably useful in illustrating thepotentialfor contamination ofultra-low sulfur distillatefuel, andsupporting the Department's contention that there will be likely be little, ifany, high sulfur distillate in use by 2018, the Department has amended its proposal by deleting this potentially confusing graphic. 18) Draft SDWarren license -In the discussion regarding the Lime Kiln, MEDEPstatesthat the Recovery Boiler is subject to MACT standards. Did MEDEP mean to say that the

Lime Kiln was subject to MACT standards? (1) The Department has corrected this misstatement in the draft SD Warren license . Although the Recovery Boiler is also subject to MACTstandards, the discussion regarding the Lime Kiln should state: "The Lime Kiln is subject to MACTstandardsfor Chemical Recovery Combustion Sources at Kraft Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR 63, Subpart MM) . " 19) We have concern over the success of the MANE-VU Region realizing the overall emission reductions expected by the "Ask" . Although Maine is actively implementing controls of the "Ask", many States are not. There is a good possibility that reasonable progress goals that States' are setting based on full implementation of the "Ask" will not be achieved without honestly discerning which emission reductions will take place and which ones will not. It is our recommendation that Maine consider providing discussion and additional plots of the reasonable progress goals without the "Ask" that are based on either "on the way (OTW)/on the books (OTB)" or "better than on the way" scenarios. An additional presentation, taking more realistic emission reductions into consideration, would offer a better representation of the span of control being implemented in the region. Although, we recognize that it is not within Maine's power to get other States to comply with the "Ask", none the less, the State should assess whether or not Pennsylvania, Ohio, Massachusetts, and New York will meet their share of the "Ask", and communicate and incorporate these findings. This is important given that these States were identified as key contributors to Maine's Class I areas. (2) (3) The Department recognizes the Commenters' concern that the MANE-VURegion may fail to realize the emission reductions anticipated by the MANE-VU "Ask. As the Commenters know, the emission reduction programs outlined by the MANE-VU "Ask" andused to establish reasonableprogress goalsfor Class I areas in Maine and other MANE-VUstates include: " Timely implementation ofBART requirements; " A low

sulfurfuel oilstrategy (#2, #4 and#6oil) ; and " A targeted EGUstrategy callingfor a 90percent or greater reduction in sulfur dioxide (SOz) emissionsfromeach ofthe electric generating unit (EGU) stacks identified by MANE-VU) as reasonably anticipated to cause or contribute to impairment ofvisibility in each mandatory Class I Federal area in the MANE-VU region.While it is true that these measures haveyet to be adopted (in their entirety) by a number

ofMANE-VUstates, it is also true that considerable progress has been made in implementing these strategies, and the Departmentfully expects that the MANE-VU states, and many other contributing states will adopt these or other measures yielding equivalent or greater reductions in SOZ emissions. While afull review ofthe MANE-VU measures implementation status is beyond the scope ofthis response document, and recognizing that severalstates have not submitted their Regional Haze State Implementation Plans, it may be helpful to summarily reviewthe status ofthese measures in the MANE-VURegion. As afederal requirementpursuant to Section 169A ofthe Clean AirAct and implementing rules (40 C .F.R . Part 51, Attachment Y), the Department believes it is reasonable to assume that all BART-eligible sources will be controlled to levels approximating those used in establishing the reasonable progress goals at MANE-VU Class Iareas. In the event that a statefails to implement the BART requirements, EPA is obligated to issue a Federal Implementation Plan, or FIP ; there is therefore a high degree ofcertainty that this program will befully implemented . Severalstates, including Maine have enacted laws or regulations implementing the MANE-VUlow

sulfurfuel strategy, with New York recently passing legislation callingfor the use ofultra-low

sulfur distillate oil beginning 2012, and New Jersey recently promulgating rules requiring the use ofultra low sulfur distillate oil in 2014 and limiting the sulfur content ofheavier oils to no more than 0 .5% in 2016 Connecticut has also adopted a low-sulfur distillatefuel oil requirement that will become effective once neighboringstates have the program(Connecticut has a 0 .3% sulfur limit, or equivalent control, for #4, #5 and #6fuel oil) . Other MANE-VUstates have enforceable commitments in their Regional Haze SIPs, and the Department expects that these states will implement this programin time to meet the 2018 regional haze deadline. While the Department does not have specific knowledge regarding the implementation of the targeted EGUstrategy in other states, it is our understanding that the MANE-VU states ,are also movingforward with the implementation ofthis program . When addressing the Regional Haze Rule requirements for each state with Class I areas to establish reasonable progress goals providingfor reasonable progress towards achieving natural visibility in each Class Iarea (40 CFR Section 51 .308 (d)(1)), Maine and the other MANE-VUpartners adhered to the EPA guidance when setting reasonable progress goals. In developing the reasonable progress goals the Class Istate must considerfourfactors (cost, time needed, energy &non-air quality environmental impacts, and remaining useful life) when assessing the appropriateness of potential emission control strategies . Maine believes that states are obligated to include all reasonable measures (or alternativeprograms providing equivalent emission reductions) in their Regional Haze SIPs, and to implement these reasonable measures by 2018 . While we are aware that some states do notshare this interpretation ofthe regional haze reasonable progress goals requirements, EPA will ultimately serve as thefinal arbitreur ofthis decision when they review each state's Regional Haze SIP . 10It is also important to note the recently revised national ambient air quality standard

(NAAQS)for SOZ is likely to reduce emissions across a wide range ofsources and in a number ofstates due to both modeled exceedences and actual nonattainmentfor the new NAAQS . These reductions were not included when establishing the reasonable progress goals in Maine and other MANE-VU states because the new S02 NAAQSwas not released until after the MANE-VUtechnical effort was completed, butshould serve to bolster the likelihood that contributing states will meet the reduction targets embodied in the MANE-VU"Ask" . For a discussion on the ability ofMaine to meet the uniformrate ofprogress requirements under the "on-the-books/on-the way " scenario, see Comment # 39 . 20) In section 1 .8, the State identifies a suite of analysis methods to produce a weight of evidence approach to basic source apportionment. Although we commend the weight of evidence approach, the FWS and NPS does not consider MANE-VU's application of the CALPUFF model as within recommended modeling practices. As such, the use of nonstandard models or configurations, customarily require a performance evaluation that demonstrates beneficial use, which was not presented in Maine's SIP . (2) (3) The CALPUFF modeling systemis normally used to address the impacts ofemissions fromPrevention ofSignificant Deterioration (PSD) sources on Class Iareas. Although widely utilizedfor this purpose, the use ofCALPUFFfor regional modeling where transport distances exceed 1000 kilometers, has not been widespread, and the model performance beyond 300kilometers is subject to some level ofuncertainty . The Interagency Workgroup on Air Quality Modeling (IWAQM) Phase IIReport (USEPA 1998), suggests that the model tends to overpredict surface concentrations at greater than 300kilometers transport distance. MANE-VUaddressed this modeling uncertainty through a performance evaluation that comparedpredicted to measured S04 emissions data, and (as the Commenters noted) restricted the use ofthe CApUFF modeling to "weight-of-evidence "purposes. MANE-VUcompared 2002 ambient S04 ion concentrations with the CALPUFF modeled predictions at 22 northeastern monitoring locations that utilize IMPROVE-type monitors. The CALPUFF model wasfound to underpredict the long-term(quarterly average) impactsfor S04 ion by at least 30%for 22 ofthe 88site/quarter combinations in the northeast, with most ofthese underpredictions occurring during thefirst two quarters of theyear. The CALPUFF model was alsofound to overpredict S04 concentrations at those locations measuring mid-range quarterly average SOQion values (i .e., those locations with neither the highest nor the lowest concentrations) . Measured quarterly averages generally showthat the average over- and underprediction balances out on that time scale

. Comparing the CALPUFFresults with monitored ambient SOQconcentrations over a 24- hour basis, MANE-VUfoundthat while the model does not seriously over- or under-predictfor most sites, it does not match the variability OfSO4 ionformation at monitoring

locations. For those monitoring sites in the northeast with the highest measured S04 concentrations, the modelseems to be biased towards underpredictionfor those sites directly downwind ofthe majorsource region, such as Maine . This implies that, given the very large percentage ofS02emissions that have been incorporated in the modeling, the modeledpredictions probably represent a lower limit to the influence ofthese sources on the receptor areas. The Department believes that the CALPUFF modeling is sufficiently rigorous to be used for weight-of-evidence purposes, and has added a reference to the performance evaluationsperformed in "Development ofParallel CALPUFFDispersion Modeling Platforms for Sulfate SourceAttribution Studies in the Northeast U .S. " (Attachment A4) . 21) Chapter 8, Emission Inventory. We commend Maine for being the first MANE-VU State to implement the low sulfur fuel strategy. It would be helpful to the reader if an explanation could be given as to why S02 emissions for EGUs increase between the 2018 OTB/OTW

inventory and the final modeling inventory. (2) (3) As noted by the commenter, SOZ emissionsfor the electric generating unit (EGU) sector increased between the 2018 OTB/OTW inventory and the 2018final modeling inventoryfrom5,436 tons per year (tpy) to 6,806 tpy, respectively. This increase is due to adjustments made to thefinal modeling inventory that had the net effect of increasing emissions in the MANE-VUregion as a whole . The adjustments included: 1) assessing the implementation ofBART at eight BART-eligible units, including Maine's Wyman Station; 2) implementation ofthe MANE- VUEGU strategy; 3) increases in SOZ emissions to estimate the effect ofemissions trading under the CAIRprogram ; and 4) emissions increases in the MANE- VUregion to reflect state's best estimates that some sources predicted by the IPM model to be closed would continue to operate, and information about where and when emission controls would be installed. While some ofthese adjustments resulted in decreases in predicted S02emissions, the net result in Maine was an increase in SO2 emissionsfromEGUs. The Department has added an explanatoryfootnote regarding this emissions increase to the regional Haze SIP narrative. 22) We recommend that Maine add text to clarify which emission reductions assumed in the final modeling inventory (Table 8-4) are being implemented. Added language would explain questions such as: is the final modeling inventory for non-EGUs point and area source SOz emissions accurate for Maine's actual implemented controls, and are all the Best Available Retrofit (BART) emissions included in these inventories? (2) (3) The emission reductions assumedin the Final Modeling Inventory arefully detailed in Section 12 ofthe Maine Regional Haze State Implementation Plan. As noted in section 12, the actual controls implemented in Maine differfromthose utilized in the FinalModeling Inventory, hence the need to demonstrate that S02 emissions in Maine will be

no greater than those used in the reasonableprogress goals modeling. The reasonable progress goals and MANE-VUcontrolstrategies were established after assessing a large number of potential emission reduction strategies in accordance with theprescribedfourfactor analysis:

1) Costs ofcompliance; 2) Time necessaryfor compliance; 3) Energy and non-air quality environmental impacts ofcompliance; and 4) Remaining useful life ofpotentially affected sources. Ultimately, the MANE-VUmembers decided that the emission control strategies contained in the MANE-VU "Ask" were reasonable, and should be implemented on a state-by-state basis and as necessary to meet the reasonable progress goals. Maine did notfully adopt all ofthe recommended MANE-VUmeasures, so it was necessary to demonstrate that projected SOZ emissions in 2018will be no greater than those utilized in the 2018 reasonable progress modeling (which was used to establish the Maine reasonable progress goals) . As long as projected 2018 SOz emissions in Maine are no greater than those usedfor the reasonable progress modeling, the modeling is validfor the purpose ofestablishing reasonable progress goals, and actually understates the potential visibility improvementfor Maine. As discussed in Section 12.10, Maine's Share ofEmission Reductions, the 2018projected (updated) S02 emissions for Maine are significantly lower than those utilized in the MANE-VUreasonable progress modeling. Although it might be desirablefor thefinal modeling inventory to be based on the actual controls being implemented in each state, doing so could only be done a ter each state hadadopted it regional haze controlstrategies, and wouldnecessarily be retrospective in nature. Given the time constraints under which the Regional Haze SIPs were being developed, a retrospective look at emissions in each state after each state adopted its regional haze controlstrategies was notpossible. See also, comment # 1. 23) An overarching concern is that it is not clear fromthe Maine BART documents (posted 6/29/10) how it applied any of the five factors in the BART analyses in making its BART determinations. For example, MAINE does not appear to have given much weight to the visibility benefits that could be realized fromthe control strategies evaluated. At least, it is not clear how Maine applied this factor in developing its BART conclusions. As we shall discuss later, there appears to be great inconsistency among the methods used by Maine to assess and evaluate costs and benefits that would result from the various control strategies chosen by Maine as representing BART. For example, MEDEP calculates cost/ton for the Androscoggin paper mill but does not calculate cost/dv. However, for the Wyman power plant, MEDEP calculates cost/dv but does not calculate cost/ton. (2) (3)The Maine BART analysis protocol is described in Section 10 . 7 ofthe Maine Regional Haze SIPand in Attachment M-1to the SIP (the Maine BARTProcess) . As the Commenters know, the federal BART rule requires that,for each BART-eligible source within the state, any BART determination must be based on an analysis ofthe best system ofcontinuous emission control technology available and the associated emission reductions achievable. In addition to considering available technologies, this analysis must evaluatefive specificfactorsfor each source (better known as the Five-Factor Analysis) : 1. The costs ofcompliance;

2 . The energy and non-air quality environmental impacts ofcompliance; 3 . Any existing pollution control technology in use at the source; 4 . The remaining useful life ofthe source; and S . The degree ofvisibility improvement which may reasonably be anticipated fromthe use of BART . Using thefirstfourfactors plus the NESCAUMzero-out modeling the Department preliminarily determined that 18 ofthe 25 BART-eligible units have existing controls that should satisfy BART technology requirementss. These units were not required to conduct a modeling analysis to assess the degree ofvisibility improvement due to the implementation of BART . The remaining sources were required to utilize CALPUFF modeling (either .1 year ofdata using the highest daily predicted change in deciviews, or 3years ofdata using the 8`" highest daily predicted change in deciview) to assess the degree ofvisibility improvement. While the Department anticipated that BARTeligible sources would provide a variety ofcost-related metrics, including costs ofcompliance, total annualized costs ($), cost effectiveness ($/ton), and dollars per deciview($/dv), most Maine BART-eligible sources did not submit all ofthese metrics in their analyses. Although the Department believes that the use ofseveral cost-related metrics provides a more comprehensive viewofthe visibility benefits provided by BART (or other controls), we do not believe that the use ofany specific metric should be mandatory . Given this, the Department utilized the information submitted by the BART eligible sources to determine BART on a case-by case basis while also recognizing the limitations imposed by statute at 38 M .R.S.A. §603-A, sub-§8, and the visibility improvements provided by the Maine Low Sulfur Fuel Programin 2018 . 24) The individual company BART determinations were not found in the record. Please add an Appendix to the State Implementation Plan for Regional Haze and include these documents to aid third-party reviewers to deal with the complete record . (2) (3) The Department has made the individual (as submitted by the sources) BART determinations available on an on-demandbasis through its Regional Haze Rulemaking website. 25) The core purpose of the BART program is to improve visibility in our Class I areas, 5 These sources generally have visibility impacts less than 0 .1 deciview

. 14and BART is not necessarily the most cost-effective solution. Instead, BART represents a

broad consideration of technical, economic, energy, and environmental (including visibility improvement) factors. (2) (3) The Department recognizes the core purpose ofthe BARTprogram, and agrees that BART is not necessarily the most cost-effective level ofemission control . The Department considered all required technical, economic, energy andenvironmental factors during the development ofits BART orders. In addition, the Department also considered the emission reductions that will be provided by the Maine Low-Sulfur Fuel Program, which mandates the use ofultra-low(15ppm) sulfur distillate at most industrialfacilities, andrequires the use oflow(0 .5%) sulfur residual (or equivalent reduction) by 2018

. The Department believes that the BARTdeterminations, as amended in itsfinal Regional Haze SIPsubmittal, establish emission control requirements that fully address both the intent and legal requirements ofthe BARTprogram, while also recognizing the scheduled implementation ofthe low-sulfurfuel oil requirements in 2018 . As the Commenter is aware, these low-sulfurfuel oil requirements are more stringent than most, ifnot all, BART determinations. 26) There are at least six Class I areas impacted by Maine's BART sources. We believe that it is appropriate to consider both the degree ofvisibility improvement in a given Class I area as well as the cumulative effects of improving visibility across all ofthe Class I areas affected. The same metric should not be used to evaluate the effects of reducing emissions froma BART source that impacts only one Class I area as for a BART source that impacts multiple Class I areas. Also, evaluating impacts at one Class I area, while ignoring others that are similarly significantly impaired should not be done. Emissions savings froma source are benefits that will be spread well beyond only the most-impacted Class I area, and should be considered. While Maine presented data describing improvements to visibility at a specific Class I area that would result fromthe various control scenarios it investigated, the State has not explained how it incorporated this information on impacts upon all Class I areas into its BART decision. Maine has ignored the other Class I areas where a given BART source is also causing or contributing to visibility impairment . The dollar cost per increment ofvisibility improvement would be substantially lower if full consideration is given to all affected Class I areas. that would benefit fromemission reductions . While we recognize that EPA has provided no guidance on this issue of assessing visibility benefits that would result in multiple Class I areas when emissions are reduced froma given BART source, we commend Wyoming and Oregon for their initiative in addressing the issue. We also recognize that there is no "perfect" method for addressing cumulative benefits, but we firmly believe that Maine must showhow it considered the cumulative impact of the BART sources the affected Class I areas. We have suggested an approach to Maine that is consistent with available information and with the approach used by Wyoming and Oregon, and again request that MEDEP showhow it has considered the cumulative benefits of potential BART reductions . (2) (3) Although it is true that at least six Class I areas are impacted by Maine BART sources, it is 15important to recognize that these impacts, in most cases, are relatively insignificant. MANEVUconducted a zero-out modeling analyses ofBART-eligible sources using CALPUFF in order to provide a regionally-consistentfoundationfor assessing the degree of visibility improvement which could resultfrominstallation ofBART controls (See Attachment L) . The MANE-VUanalysis provides an estimate ofthe maximumimpact that any BART source might have on both individual Class I area, and cumulatively across all Class I areas. The MANE-VU effort modeled the following total (SO4, NOx and PM,o) visibility impactsfor _all Maine BART-eligible sources at MANE-VU and VISTAS Class I areas: ALL BART-eligible (2002 baseline) SOURCE IMPACTS (dv's)

ACAD MOOS GRGU LYBR BRIG DSOD JARI OTCR SHEN MAINE 6

.689 6

.523 2.174 0

.821 0 .579 0 .107 0.125 0

.100 0.172 Reviewing these impacts, it will be quickly noted that even cumulatively (and across all regional haze pollutants), Maine BARTsources have visibility impacts greater than 0 .5 deciviews at onlyfive Class Iareas. Remembering that these are the modeledbenefits of eliminating all emissionsfromthese sources (i .e., "zeroing-out'), it can be seen that BARTcontrols are unlikely to provide significant visibility improvements outside ofthe Maine and New

Hampshire Class I areas. On an individual basis, the impacts are even lower. Table 10-2 ofthe Maine Regional Haze SIP illustrates the total impacts (modeled) ofindividual Maine sources on Class I areas in Maine and New Hampshire using both the NWS and MM5 meteorology. Ofthe 23 BART-eligible sources in Maine, only six had modeled impacts (on all Maine and New Hampshire Class I areas combined) ofmore than 0.5 deciviews. While the Department commends the States of Oregon and Wyomingfor their aggressive approach in implementing BART, we believe that their cumulative impacts approach is the exception, and not the norm

. The Department worked closely with EPA to ensure that all applicable requirements were met in the development ofits BARTprotocol . It must also be remembered that neither Oregon nor Wyoming has adopted additional reasonable progress controls such as those included in the MANE-VU "Ask " . As noted in the Maine Regional Haze SIP, the Maine Low Sulfur Fuel Programwill, in most every case, supersede BART control limits. Unlike Oregon or Washington, the BART requirements in Maine represent only an initial increment ofvisibility improvement, other programs willprovide visibility improvements beyond BART by 2018 . 27) Based upon our reviews of BART analyses across the U .S., we believe that cost-perdeciview($/dv) ofvisibility improvement is the most-common and most-useful parameter for assessing the cost-effectiveness of strategies to improve visibility in Class I areas. Our compilation of BART analyses across the U .S. reveals that the average cost/dv proposed by either a state or a BART source is $13 - $20 million, with a maximum of almost $50million/dv proposed by Colorado at the Martin Drake power plant in Colorado Springs. (2) (3) 16The Department is in agreement that the costper-deciview($/dv) ofvisibility

improvement provides a useful parameterfor assessing the cost-effectiveness ofpotential control strategies under BART . At the same time, although certainly very useful in the BART-determination process, costper-deciview should not always be the principal criterionfor appropriate technology or level ofemission controlfor a BART-eligible source. The Department also believes that it is prudent to consider all relevant information during the BART determination process, and not limit the scope ofits BART analyses. As noted in thefinal Maine Regional Haze State Implementation Plan submittal, and in Comments # (10and2S), BARTsources in Maine will be subject to very stringent distillate and residual oil fuel sulfur limits by 2018 . The Department believes that the Maine Low

Sulfur Fuel Program, as described in Section 12.9.1 ofthe Maine SIP must be factored into the decision matrixfor BART determinations in Maine, for this program will ultimately provide emission reductions (and visibility improvements) far exceeding those ofthe BARTprogramand across a much wider range ofsource categories. In addition, it must be noted that existing Maine statute (38 MRSA §603-A, sub-§8) limits the Department's authority to impose mandatory sulfur emission reductions. Under the enabling authority, BART is limited to either: (1) Require the use ofsulfur oil having 1 % or less ofsulfur by weight; or (2) Be equivalent to a 50% reduction in sulfur emissions froma BART eligible unit based on a BART eligible unit source emission baseline determined by the department under 40 Code ofFederal Regulations, Section 51 .308 (d)(3)(iii)(2006) and 40 Code ofFederal Regulations, Section SI Attachment Y (2006) . The Department has worked with Maine BART-eligible sources within the confines ofthis legislation to craft determinations that will maximize the short-term (2013) visibility improvementfromthe BARTprogram . Infact, some Maine BART sources are voluntarily limiting their SOz emissions through programs that go above and beyond the control limits ofthe enabling statute. 28) In the Best Available Retrofit Technology (BART) determination section for FPL Energy Wyman, LLC, three unlabeled tables identify visibility benefits based on 1s~ and 81h high values (page I 10) . Our understanding is that the quality and quantity of meteorology used during the BART determinations fall within the recommended modeling practices. Maine voluntarily agreed to limit evaluations to I high values in lieu of generating 3 years of quality meteorological input . Please communicate that the State did not use the 8 high to base their BART conclusion. (2) (3) Maine's BARTModeling Protocol (Attachment M to the Maine Regional haze SIP) allowedsources to utilize "Is' high " values in lieu ofgenerating 3years of meteorological inputs. In addition, sources could also utilize the "8th high " value, provided they also generated 3years ofquality meteorological input. FPL Energy Wyman, LLCutilized 1 year ofMM5 data with mandatory observational data as obtainedfromthe Massachusetts Department ofEnvironmental Protection. Although the source provided cost-effectiveness and incremental visibility improvement 17analysisfor the 81h high value, this information was not used in the Department's BART

determination because it does notfollowthe prescribed modeling protocol . The Department has amended the BART discussion for FPL Energy Wyman to eliminate any confusion. 29) The Power Boiler #1 and #2, and the Waste Fuel Incinerator (WFI) units at Verso Androscoggin Paper Mill (Verso Androscoggin, LLC) are BART eligible. Both SCR and SNCRare evaluated for each of these units as BART options for controlling NO, emissions . In each case, we have concerns with the cost estimation methodologies used: annual reagent and catalyst costs are significantly above what should be expected, capital recovery factor calculations use annual interest rates nearly double the standard of EPA's OAQPSAir Pollution Cost Control Manual, and recovery periods only half as long, and there are unexplained differences between the company's proposal and the Maine cost estimates. In summary, our data indicates that both SCR and SNCR should be considered as viable NOX BART conclusions for these units. Please see the detailed comments contained in Attachment 1 for specifics. (2) (3) See Response to Comment #12, above . 30) We believe that lower sulfur residual oils should be more fully evaluated as an SOZ BART option for the VersoAndroscoggin, LLC Power Boilers. Please see the detailed comments contained in Attachment 1 for specifics. (2) (3) See Responses to Comments #10, 25 and 27, above . 31) We also have several questions regarding the S02 BART conclusion for the WFI . Please see the detailed comments contained in Attachment 1 for specifics. (2) (3) The Verso Androscoggin Waste Fuel Incinerator (WFI) is licensed tofire biomass and oil, with biomass including sludge, wood waste (including bark, knots andscreenings, etc.), cotton residue, sawdust absorbedwith oil, and wastepapers. Oilshall include #2 and #6 fuel oil, specification used oil, off . specification used oil, and oily rags, each with a maximum

sulfur content not to exceed 1 .8%by weight. Thefiring rate capacity ofthe WFIdepends on whatfuel orfuel mixture is being combusted . The SOz emission limit for the WFI is 0

.80 lb/MmBtu on a 3-hour rolling average . As the Commenters noted, the WFI has very low SOz emissions (-50 tons per year) due to the inherent alkalinity (i . e., SOz control) ofthe primaryfuel and the limited quantity of fuel oil used in the WFI . During those times in whichfuel oil is combusted, the source's Title VAir Emission License (A-203-7-A-I) providesfor the use ofeither a weak white liquor and/or caustic solution to control the scrubber media pH (and emissions), Y1 necessary to meet the licensed emission limits for the unit. The Title Vlicense does not require the use ofwhite liquor and/or caustic, rather it allows its use ifnecessary. Since the use ofa weakwhite liquor and/or caustic solution whenfiring oil is discretionary, and not always necessary to meet licensed limits, it cannot be treated as an 18existing control and simply "codified " as BART . The Department does not support mandating its use (at a cost-effectiveness ofmore than $20, 000/ton and little or no perceptible visibility benefits), and considers the continued operation ofthe variable throat venture scrubber anddemister, along with the existingS02 emission limit of 0 .80 lb/MmBtu (on a 3-hour rollingaverage) to constitute BARTfor this source. 32) Power Boilers #3 and #4 at the FPL Energy Wyman Station (FPL Energy Wyman, LLC) are BART-eligible units. The State's S02 BART analysis appears to be the only . BART analysis conducted by Maine in which cost-effectiveness was not evaluated in terms of annual cost/ton ofpollutant removed . Instead, Maine appears to have relied solely upon annual cost/deciviews (dv) ofvisibility improvement. While we encourage the use of the $/dv metric, it was not properly calculated nor applied in this case. Using the data available in the BART analyses, we assessed the cost per ton of S02 reduced by the BART options, as well as corrected $/dv calculations. Based upon the results, we believe that it is reasonable to conclude that 0.5% -0.3%sulfur fuels are BART for the FPL boilers. See the discussion in Attachment 2to these comments for further details. (2)(3) As previously noted in Comment # 23, above, Maine did not prescribe the costeffectiveness criterion to be utilized by BART-eligible sources when performing their analyses. While most sources undertaking afull analysis chose to provide both dollars per ton ($/ton) and dollars per deciview($/dv) metrics, FPL Energy Wyman provided only $/dv metrics. While the Department agrees that it would be reasonable to conclude that 0 .5%-0 .3%low

sulfurfuel would constitute BART in the absence ofa broad lowsulfurfuel oil programas adopted by Maine and described in Section 12. .9.1 ofthe Maine Regional Haze SIP, the existence ofthis programleads us to a different conclusionfor Maine sources. The Department believes that the use of0 . 7%low-sulfur fuel oil constitutes an appropriate level of BART controlfor this facility. For additional information, seeComments # 10, 25 and 27, above, and Sections 10 .3 and 12

.9 .1 of the Maine Regional Haze SIP . 33) We are confused as to the BART status for Power Boiler #1 at the SAPPI SD Warren Company Paper Mill . While the company-prepared BART analysis (September 2009) did not mention this unit, the January 21, 2010, Maine BART analysis does identify and analyze BART controls for Power Boiler #2. The final Maine BART analysis for the facility, posted on June 29, 2010, is again silent on this unit . Please explain the BART eligibility status for the SAPPI SD Warren Paper Mill Power Boiler #1, and include any appropriate BART determination in the final SIP. Supporting information for this comment is included in Attachment 3to these comments. (2) (3) See Response to Comment #9, above 34) The State did a goodjob of reflecting the five-factor BART protocol in the Departmental Findings of Fact and Order for the Domtar Maine, LLC - Woodland Mill . Section 11 makes reference fromthe company BART determination to a Dry Electrostatic Precipitator BART alternative estimated to cost $4,640 per ton of particulatematter 19removed. It also makes reference to the Selective Non-Catalytic Reduction (SNCR)

BART alternative estimated by the company to cost $7,360 per ton ofNO,, removed. If the detailed information correctly supports the values shown above, then it maybe reasonable to conclude that the cost per ton of removal was excessive. Maine seemed to rely solely upon the MANE-VUvisibility data to evaluate in a general way the visibility impact of a given unit on nearby Class I areas, but individual modeling of each BART alternative was not performed. In the case of the Woodland Mill it seemed that by concluding that an alternative was not cost-effective on a cost per ton basis, Maine believes that the specific cost ofvisibility improvement was not necessary. Normally, the visibility cost step is performed, even if cost perton is deemed to be excessive. Existing SOZ controls on Power Boiler #9 and the Lime Kiln seemed to be considered `top controls', so further cost analysis was not necessary. (2) (3) The Department appreciates the Commenters' thorough reviewofthe Domtar Maine, LLCBART determination. 35) As we understand, Maine proposes that Lincoln Paper and Tissue, LLCbe allowed to burn 2%S fuel oil . Additionally, S02 emissions fromthe recovery boiler shall be controlled to 141 ppmv (dry basis) @ 8%OZ on a 24-hour block average basis when firing only black liquor or when firing a combination of black liquor and oil . The recovery boiler fires #6-fuel oil . Oil fired in the recovery boiler alone shall not exceed 0.7%sulfur by weight or 2.0% sulfur by weight when firing a combination ofblack liquor and oil . The recovery boiler is fired with fuel oil for startup purposes (in order to initiate Black Liquor Solids (BLS) firing) in addition to shutdowns and other events which require the addition of oil firing. Maine should explain why use of lower sulfur (0.7%S) fuel (that is already used when the recovery furnaces fires 100% #6 oil) would incur a capital cost that made use of that fuel all the time too expensive. The Lincoln Paper and Tissue BART determination is deficient because it does not evaluate the use of 0 .7% fuel oil at all times. (2) (3) The Department does not believe that the use offuel oil with a sulfur content ofless than 2.0%is necessary whenfiring a combination offuel oil and black liquor because the cofiringprocess inherently has very low S02 emissions. The recovery boiler process includes: 1. Combustion oforganic material in the black liquor to create steam ; 2 . Reduction ofinorganic sulfur compounds to sodium sulfide, which exits the bottomofthe recovery boiler as smelt; 3 . Production ofa molten inorganicf ow composedprimarily ofsodiumcarbonate and sodiumsulfide, which is later recycled; 4 . Recovery of inorganic dustfromthefue gas; and 5 . Production ofsodium fume to capture the combustion residue ofreleased sulfur andsulfur compounds. The sodium-rich environment ofthe recovery boiler results in the reduction ofinorganic sulfurfromboth the black liquor, andalsofrom anyfuel used in co-firing . As a result, 20when co-firing black liquor withfuel oil, thefuel sulfur content plays little, ifany role, in

SOZ air emissions. For those periods that black liquor is not being fired, the conversion ofinorganic sulfur compounds to sodiumsulfide is not taking place, hence the Department's requirement to burn low-sulfurfuel oil at these times . 36) Based upon the 6/29/10 BART analysis, Maine has determined that for NO, Dragon Products Company shall operate an SNCR (Selective Non-Catalytic Reduction) systemto reduce NO, emissions fromthe calciner to achieve a 45% control efficiency. NO,, emissions fromthe kiln system shall be limited to 350

.0 lb/hr on a 90dayrolling average and 1533.0 tons/year on a 12 month rolling total basis. We concur. (2) (3) The Department appreciates the Commenters' support. 37) Maine is limiting emissions fromKatahdin Paper's only BART source to < 250 tpy to exempt it fromBART . We concur . (2) (3) The Department appreciates the Commenters' support. 38) Maine is limiting emissions fromRed Shield Acquisition, LLC's only BART sources to < 250 tons/year to exempt it fromBART. We concur (2) (3) The Department appreciates the Commenters'support. However, Red Shield Acquisition, LLChas subsequently decided to undertake a BART analysis ofits #4 Recovery Boiler and Lime Kiln in lieu ofafederally-enforceable cap of250tons per year. The Department has included the results ofthe BARTanalysisfor this source in its final Regional Haze SIP . 39) Maine is limiting emissions fromRumford Paper to less than 250tons per year so as to exempt it fromBART. Please assure that Departmental Findings of Fact and Order or other federally enforceable documents are promulgated to define the emission limitations and place themin the official BART record. (2) (3) The Department has made the suggested change. 40) MEDEP is capping the Verso Bucksport paper mill (Verso Bucksport, LLC) out of BART, but did not post the actual permit that does so. Please post the pertinent permit . (2) (3) The Department has included the Verso Bucksport, LLC BART determination in itsfinal proposal . Although the draft BART determination was posted on the Department's Regional Haze Website, some users experienced difficulty in accessing some BART determinations on the FTP site due to systemincompatibility. 41) By settingreasonable progress goals based on the "Ask", rather than the OTW/OTB inventory, the MANE-VU States have made it more difficult to demonstrate that they have implemented the controls necessary to meet the reasonable progress goals. It would 21be helpful for Maine to discuss whether or not the OTW/OTB controls were sufficient to

meet the uniformrate of progress at the Maine Class I areas. (2)(3) Aspart ofits reasonableprogress goals modeling effort, MANE-VUmodeled the projected visibility improvement at MANE-VUClass Iareas that would resultfromthe implementation of "on-the-book/on-the-way (OTB/OTW) controls in the MANE-VU region and other RPOs. Thefollowing graphics (fromthe NESCAUMReport "MANE- VUModelingfor Reasonable Progress Goals') illustrate that the emission reductions modeled under the OTB/OTW

scenario, are sufficient to meet uniformrate ofprogress at Maine Class I areas: Visibility Improvement Relative to UniformRate of Progress at Acadia National Park

)

2000 2005 2010 2015 2020 2025 Visibility Improvement Relative to UniformRate of Progress at Moosehorn National Wildlife Refuge and Roosevelt-Campobello International Park2"I

; 20 ° 1s 18 17 w a t ! ~ , C)TBI+C3TW

. *. w

~ . (5C3C ' .- S-2 (15 ppm) 167 EGUs

~ PPM)

2000 2005 2010 2015 2020 2025 It must be remembered, however, that EPAguidancefor setting reasonable progress goals requires states to consider reviewing all measures identified through thefourfactor analysis process and to adopt each measure that is determined to be reasonable. Maine andthe MANE-VUmembership believe that thefourfactor analysis provision in the Clean Air Act requires states to analyze additional measures, and adopt those that are reasonable. Maine believes that the measures identified and known as the MAINEVU "Ask" are, in fact reasonable, and that these or other measures providing equivalent emission reductions, must be adopted by each state. 42) On page 133, the statement is made that MANE-VU States have up to 10 years to implement reasonable controls. We believe this to be incorrect statement . It is our understanding that the regional haze rule requires the controls to be in progress (e.g., BART determination or rule requirement) when the Regional Haze SIP is submitted as final . (2) (3) The Department agrees with the Commenters that this statement is incorrect . When originally drafted in 2008, this statement was valid, in that states wouldhave had up to 10years to implement additional reasonable controls as determined by the MANE-VU membership

. With the Maine Regional Haze SIP now on track forsubmittal in late 2010, a 10year implementation "window" would mean that reasonable measures were not implementedprior to the July 31, 2018planning deadline. The Department has amended its proposal to read: "Under this plan, the affected states will have until July 31, 2018 to implement reasonable and cost-effective control measures to reduce primarily S02 and NO, emissions. With regard to thefederal Regional Haze Rule requirements, the Department understands that EPA cannotfully approve a Regional Haze Sip unless all measures are adoptedand will be (federally) enforceable.2343) Table 11-5 summarizes S02 emissions in 2002 and 2018 modeling inventory for 12

sources that were assumed to be required to install BART controls. Asimilar table which summarizes actual BART reductions for Maine sources would be extremely helpful . (2) (3) The Department has included a similar table detailing projected emission reductions attributable to the application of BART to Maine BART-eligible sources in Section 10 of the Maine Regional Haze SIP . 44) MANE-VU indicated that emissions were backfilled in the final inventory calculations in order to fully meet the Clean Air Act Interstate Rule (CAIR) cap. When this backfill method was applied to sources outside of MANE-VUemission rates for some sources were overestimated, ignoring State rules and consent decrees. Please explain in more detail how Maine consulted with these non-MANE-VU States and how the results fromthis consultation were reconciled in making these emission control decisions. (2) (3) MANE-VU

worked closely with other RPOs (VISTAS, MRPO, and CENRAP) in the development ofits modeling inventories, ultimately utilizing the VISTAS "Base G2" inventory as the basisforfurther adjustments that incorporated additional state changes and the MANE-VUregional haze control strategies as detailed in the MANE-VU "Ask" . One ofthese adjustments involved "backfilling" or increasing SOZ emissions at some facilities/regions to estimate the effect ofthe MANE- VUEGU Control strategy and emissions trading under the CAIRprogram . The emissions impacts ofthe MANE-VUEGU Control Strategy were developed by MARAMA, after gathering informationfromMANE-VU, MRPOand VISTASstates, and regional organization staff . These stakeholders reviewed andrevised the IPM results to reflect the controls panned to come online, andverify that known and existing controls and emission rates were reflected in the IPM runs. As part ofthese consultations, adjustments were made to specific units using information provided by the states, including which units would install controls and when these controls wouldcome on-line. In addition to the 167 stacks MANE-VUincorporatedfurther corrections to source emissions as requested by VISTASstates at specific units. During this process, MANE-VUrecognized that under CAIR, reductions at one unit due to the MANE-VUEGU Control Strategy could offset by increases at another unit within the CAIR region. Under this scenario, even though MANE-VUEGUControl Strategy would reduce SOZ emissions in the three RPOs by more 515, 000 tons fromthe targeted units, total EGUemissions would not decrease because most states do not restrict emissions trading. In an effort to address the effect ofemissions trading, MANE-VU decided that emissions should be increased ("backfilled ") within the CAIR region. For MANE-VU, 75,809 tons were added back, leaving the total regional emissionsfromthe MANE-VUregion greater than the original inter-RPO (IPM) estimate, but consistent with state projections. The remaining 440,541 tons were allocated to the MRPOand 24VISTAS based on thefraction oftheir contribution to total S02emissions. The intent of

thefinal EGUadjustments was to retain the same level ofemissions as predicted by the RPOCAIR IPM

runfor the three regions together. The location ofthe emissions, however, were modified to better reflect the state's estimates ofwhere emissions reductions would be achieved, and to reflect reductions at the 167stacks indentified by the MANE-VUEGUstrategy . Overall, regional emissions, increased in both the MANE-VUand VISTAS region, and declined in the MRPO(in comparison with the RPO2 .1 .9 IPM

run) . As noted above MANE-VUworked closely in the development ofboth the VISTAS "Base G2 " and during the development ofthe MANE-VUadjustments used in thefinal modeling inventory, and provided several opportunitiesfor state agencies and regional staff to note state programs and consent decrees (section 12 ofthe Maine State Implementation Plan for Regional Haze provides an overview ofstate programs and consent decrees that were included in the regional modeling) . While the Department believes that most, ifnot all, ofthese relevant controls were incorporated in thefinal regional modeling, it is important to note that under an un-restricted emissions tradingprogram such as CAIR, these specific state controlprograms and consent decrees would arguably have little impact on total SOZ emission in the CAIR region (reductions at thesefacilities could be offset by increases at otherfacilities) . 45) In the Long TermStrategy Section, (Section 12.7 .2), please identify whether the State implements a smoke management plan. If so, identifywhether the program is voluntary or mandatory and whether the impacts to the Class I areas are considered during the process. (2) (3) Although Maine has adopted a number ofprograms designed to address wood smoke emissions (see section 12.7.3 ofthe Maine Regional Haze SIP, it has not adopted an agricultural andforestry smoke managementplan per se. Agricultural andforestry open burning activities are regulated by statute at 4 MRSA Section 9321 et seq., with 4 MRSA Section 9325 stating (in relevantpart) : "§9325 . Open burning 1 . Permissible open burning with permit. When notprohibited by statute, rule ofany state agency or local ordinance, the types ofburning described in this subsection are allowedprovided that a permit has been obtainedfromthe townforest fire warden orfromtheforest ranger having jurisdiction over the location where the fire is to be set. The burning must be conducted according to the terms and conditions ofthe permit and may not create a nuisance. A permit is requiredfor : A . Recreational campfires kindledwhen the ground is not covered by snow ; [1991, c. 36, §4 (NEW).] B . Fires in conjunction with holiday andfestive celebrations; [1991, c. 36, §4 (NEW).] C . Burning ofsolid or liquidfuels and structuresfor research or bona fide instruction and training ofmunicipal, volunteer and industrialfirefighters when 25conducted under the direct control andsupervision ofqualified instructors; [1991, c.

36, §4 (NEW).] D . Burningfor agricultural purposes including, but not limited to, open burning ofblueberryfields, potato tops andhayfields andprescribed burning for timberland management ; [1991, c . 36, §4 (NEW).] (emphasis added) " 4MRSA Section 9321 establishes a number ofmandatory criteriafor open burning activities, but does notspecifically address impacts on Class Iareas. 46) Table 12-1 lists non-CAIR BART facilities that were modeled. Please confirm the modeled emissions are consistent with the actual BART determinations. It is the Department's understanding that the estimated reductionsfor the twelve BARTeligible units in the MANE-VUstates that wouldprobably be controlled as a result of BART requirements are consistent with actual BARTdeterminations- at leastfor those sources located in the State ofMaine . As noted in Comment #9, above, it was subsequently determined that the SAPPI (SDWarren) No. l Power Boiler is not a BARTeligible source, but the modeled emissionsfor this source are consistent with projected emissionsfor 2018

. Infact, the MANE-VUreasonable progress modeling actually underestimated the emission reductions attributable to the application of BART to Maine BART-eligible sources, which can be seen by comparing Table 10-9 with Tables 11-5 and 12-1 . Since the other non-CAIR BART-eligible units are located in Maryland and New York, the Department is unable to confirm that the actual BART determinationsfor these sources arefully consistent with modeledemissions, since these States have not completedfinal BART determinations for these sources. It is the Department's understanding that thefinal BART determinationsfromthese States will be at least as stringent as those modeled. 47) It should be stated earlier in the document that Maine will be fully meeting the "Ask" by 2018. Providing a statement to this effect at the beginning of the document will address reader questions earlier in the reviewof RHSIP . (2) (3) The Department agrees with the Commenters and has added a statement that Maine will be fully meeting the "Ask " to section 3.6Meeting the Ask- Maine. 48) In section 12.12, the State has done a goodjob discussing its commitment to ensure that the New

Source Review/ Prevention of Significant Deterioration (PSD) Programin the State will work towards the interests of their regional haze goal by including Section 12.12 . This section links reasonable progress for visibility to the Prevention of Significant Deterioration requirements . The Department appreciates the Commenters' support . 49) The Table on Page 110 (as it pertains to Wyman Unit 3) contains an apparenttypographical error. The Particulate Matter Emission Limit is listed as 0 .15 lb/Mmbtu (referenced BART order) . This appears to be a typo as the PM limit for Unit 3, according to the BART Order (December 11, 2007), is 0 .18 lb/Mmbtu. (4) The Department has amended its proposal to properly note that thefinal BART order particulate emission limitfor Wyman Unit 3 is 0 .18 lb/MmBtu.ATTACHMENT 1 To NPS/FWS Comments -Maine Draft Regional Haze SIP

NPS Comments Regarding Verso Androscoggin Paper Mill BART Evaluation July 23, 2010 Power Boilers #1 : NOX The following statement by Verso is misleading: The Androscoggin Mill followed the guidance and procedures outlined in 40 CFR Part 51, Appendix Y and the OAQPS Air Pollution Cost Control Manual . Supporting cost evaluation spreadsheets are provided in Attachment C, Table Nos. C-1, C-2, C-3, and C-4 . While we applaud Verso's intent to use the Cost Manual, the actual Verso approach appears to have borrowed the Cost Manual method for evaluating wet scrubbers and applied it to SCR and SNCR, which we believe is inappropriate. In actuality, there is no OAQPSAir Pollution Cost Control Manual (Cost Manual) procedure for evaluating costs for SCR or SNCR for oil-fired EGUs. The procedures described by the Cost Manual are intended for use with coal-fired boilers > 250 mmBtu/hr . So we adapted them to oil-fired boilers (see electronic attachment), but the cost algorithms for the Direct Capital Costs are fromthe Cost Manual coal-boiler method and therefore questionable. Even if we accept the Verso approach as a default, it still contains some highly questionable estimates for SCR, and Verso clearly did not followthe Cost Manual : " If we assume that Power Boilers #1  are capable ofproducing about 68 MW each, then the Total Capital Investment (TCI) per kW is about $115 for SCR, which is in the middle of the $50 -$260/kW range for coal-fired EGUs . We have applied an adapted Cost Manual approach which estimates a slightly higher TCI . We will provide an electronic Excel workbook containing that data via e-mail to MEDEP staff . " Verso has estimated an annual reagent cost of $414,000/boiler . This exceeds the $54,000 annual reagent cost that the Cost Manual procedure estimates. Verso mustjustify this estimate. " Verso has estimated an annual catalyst replacement cost of $155,000/boiler . Since this exceeds the $92,000 annual catalyst replacement cost that the Cost Manual procedure estimates for the 330 MW Naughton Unit #3 (that Wyoming is requiring to install SCR as BART), the Verso estimate appears to be very high. Our adapted Cost Manual method estimates catalyst volume at 88 m3, a 24,000 hour catalyst life, and an annual Catalyst Replacement Cost = $41,000/boiler . Furthermore, because most catalyst vendors do not charge for recovery of the spent catalyst, that $30,000 annual cost also appears unfounded. " Verso's Capital Recovery Factor (12.4%interest over a 10-year SCR life) is inflated. The Cost Manual recommends 7%interest over a 20-year SCR life. i " Verso estimates an annual cost of $5.1 million to control both boilers versus our estimate of $1 .1 million for each boiler, and Verso estimates $7,361/ton versus our $3,070/ton. 28Verso assumed a $0.08/kWh cost for electricity .According to Maine Department of Environmental Protection (MEDEP) : The cost effectiveness numbers in the table above are based on controlling NOx emissions from Power Boilers #1 and #2 at the control effectiveness rates indicated in the table from the highest estimated two year average annual emissions between 2002 and 2008 . In recent years (2008 and 2009) these boilers have been operating close to only 20%of the time, which for example, would result in an actual cost effectiveness of $16,313 per ton of NOx removed with the installation ofSCR

. . MEDEP estimates cost-effectiveness at $5,271/ton versus the $7,361/ton estimated by Verso; we request an explanation for this difference. Furthermore, if MEDEP intends to consider the reduced operation of these boilers in the economic analysis, those reduced operational parameters should be made federally enforceable if they affect the outcome of the analysis. Because BART is a visibility improvement program, we believe that cost/deciview($/dv) is a very important parameter . In this case, for the four Class I areas evaluated by Verso, SCR would improve visibility by a total of 4 .6 dv. (We would also like to see the visibility improvements that would occur in the other two Class I areas.) This results in a cost-effectiveness value of less than 0 .5 million/dv, which is quite reasonable compared to the average $13 -$20 million/dv that we are seeing accepted by states and sources that are proposing reductions under BART. Even if one considers only the visibility improvement at Acadia National Park, the addition of SCR results in a cost-effectiveness value of $1 .3 million/dv. This leads to the conclusion that SCR is BART for the Androscoggin power boilers. The same situation applies to SNCR . The actual Verso approach appears to have borrowed the Cost Manual method for evaluating wet scrubbers and applied it to SNCR, which we believe is inappropriate. Even if we accept the Verso approach as a default, it still contains some highly questionable estimates for SNCR : " If we assume that Power Boilers #1  are capable of producing about 68 MW each, then the Total Capital Investment (TCI) per kW is about $47 for SNCR, which is on the high end of the $29 -$45/kW range we are seeing in proposals to install SNCR on coal-fired EGUs (See http://www .wra_pair .org/forums/ssjf/bart.html ) . We have applied an adapted Cost Manual approach which estimates a $26/kW . We will provide an electronic Excel workbook containing that data via e-mail to MEDEP staff . Verso should provide vendor quotes to support its higher-than expected estimates. " Verso has estimated a Direct Annual Cost (DAC) of $0.55 million/boiler . Since this exceeds the $0.12 million DACthat the Cost Manual procedure estimates, the Verso estimate appears to be very high. The biggest difference is in Verso's estimate of almost $0.5 million/year/boiler for reagent versus the Cost Manual estimate of $0.06 million/yr . " Verso's Capital Recovery Factor (12.4%interest over a 10-year SNCR life) is inflated. The Cost Manual recommends 7% interest over a 20-year SCRlife. 2 " Verso estimates an annual cost of $2.6 million to control both boilers versus our estimate of $0.29 million for each boiler, or Verso's $9,758/ton versus our $2,128/ton.Verso assumed a $0.08/kWh cost for electricity .MEDEP estimates cost-effectiveness at $5,973/ton versus the $9,758/ton estimated by

Verso; we request an explanation for this difference. In this case, for the four Class I areas evaluated by Verso, SNCRwould improve visibility by a total of 4.3 dv. (We would also like to see the visibility improvements that would occur in the other two Class I areas.) This results in a cost-effectiveness value of less than 0.13 million/dv, which is quite reasonable compared to the average $13 -$20 million/dv that we are seeing accepted by states and sources that are proposing reductions under BART. Even if one considers only the visibility improvement at Acadia National Park, the addition of SCR results in a cost-effectiveness value of $0.41 million/dv. This leads to the conclusion that SNCR could also be a candidate for BART for the Androscoggin power boilers if SCR is rejected. Power Boilers #1 : SOZ Some comments on Verso's BART analysis for S02 fromthe Androscoggin mill Power Boilers #1 . Power Boilers #1 &

#2 wet scrubber cost analysis " Verso's Purchased Equipment Costs are not supported orjustified. " Is there a state sales tax exemption for pollution control equipment? " Verso's Maintenance costs are not supported orjustified. " Verso's Utilities costs are not supported orjustified. " Can Verso use waste caustic fromthe mill to augment caustic purchases? (We are seeing this at other mills.) " Verso's annualized costs do not make sense--the numbers do not work out as

3 presented. " Verso overestimated the interest rate and underestimated equipment life. According to the OAQPS Control Cost Manual, the correct interest rate is 7%and the correct equipment life is 15 years. 4 Verso's Power Boilers #1  lower sulfur fuels analysis is incomplete. For example, FPL evaluated 1%S residual, 0 .5%S residual and 0.3%S residual fuel oils for its Wyman facility, Verso should at least evaluate the lower sulfur residual oils. Waste Fuel Incinerator (WFI : NOX We adapted the OAQPS Air Pollution Cost Control Manual (Cost Manual) procedure for evaluating costs for SCR or SNCR for oil-fired EGUs to oil-fired EGUs (see electronic attachment), but the cost algorithms for the Direct Capital Costs are from the Cost Manual coal-boiler method and therefore questionable. So, even if we accept the Verso approach as a default, it still contains some highly questionable estimates for SCR : " Ifwe assume that the WFI is capable of producing about 48 MW, then the Total Capital Investment (TCI) per kW is about $165 for SCR, which is in the middle ofthe $503 Verso assumed a $0.08/kWh cost for electricity. In Massachusetts, sources evaluated

1%S residual, 0

.5%S residual, 0

.3%S residual, 0

.3%S distillate, 0

.05%S distillate, and 0 .0015%S distillate.$260/kW range for coal-fired EGUs. We have applied an adapted Cost Manual approach which estimates a slightly lower TCI . We will provide an electronic Excel workbook containing that data via e-mail to MEDEP staff . " Verso has estimated an annual reagent cost of $286,000. This exceeds the $72,000 annual reagent cost that the Cost Manual procedure estimates . " Verso's Capital Recovery Factor (12.4% interest over a 10-year SCR life) is inflated. The Cost Manual recommends 7%interest over a 20-year SCRlife. 5 " Verso estimates an annual cost of $2.4 million to control the WFI versus our estimate of $0.9 million, or Verso's $5,092/ton versus our $1,986/ton. MEDEP estimates cost-effectiveness at $4,676/ton versus the $5,092/ton estimated by Verso; we request an explanation for this difference. Because BART is a visibility improvement program, we believe that cost/deciview ($/dv) is a very important parameter . In this case, for the four Class I areas evaluated by Verso, SCR would improve visibility by a total of 1 .0 dv. (We would also like to see the visibility improvements that would occur in the other two Class I areas.) This results in a costeffectiveness value of less than $1 million/dv, which is quite reasonable compared to the average $13 -$20 million/dv that we are seeing accepted by states and sources that are proposing reductions under BART. Even if one considers only the visibility improvement at Acadia National Park, the addition of SCR results in a cost-effectiveness value of $2.3 million/dv. This leads to the conclusion that SCR is BART for the Androscoggin WFI . The same situation applies to SNCR . So, even if we accept the Verso approach as a default, it still contains some highly questionable estimates for SNCR : " Although Verso stated that SNCRcould achieve 35% control, its cost analysis is based upon 30%

control . " If we assume that the WFI is capable of producing about 48 MW, then the Total Capital Investment (TCI) per kW is about $65 for SNCR, which is above the high end of the $29 -$45/kW

range we are seeing in proposals to install SNCR on coal-fired EGUs. We have applied an adapted Cost Manual approach which estimates a $31/kW . We will provide an electronic Excel workbook containing that data via e-mail to MEDEP staff . Verso should provide vendor quotes to support its higher-than expected estimates. " Verso has estimated a Direct Annual Cost (DAC) of $0.41 million. Since this exceeds the $0.13 million DACthat the Cost Manual procedure estimates, the Verso estimate appears to be high. The biggest difference is in Verso's estimate of almost $0.34 million/year perboiler for reagent versus the Cost Manual estimate of $0.07 million/yr . " Verso's Capital Recovery Factor (12.4%interest over a 10-year SNCR life) is inflated. The Cost Manual recommends 7%interest over a 20-year SNCR life. 6 " Verso estimates an annual cost of $1 .1 million to control the WFI versus our estimate of $0.27 million, or Verso's $7,009/ton versus our $1,757/ton. 5 6 Verso assumed a $0.07/kWh cost for electricity. Verso assumed a $0.07/kWh cost for electricity. 34MEDEP estimates cost-effectiveness at $5,944/ton versus the $7,009/ton estimated by

Verso; we request an explanation for this difference. In this case, for the four Class I areas evaluated by Verso, SNCRwould improve visibility by a total of 0.2 dv. (We would also like to see the visibility improvements that would occur in the other two Class I areas.) This results in a cost-effectiveness value of less than 1 .4 million/dv, which is quite a bargain compared to the average $10 -$20 million/dv that we are seeing accepted by states and sources that are proposing reductions under BART. Even if one considers only the visibility improvement at Acadia National Park, the addition of SCR results in a cost-effectiveness value of $2.7 million/dv. This leads to the conclusion that SNCR could also be a candidate for BART for the Androscoggin power boilers if SCR is ruled out . Waste Fuel Incinerator (WFI : S02 This is what Verso says about SOZ BART for the Androscoggin Waste Fuel Incinerator : When No. 6fuel oil is fired at significant levels, the Mill adds caustic to the wet scrubber to meet the S02emission limitfor the WFI . S02 BARTANALYSIS Identify BART The WFI has very low S02 emissions due to the inherent alkalinity (i .e., S02 control) of the primary fuel and the small amount of fuel oil used in the WFI . In addition during the limited amount of time that No. 6fuel oil is used to provide a significant amount of the heat for the WFI, caustic is added to the wet scrubber. Since there are only 50 tons of S02 to control annually, the addition of caustic to the wet scrubber would end up controlling a very small amount of emissions on an annual basis. Considering visibility, the low, pre-control visibility impacts from the WFI mean that any visibility reductions associated with post-control of S02 emissions would be imperceptible. Based on the information developed in the Impacts Analysis, the Androscoggin Mill believes that there is no S02 BART determination for S02fromthe WFI . Is Verso saying that it does not want its current procedure of adding caustic to the wet scrubber when burning fuel oil to be considered BART, but will keep doing it anyway? If so, that is clearly wrong because BART would include this practice as a technically-and economically-feasible option, as proven by Verso. Finally, a control option does not have to produce a perceptible improvement to be viable.ATTACHMENT 2 To NPS/FWS Comments -Maine Draft Regional Haze SIP NPS Comments Regarding FPL Energy Wyman Station BART Evaluation July 20, 2010 Beginning in 2006, capacity utilization of, and emissions fromUnits #3  dropped so much that, assuming that trend continues, it would likely be cost-prohibitive to make any substantial capital expenditures to reduce emissions. Furthermore, as noted by Maine Department of Environmental Protection (MEDEP), NOX emissions are already so low as to make any significant additional expenses economically infeasible. So, we shall focus our comments on reducing S02 emissions by switching to lower sulfur fuels. S02 This appears to be the only BART analysis conducted by MEDEP in which costeffectiveness was not evaluated in terms of annual cost/ton of pollutant removed. Instead, MEDEP appears to have relied solely upon annual cost/deciviews (dv) of visibility improvement . While we encourage the use of the $/dv metric, it was not properly calculated nor applied in this case. MEDEP also evaluated the BART strategies on the basis of incremental cost/dv. While that is certainly a valid and useful parameter, it must be used with caution and its results placed into the proper perspective. The basic premise underlying the incremental cost analysis is to identify those strategies that contribute relatively little environmental benefit in proportion to their cost. Because, in most cases, the cost of pollution control rises exponentially with control efficiency, the slope of the cost curve will also increase. For this reason, rigid use of incremental cost effectiveness will always result in the choice of the cheapest option if carried to its ultimate extent . (For example, if this approach were used to evaluate PM

controls, it is likely that all controls more expensive than a multiple cyclone would be rejected.) According to the NSRWorkshop manual, "As a precaution, the difference in incremental costs among dominant alternatives cannot be used by itself to argue one dominant alternative is preferred to another." Instead, it should be used to compare closely performing options. However, FPL did evaluate the costs and benefits of several S02 reduction options, including the use of lower sulfur fuels. In doing so, FPL included estimates of the annual costs and emission reductions for each option, as well as the cost/ton for each of those options; those results are contained in Tables 5-3 thru 5-5 of the FPL BART analysis. We used the data from FPL's Table 5-3 to generate the cost-benefit data, and have summarized our results below . We will provide an electronic Excel workbook containing that data under e-mail to MEDEP staff. BART Guidelines: "You should consider the incremental cost effectiveness in combination with the average cost effectiveness when considering whether to eliminate a control option" and "You should exercise caution not to misuse these [average and incremental cost effectiveness] techniques . . . [but consider them in situations where an 36option shows] . . .slightly greater emission reductions. . ."Wyman #3 (2007 -2008)

Fuel Sulfur (%) 1 0.7 0.5 0.3

l C t 175,30 $ 206,24

$ 835,28

$ 1,722,12

$ os Increased Annual Fue 6 3 3 7 S02 Emission Reductions (tpy) 270 351 405 459 S02 Reductions Cost-Effectiveness $ 650 $ 588 $ 2,064 $ 3,755 ($/ton Greatest Visibility Improvement (dv) 0.99 1 .43 . 1 .78 2.15 Cost-Effectiveness ($/dv) $ 177,07 $ 144,22 6 $ 4690,26 $ 800,989 7 0.5 0.3 Increased Annual Fuel Cost $2,910,880 $ 7,014,74 3 S02 Emission Reductions (tpy) 250 499 S02 Reductions Cost-Effectiveness $/ton) $11,656 $ 14,045 Greatest Visibility Improvement (dv) 0.41 0.84 Cost-Effectiveness ($/dv) $7,099,707 $ 8,350,88 5 Wyman #4 (2007 -2008) Our results differ from those presented by MEDEP because we used the most-recent (2007 - 2008) average fuel use data provided by FPL instead of the maximumtwo-year average. We did this because the most-recent two years are much more representative of anticipated reduced operation of these units. While use of the reduced-capacity operation data did not affect the $/ton estimate (which MEDEP did not include), it has a great effect on the $/dv estimate because ofthe reduced annual costs. Ourresults indicate that, on a $/ton basis, use of 0 .7%sulfur oil is the most cost-effective. However, BART is not necessarily the most cost-effective solution. Instead, the $2,000/ton cost of switching Unit #3 to 0.5 % sulfur oil would be considered reasonable by most states. As noted above, MEDEP appears to have relied solely upon $/dv of visibility improvement . However, the baseline for estimating the increased costs of lower sulfur fuels (2% sulfur) is different from the baseline for existing visibility impacts (1 .6% S) . Therefore, the visibility benefits are underestimated because the baseline impacts are th underestimated. MEDEP has also presented 98 percentile visibility values despite using only one year of meteorological data- that is misleading because, when only one year is modeled, only the maximum values are to be used. Because BART is a visibility improvement program, we believe that cost/deciview($/dv) is a very important parameter . In this case, for the six Class I areas evaluated by FPL, 38lower-sulfur (0.5% -0.3% S) fuels would improve visibility by a total of 6.9 - 9 .7 dv. This results in a cost-effectiveness value of $0.2 - 2.1 million/dv, which is relatively inexpensive compared to the average $13 -$20 million/dv that we are seeing accepted by states and sources that are proposing reductions under BART. Even if one considers only the visibility improvement at Acadia National Park, the lower-sulfur fuels result in costeffectiveness values of $0 .5 - 8 .4 million/dv. This leads to the conclusion that 0 .5%- 0 .3%sulfur fuels are BART for the FPL boilers.ATTACHMENT 3 To NPS/FWS Comments -Maine Draft Regional Haze SIP NPS

Comments Regarding SAPPI SD Warren Paper Mill BART Evaluation July 20, 2010 Page 63 of the 2/06/09 draft of Maine Department of Environmental Protection (MEDEP) RH SIP contains Table 8-2 titled "Modeled Impacts. . .of Maine BART-Eligible Sources. . ." That table shows a 0 .75 dv impact at Acadia and 0 .78 dv at Moosehorn from Power Boiler #1 at the SAPPI SD Warren Paper mill . The September 2009 company BART report did not evaluate Power Boiler #1 . The MEDEP BART analysis (1/21/10) listed Power Boiler #1 as a BART source and included a BART determination for it. The MEDEP BART analysis (posted 6/29/10) did not mention Power Boiler #l . Why was Power Boiler #1 omitted fromthe BART determination?